Epstein Secrets

ose his Fifth Amendment rights, he will expose himself to an adverse inference at the summary-judgment stage and at trial. See generally, Wehling v. Columbia Broad Sys., 611 F.2d 1026, 1027 (5th Cir. 1980) (observing that "invocation of the privilege would be subject to the drawing of an adverse inference by the

ered on FLSD Docket 08/12/2008 Page 3 of 13 "agreed to defer federal prosecution in favor of prosecution by the State of Florida .... " See In re. Jane Doe, Case No. 08-80736-CIV-Marra/Johnson (S.D. Fla.) (DE 14), Deel. of AUSA Villafana, 07/09/08, ,i 5, attached hereto as Exhibit "A" (emphasis added).

ributes to public understanding of the rule of law" and "validates [its] claim of functioning as surrogates for the public."J9 48 Westmoreland v. Columbia Broad. Sys., Inc., 752 F.2d 16, 23 (2d Cir. 1984) (quoting Globe Newspaper Co. v. Superior Court for Norfolk Cly., 457 U.S. 596, 606, 102 S.Ct. 2613, 73

his victims. In return, prosecutors declined to bring federal charges. Shortly after Epstein entered his plea, two of his victims, proceeding as "Jane Doe 1" and "Jane Doe 2," filed suit against the Government in the Southern District of Florida under the Crime Victims' Rights Act ("CVRA"). The victim

ial system would be well served were our common law courts to revitalize this crucial qualification to the litigation privilege. " Westmoreland v. Columbia Broad. Sys., Inc., 752 F.2d 16, 23 (2d Cir. 1984) (quoting Globe Newspaper Co. v. Superior Court for Norfolk Cty., 457 U.S. 596, 606 (1982)). 49 Richmon

his victims. In return, prosecutors declined to bring federal charges. Shortly after Epstein entered his plea, two of his victims, proceeding as "Jane Doe 1" and "Jane Doe 2," filed suit against the Government in the Southern District of Florida under the Crime Victims' Rights Act ("CVRA"). The victims

ose his Fifth Amendment rights, he will expose himself to an adverse inference at the summary-judgment stage and at trial. See generally, Wehlingl. Columbia Broad. Sys, 611 F.2d 1026, 1027 (5th Cir. 1980) (observing that "invocation of the privilege would be subject to the drawing of an adverse inference by t

ed on FLSD Docket 07/15/2008 Page 1 of 8 1 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 08-80736-CIV-MARRA/JOHNSON IN RE: JANE DOE, Petitioner. FILED by I G D.C. JUL 0 9 2008 STEVEN M LANIMORE CURS U.S. DISE c s.o.or FLA • W.P.B. GOVERNMENT'S RESPONSE TO VICTIM'S EMERGENCY

oose his Fifth Amendment rights, he will expose himself to an adverse inference at the summary-judgment stage and at trial. See generally. Wehlingl. Columbia Broad. Sys., 611 F.2d 1026, 1027 (5th Cir. 1980) (observing that "invocation of the privilege would be subject to the drawing of an adverse inference by

tted willful acts of child sexual abuse on Jane Doe. These acts resulted in mental or sexual injury to Jane Doe, that caused or were likely to cause Jane Doe's mental or emotional health to be significantly impaired. 26. Epstein's conduct caused severe emotional distress to Jane Doc. Epstein knew or had