Epstein Secrets

Case 9:08-cv-80119-KAM Document 16-2 Entered on FLSD Docket 07/01/2008 Page 2 of 4 : tiP • ' CASE PIO ±-122OO.1.:IFO-51/4 541sXXX CF V. JEFFREY E. EPSTEIN Z41 'FP ^i ria4 Y tr..mr.y..PRzia"rtnivz•zrt : . • . 7 'Crt. Rep. lun,L__ Date : • -17 vcri J „Asir )----=-- • / PD e--P:9fot Pres, D

events or omissions giving rise to the claim occurred in this District. Factual Allegations 7. At all relevant times, Defendant Jeffrey Epstein ("Epstein") was an adult male, 52 years old. Epstein is a financier and money manager with a secret clientele limited exclusively to billionaires. He is hims

, represented by Assistant United States , and Mr. Epstein, entered into a deferred- prosecution agreement (

' CASE PIO ±-122OO.1.:IFO-51/4 541sXXX CF V. JEFFREY E. EPSTEIN Z41 'FP ^i ria4 Y tr..mr.y..PRzia"r

ach, Florida 33401 Tel. 561 659 8300 Fax. 561 835 8691 By: Jack A. Goldberger Fla. Bar No. 262013 jgoldberger®agwpa.com Attorneys for Defendant Jay Epstein CERTIFICATE OF COMPLIANCE WITH LOCAL RULE 711.A.3 While defense counsel admittedly did not confer with plaintiffs' counsel prior to filing the moti

l distress based on the same factual allegations. Defendant Epstein has moved to dismiss only Count I of the Complai

' CASE PIO ±-122OO.1.:IFO-51/4 541sXXX CF V. JEFFREY E. EPSTEIN Z41 'FP ^i ria4 Y tr..mr.y..PRzia"rt

dence of prior statements (including inconsistent statements) given by witnesses whom law-enforcement has previously interviewed. See. e.g., Cox v. Treadway. 75 F.3d 230, 239 (6th Cir. 1996) (holding that district court properly admitted testimony of prosecutor about prior inconsistent statements that w

9-KAM Document 38 Entered on FLSD Docket 08/12/2008 Page 1 of 13 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA JANE DOE NO. 2, vs. JEFFREY EPSTEIN. JANE DOE NO. 3, VS. JEFFREY EPSTEIN. / JANE DOE NO. 4, vs. JEFFREY EPSTEIN. JANE DOE NO. 5, vs. JEFFREY EPSTEIN. CASE NO.: 08-80119-CIV-K

VEN CLERK M LAD U -EL-r-EyeAgr CASE NO.: 08-80232-CIV- -KAM-L CASE NO.: 08-80380-CIV-KAM-LRJ CASE NO.: 08-80381-CIV-KAM-LRJ FILED UNDER SEAL. EPSTEIN'S REPLY IN SUPPORT OF MOTION TO STAY This motion is filed under seal because the deferred-prosecution agreement between the United States Attorney's

ach, Florida 33401 Tel. 561 659 8300 Fax. 561 835 8691 By: Jack A. Goldberger Fla. Bar No. 262013 jgoldberger®agwpa.com Attorneys for Defendant Jay Epstein CERTIFICATE OF COMPLIANCE WITH LOCAL RULE 711.A.3 While defense counsel admittedly did not confer with plaintiffs' counsel prior to filing the moti

OUTHERN DISTRICT OF FLORIDA JANE DOE NO. 2, vs. JEFFREY EPSTEIN. JANE DOE NO. 3, VS. JEFFREY EPSTEIN.

between the United States Attorney's Office and Mr. Epstein. discussed herein, contains a confidentiality cla

dence of prior statements (including inconsistent statements) given by witnesses whom law-enforcement has previously interviewed. See. e.g., Cox v. Treadway. 75 F.3d 230, 239 (6th Cir. 1996) (holding that district court properly admitted testimony of prosecutor about prior inconsistent statements that w

9-KAM Document 38 Entered on FLSD Docket 08/12/2008 Page 1 of 13 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA JANE DOE NO. 2, vs. JEFFREY EPSTEIN. JANE DOE NO. 3, VS. JEFFREY EPSTEIN. / JANE DOE NO. 4, vs. JEFFREY EPSTEIN. JANE DOE NO. 5, vs. JEFFREY EPSTEIN. CASE NO.: 08-80119-CIV-K

VEN CLERK M LAD U -EL-r-EyeAgr CASE NO.: 08-80232-CIV- -KAM-L CASE NO.: 08-80380-CIV-KAM-LRJ CASE NO.: 08-80381-CIV-KAM-LRJ FILED UNDER SEAL. EPSTEIN'S REPLY IN SUPPORT OF MOTION TO STAY This motion is filed under seal because the deferred-prosecution agreement between the United States Attorney's

ach, Florida 33401 Tel. 561 659 8300 Fax. 561 835 8691 By: Jack A. Goldberger Fla. Bar No. 262013 jgoldberger®agwpa.com Attorneys for Defendant Jay Epstein CERTIFICATE OF COMPLIANCE WITH LOCAL RULE 711.A.3 While defense counsel admittedly did not confer with plaintiffs' counsel prior to filing the moti

OUTHERN DISTRICT OF FLORIDA JANE DOE NO. 2, vs. JEFFREY EPSTEIN. JANE DOE NO. 3, VS. JEFFREY EPSTEIN.

between the United States Attorney's Office and Mr. Epstein. discussed herein, contains a confidentiality cla

dence of prior statements (including inconsistent statements) given by witnesses whom law-enforcement has previously interviewed. See. e.g., Cox v. Treadway. 75 F.3d 230, 239 (6th Cir. 1996) (holding that district court properly admitted testimony of prosecutor about prior inconsistent statements that w

9-KAM Document 38 Entered on FLSD Docket 08/12/2008 Page 1 of 13 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA JANE DOE NO. 2, vs. JEFFREY EPSTEIN. JANE DOE NO. 3, VS. JEFFREY EPSTEIN. / JANE DOE NO. 4, vs. JEFFREY EPSTEIN. JANE DOE NO. 5, vs. JEFFREY EPSTEIN. CASE NO.: 08-80119-CIV-K

VEN CLERK M LAD U -EL-r-EyeAgr CASE NO.: 08-80232-CIV- -KAM-L CASE NO.: 08-80380-CIV-KAM-LRJ CASE NO.: 08-80381-CIV-KAM-LRJ FILED UNDER SEAL. EPSTEIN'S REPLY IN SUPPORT OF MOTION TO STAY This motion is filed under seal because the deferred-prosecution agreement between the United States Attorney's

ach, Florida 33401 Tel. 561 659 8300 Fax. 561 835 8691 By: Jack A. Goldberger Fla. Bar No. 262013 [email protected] Attorneys for Defendant Jay Epstein CERTIFICATE OF COMPLIANCE WITH LOCAL RULE 711.A.3 While defense counsel admittedly did not confer with plaintiffs' counsel prior to filing the moti

OUTHERN DISTRICT OF FLORIDA JANE DOE NO. 2, vs. JEFFREY EPSTEIN. JANE DOE NO. 3, VS. JEFFREY EPSTEIN.

between the United States Attorney's Office and Mr. Epstein. discussed herein, contains a confidentiality cla

dence of prior statements (including inconsistent statements) given by witnesses whom law-enforcement has previously interviewed. See. e.g., Cox v. Treadway. 75 F.3d 230, 239 (6th Cir. 1996) (holding that district court properly admitted testimony of prosecutor about prior inconsistent statements that w

Case 9:08-cv-80119-KAM Document 38 Entered on FLSD Docket 08/12/2008 Page 1 of 13 JANE DOE NO. 2, vs JEFFREY EPSTEIN. I JANE DOE NO. 3, vs. JEFFREY EPSTEIN. I JANE DOE NO. 4, vs. JEFFREY EPSTEIN. I JANE DOE NO. 5, vs. JEFFREY EPSTEIN. I UNITED STATES D

OF MOTION TO STAY ' This motion is filed under seal because the deferred-prosecution agreement between the United States Attorney's Office and Mr. Epstein. discussed herein, contains a confidentiality clause. A motion to seal has been filed contemporaneously. Case 9:08-cv-80119-KAM Document 38

between the United States Attorney's Office and Mr. Epstein. discussed herein, contains a confidentiality cla

ion In 2006, a Florida state grand jury indicted Jeffrey Epstein on allegations similar to those in the i

dence of prior statements (including inconsistent statements) given by witnesses whom law-enforcement has previously interviewed. See, e.g., Cox v. Treadway, 75 F.3d 230, 239 (6th Cir. 1996) (holding that district court properly admitted testimony of prosecutor about prior inconsistent statements that w

9-KAM Document 38 Entered on FLSD Docket 08/12/2008 Page 1 of 13 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA JANE DOE NO. 2, vs. JEFFREY EPSTEIN. JANE DOE NO. 3, VS. JEFFREY EPSTEIN. / JANE DOE NO. 4, vs. JEFFREY EPSTEIN. JANE DOE NO. 5, vs. JEFFREY EPSTEIN. CASE NO.: 08-80119-CIV-K

VEN CLERK M LAD U -EL-r-EyeAgr CASE NO.: 08-80232-CIV- -KAM-L CASE NO.: 08-80380-CIV-KAM-LRJ CASE NO.: 08-80381-CIV-KAM-LRJ FILED UNDER SEAL. EPSTEIN'S REPLY IN SUPPORT OF MOTION TO STAY This motion is filed under seal because the deferred-prosecution agreement between the United States Attorney's

OUTHERN DISTRICT OF FLORIDA JANE DOE NO. 2, vs. JEFFREY EPSTEIN. JANE DOE NO. 3, VS. JEFFREY EPSTEIN.

between the United States Attorney's Office and Mr. Epstein. discussed herein, contains a confidentiality cla

dence of prior statements (including inconsistent statements) given by witnesses whom law-enforcement has previously interviewed. See. e.g., Cox v. Treadway, 75 F.3d 230, 239 (6th Cir. 1996) (holding that district court properly admitted testimony of prosecutor about prior inconsistent statements that w

f his clients is the purported victim. Accordingly, I will address facts related to C.W., T.M., and S.R. All three of those clients were victims of Jeffrey Epstein's while they were minors beginning when they were fifteen years old. 'Please note that the dates on the U.S. Attorney's Office letters to C.W. and T.

thern District of Florida asks that you provide the following notice to your client, On June 30, 2008, Jeffrey Epstein (hereinafter referred to as "Epstein) entered a plea of guilty to violations of Florida Statutes Sections 796.07 (felony solicitation of prostitution) and 796.03 (procurement of minors

401 (561)8204711 Facsimile: (561)8204777 July 9, 2008 VIA FACSIMILE Brad Edwards, Esq. The Law Offices of Brad Edwards & Associates, [.LC Re: Jeffrey 4..stein/QIN...la NOTIFICATION OF IDENTIFIED VICTIM Dear Mr. Edwards: By virtue of this letter, the United States Attorney's Office for the Southe

ceed under Section 2255 as she would have had, if Mr. Epstein EFTA00233829 Case 9:08-cv-80736-KAM Document

vidence of prior statements (including inconsistent statements) given by witnesses whom law-enforcement has previously interviewed. See, e.g., Cox' Treadway, 75 F.3d 230 (6th Cir. 1996) (holding that district court properly admitted testimony of prosecutor about prior inconsistent statements that witnes

which of his clients is the purported victim. Accordingly,) will address facts related to , S. and S.R. All three of those clients were victims of Jeffrey Epstein's while they were minors beginning when they were fifteen years old. 'Please note that the dates on the U.S. Attorney's Office letters to III and In

fteenth Judicial Circuit, Palm Beach County, Florida. This charge was based upon the offenses alleged in paragraph 1 of the petition. Second, while Epstein has been under federal investigation, he has not been charged in EFTA00183654 Case 9:08-cv-80736-KAM Document 13 Entered on FLSD Docket 07/15/20

treet, Suite 202 Hollywood, Florida 33020. Re: Jeffrey E eir m/SaVhiii: NOTIFICATION OF IDENTIFIED VICT

ve the federal investigation. al 5. At that time, Mr. Epstein had been charged by the State of Florida with so

idence of prior statements (including inconsistent statements) given by witnesses whom law-enforcement has previously interviewed. See, e.g., Cox'. Treadway, 75 F.3d 230 (6th Cir. 1996) (holding that district court properly admitted testimony of prosecutor about prior inconsistent statements that witnes

4. A CNN.com - Sandy Berger to plead guilty on documents charge - Apr I, 2005 (http://edition.am.com/2005/LAW/04/01/berger.plea0 15. na b Smith, is Jeffrey, Berger Case Still Roils Archives, Justice Dept., Washington Post, February 21, 2007 (http://www.washingtonpost.cotn/svp-dyn/content/article/2007/02

The requirement of literal compliance, however, assumes that the objections raise a matter I which ' controverted. For example, in United States Treadway, 328 F.3d 878, 885-86 (6th Cir.200 , petition for cert. filed,No. 02-11197, — U.S.L.W. ---- (U.S. June 9, 2003), where the defendant had not objec