Epstein Secrets

im for damages. whether pursuant to state. federal or common law". Exhibit 2, NPA 1 8. More is required of a plaintiff than to simply allege, as did Jane Doc 101, that she "exclusively seeks civil remedies pursuant to 18 USC 2255." Exhibit 27, Amended Complaint 1 24. Such an averment satisfies only the e

Epstein committed willful acts of child sexual abuse on Jane Doe. These acts resulted in mental or sexual injury that caused or were likely to cause Jane Doe's mental or emotional health to be significantly impaired. 25. Epstein's conduct caused severe emotional distress to Janc Doe. Epstein knew or had

were likely to cause Jane Doe's mental or emotional health to be significantly impaired. 25. Epstein's conduct caused severe emotional distress to Janc Doe. Epstein knew or had reason to know that his intentional and outrageous conduct would cause emotional distress and damage to Jane Doe, or Epstein a

Adam Horowitz, counsel for plaintiffs 5 Jane 2 through Jane Doe 7. 6 THE COURT: Good morning. 7 MR. EDWARDS: Brad Edwards, counsel for plaintiff Jane 8 Doe. 9 THE COURT: Good morning. 10 MR. GARCIA: Good morning, Your Honor. Sid Garcia for 11 Jane Doe II. 12 THE COURT: Good morning. 13 MR. WILLI

ovisions of the NPA. We informed the USAO of this request the very next day in a letter to Mr. Acosta. See Exhibit 3, November 29, 2007 Letter from J. Leficowitz to U.S. Attorney Acosta at 4. • In a December 4, 2007 letter, Mr. Acosta stated that he supported the defense's appeal to Washington. See Exhibit

im for damages, whether pursuant to state. federal, or common law". Exhibit 2, NPA 18. More is required of a plaintiff than to simply allege, as did Jane Doe 101, that she "exclusively seeks civil remedies pursuant to 18 USC 2255." Exhibit 27, Amended Complaint 1 24. Such an averment satisfies only the exc

s, while Jane Doe I1 already bad a pending state court suit filed in July of 2008 seeking damages against Epstein for sexual assault and conspiracy. Jane Doe H in her federal complaint alleged Epstein could "not contest liability for claims brought exclusively pursuant to 18 U.S.C. §2255". Exhibit 27, Amend

several objections to the suggested modification in my letter to Mr. Acosta, dated December 21, 2007. See Exhibit 21, December 21, 2007 Letter from J. Leficowitz to U.S. Attorney Acosta. I personally became aware of the inclusion of that language on Wednesday, August 13, 2008 and discussed the matter with yo

im for damages, whether pursuant to state. federal, or common law". Exhibit 2, NPA 18. More is required of a plaintiff than to simply allege, as did Jane Doe 101, that she "exclusively seeks civil remedies pursuant to 18 USC 2255." Exhibit 27, Amended Complaint 1 24. Such an averment satisfies only the exc

s, while Jane Doe I1 already bad a pending state court suit filed in July of 2008 seeking damages against Epstein for sexual assault and conspiracy. Jane Doe H in her federal complaint alleged Epstein could "not contest liability for claims brought exclusively pursuant to 18 U.S.C. §2255". Exhibit 27, Amend

several objections to the suggested modification in my letter to Mr. Acosta, dated December 21, 2007. See Exhibit 21, December 21, 2007 Letter from J. Leficowitz to U.S. Attorney Acosta. I personally became aware of the inclusion of that language on Wednesday, August 13, 2008 and discussed the matter with yo

s, while Jane Doe I1 already bad a pending state court suit filed in July of 2008 seeking damages against Epstein for sexual assault and conspiracy. Jane Doe H in her federal complaint alleged Epstein could "not contest liability for claims brought exclusively pursuant to 18 U.S.C. §2255". Exhibit 27, Amend

im for damages, whether pursuant to state. federal, or common law". Exhibit 2, NPA 18. More is required of a plaintiff than to simply allege, as did Jane Doe 101, that she "exclusively seeks civil remedies pursuant to 18 USC 2255." Exhibit 27, Amended Complaint 1 24. Such an averment satisfies only the exc

several objections to the suggested modification in my letter to Mr. Acosta, dated December 21, 2007. See Exhibit 21, December 21, 2007 Letter from J. Leficowitz to U.S. Attorney Acosta. I personally became aware of the inclusion of that language on Wednesday, August 13, 2008 and discussed the matter with yo

the formcr firm of Herman, Sloman, & Mermelstein, filed five lawsuits, each asking for $50 million, against Mr. Epstein. Each lawsuit is entitled "Jane Doe # vs. 'effigy Epstein" despite the fact that each of the plaintiffs is an adult and not entitled to plead anonymously. See Tab 32, Examples of Federa

tion Agreement. 21. His attorneys asked to "please do whatever you can to keep this from limit public." See Tab 27, September 24, 2007 Email from J. Leficowitz to,. 22. -replied that she had "forwarded your message only to Alex [Acosta], [ , and I don't anticipate it going any further than that." Id.

given to attorneys for the victims about the non-prosecution agreement, including information about what could be told to Brad Edwards (counsel for Jane Doe #1 and Jane Doe #2) about the non-prosecution agreement; f) All correspondence, documents, and other information regarding Epstein's awareness that

ich involves "File folder entitled '12/05/07 Starr to Acosta' containing drafts of 11/30/07 letters from A. Acost to K. Starr and from J. Sloman to J. Leficowitz re performance and victim notification with handwritten notes and edits by A. Marie Villafafia." This information goes very directly to the issues i