Epstein Secrets

) & (8). It is now beyond dispute, for example, that in September 2007, the U.S. Attorney's Office formally signed a non-prosecution agreement with Jeffrey Epstein that barred his The victims are contemporaneously filing a motion to have their facts accepted by the Court. EFTA00177009 Case 9:08-cv-80736-KAM

ein agreed to a "confidentiality" provision in the agreement barring its disclosure to anyone — including the victims. For the next nine months, as Epstein was well aware, the U.S. Attorney's Office assiduously concealed from the victims the existence of this signed non-prosecution agreement. Indeed, th

t's desire that federal charges be filed against defendant Epstein. In particular, he wrote on behalf of his clients

formally signed a non-prosecution agreement with Jeffrey Epstein that barred his The victims are contempo

criminal prosecution commensurate with the crimes Mr. Epstein has committed, and we further urge you to take t

a victim the right to "be treated with fairness and with respect for the victim's dignity and privacy." 18 U.S.C. § 3771(a)(8). As Magistrate Judge Orenstein observed in Turner: "Neither the text of the statute nor its legislative history provides guidance as to what specific procedures or substantive re

18 19 20 21 22 23 24 25 were sometimes partially or fully nude. She also encouraged these minors to engage in additional acts of abuse with Jeffrey Epstein. The indictment makes plain, your Honor, this was not a single incident or a single victim or anything isolated but, instead, it was an ongoing sch

.C. (212) 805-0300 EFTA00066240 Lb k7e2MaxC kjc 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 arrest of Mr. Epstein. Is that accurate and did that include information as to her whereabouts? : Your Honor, that information did not include information about her whe

deliver me, with full knowledge of the heinous and dehumanizing abuse that awaited me, straight to the hands of Jeffrey Epstein. Without Ghislaine, Jeffrey could not have done what he did. She was in charge. She egged him on and encouraged him. She told me of others she recruited and she thought it wa

16 17 18 19 20 21 22 23 24 25 arrest of Mr. Epstein. Is that accurate and did that include informati

flight, and the courts have -- in this circuit have thought about and researched what weight should be given to that. There is an opinion by Judge Orenstein in the Eastern District, United States v. Turner, from April 2005, not cited by the government, in which the court, after carefully surveying the l

16 17 18 19 20 21 22 23 24 25 arrest of Mr. Epstein. Is that accurate and did that include informati

encouraged 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 these minors to engage in additional acts of abuse with Jeffrey Epstein. The indictment makes plain, your Honor, this was not a single incident or a single victim or anything isolated but, instead, it was an ongoing sch

04/01/2021, 3068296. Page75 of 351 26 k7e2MaxC kjc 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 arrest of Mr. Epstein. Is that accurate and did that include information as to her whereabouts? : Your Honor, that information did not include information about her whe

deliver me, with full knowledge of the heinous and dehumanizing abuse that awaited me, straight to the hands of Jeffrey Epstein. Without Ghislaine, Jeffrey could not have done what he did. She was in charge. She egged him on and encouraged him. She told me of others she recruited and she thought it wa

flight, and the courts have -- in this circuit have thought about and researched what weight should be given to that. There is an opinion by Judge Orenstein in the Eastern District, United States v. Turner, from April 2005, not cited by the government, in which the court, after carefully surveying the l

l relevant times, the Office had approximately 20 Assistant U.S. Attorneys assigned to the West Palm Beach location. The prosecutor assigned to the Epstein case, I I end I were assigned to different sections within the Office. We reported to different supervisors. 11. I did not participate in any way

ent 79 Entered on FLSD Docket 05/03/2011 Page 2 of 4 violated Florida Bar rules and Department of Justice regulations by representing employees of Jeffrey Epstein ("Epstein") in civil litigation after the undersigned retired from the United States Attorney's Office for the Southern District of Florida (the "Of

Justice regulations by representing employees of Jeffrey Epstein ("Epstein") in civil litigation after the

s retained to represent several other members of Mr. Epstein's staff in their civil depositions. I5.. After

a victim the right to "be treated with fairness and with respect for the victim's dignity and privacy." 18 U.S.C. § 3771(a)(8). As Magistrate Judge Orenstein observed in Turner "Neither the text of the statute nor its legislative history provides guidance as to what specific procedures or substantive rel

l relevant times, the Office had approximately 20 Assistant U.S. Attorneys assigned to the West Palm Beach location. The prosecutor assigned to the Epstein case, Ann Marie Villafana, end I were assigned to different sections within the Office. We reported to different supervisors. 11. I did not partic

ent 79 Entered on FLSD Docket 05/03/2011 Page 2 of 4 violated Florida Bar rules and Department of Justice regulations by representing employees of Jeffrey Epstein ("Epstein") in civil litigation after the undersigned retired from the United States Attorney's Office for the Southern District of Florida (the "Of

Justice regulations by representing employees of Jeffrey Epstein ("Epstein") in civil litigation after the

s retained to represent several other members of Mr. Epstein's staff in their civil depositions. I5.. After

a victim the right to "be treated with fairness and with respect for the victim's dignity and privacy." 18 U.S.C. § 3771(a)(8). As Magistrate Judge Orenstein observed in Turner "Neither the text of the statute nor its legislative history provides guidance as to what specific procedures or substantive rel

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

a victim the right to "be treated with fairness and with respect for the victim's dignity and privacy." 18 U.S.C. § 3771(a)(8). As Magistrate Judge Orenstein observed in Turner: "Neither the text of the statute nor its legislative history provides guidance as to what specific procedures or substantive re

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

a victim the right to "be treated with fairness and with respect for the victim's dignity and privacy." 18 U.S.C. § 3771(a)(8). As Magistrate Judge Orenstein observed in Turner: "Neither the text of the statute nor its legislative history provides guidance as to what specific procedures or substantive re

reference 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

etitioners, or the defense attorneys representing Jeffrey Epstein. Nor are the subjective beliefs of DOJ e

a victim the right to "be treated with fairness and with respect for the victim's dignity and privacy." 18 U.S.C. § 3771(a)(8). As Magistrate Judge Orenstein observed in Turner : "Neither the text of the statute nor its legislative history provides guidance as to what specific procedures or substantive re

s federal civil actions in Florida. Compl. ¶ 8-21, 26-27. Ms. Maxwell was not a party to any of those litigations: not the criminal case against Mr. Epstein (Compl. ¶ 14), any non-prosecution agreement between Mr. Epstein and the U.S. Attorney's Office (Comp1.11 11-13), the litigation concerning the Cri

those litigations: not the criminal case against Mr. Epstein (Compl. ¶ 14), any non-prosecution agreement bet

f a defamation claim," a Court may properly dismiss a defamation such a claim pursuant to Rule 12(b)(6) where a qualified privilege is established. Orenstein v. Figel, 677 F.Supp.2d 706, 711 (S.D.N.Y. 2009); see also Fuji Photo Film U.S.A., Inc. v. McNulty, 669 F.Supp.2d 405 (S.D.N.Y. 2009). Ms. Maxwell'