Epstein Secrets

iled in federal court (Jane Doe v. Epstein, Case No. 08-CIV- 80893, U.S.D.C. S.D. Fla.), and two of which have been fil~d in state court in the 15th Judicial Circuit Court, Palm Beach County, State of Florida, (L.M. v. Esptein, Case No. 502008CA028051XXXXMB AB; E.W. v. Epstein, Case No. 502008CA028058XXXXMB AB), (here

regarding any plaintiffs case against Jeffrey Epstein. Case 9:08-cv-80119-KAM Document 405 Entered on FLSD Docket 11/12/2009 Page 30 of 33 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CIV-80119-MARRA/JOHNSON JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. I -------------

right to appeal his conviction and sentence in the state court. 12. The defendant agrees that he will make a binding recommendation that the 15th Judicial Circuit Court impose a sentence of at least eighteen (18) months' imprisonment to be followed by at least twelve (12) months of community control/home confinemen

y of the victims identified in the federal investigation file suit pursuant to 18 U.S.C. § 2255, the defendant will not contest the jurisdiction of the U.S. District Court for the Southern District of Florida over his person and/or the subject matter, and the defendant will not contest that the identified victims are

States District Court, Southern District of Florida, Case No. 08-CV-80119 [as to Edwards' representation only] 13. E.W. v. Jeffrey Epstein, 15th Judicial Circuit Court, Palm Beach County, Case No. 50-2008-CA-028058-XXXXMB AD 15. Jane Doe v. Jeffrey Epstein, United States District Court, Southern District of Flo

ctions. Only five of those actions involved Edwards' three clients as follows: 6. and 16. Jane Doe No. 2 v. Jeffrey Epstein, Consolidated Action, United States District Court, Southern District of Florida, Case No. 08-CV-80119 [as to Edwards' representation only] 13. E.W. v. Jeffrey Epstein, 15th Judicial Circuit Court

55 claim. Finally, the state court is perfectly capable and able to protect the rights of the parties. In fact, there are currently before the 15th Judicial Circuit Court, Palm Beach County, Florida, additional cases against EPSTEIN based on similar allegations of sexual exploitation and abuse. In the Jane Doe II st

e 492 F.Supp.2d 1186, 1188 (N.D. Cal. 2007), (emphasis added). 18 U.S.C.A. §2255 "merely provides a cause of action for damages in 'any appropriate United States District Court.'" Id, at 1189. In Tilton v. Playboy Entertainment Group Inc 554 F.3d 1371 (11th Cir. Jan. 15, 2009), the District Court granted plaintiff "the min

right to appeal his conviction and sentence in the state court. 12. The defendant agrees that he will make a binding recommendation that the 15th Judicial Circuit Court impose a sentence of at least eighteen (18) months' imprisonment to be followed by at least twelve (12) months of community control/home confinement

y of the victims identified in the federal investigation file suit pursuant to 18 U.S.C. § 2255, the defendant will not contest the jurisdiction of the U.S. District Court for the Southern District of Florida over his person and/or the subject matter, and the defendant will not contest that the identified victims are

g and executing the agreed upon sentence between the State Attorney's Office and Epstein, the details of which are set forth above. Should the 15th Judicial Circuit Court Judge impose a sentence below that agreed upon herein, the interest of the United States will not be vindicated and the United States may elect to

o seek reimbursement by filing suit pursuant to 18 U.S.C. § 2255. The Trust will be disbursed to the individuals by the Trustee to be designated by the U.S. District Court for the Southern District of Florida. 6. The United States and Epstein's attorneys will agree upon a list of identified persons after Epstein has

right to appeal his conviction and sentence in the state court. 12. The defendant agrees that he will make a binding recommendation that the 15th Judicial Circuit Court impose a sentence of at least eighteen (18) months' imprisonment to be followed by at least twelve (12) months of community control/home confinement

y of the victims identified in the federal investigation file suit pursuant to 18 U.S.C. § 2255, the defendant will not contest the jurisdiction of the U.S. District Court for the Southern District of Florida over his person and/or the subject matter, and the defendant will not contest that the identified victims are

right to appeal his conviction and sentence in the state court. 12. The defendant agrees that he will make a binding recommendation that the 15th Judicial Circuit Court impose a sentence of at least eighteen (18) months' imprisonment to be followed by at least twelve (12) months of community control/home confinement

y of the victims identified in the federal investigation file suit pursuant to 18 U.S.C. § 2255, the defendant will not contest the jurisdiction of the U.S. District Court for the Southern District of Florida over his person 3 08-80736-CV-MARRA RFP WPB 000272 EFTA00184357 Case 9:08-cv-80736-KAM Document 361-18 Ent

te a private right of action. See H800.02, 800.03, 800.04, Fla. Stat. Rather, the ' This action began in Florida state court, Palm Beach County 15th Judicial Circuit Court, and was removed to Federal Court pursuant to a Notice of Removal filed by Defendants. EFTA00175322 Case 9:08-cv-80811-KAM Document 35 Entered

ho is a victim of a violation of section ... of this title and who suffers personal injury as a result of such violation may sue in any appropriate United States District Court and shall recover the actual damages such minor sustains and the cost of the suit, including a reasonable attorney's fee. Any minor as described in

right to appeal his conviction and sentence in the state court. 12. The defendant agrees that he will make a binding recommendation that the 15th Judicial Circuit Court impose a sentence of at least eighteen (18) months' imprisonment to be followed by at least twelve (12) months of community controVhome confinement

y of the victims identified in the federal investigation file suit pursuant to 18 U.S.C. § 2255, the defendant will not contest the jurisdiction of the U.S. District Court for the Southern District of Florida over his person and/or the subject matter, and the defendant will not contest that the identified victims are