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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 EFTA00081017 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 EFTA00081103 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
on FLSD Docket 07/05/2013 Page 28 of 101 confer with the government's attorney, but is silent as to documents offered during the trial. See In re Slier, 571 F.3d at 609-10. Petitioners' belief that they are entitled to grand jury records also fails. The traditional rule of grand jury secrecy may be
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
eding, and the right to 26 EFTA00205649 confer with the government's attorney, but is silent as to documents offered during the trial. See In re Slier, 571 F.3d at 609-10. Petitioners' belief that they are entitled to grand jury records also fails. The traditional rule of grand jury secrecy may be
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
8 F.3d 1308, 1317 (10th Cir. 2008) (holding "that the CVRA does not provide 'victims' with a right of access to the government's files"); cf. In re Slier, 571 F.3d 604, 609 (6th Cir. 2009) (holding that "the CVRA does not provide an independent right to obtain PSRs"); Kenna v. United States, 453 F.3d
) 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
Page: EFTA00010542 →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
Page: EFTA00010542 →ring into a non-prosecution agreement (NPA) with Jeffrey Epstein? Petitioners seek 1 This Court previousl
Page: EFTA00010542 →be heard at a proceeding, and the right to confer with the government's attorney, but is silent as to documents offered during the trial. See In re Slier, 571 F.3d at 609-10. Petitioners argument that they are entitled to grand jury records similarly fails. The traditional rule of grand jury secrecy
Page: EFTA00010569 →Entities connected to both Jeffrey Epstein and Slier

Marc Rich
PERSON
Woody Allen
PERSON
NEW YORK NY
LOCATION
Joi Ito
PERSON
Alan Dershowitz
PERSON
George W. Bush
PERSON
Donald Trump
PERSON
Bradley Edwards
PERSON
United States
LOCATION
Condoleezza Rice
PERSON
Harry Reid
PERSON
Joe Biden
PERSON
Prince Charles
PERSONJane Doe
PERSON
Department of Justice
ORGANIZATIONMaria Farmer
PERSON
Kenneth Marra
PERSON
Julie K. Brown
PERSON
Alexander Acosta
PERSONthe Southern District
LOCATION