Epstein Secrets

is no way of knowing whether the State would have offered a plea bargain within the proper range of punishment that he deemed acceptable"); State.. Mazzone, W.Va. 368, 572 S.E.2d 891, 897 (2002) (where plea agreement was that defendant would plead guilty to 2 felony counts of felon in possession of fi

U.S. Attorney's Office. Mr. Edwards first saw a reference to the NPA on or after July 9, 2008, when the Government filed its responsive pleading to Jane Doe's emergency petition. That pleading was the first public mention of the non-prosecution agreement and the first disclosure to Mr. Edwards (and thus t

TES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 08-80736-Civ-Marra/Johnson JANE DOE #1 and JANE DOE #2 v. UNITED STATES JANE DOE 1 AND JANE DOE 2'S REPLY TO INTERVENOR EPSTEIN'S BRIEF IN OPPOSITION TO PROPOSED REMEDIES Bradley J. Edwards Edwards Pottinger LP 425 North Andrews Avenue, Suite

of all relevant circumstances, it is important to understand the very limited reference the victims made to Epstein's NPA in their civil lawsuits. Jane Doe I and 2 filed their civil lawsuits in about September 2008, only after their CVRA petition had been filed — and had succeeded in forcing the USAO- SDF

tive one); Ex parte Rich, 194 S.W.3d 508, 515 (Tex. Crim. App. 2006) (court cannot enforce an illegal sentence below the statutory range); State v. Mazzone, 212 W.Va. 368, 374 (2002) (court would not enforce plea agreement that called for court to unlawfully sentence the defendant by treating two misdem

TES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 08-80736-Civ-Marra/Johnson JANE DOE #1 and JANE DOE #2 v. UNITED STATES JANE DOE 1 AND JANE DOE 2'S REPLY TO INTERVENOR EPSTEIN'S BRIEF IN OPPOSITION TO PROPOSED REMEDIES Bradley J. Edwards Edwards Pottin er LP Paul G. Cassell Pro Hac Vice T

also extends to "Other Potential Defendants," defined as any "other person or entity would could have been included as a potential defendant" in the Jane Does lawsuit alleging sex abuse. Obviously, the United States was a not sex abuser and could not have been included in the lawsuit against Epstein. 42

tive one); Ex parte Rich, 194 S.W.3d 508, 515 (Tex. Crim. App. 2006) (court cannot enforce an illegal sentence below the statutory range); State v. Mazzone, 212 W.Va. 368, 374 (2002) (court would not enforce plea agreement that called for court to unlawfully sentence the defendant by treating two misdem

l plea agreement); State v. Wall, 502 S.E.2d 585, 588 (N.C. 1998) (same); Ex parte Rich,194 S.W.3d 508, 515 (Tex. Crim. App. 2006) (same); State v. Mazzone, 572 S.E.2d 891, 897 (W.Va. 2002) ("[A] plea agreement which cannot be fulfilled based upon legal impossibility must be vacated in its entirety.").

U.S. Attorney's Office properly conferred in a timely fashion back in 2007"); id. at 24-25 ("If the Government had properly conferred with the two Jane Does ... [t]hese events would have provided Jane Doe 1 and 2 with much more information about Epstein's criminal conspiracy and its scope and operation,