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

requires that a crime victim be harmed by an offense that "is charged in Federal district court." (DE 403-15:1-2). The U.S. Department of Justice, Office of Legal Counsel ("OLC") confirmed this view in 2010, noting that "the CVRA is best read as providing that the rights identified in section 3771(a) are guaranteed f

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

TMENT’S INTERPRETATION OF THE CVRA’S DEFINITION OF “CRIME VICTIM” AT THE TIME OF THE EPSTEIN INVESTIGATION ................ 192 A. April 1, 2005 Office of Legal Counsel “Preliminary Review” ............................192 B. 2005 Attorney General Guidelines for Victim and Witness Assistance ..............193 IV.

175 Epstein’s state guilty plea.250 As U.S. Attorney, Acosta had the authority to resolve the case in this manner, but OPR concludes that in light of all the s

to represent her “because she was unable to get anyone from the [USAO] to tell her what was actually going on with the federal criminal case against Jeffrey Epstein.”347 Villafaña told OPR that Wild did not contact her directly and she was not aware of 344 In

] OPR’s conclusion that deferring prosecution of Jeffrey Epstein to the State Attorney rather than proceed

parents finding out about their involvement with Mr. Epstein. Additionally,

uns for the first tune Feb 19 - Villafada completes third update 10 prosecution memorandum Feb 28 - USAO nmifies DOJ Civli Rights Division that Epstem investigation is ongoing Additional Key Dates Dec 17.2010 - DOJ Office of Legal Counsel issues opinion regarding CVRA Oct 20 I I - DOJ revises

ice. III. THE DEPARTMENT’S INTERPRETATION OF THE CVRA’S DEFINITION OF “CRIME VICTIM” AT THE TIME OF THE EPSTEIN INVESTIGATION A. April 1, 2005 Office of Legal Counsel “Preliminary Review” In 2005, Department management requested informal guidance from the Department’s Office of Legal Counsel (OLC) regarding int

to Intervene on a Limited Basis filed by United States of America. Replies due by 2/2/2015. ( ) (Entered: 01/22/2015) 295 MOTION Limited Intervenor Jeffrey Epstein's Response to Order Requesting Justification for Supplemental Protective Order re 286 Order by Jeffrey Epstein. (Black, Roy) Modified to re- docket, s

iled by Jane Doe. (Edwards, Bradley) (Entered: 10/28/2013) MOTION to Expedite Jane Doe #1 and Jane Doe #2 Unopposed Motion for Expedited Ruling on Epstein's Unopposed Motion for Intervention in Advance of Eleventh Circuit Argument by Jane Doe. (Attachments: # 1 Text of Proposed Order)(Edwards, Bradley)

t Palm Beach, Fl 33401 561-202-6360 Intervenor Jeffrey Epstein Intervenor Alan M. Dershowitz Interven

nt conference 385 386 388 , the Court finds that Mr. Epstein's interest in this case is adequately preserved b

Colchico, Consor and Associates, 561-682-0905 (ir) (Entered: 08/12/2011) 08/19/2011 90 NOTICE by United States of America o artment of Justice, Office of Legal Counsel Opinion (Attachments: # 1 Exhibit A)( (Entered: 08/19/2011) 08/22/2011 91 Unopposed MOTION for Extension of Time to File Supplemental Briefing b

l 77 W 66TH St, Room 1628 New York, NY 10023 Re: Good Morning America and Night Line interview with Jane Doe 3 (VR) Dear Mr. Zucker: I represent Jeffrey Epstein. I have been informed by Producer James Hill that ABC intends to air an interview, conducted by a Good Morning America co-host, of a woman known in

. Slater filed a declaration stating that when Jane Doe 3 was interviewed by the FBI in 2007 she refused to cooperate with the investigation of Mr. Epstein declaring she wanted nothing to do with the matter. For ABC to air these untested allegations on national television as "news" when Jane Doe 3 inte

th Jane Doe 3 (VR) Dear Mr. Zucker: I represent Jeffrey Epstein. I have been informed by Producer James H

e refused to cooperate with the investigation of Mr. Epstein declaring she wanted nothing to do with the matt

.ne1 (617)227.3760 FAX (617)318453d NIGHT EMERGENCY: (617)90144:2 April 23, 2015 Via Email and U.S. Mail John Zucker Assistant Legal Counsel Office of Legal Counsel 77 W 66TH St, Room 1628 New York, NY 10023 Re: Good Morning America and Night Line interview with Jane Doe 3 (VR) Dear Mr. Zucker: I represent J

el 77 W 66TH St, Room 1628 New York, NY 10023 Re: Good Morning America and Night Line interview with Jane Doe 3 . Dear Mr. Zucker: I represent Jeffrey Epstein. I have been informed by Producer James Hill that an interview, conducted by a Good Morning America co-host, of a woman known in court papers as Ja

from FBI Special Agent Timothy R. Slater reflects that when Jane Doe 3 was first interviewed she refused to cooperate with the investigation of Mr. Epstein declaring she wanted nothing to do with the matter. Now, it appears, ABC intends to provide her with a national platform to make allegations she de

ith Jane Doe 3 . Dear Mr. Zucker: I represent Jeffrey Epstein. I have been informed by Producer James H

e refused to cooperate with the investigation of Mr. Epstein declaring she wanted nothing to do with the matt

PARK PLAZA,SUI7E 1008 EMAIL ADDRESSES: BOSTON.MASSACIRISETTS 02116 April 23, 2015 Via Email and U.S. Mail John Zucker Assistant Legal Counsel Office of Legal Counsel 77 W 66TH St, Room 1628 New York, NY 10023 Re: Good Morning America and Night Line interview with Jane Doe 3 . Dear Mr. Zucker: I represent Je

l 77 W 66TH St, Room 1628 New York, NY 10023 Re: Good Morning America and Night Line interview with Jane Doe 3 (VR) Dear Mr. Zucker: I represent Jeffrey Epstein. I have been informed by Producer James Hill that an interview, conducted by a Good Morning America co-host, of a woman known in court papers as Ja

from FBI Special Agent Timothy R. Slater reflects that when Jane Doe 3 was first interviewed she refused to cooperate with the investigation of Mr. Epstein declaring she wanted nothing to do with the matter. Now, it appears, ABC intends to provide her with a national platform to make allegations she de

th Jane Doe 3 (VR) Dear Mr. Zucker: I represent Jeffrey Epstein. I have been informed by Producer James H

e refused to cooperate with the investigation of Mr. Epstein declaring she wanted nothing to do with the matt

MAIL ADDRESSES: BOSTON. MASSACHUSETTS 02116 FAX NIGHT " • ' (61 April 23, 2015 Via Email and U.S. Mail John Zucker Assistant Legal Counsel Office of Legal Counsel 77 W 66TH St, Room 1628 New York, NY 10023 Re: Good Morning America and Night Line interview with Jane Doe 3 (VR) Dear Mr. Zucker: I represent J

l 77 W 66TH St, Room 1628 New York, NY 10023 Re: Good Morning America and Night Line interview with Jane Doe 3 (VR) Dear Mr. Zucker: I represent Jeffrey Epstein. I have been informed by Producer James Hill that an interview, conducted by a Good Morning America co-host, of a woman known in court papers as Ja

from FBI Special Agent Timothy R. Slater reflects that when Jane Doe 3 was first interviewed she refused to cooperate with the investigation of Mr. Epstein declaring she wanted nothing to do with the matter. Now, it appears, ABC intends to provide her with a national platform to make allegations she de

th Jane Doe 3 (VR) Dear Mr. Zucker: I represent Jeffrey Epstein. I have been informed by Producer James H

e refused to cooperate with the investigation of Mr. Epstein declaring she wanted nothing to do with the matt

EMAIL ADDRESSES: BOSTON. MASSACHUSETTS 02116 FAX NIGHT EMERGENCY: April 23, 2015 Via Email and U.S. Mail John Zucker Assistant Legal Counsel Office of Legal Counsel 77 W 66TH St, Room 1628 New York, NY 10023 Re: Good Morning America and Night Line interview with Jane Doe 3 (VR) Dear Mr. Zucker: I represent J

To: Lisa Randal Bcc: Ian Osborne From: Jeffrey Epstein Sent Wed 11/28/2012 4:28:51 PM Subject Re: Invite to Dialog 2014 (16 months away) sundance is nice „ go On Wed, Nov 28, 2012 at 11:17 AM, Lisa R

o: Lisa Randal Bcc: Ian Osborne From: Jeffrey Epstein Sent Wed 11/28/2012 4:28:51 PM Subject Re: Inv

To: Lisa Randal Bcc: Ian Osborne From: Jeffrey Epstein Sent Wed 11/28/2012 4:28:51 PM Subject

on International Policy; Center for American Progress. *David Barron*— Professor, Harvard Law School. Fmr Acting AsstU.S. Attorney General in the Office of Legal Counsel. *ICirsten Bartok*-- CEO, AirFinance. Fmr CFO of XOJet. Fmr GP at Alpine Investors. *Evan Bayh*— Sr Advisor, Apollo Management. Partner, McGuireWoo

ubject Re: Invite to Dialog 2014 (16 months away) So let me understand. You arc suggesting tourism? Sent from my Verizon Wireless BlackBerry From: Jeffrey Epstein [email protected]> Date: Wed, 28 Nov 2012 11:28:51 -0500 To: Lisa Randall Subject: Re: Invite to Dialog 2014 (16 months away) sundance is nic

rom my Verizon Wireless BlackBerry From: Jeffrey Epstein [email protected]> Date: Wed, 28 Nov 2012 11

Sent from my Verizon Wireless BlackBerry From: Jeffrey Epstein [email protected]> Date: Wed, 28 Nov

for American Progress. EFTA_R1_00481818 EFTA01975836 *David Barron"— Professor, Harvard Law School. Fmr Acting AsstU.S. Attorney General in the Office of Legal Counsel. *Kirsten Bartokt-- CEO, AirFinance. Fmr CFO of XOJet. Fmr GP at Alpine Investors. *Evan Bayht — Sr Advisor, Apollo Management. Partner, McGuireWoo