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e Agreement, the SDFL unilaterally proposed to divest its right to select the attorney representative for the victims. Contrary to Messrs. Starr and Whitley's recent assertion that this was "engineered in a way that appears intended to profit particular lawyers in private practice in South Florida with
ed female in the presence of Jane Doe #2, who was then a fourteen- year-old girl. i • (8) In or around 2001, Defendant JEFFREY EPSTEIN paid $300 to Jane Doe #2, who was then a fourteen-year-old girl, for allowing an unidentified female to perform oral sex on Jane Doe #2 in EPSTEIN's presence. (9) On, o
er 30, 2004, DefendantMIMS placed a telephone call to a telephone used by Jane Doe #3. (23) Ilkor around 2004, Defendant JEFFREY EPSTEIN directed Jane Doe '4, #3, who was then a sixteen- or seventeen-year-old girl, to straddle an adult female and to touch the adult female's breasts. (24) In or around
39, 117 S. Ct. 417, 421, 136 L.Ed.2d 347 (1996) ("We have long held that the 'touchstone of the Fourth Amendment is reasonableness."); / Kyles v. Whitley, 514 U.S. 419, 432-33, 115 S. Ct. 1555, 1565, 131 L.Ed.2d 490 (1995) (under the Due Process Clause and 11 Brady v. Maryland, 373 U.S. 83, 83 S. Ct
red the girls for Epstein's sexual gratification or participated in the sexual abuse themselves. The victims include the petitioners in this case, Jane Doe 1 and Jane Doe 2, who were 15 years old when first sexually abused by Epstein. B. Aug. 2006 Letter to Crime Victim about CVRA Rights Throughout the
her statutory rights under the CVRA. For example, in 2006 and before an indictment was drafted in 2007, the U.S. Attorney's Office told petitioner Jane Doe 2 in a letter that she had statutory rights "to confer with the attorney for the Government in the case," "to be treated with fairness," and to petit
& II BACKUP BINDERS PALM BEACH LITIGATION -Non-Prosecution Agreement and Addendum -June 12, 2008 Draft DOJ Letter -Letter to Filip from Starr and Whitley (5-27-08) -March 28, 2008 Letter to DOJ -DOJ Submission (Summary) -DOJ Submission (Attachment Letter) EFTA00300514 -April 8, 2009 Submission to
der of Dismissal Rosenfeldt vs. Rothstein Doe 1 Case # 6596 Doe II Case # 20614 Document Production Doe II Case # 20614 Jane Doe 8 Case # 80802 Jane Doe 102 Case # 80656 CMA Case# 80811 AC Case # 25129 DRAWER TWO: Josefsberg Invoices and Disc 81092 Doe 2 Case # 80119 Poe 3 Case# 80232 DRAWER T
ent • The inclusion or Section 2255. a purely civil remedy. raises the risk of excessive government interference in private, civil matters. As Mr. Whitley states in his ;minion. . . .unnecessary entanglement of the government in such cases and the use of federal resources could improperly influence s
tream aircraft owned by Hyperion Air, Inc. (201) On or about August 18, 2005, Defendant placed one or more telephone calls to a telephone used by Jane Doe #17. (202) On or about August 19, 2005, Defendant wk/a placed one or more telephone calls to a telephone used by Jane Doe #17. (203) On or about
rom to Lefkowitz re: deadline to comply with the agreement resolving Epstein's federal and state liabilities 193. 5/19/2008 Letter from Starr and Whitley to Filip43 re: asking him to review the federal involvement in Epstein's matter S Chief, Child Exploitation and Obscenity Section, Department of J
article: "Palm Beach Man Faces Lawsuit in Teen Sex Case" 170. 1/29/2008 Motion to Intervene, Jane Doe No. 1, et aL v. Epstein, 08-80069 (filed by Jane Doe's mother) 171. 1/29/2008 Motion to Stay Proceedings Pending Jane Doe No. 1 Reaching Age of Majority, Jane Doe No. 1, et aL v. Epstein, 08-80069 (fil
e Agreement, the SDFL unilaterally proposed to divest its right to select the attorney representative for the victims. Contrary to Messrs. Starr and Whitley's recent assertion that this was "engineered in a way that appears intended to profit particular lawyers in private practice in South Florida with
female in the presence of Jane Doe #2, who was then a fourteen- .; ;. year-old girl. (8) In or around 2001, Defendant JEFFREY EPSTEIN paid $300 to Jane Doe #2, who was then a fourteen-year-old girl, for allowing an unidentified female to perform oral sex on Jane Doe #2 in EPSTEIN's presence. (9) On or
r concerns on this matter. I respectfully request that you consider the issues I discuss below in conjunction with the ethics opinion of Mr. Joe I). Whitley that I faxed to your Office on December 7. Background of Negotiations believe it is important for you to be aware of the full scope and substance
ed to include Jane Doe #2 among the list of Epstein's victims. Ironically, these same attempts to protect Jane Doe #2's rights are now being used by Jane Doe #2 to allege violations of the CVRA. Petitioners also allege that the letters sent to Jane Doe #1 and Jane Doe #2 during the period when Epstein wa
ed her for having spoken with him the previous day, reiterated the defense team’s various complaints, and asked her to meet with him, Lefkowitz, and Whitley. Meanwhile, Oosterbaan’s Deputy Chief drafted a decision letter to be sent from Oosterbaan to Lefkowitz, and over the course of several weeks, i
victim denied being involved in, or being a victim of, criminal activity. Later, the victim obtained new counsel and joined the CVRA litigation as “Jane Doe #2.” 219 In his March 20, 2011 letter, addressed “To whom it may concern,” and published online in The Daily Beast, Acosta described “a year-lo
Entities connected to both Whitley and Jane Doe

Jeffrey Epstein
PERSON
Bradley Edwards
PERSON
Kenneth Marra
PERSON
Paul Cassell
PERSONJack Goldberger
PERSON
Scarlett Johansson
PERSON
United States
LOCATION
Alan Dershowitz
PERSONthe Southern District
LOCATION
George W. Bush
PERSONLeon Black
PERSON
Ghislaine Maxwell
PERSON
Alexander Acosta
PERSON
Salt Lake City
LOCATION
A. Marie Villafana
PERSONScott Rothstein
PERSONRobert C. Josefsberg
PERSON
Department of Justice
ORGANIZATIONJack Scarola
PERSON
Prince Andrew
PERSON