Epstein Secrets

ndersigned Assistant United States Attorney, and files this response to the Court's Order requesting the position of the United States on Defendant Jeffrey Epstein's Motion to Stay Proceedings [DE 99]. For the reasons set forth below, it is the United States' position that a stay of the proceedings is not necessa

f the civil proceedings in the "interests of justice" until the "expiration" of the Non- Prosecution Agreement ["NPA"] between the United States and Epstein? By filing this response, the United States does not make itself a party to this litigation and takes no position with respect to the outcome of an

Y. 1655 Pike DeleePh.„,.. .ML lt Fst!ii!lefleach, IR. »CI 1 0 C) Par 1 sprat your tether rear*, taw fifty sullierdoller 2 leoseit arrest Jeffrey ipater says that pH, lir with 3 your aunt and tale ad bar bra liar trots le that I Cerrees7 S Us. 6 0. Iles ray have you bra lira with P

es the United States take any position regarding Defendant Epstein's performance of hi s obligations pursuant to th

have prepared documents to charge at least one of Mr. Epstein's lady friends in state court. If they can push

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her unfair injury; or (4) any other special circumstances indicating unconstitutionality or even impropriety. Incendy at 956 (citing United States' Kordel, 397 U.S. I, 11 (1970)). See also Securities and Exchange Comm'nl. Wright, 261 Fed. Appx. 259, 263 (11th Cir. 2008) ("[N]o 'special circumstances'

vernment Misconduct in Parallel Investigations Barr Says Legal Path to Census Citizenship Question Exists but He Gives No Details Public Corruption Epstein Who Protected Jeffrey Epstein? New York Times By The Editorial Board 7/8/19 On Monday, the United States District Court for the Southern Distric

d around the same time that he started to recruit underage girls to the mansion, according to the indictment unsealed on Monday. The Mystery Around Jeffrey Epstein's Fortune and How He Made It Bloomberg By Tom Metcalf, Caleb Melby and Sophie Alexander 7/9/19 In a neighborhood of millionaires and billionaires,

ney. This, when I investigated him in 2002, really turned out to be untrue. What was interesting was that the man who claimed to have sort of taught Jeffrey many financial tricks, and who claims to this day that Jeffrey has his money, is a gentleman by the name of Steve Hoffenberg, who went to jail for

uage of the legal system, the accusations against Mr. Epstein are nauseating. From "at least in or about" 2002

gazine to visit the mansion for a 2003 profile, "The Talented Mr. Epstein." The article describes a main hallway that was

evidence for its criminal prosecution," or (2) "fail to advise the defendant in its civil proceeding that it contemplates his criminal prosecution." Kordel, 397 U.S. at 11-12 (emphasis added). In Kordel, a corporate executive was convicted of violating the Food, Drug, and Cosmetic Act partly on the basi

SDNY News Clips, Tuesday, July 9, 2019 SDNY News Clips Tuesday, July 9, 2019 Contents Public Corruption 2 Epstein 2 Complex Frauds 32 Gyure 32 Terrorism & Narcotics 35 Wise Honest 35 Matters of Interest 37 Trump Can't Block Twitter Followers, US Appea

entleman by the name of Steve Hoffenberg, who went to jail for 20 years for committing the biggest Ponzi scheme pre-Bemie Madoff. So, the mystery of Jeffrey Epstein's wealth has never been clarified. AMY GOODMAN: He started out as a Dalton teacher, right? VICKY WARD: Right. AMY GOODMAN: A teacher at the private

ney. This, when I investigated him in 2002, really turned out to be untrue. What was interesting was that the man who claimed to have sort of taught Jeffrey many financial tricks, and who claims to this day that Jeffrey has his money, is a gentleman by the name of Steve Hoffenberg, who went to jail for

uage of the legal system, the accusations against Mr. Epstein are nauseating. From "at least in or about" 2002

gazine to visit the mansion for a 2003 profile, "The Talented Mr. Epstein." The article describes a main hallway that was

evidence for its criminal prosecution," or (2) "fail to advise the defendant in its civil proceeding that it contemplates his criminal prosecution." Kordel, 397 U.S. at 11-12 (emphasis added). In Kordel, a corporate executive was convicted of violating the Food, Drug, and Cosmetic Act partly on the ba

ASE NO.: 08-CV-80119-MARRA/JOHNSON Plaintiff, vs. JEFFREY EPSTEIN, Defendant. ____________________________________/

n Agreement [“NPA”] between the United States and Epstein? By filing this response, the United States does

oes the United States take any position regarding Defendant Epstein’s performance of his obligations pursuant to the

ng the position of the United States on Defendant Jeffrey Epstein’s Motion to Stay Proceedings [DE 99]. Fo

rovided by the Supreme Court in [United States v. Kordel] are: (1) if the Government brought the civil act

/25/2009 Page 1 of 15 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CV-80119-MARRA-JOHNSON JANE DOE NO. 2, Plaintiff, V. JEFFREY EPSTEIN, Defendant. I --------------- Defendant, Jeffrey Epstein's Motion To Stay And Or Continue Action For Time Certain Based On Parallel Civil And Cri

Australian Avenue South Suite 1400 West Palm Beach, FL 33401-5012 561-659-8300 Fax: 561-835-8691 [email protected] Co-Counsel for Defendant Jeffrey Epstein 14 Case 9:08-cv-80119-KAM Document 65 Entered on FLSD Docket 03/25/2009 Page 15 of 15 Page 15 By: --4~~--+--11---- ROB D. RI N

an Avenue South Suite 1400 West Palm Beach, FL 33401-5012 561-659-8300 Fax: 561-835-8691 [email protected] Co-Counsel for Defendant Jeffrey Epstein 14 Case 9:08-cv-80119-KAM Document 65 Entered on FLSD Docket 03/25/2009 Page 15 of 15 Page 15 By: --4~~--+--11---- ROB D. RI N, JR., ES

13 In the instant case, the privilege applies as Defendant EPSTEIN "has reasonable cause to apprehend danger from a

elated criminal prosecution when "special circumstances" so require in the "interests of justice." (Bold emphasis added). See also United States v. Kordel, 397 U.S. 1, 12 & n. 27, 90 S.Ct. 763, 769-70 & n.27 (1970). The Ventura Court went on to state that "situations where a defendant in both criminal

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA JANE DOE NO. 2, CASE NO.: 08-CV-80119-MARRA/JOHNSON Plaintiff, vs. JEFFREY EPSTEIN, Defendant. ____________________________________/ JANE DOE NO. 3, CASE NO.: 08-CV-80232-MARRA/JOHNSON Plaintiff, vs. JEFFREY EPSTEIN, Defendant. ___

of the civil proceedings in the “interests of justice” until the “expiration” of the Non- Prosecution Agreement [“NPA”] between the United States and Epstein? By filing this response, the United States does not make itself a party to this litigation and takes no position with respect to the outcome of any

oes the United States take any position regarding Defendant Epstein’s performance of his obligations pursuant to the

ng the position of the United States on Defendant Jeffrey Epstein’s Motion to Stay Proceedings [DE 99]. Fo

659 F.2d 660, 668 (5th Cir. 1981) (add’l citations omitted). Examples of “special circumstances” provided by the Supreme Court in [United States v. Kordel] are: (1) if the Government brought the civil action solely to obtain evidence for its criminal prosecution, (2) if the Government failed to advise t

es the United States take any position regarding Defendant Epstein's performance of his obligations pursuant to the

NO.: 08-CV-80119-MARRA/JOHNSON Plaintiff, vs. JEFFREY EPSTEIN, Defendant. JANE DOE NO. 3, CASE NO.:

spondence or oral communications between the parties in these civil suits. Based on the information presented by the Court and a review of Defendant Jeffrey Epstein's Motion to Stay and/or Continue Action for Time Certain Based on Parallel Civil and Criminal Proceedings with Incorporated Memorandum of Law (Court

f the civil proceedings in the "interests of justice" until the "expiration" of the Non- Prosecution Agreement ["NPA"] between the United States and Epstein? By filing this response, the United States does not make itself a party to this litigation and takes no position with respect to the outcome of an

her unfair injury; or (4) any other special circumstances indicating unconstitutionality or even impropriety. Incendy at 956 (citing United States. Kordel, 397 U.S. 1, 11 (1970)). See also Securities and Exchange Comm' n I Wright, 261 Fed. Appx. 259, 263 (11th Cir. 2008) ("[N]o `special circumstanc

spondence or oral communications between the parties in these civil suits. Based on the information presented by the Court and a review of Defendant Jeffrey Epstein's Motion to Stay and/or Continue Action for Time Certain Based on Parallel Civil and Criminal Proceedings with Incorporated Memorandum of Law (Court

f the civil proceedings in the "interests of justice" until the "expiration" of the Non- Prosecution Agreement ["NPA"] between the United States and Epstein? By filing this response, the United States does not make itself a party to this litigation and takes no position with respect to the outcome of an

es the United States take any position regarding Defendant Epstein's performance of his obligations pursuant to the

NO.: 08-CV-80119-MARRA/JOHNSON Plaintiff, vs. JEFFREY EPSTEIN, Defendant. JANE DOE NO. 3, CASE NO.:

her unfair injury; or (4) any other special circumstances indicating unconstitutionality or even impropriety. Incendy at 956 (citing United States. Kordel, 397 U.S. 1, 11 (1970)). See also Securities and Exchange Con:nen, Wright, 261 Fed. Appx. 259, 263 (11th Cir. 2008) ("[N]o `special circumstances'