Epstein Secrets

COURT SOUTHERN DISTRICT OF NEW YORK X Plaintiff, 19 Civ. 10475 (LGS) -against- DARREN K. INDYKE, in his capacity as executor : of the Estate of Jeffrey Edward Epstein, et al., Defendants. LORNA G. SCHOFIELD, District Judge: X OPINION AND ORDER On January 21, 2021, Plaintiff iled a motion to dismiss this acti

k law. These claims stem from and/or arise in connection with Mr. EFTA00095371 Case 1:19-cv-10475-LGS-DCF Document 118 Filed 02/10/21 Page 2 of 6 Epstein's and Ms. Maxwell's alleged sexual abuse of Plaintiff. Defendants did not file counterclaims. On June 2, 2020, the Superior Court of the United Sta

Epstein Victims' Compensation Program, a voluntary independent program designed to compensate and resolve the claims of victims of sexual abuse by Jeffrey Epstein (the "Program"). On June 22, 2020, based on an understanding that Plaintiff wished to participate in the Program and that participation could result

pacities as appointed executors of the Estate of Jeffrey E. Epstein (the "Estate") (Indyke and Kahn together

pacities as appointed executors of the Estate of Jeffrey E. Epstein (the "Estate") (Indyke and Kahn together,

aintiff executed a release, releasing the Estate, Mr. Epstein and other related entities and individuals, incl

A district court may exercise its "sound discretion" in deciding a Rule 41(a)(2) motion. Catanzano v. Wing, 277 F.3d 99, 109 (2d Cir. 2001); accord Stinson v. City Univ. of New York, No. 18 Civ. 5963, 2020 WL 2133368, at *2 (S.D.N.Y. May 4, 2020). Although "[v]oluntary dismissal without prejudice is .

77 everything, but I really do not think that Mr. Epstein is going to engage in serious negotiations until

orking on a deferred [sic] prosecution agreement because it may well be that we cannot reach agreement here.” The defense redline version required Epstein to plead guilty to a federal information charging two misdemeanor counts of attempt to intentionally harass a person to prevent testimony, the pendi

154 The Affirmation read: “I, Jeffrey E. Epstein do hereby re-affirm the Non-Prosecution

d victims of state crimes secure civil financial settlements.” 154 The Affirmation read: “I, Jeffrey E. Epstein do hereby re-affirm the Non-Prosecution Agreement and Addendum to same dated October 30, 2007.” 155 Villafaña sent Lefkowitz a five-page letter r

147 Acosta and Villafaña were copied on this email. 148 The Addendum is attached as Exhibit 4 to this Report. 94 D. Epstein Further Delays His Guilty Plea The addendum did not bring the case to conclusion. Instead, the matter entered a new, protracted phase, which inv

154 The Affirmation read: “I, Jeffrey E. Epstein do hereby re-affirm the Non-Prosecution A

d to establish that government lacked probable cause to believe the defendant’s wife had committed a crime at the time it threatened to charge her); Stinson v. State, 839 So. 2d 906, 909 (Fla. App. 2003) (“In cases involving . . . a promise not to prosecute a third party, the government must act in good

TRICT OF FLORIDA Case No. 9:08-ev-80736-Civ-ICAM JANE DOE 1 and JANE DOE 2 I UNITED STATES JANE DOE 1 AND JANE DOE 2'S RESPONSE IN OPPOSITION TO EPSTEIN'S MOTION FOR A PROTECTIVE CONFIDENTIALITY ORDER COME NOW Jane Doe 1 and Jane Doe 2 (also referred to as "the victims"), by and through undersigned

o the case, suggesting in its plot that federal government had intervened improperly to prevent effective prosecution. See Law & Order Commemorates Jeffrey Epstein's Taste for Teen Hookers, http://gawker.comM5751094/law--order-commemorates-jeffrey-epsteins-taste-for- teen-hookers. The public interest in this ca

ld have been. There has long been suspicion that Jeffrey Epstein was receiving favorable treatment in the

from the 12 EFTA00209247 correspondence where Mr. Epstein's attorneys urged the United States Attorney's of

on. DE 188 at 9-10 (emphasis added). Accordingly, the issue has already been settled once — and the Court should not revisit it. See United States Stinson, 97 F.3d 466, 469 (11th Cir.1996) (discussing law of the case doctrine); see also Singh' Washington Univ., 383 F.Supp.2d 99, 101 (D.D.C. 2009) (in

Conduct Continued Past November I, 2004 4 C. The Goals of Sentencing Are Not Served by Applying the More Onerous 2004 Guidelines Based Solely on Epstein's Conduct 8 II. The Five-Point Adjustment Under USSG § 4B1.5 Does Not Apply 10 A. Ms. Maxwell Does Not Present a Continuing Danger to the Publi

ld be unjust and contrary to the express purpose of § 4B1.5.6 Furthermore, by applying § 4B1.5 Ms. Maxwell would face the same sentencing range that Jeffrey Epstein would face for the same offenses, even though he was indisputably the more culpable offender. It would be fundamentally unjust and contrary to the g

bi C. Stemheim Law Offices of Bobbi C. Stemheim Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN &

kely v. Washington, 542 U.S. 296 (2004) 4 Kimbrough v. United States, 552 U.S. 85 (2007) 15 Peugh v. United States, 569 U.S. 530 (2013) 1, 4 Stinson v. United States, 508 U.S. 36 (1993) 14 United States v. Bennett, 37 F.3d 687 (1st Cir. 1994) 8 United States v. Booker, 543 U.S. 220 (2005)

CT COURT SOUTHERN DISTRICT OF NEW YORK X Plaintiff, 19 Civ. 10475 (LGS) -against- DARREN K. INDYKE, in his capacity as executor : of the Estate ofJeffkey Edward Epstein, et al., Defendants. LORNA G. SCHOFIELD, District Judge: X OPINION AND ORDER On January 21, 2021, Plaintiff filed I motion to dismiss this act

plaint against Ms. Maxwell and Defendants Darren K. Indyke and Richard D. Kahn in their official capacities as appointed executors of the Estate of Jeffrey E. Epstein (the "Estate") (Indyke and Kahn together, the "Co-Executors"). The Complaint alleges claims of battery, false imprisonment and intentional inflictio

pacities as appointed executors of the Estate of Jeffrey E. Epstein (the "Estate") (Indyke and Kahn together,

pacities as appointed executors of the Estate of Jeffrey E. Epstein (the "Estate") (Indyke and Kahn togeth

ce of an offer of compensation on October 5, 2020. In exchange for the offer of compensation, Plaintiff executed' release, releasing the Estate, Mr. Epstein and other related entities and individuals, including Ms. Maxwell, from any and all claims (the "General Release"). To receive her compensation, Pl

laintiff executed' release, releasing the Estate, Mr. Epstein and other related entities and individuals, incl

). I district court may exercise its "sound discretion" in deciding' Rule 411(2) motion. Catanzano v. Wing, 277 F.3d 99, 109 (2d Cir. 2001); accord Stinson v. City Univ. of New York, No. 18 Civ. 5963, 2020 WL 2133368, at *2 (S.D.N.Y. May 4, 2020). Although "[v]oluntary dismissal without prejudice is ..