Epstein Secrets

, vs UNITED STATES OF AMERICA, Respondent. I JEFFREY EPSTEIN, Intervenor. I INTERVENOR JEFFREY EPST

PRECLUDE IMPOSITION OF THE EPSTEIN REMEDIES A. Mr. Epstein was not a Party to the Underlying Litigation and

o prosecuting what was, at heart, a local sex abuse case." See Jeffrey Sloman, Alex Acosta Acted with Professionalism and Integrity in Handling the Jeffrey Epstein Case, Miami Herald Op-Ed, Feb. 15, 2019. The USAO-SDFL's decision to enter into the NPA was also influenced by its consideration of the privacy interest

EEMENT 1 EFTA00299022 TABLE OF CONTENTS INTRODUCTION BACKGROUND ARGUMENT I. PRINCIPLES OF PROCEDURAL DUE PROCESS PRECLUDE IMPOSITION OF THE EPSTEIN REMEDIES A. Mr. Epstein was not a Party to the Underlying Litigation and There is no Judgment Against him B. There is no Judicial Finding of "Bad

teenth Judicial Circuit in and for Palm Beach County on one count of solicitation of prostitution, in violation of Fla. Stat. §796.07. See State v. Jeffiey E. Epstein, 50-2006-CF-009454-AXXX-MB. In or around November 2006, while the state court charge was pending, Mr. Epstein learned that the United States Attorn

4 The fact that Mr. Epstein's counsel sought to keep the NPA outside the public record was hardly unusual. The NPA is not a judicial document. See Craig S. Morford, Acting Deputy Attorney General, Selection and Use of Monitors in Deferred Prosecution Agreements and Non—Prosecution Agreements with Corporations,

For A Millionaire Sex Abuser,” Huffington Post, Nov. 29, 2018; Julie K. Brown, et al., “Lawmakers issue call for investigation of serial sex abuser Jeffrey Epstein’s plea deal,” Miami Herald, Dec. 6, 2018. 5 Doe v. United States, 359 F. Supp. 3d 1201 (S.D. Fla., Feb. 21, 2019) (Opinion and Order, 9:08-80736-CIV

n by negotiating and executing a federal non-prosecution agreement (NPA). The NPA was intended to end a federal investigation into allegations that Epstein engaged in illegal sexual activity with girls.1 OPR also investigated whether USAO prosecutors committed professional misconduct by failing to con

e Parties Continue to Negotiate Issues concerning the Attorney Representative and Finally Reach Agreement on the NPA Addendum ................91 D. Epstein Further Delays His Guilty Plea .................................................................94 E. Epstein Seeks Departmental Review of the NP

Its 2006–2008 Federal Criminal Investigation of Jeffrey Epstein and Its Interactions with Victims during

me when you were first authorized to investigate Mr. Epstein that the office had concerns about taking this c

to plea agreements, which involve the formal conviction of a corporation in a court proceeding. Memorandum from Acting Deputy Attorney General Craig S. Morford to Heads of Departmental Components and United States Attorneys at n.2 (Mar. 7, 2008), available at https://www.justice.gov/archives/jm/criminal-res

CT OF FLORIDA CASE No. 08-80736-CIV-MARRA/JOHNSON JANE DOE 1 AND JANE DOE 2, Plaintiffs I. UNITED STATES OF AMERICA, Defendant / INTERVENOR JEFFREY EPSTEIN'S MEMORANDUM IN SUPPORT OF HIS ATTENDANCE AT OR PARTICIPATION IN SETTLEMENT CONFERENCE Intervenor Jeffrey Epstein has requested that he be permitted

likely that any meaningful settlement discussions can take place between the plaintiffs and the government without touching on remedy. Granting Mr. Epstein, through counsel, the right to participate in the settlement conference is necessary to effectuate Judge Marra's order granting Mr. Epstein's motion

ED STATES OF AMERICA, Defendant / INTERVENOR JEFFREY EPSTEIN'S MEMORANDUM IN SUPPORT OF HIS ATTENDANC

government without touching on remedy. Granting Mr. Epstein, through counsel, the right to participate in the

nd the defendant, are never filed with the federal court and by definition precede the institution of federal criminal charges. See Memorandum from Craig S. Morford, Acting Deputy Att'y Gen., U.S. Dep't of Justice, to Heads of Department Components, U.S. Att'ys re: Selection and Use of Monitors in Deferred Pro

ISTRICT OF FLORIDA CASE No. 08-80736-CIV-MARRA/JOHNSON JANE DOE I AND JANE DOE 2, Plaintiffs v. UNITED STATES OF AMERICA, Defendant INTERVENOR JEFFREY EPSTEIN'S MEMORANDUM IN SUPPORT OF HIS ATTENDANCE AT OR PARTICIPATION IN SETTLEMENT CONFERENCE Intervenor Jeffrey Epstein has requested that he be permitted

conference to be convened in this matter. The right to participate in the settlement conference flows inexorably from Judge Marra's granting of Mr. Epstein's motion to intervene as of right at the remedy stage of these proceedings to advocate for why the remedy in this case—to the extent that the plain

UNITED STATES OF AMERICA, Defendant INTERVENOR JEFFREY EPSTEIN'S MEMORANDUM IN SUPPORT OF HIS ATTENDANC

e flows inexorably from Judge Marra's granting of Mr. Epstein's motion to intervene as of right at the remedy

the government and the defendant that are never filed with the court and do not result in the institution of criminal charges. See Memorandum from Craig S. Morford, Acting Deputy Att'y Gen., U.S. Dep't of Justice, to Heads of Department Components, U.S. Att'ys re: Selection and Use of Monitors in Deferred Pros