Epstein Secrets

ction of the attorney representative. As a result, on October 29, 2007, the parties executed an Addendum wherein it was mutually agreed that former United States District Court Judge Edward B. would serve as the independent third-party. Judge Davis selected the venerable law firm of Podhurs and Josefsberg to represent the

ee of Defendant JEFFREY EPSTEIN prepared a written telephoF message for Defendant JEFFREY EPSTEIN's review regarding a telephone call received from T.M. and Jane Doe #12 that stated: "They are available all weekend and maybe pane Doe #13] too". 20 EFTA00225764 (83) On or about December 30, 2004,

or more telephone calls to a telephone used by Jane Doe #7. (58) On or about July 16, 2004, Defendant placed a telephone call telephone used by T.M. (59) On or about July 17, 2004, one of Defendant JEFFREY EPSTEIN's employees prepared a written telephone message for Defendant JEFFREY EPSTEIN's

a telephone call to a telephone used by Jane Doe #8. D (56) On or about July 15, 2004, Defendant placed a telephone call to a telephone used by T.M. (57) On or about July 16, 2004, Defendant placed one or more telephone calls to a telephone used by Jane Doe #7. (58) On or about July 16, 2004

n a federal grand jury investigation into allegations arising out of the same incidents alleged in the instant action (Grand Jury No. 07-103 (WPB), United States District Court for the Southern District of Florida) ("the Federal Criminal Action"). In September 2007, the USAO and Mr. Epstein entered into a highly unusual a

d to Bradley Edwards' three clients, T.M., C.W., and S.R.' Your Affiant's letter to C.W. was provided by the FBI. (Ex. 11. Your Affiant's letter to T.M. was hand-delivered by myself to T.M. at the time that she was interviewed (Ex. 2).2 Both C.W. and T.M. also received letters from the FBI's Victim-

se the U.S. Attorney's modification limited Epstein's liability to victims whom the United States was prepared to name in an indictment. In light of T.M.'s prior statements to law enforcement, your AMant could not in good faith include T.M. as a victim in an indictment and, accordingly, could not inc

n a federal grand-jury investigation into allegations arising out of the same incidents alleged in the instant action (Grand Jury No. 07-103 (WPB), United States District Court for the Southern District of Florida) ("the Federal Criminal Action"). In September 2007, the USAO and Mr. Epstein entered into a highly unusual a

se the U.S. Attorney's modification limited Epstein's liability to victims whom the United States was prepared to name in an indictment. In light of T.M.'s prior statements to law enforcement, your Affiant could not in good faith include T.M. as a victim in an indictment and, accordingly, could not i

d to Bradley Edwards' three clients, T.M., C.W., and S.R.' Your Affiant's letter to C.W. was provided by the FBI. (Ex. 1). Your Affiant's letter to T.M. was hand-delivered by myself to T.M. at the time that she was interviewed (Ex. 2).2 Both C.W. and T.M. also received letters from the FBI's Victim-

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

e of Defendant JEFFREY EPSTEIN prepared a written telephone message for Defendant JEFFREY EPSTEIN's review regarding a telephone call received from T.M. and Jane Doe #12 that stated: "They are available all weekend and maybe [Jane Doe #18] too". 20 Case No. 08-80736-CV-MARRA P-013469 EFTA00230374

more telephone calls to a telephone used by Jane Doe #7. (48) On or about July 5, 2004, Defendant placed a telephone call to a telephone used by T.M. 14 Case No. 08-80736-CV-MARRA P-013463 EFTA00230368 (49) In or around July 2004, Defendant JEFFREY EPSTEIN masturbated in the presence of Jan

I sent him a letter on July 25, 2008, explaining that the government believed 18 U.S.C. 3771(a)(5) was not triggered until an offense was charged in United States District Court. We also stated that, in the government's view, the relevant facts were: (1) there are no charges in district court filed against Jeffrey Epstein; a

Dec. 1, and Dec. 2 -- what times those dahys are good for you (and discuss. We look forward to discussing all these issues with you soon ane Doe, T.M., and E.W. EFTA00206904 Ronald N. Boyce Presidential Professor of Criminal Law S.J. Quinney College of Law at the University of Utah 332 S. 1400

A. Lee Assistant United States Attorney II EFTA00191209 SERVICE LIST Jane Does 1 and 4 United States, Case No. 08-80736-CIV-MARRA/MATTHEWMAN United States District Court, Southern District of Florida Brad Edwards, Esq., Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, P.L. 425 North Andrews Avenue, Suite 2 For

parties to this litigation 59 12/11/2007 email from Marie Villafafia to Jeff Sloman and Alex Acosta regarding call with lawyer for Jane Doe #2 (T.M.) Work Product Deliberative Process 60 12/3/2007 emails between Marie Villafatta, Alex Acosta, and Jeff Sloman regarding history of plea negotia

iia A. MARIE VILLAFA&A Assistant United States Attorney SERVICE LIST Jane Does 1 and 2 v. United States, Case No. 08-80736-CIV-MARRA/MATTHEWMAN United States District Court, Southern District of Florida Brad Edwards, Esq., Farmer Jaffe Weissing Edwards Fistos Lehrman 425 N Andrews Ave Ste 2 Fort Lauderdale, FL 33301-

t Deliberative Process P-014440 12/11/2007 email from Marie Villafafta to Jeff Sloman and Alex Acosta regarding call with lawyer for Jane Doe #2 (T.M.) Work Product Deliberative Process P-014441 12/12/2007 emails between Marie Villafafta, Frederica Devlin, and Bob Senior regarding planning indi

iia A. MARIE VILLAFA&A Assistant United States Attorney SERVICE LIST Jane Does 1 and 2 v. United States, Case No. 08-80736-CIV-MARRA/MATTHEWMAN United States District Court, Southern District of Florida Brad Edwards, Esq., Farmer Jaffe Weissing Edwards Fistos Lehrman 425 N Andrews Ave Ste 2 Fort Lauderdale, FL 33301-

t Deliberative Process P-014440 12/11/2007 email from Marie Villafafta to Jeff Sloman and Alex Acosta regarding call with lawyer for Jane Doe #2 (T.M.) Work Product Deliberative Process P-014441 12/12/2007 emails between Marie Villafafta, Frederica Devlin, and Bob Senior regarding planning indi

e via the CM/ECF system. Assistant United States Attorney SERVICE LIST Jane Does 1 and 2'. United States, Case No. 08-80736-CIV-MARRA/MATTHEWMAN United States District Court, Southern District of Florida Brad Edwards, Esq., Farmer Jaffe Weissing Edwards Fistos Lehrman 425 N Andrews Ave Ste 2 Fort Lauderdale, FL 33301-

with Ken Starr P-014440 12/11/2007 email from to and Alex Acosta Work Product Deliberative Process regarding call with lawyer for Jane Doe #2 (T.M.) P-014441 12/12/2007 emails between and Work Product Deliberative Process 6(e) regarding planning indictment review P-014442 12/14/2007 em

al or in pleadings, the Intervenors need not even demonstrate "good cause" in order to obtain relief. As the Hon. Karon Owen Bowdre, Chief Judge of the U.S. District Court for the Northern District of Alabama recently held: '(...continued) LEXIS 66742, at "9-11 (finding settlement communications non-discoverable as "

upon conviction, did not require sex offender registration. 3. Jane Doe #1 is a woman with initials C.W., and Jane Doe #2 is a woman with initials T.M. Both were victims of Epstein's while they were minors beginning when they were fifteen years old. Both Jane Does were identified through the Palm Be