Epstein Secrets

equest Seeking Photos Of Jeffrey Epstein And Records Surrounding His Apparent Suicide (Aug. 12, 2019) 8 Nick Bryant, Here Is Pedophile Billionaire Jeffrey Epstein's Little Black Book, Gawker (Jan. 23, 2015) 16 Office of the Inspector General, Audit of the Federal Bureau of Prisons ' Monitoring of Inmate Commu

rtment of Justice's Inspector General, and the Bureau of Prisons itself all launched investigations. For his part, the President has suggested that Epstein was "killed" while in federal custody. Matt Zapotosky, Trump questions whether Jeffrey Epstein was killed in federal custody. His attorney general a

ive is his brother Mark, who has said they "were not that close" and is himself eager for more documents to be released by BOP. See Julie K. Brown, Je •ey Epstein Wasn't Trafficking Women — And He Didn't Kill Himself Brother Says, Miami Herald (Nov. 14, 2019), hups://hrld.us/3ibIANJ (noting that "Mark Epstein

m OTHER AUTHORITIES Ali Watkins & Michael Gold, Jeffrey Epstein Autopsy Results Show He Hanged Himself in

s to be released by BOP. See Julie K. Brown, Je •ey Epstein Wasn't Trafficking Women — And He Didn't Kill Hi

under which [each] deletion is made"). Failure to meet that burden requires disclosure of the requested documents. See Nat'l Council of La Raza v. Dep't of Justice, 411 F.3d 350, 355-56 (2d Cir. 2005). A court reviews de novo an agency's decision to withhold information from the public. See 5 U.S.C. § 552(a)(4

m OTHER AUTHORITIES Ali Watkins & Michael Gold, Jeffrey Epstein Autopsy Results Show He Hanged Himself in

s to be released by BOP. See Julie K. Brown, Je •ey Epstein Wasn't Trafficking Women — And He Didn't Kill Hi

equest Seeking Photos Of Jeffrey Epstein And Records Surrounding His Apparent Suicide (Aug. 12, 2019) 8 Nick Bryant, Here Is Pedophile Billionaire Jeffrey Epstein's Little Black Book, Gawker (Jan. 23, 2015) 16 Office of the Inspector General, Audit of the Federal Bureau of Prisons ' Monitoring of Inmate Commu

rtment of Justice's Inspector General, and the Bureau of Prisons itself all launched investigations. For his part, the President has suggested that Epstein was "killed" while in federal custody. Matt Zapotosky, Trump questions whether Jeffrey Epstein was killed in federal custody. His attorney general a

ive is his brother Mark, who has said they "were not that close" and is himself eager for more documents to be released by BOP. See Julie K. Brown, Je •ey Epstein Wasn't Trafficking Women — And He Didn't Kill Himself Brother Says, Miami Herald (Nov. 14, 2019), hups://hrld.us/3ibIANJ (noting that "Mark Epstein

under which [each] deletion is made"). Failure to meet that burden requires disclosure of the requested documents. See Nat'l Council of La Raza v. Dep't of Justice, 411 F.3d 350, 355-56 (2d Cir. 2005). A court reviews de novo an agency's decision to withhold information from the public. See 5 U.S.C. § 552(a)(4

form the basis for Counts Five and Six—to the grand jury in the Southern District of Florida in support of a proposed 60-count federal indictment of Jeffrey Epstein and Sarah Kellen. (Id. at 22:17-31:6). The indictment included a conspiracy count and a substantive count alleging a sex trafficking offense involvi

torney's Office for the Southern District of Florida ("USAO-SDFL") interviewed Accuser-4 in or around 2007 during their three- year investigation of Epstein's alleged sexual abuse (the "Florida Investigation"). And remarkably, although interviewed just a few years after she claims any misconduct occurred

LP 800 Third Avenue New York, NY 10022 Phone: Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN &

5a). "[F]rom 2001 to 2004, [Accuser-4] provided Mr. Epstein with ... over 100 massages and all but three of

ell with sex trafficking offenses under 18 U.S.C. § 1591 (Counts Five and Six) and has dramatically expanded the timeframe of the Mann Act 2 Ex. A (Dep't of Justice, Office of Professional Responsibility, Investigation into the U.S. Attorney's Office for the Southern District of Florida's Resolution of its 2006-

after your confirmation as Attorney General, you were asked directly by Fox News' America Reports host John Roberts: "DOJ may be releasing the list ofJeffrey Epstein's clients; will that really happen?"' Your response was: "It's sitting on my desk right now to review."' On February 27, you released binders of docum

hat really happen?"' Your response was: "It's sitting on my desk right now to review."' On February 27, you released binders of documents related to Epstein to conservative influencers and commentators,' but despite the major media event the White House staged around this release, these files were large

es not contradict any official statement from DOJ and accords with the DOJ Inspector General's investigation into the Bureau of Prisons' custody of Jeffrey Epstein.10 However, public skepticism of the government's transparency in this matter has been needlessly increased due to your release of surveilla

as mentioned. Notably, in 2002, Mr. Trump said of Mr. Epstein, "I've known Jeff for 15 years. Terrific guy, He

will get everything"; that you were "assured" there was more; and that the country would eventually see "the full Epstein files."6 1 Memorandum from Dep't of Justice and Fed. Bureau of Investigation on Review of Investigative Holdings Relating to Jeffrey Epstein (Jul. 7, 2025), available at https://www.justice.go

after your confirmation as Attorney General, you were asked directly by Fox News' America Reports host John Roberts: "DOJ may be releasing the list ofJeffrey Epstein's clients; will that really happen?"' Your response was: "It's sitting on my desk right now to review." On February 27, you released binders of docume

that really happen?"' Your response was: "It's sitting on my desk right now to review." On February 27, you released binders of documents related to Epstein to conservative influencers and commentators,' but despite the major media event the White House staged around this release, these files were large

es not contradict any official statement from DOJ and accords with the DOJ Inspector General's investigation into the Bureau of Prisons' custody of Jeffrey Epstein.10 However, public skepticism of the government's transparency in this matter has been needlessly increased due to your release of surveilla

as mentioned. Notably, in 2002, Mr. Trump said of Mr. Epstein, "I've known Jeff for 15 years. Terrific guy, He

will get everything"; that you were "assured" there was more; and that the country would eventually see "the full Epstein files.' 1 Memorandum from Dep't of Justice and Fed. Bureau of Investigation on Review of Investigative Holdings Relating to Jeffrey Epstein (Jul. 7, 2025), available at https://www.justice.go

& DAG Congressional Priority (Reed from OLA via email) In light of the professional ties to the firm, Kirkland & Ellis that previously represented Jeffrey Epstein, requesting the AG & DAG recuse themselves from any and all matters related to his case in order to ensure and maintain the integrity of the crimin

NY, charging Jeffrey Epstein with the sex trafficking of minors. Further mentions Members of Congress and DOJ's/OPR inquires into the crimes of Mr. Epstein, which a federal judge on 02/21/2019, held that the secret deal secured by Epstein's lawyers violated the Crime Victims' Rights Acts. See WF 416704

rm, Kirkland & Ellis that previously represented Jeffrey Epstein, requesting the AG & DAG recuse themselv

ongress and DOJ's/OPR inquires into the crimes of Mr. Epstein, which a federal judge on 02/21/2019, held that

District of Florida Alex 'Indictment, United States v. Epstein, No. 19 Crim. 490 (S.D.N.Y. July 2, 2019), ECF No. 2. 2 Id. at I. 3 Press Release, Dep't of Justice, U.S. Attorney's Office, S.D.N.Y., Jeffrey Epstein Charged In Manhattan Federal Court With Sex Trafficking Of Minors: Alleged Conduct Occurred in bo

IN THE DISTRICT COURT OF APPEAL OF THE STATE OF FLORIDA, FOURTH DISTRICT JEFFREY EPSTEIN, Petitioner, v. STATE OF FLORIDA, Respondent. CASE NO. 4D09-2554 PALM BEACH COUNTY L.T. CASE NO. 2008 CF 009381A REPLY TO RESPONSES TO EMERGE

Judge Colbath defer to the federal court, which has twice denied disclosure of the confidential non- prosecution between the U.S. government and Mr. Epstein to third parties. Just 1 09/12/2019 Agency to Agency Requet: 19-411 CONFPI535ENTIAL SDNY_GM_00331783 EFTA 00204509 EFTA02729494 last week, J

APPEAL OF THE STATE OF FLORIDA, FOURTH DISTRICT JEFFREY EPSTEIN, Petitioner, v. STATE OF FLORIDA, Res

non- prosecution between the U.S. government and Mr. Epstein to third parties. Just 1 09/12/2019 Agency to

ted States v. John Doe Inc. I, 481 U.S. 102, 109 n.5 (1987); United States v. Eisenberg, 711 F.2d 959, 961 (11th Cir. 1983); Lance v. United States Dep't of Justice (In re Grand Jury Investigation), 610 F.2d 202, 213 (5th Cir. 1980). A ruling unsealing the non-prosecution agreement and addendum would not disclo

eference to the position taken by employees of the Department of Justice (DOJ) in letters to the petitioners, or the defense attorneys representing Jeffrey Epstein. Nor are the subjective beliefs of DOJ employees relevant to the issue of whether a duty existed under § 3771(a)(5) to consult with petitioners prio

later, on July 9, 2008, the Government filed its Response and an accompanying Declaration, establishing that (1) no federal criminal case charging Epstein had ever been filed and that a non- prosecution agreement ("NPA") had been signed and (2) despite this, the U.S. Attorney's Office had used its best

titioners, or the defense attorneys representing Jeffrey Epstein. Nor are the subjective beliefs of DOJ em

s been filed." 23 EFTA00078857 Case 9:08-cv-80736-KAM Document 62 Entered on FLSD Docket 04/08/2011 Page 24 of 54 In Sieverding v. United States Dep't of Justice, 693 F. Supp. 2d 93 (D.D.C. 2010), the district court discussed a series of claims brought by the Sieverdings, a husband and wife so well known to

eference to the position taken by employees of the Department of Justice (DOJ) in letters to the petitioners, or the defense attorneys representing Jeffrey Epstein. Nor are the subjective beliefs of DOJ employees relevant to the issue of whether a duty existed under § 3771(a)(5) to consult with petitioners prio

later, on July 9, 2008, the Government filed its Response and an accompanying Declaration, establishing that (1) no federal criminal case charging Epstein had ever been filed and that a non- prosecution agreement ("NPA") had been signed and (2) despite this, the U.S. Attorney's Office had used its best

titioners, or the defense attorneys representing Jeffrey Epstein. Nor are the subjective beliefs of DOJ em

V-MARRAMOHNSON EFTA00208059 Case 9:08-cv-80736-KAM Document 57-1 Entered on FLSD Docket 04107/2011 Page 24 of 54 In Sieverding v. United States Dep't of Justice, 693 F. Supp. 2d 93 (D.D.C. 2010), the district court discussed a series of claims brought by the Sieverdings, a husband and wife so well known to

ed States, 817 F. Supp. 2d 1337, 1342-45 (SD. Fla. 2011) (recognizing that 1/8 U.S.C. § 3771(a) can apply before formal charges are filed); Jordan v. Dep't of Justice, 173 F. Supp. 3d 44, 52 (S.D.N.Y. 2016) (citing In re Dean, 527 F.3d at 395); United States v. BP Prod. N. Am., Inc., No. H-07-434, 2008 WL 501321, a

Defining the Scope of 18 U.S.C. § 666, 46 Colum. JE. & Soc. Probs. 207, 237-45 (2012) (arguing for br