Epstein Secrets

E-mail and U.S. Mail Brad Edwards, Esq. Rothstein Rosenfeldt Adler 401 East Las Olas Boulevard Suite 1650 Fort Lauderdale, FL 33301 Re: Doe v. E_pstein L.M. v. Epstein E.W. v. Epstein Dear Brad: A L!MlHD LIABILITY PARTNERSH IP August27,2009 AbELO!)I ). BENAVENTE P"RAI.EGAI./INVESTIGATOR ) ES

pending motion for a protective order filed by Jane Does 2-8.1 Jane Doe supplements those facts with the following facts. 2. On June 30, 2008, Jeffrey Epstein pled guilty to one count of procuring a person under 18 for prostitution and one count of felony solicitation to prostitution before the Circuit Co

119-MARRA/JOHNSON 4 Please be advised that Mr. Epstein plans to be in attendance at the deposition of y

rder (Case No. 08-CV-80119, dkt. #292) preventing defendant Epstein from attending her upcoming deposition and suppl

th the following facts. 2. On June 30, 2008, Jeffrey Epstein pled guilty to one count of procuring a

se he had not talked to her he had not had “contact.” The law does not take such an absurdly narrow view of what amounts to “contact.” See, e.g., BRYAN A. GARNER, BLACK’S LAW DICTIONARY (8th ed. 2004) (defining “no contact” order as the same as a “stay-away order” and noting that a “stay-away order” usually “

uite 1650 Fort Lauderdale, FL 33301 Re: Doe v. E_pstein L.M. v. Epstein E.W. v. Epstein Dear Brad: A

th the following facts. 2. On June 30, 2008, Jeffrey Epstein pled guilty to one count of procuring a person u

119-MARRA/JOHNSON 4 Please be advised that Mr. Epstein plans to be in attendance at the deposition of y

rder (Case No. 08-CV-80119, dkt. #292) preventing defendant Epstein from attending her upcoming deposition and suppl

th the following facts. 2. On June 30, 2008, Jeffrey Epstein pled guilty to one count of procuring a

w view of what amounts to “contact.” See, e.g., BRYAN A. GARNER, BLACK’S LAW DICTIONARY (8th ed. 2004) (defining

GING RIGHTS ATTACH UNDER THE CVRA ............... 90 A. A Test for Determining When Rights Attach.......0...000ccceeee 9] B. Applying the Test to the Epstein Case ..........ccccccceccccceceeeneees 93 C. Current Department Policy on Pre-charging Rights.................... 94 D. State Law Extension of Pre-ch

ll phases of the criminal justice process.° Congress drafted the CVRA, for example, broadly to make crime victims participants in criminal cases. The Jeffrey Epstein sex abuse case demonstrates the importance of victim participation even before charges are filed. A. A BRIEF HISTORY OF CRIME VICTIMS’ RIGHTS The c

have taken steps to object” to the plea agreement, and that they believed criminal prosecution to be “extremely important”). 4 See ANTONIN SCALIA & BRYAN A. GARNER, READING Law: THE INTERPRETATION OF LEGAL TEXTS 56 (2012). °° 18 U.S.C. § 3771(a) (2012) (enumerating eight rights), id. § 3771(c)(1) (requiring gov

for crime victims has arisen - specifically, the Jeffrey Epstein sex abuse case before a federal court in Florida. In that case, girls victimized by Epstein have argued that they should have been consulted about a federal nonprosecution agreement; Department attorneys have responded that because prosecuto

Congress sought to end that suffering by making victims meaningful participants in criminal cases. 3° C. AN ILLUSTRATION OF THE PRE-CHARGING ISSUE: THE JEFFREY EPSTEIN CASE Grven the potentially expansive scope of victims' rights under both state provisions and the CVRA, a critical question arises about how to appl

under the Act even before charges are filed. [*73] C. COURTS RECOGNIZE THAT CRIME VICTIMS HAVE CVRA RIGHTS BEFORE CHARGING 4 See Antonin Scalia & Bryan A. Garner, Reading Law: The Interpretation of Legal Texts 56 (2012). % 18 U.S.C. § 3771(a) (2012) (enumerating eight rights); id. § 3771(c)(1) (requiring gove