Epstein Secrets

d by the government arc subject to a protective order prohibiting their disclosure. In the related case 9:08-CV-80893 (the case where Jane Doe I and Jane Doe 2 sued Mr. Epstein for money), the Magistrate Judge prohibited Jane Doe 1 and Jane Doe 2 EFTA00177187 Case 9:08-cv-80736-KAM Document 56 Entered on

. 08-80736-CIV-MARRA/JOHNSON JANE DOE #1 and JANE DOE #2, Plaintiffs, 1. UNITED STATES OF AMERICA, Defendant. NOTICE OF' OBJECTION Petitioners Jane Doe 1 and Jane Doe 2 have moved for disclosure of settlement letters between the U.S. Attorney's Office and the lawyers who represented Jeffrey Epstein du

AM Document 56 Entered on FLSD Docket 04/07/2011 Page 2 of 19 Non-Prosecution Agreement reached between the U.S. Attorney's Office and Mr. Epstein. Jane Doe 1 and Jane Doc 2 also seek other unspecified relief, which they call "appropriate remedies," for the government's purported failure to keep them invol

trict court concluded that the violations alleged by the victims did not provide a basis for rejecting the plea agreement. Id. at 726-27; see In re Acker, 596 F.3d 370, 373 (6th Cir. 2010) (denying mandamus where petitioners sought to vacate plea agreement which made no provision for restitution in de

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

391, 394 (5th Cir. 2008). The Sixth Circuit has deemed it "uncertain" whether CVRA protections apply "prior to [the] filing of ... charges." In re Acker, 596 F.3d 370, 373 (6th Cir. 2010). The district courts that have considered the question are divided. Compare, e.g., 1' United States it Oakum, No

161 Entered on FLSD Docket 04/17/2012 Page 1 of 23 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE No. 08-80736-CIV-MARRA/JOHNSON JANE DOE 1 and JANE DOE 2, Plaintiffs, v. UNITED STATES OF AMERICA, Defendant. SUPPLEMENTAL BRIEFING OF INTERVENORS ROY BLACK, MARTIN WEINBERG, AND JAY LE

strict court concluded that the violations alleged by the victims did not provide a basis for rejecting the plea agreement. Id. at 726-27; see In re Acker, 596 F.3d 370, 373 (6th Cir. 2010) (denying mandamus where petitioners sought to vacate plea agreement which made no provision for restitution in d

d by the government are subject to a protective order prohibiting their disclosure. In the related case 9:08-CV-80893 (the case where Jane Doe 1 and Jane Doe 2 sued Mr. Epstein for money), the Magistrate Judge prohibited Jane Doe I and Jane Doe 2 EFTA00205542 Case 9:08-cv-80736-KAM Document 160 Entered on

trict court concluded that the violations alleged by the victims did not provide a basis for rejecting the plea agreement. Id. at 726-27; see In re Acker, 596 F.3d 370, 373 (6th Cir. 2010) (denying mandamus where petitioners sought to vacate plea agreement which made no provision for restitution in de

07 with the execution of the NPA but instead deferred any disclosure until after Mr. Epstein's plea of guilty in state court. 3 EFTA00621911 3. Jane Doe 2 was hostile to the efforts of the USAO and FBI to cooperate against Mr. Epstein, see Villafana Declaration, Dkt. 14 at pg. 4, 6, see Dkt. 361, Exhib

, 563 F.3d 1092, 1099 (10th Cir. 2009) (stating that "the purpose of the CVRA is to permit victim participation in ongoing criminal matters"); In re Acker, 5% F.3d 370, 373 (6th Cir. 2010) (characterizing as "uncertain" the question whether a victim has rights before formal charges are filed). 2 EFT

ls between his lawyers and federal prosecutors during the criminal investigation [DE 50 at 5]. Mr. Epstein also opposes the motion of Jane Doe 1 and Jane Doe 2 to use the content of the communications that memorialized ongoingse plea and settlement negotiations as substantive evidence in their quest to inva

trict court concluded that the violations alleged by the victims did not provide a basis for rejecting the plea agreement. Id. at 726-27; see In re Acker, 596 F.3d 370, 373 (6th Cir. 2010) (denying mandamus where petitioners sought to vacate plea agreement which made no provision for restitution in d

Intervenor Jeffrey Epstein s Motion For a Protective Order And Opposition to Motions of Jane Doe 1 And Jane Doe 2 For Production, Use, And Disclosure Of Plea Negotiations Jeffrey Epstein opposes the motion of Jane Doe 1 and Jane Doe 2 for dislcosure of all the

trict court concluded that the violations alleged by the victims did not provide a basis for rejecting the plea agreement. Id. at 726-27; see In re Acker, 596 F.3d 370, 373 (6th Cir. 2010) (denying mandamus where petitioners sought to vacate plea agreement which made no provision for restitution in d

ls between his lawyers and federal prosecutors during the criminal investigation [DE 50 at 5]. Mr. Epstein also opposes the motion of Jane Doe 1 and Jane Doe 2 to use these plea negotiations as substantive evidence in their quest to invalidate the Non- Prosecution Agreement [DE 51], as well as their motion t

trict court concluded that the violations alleged by the victims did not provide a basis for rejecting the plea agreement. Id. at 726-27; see In re Acker, 596 F.3d 370, 373 (6th Cir. 2010) (denying mandamus where petitioners sought to vacate plea agreement which made no provision for EFTA00301887 r

ney General or any office under his direction.'" Id. at *2 (quoting 18 U.S.C. § 3771(d)(6)). For these reasons, the Court should deny the motion of Jane Doe 1 and Jane Doe 2 to discover and use the plea negotiation letters as evidence. PART II MR. EPSTEIN'S PLEA NEGOTIATIONS ARE PRIVILEGED AND NOT DISCO

trict court concluded that the violations alleged by the victims did not provide a basis for rejecting the plei. agreement. Id. at 726-27; see In re Acker, 596 F.3d 370, 373 (6th Cir. 2010) (denying mandamus where petitioners sought to vacate plea agreement which made no provision for restitution in d