Epstein Secrets

notice of court proceedings as required by 18 U.S.C. § 3771(a)(2) are frivolous; the only court proceedings that have taken place in connection with Epstein's criminal offenses were state court proceedings involving state criminal offenses, for which the CVRA does not 2 EFTA00799496 Case 9:08-cv-8073

ling was also necessary to ensure secrecy, so that as few persons as possible were aware that minor girls were coming at unusual hours to Defendant, Jeffrey Epstein's mansion. 48. Defendant, Sarah Kellen, also needed (directly or indirectly) to make transportation arrangements for many of the girls, as they were

f is included in the list of victims identified by the Federal Government as victims of the Defendant, Jeffrey Epstein's illegal conduct. Defendant, Jeffrey Page 5 of 17 EFTA00799582 Case 9:08-cv-80736-KAM Document 205-6 Entered on FLSD Docket 07/05/2013 Page 90 of 101 Epstein, is thus estopped by his ple

ert[ing] a cause of action against the Defendant, Jeffrey Epstein, pursuant to [18 U.S.C. § 2255] and the

nd we are going to be filing civil cases against Mr. Epstein, and this agreement, undoubtedly it will play a b

s strong evidence that Congress did not intend to authorize other remedies that it simply forgot to incorporate expressly." United States States v. Monzel, 641 F.3d 528, 542 (D.C. Cir.), cert. denied, No. 11-85, S. Ct. 2011 WL 3055311 (Nov. 28, 2011) (quoting Mertens v. Hewitt Associates, 508 U.S. 24

notice of court proceedings as required by 18 U.S.C. § 3771(a)(2) are frivolous; the only court proceedings that have taken place in connection with Epstein's criminal offenses were state court proceedings involving state criminal offenses, for which the CVRA does not 2 EFTA00208824 Petitioners' righ

ling was also necessary to ensure secrecy, so that as few persons as possible were aware that minor girls were coming at unusual hours to Defendant, Jeffrey Epstein's mansion. 48. Defendant, also needed (directly or indirectly) to make transportation arrangements for many of the girls, as they were often too yo

f is included in the list of victims identified by the Federal Government as victims of the Defendant, Jeffrey Epstein's illegal conduct. Defendant, Jeffrey Page 5 of 17 EFTA00208910 Epstein, is thus estopped by his plea and agreement with the Federal Government from denying the acts alleged in this Compla

ert[ing] a cause of action against the Defendant, Jeffrey Epstein, pursuant to [18 U.S.C. § 2255] and the

nd we are going to be filing civil cases against Mr. Epstein, and this agreement, undoubtedly it will play a b

s strong evidence that Congress did not intend to authorize other remedies that it simply forgot to incorporate expressly." United States States v. Monzel, 641 F.3d 528, 542 (D.C. Cir.), cert. denied, No. 11-85, S. Ct. 2011 WL 3055311 (Nov. 28, 2011) (quoting Mertens v. Hewitt Associates, 508 U.S. 24

notice of court proceedings as required by 18 U.S.C. § 3771(a)(2) are frivolous; the only court proceedings that have taken place in connection with Epstein's criminal offenses were state court proceedings involving state criminal offenses, for which the CVRA does not 2 EFTA00795172 Case 9:08-cv-8073

ling was also necessary to ensure secrecy, so that as few persons as possible were aware that minor girls were coming at unusual hours to Defendant, Jeffrey Epstein's mansion. 48. Defendant, Sarah Kellen, also needed (directly or indirectly) to make transportation arrangements for many of the girls, as they were

f is included in the list of victims identified by the Federal Government as victims of the Defendant, Jeffrey Epstein's illegal conduct. Defendant, Jeffrey Page 5 of 17 EFTA00795258 Case 9:08-cv-80736-KAM Document 205-6 Entered on FLSD Docket 07/05/2013 Page 90 of 101 Epstein, is thus estopped by his ple

ert[ing] a cause of action against the Defendant, Jeffrey Epstein, pursuant to [18 U.S.C. § 2255] and the

nd we are going to be filing civil cases against Mr. Epstein, and this agreement, undoubtedly it will play a b

s strong evidence that Congress did not intend to authorize other remedies that it simply forgot to incorporate expressly." United States States v. Monzel, 641 F.3d 528, 542 (D.C. Cir.), cert. denied, No. 11-85, S. Ct. 2011 WL 3055311 (Nov. 28, 2011) (quoting Mertens v. Hewitt Associates, 508 U.S. 24

notice of court proceedings as required by 18 U.S.C. § 3771(a)(2) are frivolous; the only court proceedings that have taken place in connection with Epstein's criminal offenses were state court proceedings involving state criminal offenses, for which the CVRA does not 2 EFTA00205603 Petitioners' righ

D) see also First Am. Compl. 1 32-33, Doe'. Epstein, Case No. 08-80893-CIV-MARRA (S.D. Fla.) ("assert[ing] a cause of action against the Defendant, Jeffrey Epstein, pursuant to [18 U.S.C. § 2255] and the [Non-Prosecution] agreement between the Defendant, Jeffrey Epstein, and the United States Government"); Comp

ert[ing] a cause of action against the Defendant, Jeffrey Epstein, pursuant to [18 U.S.C. § 2255] and the

nd we are going to be filing civil cases against Mr. Epstein, and this agreement, undoubtedly it will play a b

des strong evidence that Congress did not intend to authorize other remedies that it simply forgot to incorporate expressly." United States States" Monzel, 641 F.3d 528, 542 (D.C. Cir.), cert. denied, No. 11-85, S. Ct. 2011 WL 3055311 (Nov. 28, 2011) (quoting Mertens I. Hewitt Associates, 508 U.S. 24

notice of court proceedings as required by 18 U.S.C. § 3771(a)(2) are frivolous; the only court proceedings that have taken place in connection with Epstein's criminal offenses were state court proceedings involving state criminal offenses, for which the CVRA does not 2 EFTA00205625 Petitioners' righ

D) see also First Am. Compl. 1 32-33, Doe'. Epstein, Case No. 08-80893-CIV-MARRA (S.D. Fla.) ("assert[ing] a cause of action against the Defendant, Jeffrey Epstein, pursuant to [18 U.S.C. § 2255] and the [Non-Prosecution] agreement between the Defendant, Jeffrey Epstein, and the United States Government"); Comp

ert[ing] a cause of action against the Defendant, Jeffrey Epstein, pursuant to [18 U.S.C. § 2255] and the

nd we are going to be filing civil cases against Mr. Epstein, and this agreement, undoubtedly it will play a b

des strong evidence that Congress did not intend to authorize other remedies that it simply forgot to incorporate expressly." United States States" Monzel, 641 F.3d 528, 542 (D.C. Cir.), cert. denied, No. 11-85, S. Ct. 2011 WL 3055311 (Nov. 28, 2011) (quoting Mertens I. Hewitt Associates, 508 U.S. 24

to do anything at all to unearth all the hurt and pain it has taken me this long to process." Julie K. Brown, Prosecutors finally want to hear from Jeffrey Epstein's victims, MIAMI HERALD, 2019, https://www.miamiherald.com/news/state/florida/article230275434.html (last visited June 21, 2019). 18 EFTA00085726

osecutor's conferral obligations; and the government violated the CVRA by failing to advise the victims that it intended to enter into the NPA with Epstein. The government will not EFTA00085709 Case 9:08-cv-80736-KAM Document 462 Entered on FLSD Docket 06/24/2019 Page 2 of 32 what they call "rescissi

ring into a non-prosecution agreement (NPA) with Jeffrey Epstein? Petitioners seek 1 This Court previousl

estion that Congress intended, but simply forgot, to provide additional remedies beyond those already specified. Courts agree. See United States v. Monzel, 641 F.3d 528, 542 (D.C. Cir. 2011) (holding that the CVRA's "carefully crafted and detailed enforcement scheme," provides "strong evidence that Co

15 (quoting former First Assistant U.S. Attorney Jeffrey Sloman). Indeed, one of the experts that Interve

r determining remedy, neither party disputes that Mr. Epstein has a right to be heard . . . . Mr. Epstein resp

g enforcement of their rights in appellate courts had to shoulder the heavy burden traditionally associated with the "mandamus" relief. See U.S. v. Monzel, 641 F.3d 58, 532-33 (D.C. Cir. 2011) (discussing 18 U.S.C. § 3771(d)(3) and holding crime victims had to satisfy high mandamus standards); United S

RECEIVED PROCEDURAL DUE PROCESS THROUGH AN OPPORTUNITY TO BE HEARD AND SUBMIT EVIDENCE ON ISSUES PERTAINING TO REMEDIES. 6 A. As an Intervenor, Epstein Has Received Procedural Due Process 6 B. The Court's Findings About Epstein Counsel's Awareness of Concealment of the Non- Prosecution Agreement a

15 (quoting former First Assistant U.S. Attorney Jeffrey Sloman). Indeed, one of the experts that Interve

r determining remedy, neither party disputes that Mr. Epstein has a right to be heard . . . . Mr. Epstein resp

) based on this Court's finding that the government failed to confer with Petitioners prior to entering into a non-prosecution agreement (NPA) with Jeffrey Epstein? Petitioners seek 1 This Court previously found that Petitioners are crime victims under the CVRA; a crime victim's rights under the CVRA attach be

osecutor's conferral obligations; and the government violated the CVRA by failing to advise the victims that it intended to enter into the NPA with Epstein. The government will not EFTA00010542 --- PAGE BREAK --- Case 9:08-cv-80736-KAM Document 462 Entered on FLSD Docket 06/24/2019 Page 2 of 32 what

ring into a non-prosecution agreement (NPA) with Jeffrey Epstein? Petitioners seek 1 This Court previousl

estion that Congress intended, but simply forgot, to provide additional remedies beyond those already specified. Courts agree. See United States v. Monzel, 641 F.3d 528, 542 (D.C. Cir. 2011) (holding that the CVRA's "carefully crafted and detailed enforcement scheme," provides "strong evidence that Co