10
Shared Docs
9
Same-Page
52 / 10
Mentions
— a similar effort to intervene on a "reputational" claim. That claim was made by Bruce Reinhart who — like Dershowitz — had previously represented Jeffrey Epstein's interests in related litigation. Reinhart moved to intervene in this case to contest the victims' allegations that Reinhart (a former prosecutor in
attempted to block discovery of materials in this case, leading to an Eleventh Circuit ruling that the victims' discovery efforts were proper. Doe'. Epstein, 749 F.3d 999 (1 1 th Cir. 2014). 3 Remarkably, even though the Court directed the Government to begin producing discovery in June 2013, the Govern
e criminal prosecution broke) Dershowitz stated "I'm on my 20th book. . . . The only person outside of my immediate family that I send drafts to is Jeffrey." The Talented Mr. Epstein, by Vicky Ward, in Vanity Fair (Jan. 2005)21 Dershowitz has also been quoted as saying that, even if Epstein went bankrup
n asked: Do you know what Jeffrey Epstein's relationship is with Alan Dershowitz? That's somebody [i.e., Dershowitz] who you know to have stayed at Jeffery Epstein's house on many occasions, correct? And also somebody who you know to have been at the house when E.W. was in Jeffrey Epstein's bedroom getting sexua
in took the Fifth when asked during his deposition "[h]ave you ever socialized with Alan Dershowitz in the presence of females under the age of 18?" Jeffrey Epstein Depo. at 90, Epstein'. Edwards, No. 502009CA040800XXXXMB (Palm. Beach Cty. Cir. Ct. Mar. 17, 2010) (excerpts attached as Exhibit 24). Indeed, going a ste
tance. She was sexually trafficked and abused by Mr. Epstein (and others at the direction of Mr. Epstein) not
ediate family that I send drafts to is Jeffrey." The Talented Mr. Epstein, by Vicky Ward, in Vanity Fair (Jan. 2005)21 Der
victim to this case: a young woman Jeffrey Epstein sexual abused when she was under age. On August 20, 2014, counsel sent a letter to U.S. Attorney Wilfredo Ferrer requesting the Govermnent's consent to a stipulated motion to simply add her into the case (as had been done earlier with Jane Doe No. 2). Counsel
rent victims have responded by explaining how these documents are relevant, including explaining how these documents might bear on the way in which Epstein used his powerful political and social connections to secure a favorable plea deal, as well as provide proof of the Government's motive to delibera
d be as interested in him as a friend if we had hamburgers on the boardwalk in Coney Island and talked about his ideas.- Vanity Fair Reminds Us When Jeffrey Epstein Warn 't a Creep. by Ray Gustini, in The Wire (June 21, 2011). Second, Jeffrey Epstein brazenly abused numerous girls in his Florida mansion, his New Yo
e criminal prosecution broke) Dershowitz stated "I'm on my 20th book. . . . The only person outside of my immediate family that I send drafts to is Jeffrey." The Talented Mr. Epstein. by Vicky Ward, in Vanity Fair (Jan. 2005).11 Dershowitz has also been quoted as saying that, even if Epstein went bankru
n asked: Do you know what Jeffrey Epstein's relationship is with Alan Dershowitz? That's somebody [i.e., Dershowitz] who you know to have stayed at Jeffery Epstein's house on many occasions, correct? And also somebody who you know to have been at the house when was in Jeffrey Epstein's bedroom getting sexually
in took the Fifth when asked during his deposition "[h]ave you ever socialized with Alan Dershowitz in the presence of females under the age of Isr• Jeffrey Epstein Depo. at 90, Epstein' Edwards. No. 502009CA040800XXXXMB (Palm. Beach Cty. Cir. Ct. Mar. 17, 2010) (excerpts attached as Exhibit 24). Indeed, going a step
. Dershowitz had sex with minors in concert with Mr. Epstein. Only Prof. Dershowitz is situated to protect hi
ediate family that I send drafts to is Jeffrey." The Talented Mr. Epstein. by Vicky Ward, in Vanity Fair (Jan. 2005).11 De
ictim to this case.: a young woman Jeffrey Epstein sexual abused when she was under age. On August 20, 2014. counsel sent a letter to U.S. Attorney Wilfredo Ferrer requesting the Government's consent to a stipulated motion to simply add her into the case (as had been done earlier with Jane Doe No. 2). Counsel
/2013 Page 19 of 23 Bates Range Description Privilege(s) Asserted Box #3 P-011923 Thru P-011966 Folder entitled "Responses to Arguments from JE Counsel" containing: II 7/13/2007 letter from Lilly Ann Sanchez to with handwritten attorney notes; • 6/25/2007 letter from Gerald Lefcourt t
ml 6/25/2007 email from to and entitled "Thoughts on Lefcourt's letter" Handwritten and typed attorney ( ) notes regarding main themes raised by Epstein counsel Work product Deliberative process 6(e) Attorney-Client Privilege Box #3 P-011967 Thru P-012016 Composition book entitled "Operation
y and privacy."2 The undisputed evidence begins in 2005, when the Palm Beach Police Department ("PBPD") had identified numerous girls as victims of Jeffrey Epstein's sexual crimes. In 2006, the PBPD turned the case over to federal authorities for further investigation. As early as March 15, 2007 and throughout t
e victims. The letter also falsely claimed that "Mr. Epstein never targeted minors," and urged the Government
tion Box #3 P-012017 Thru P-012055 Motion of Jeffrey Epstein to Intervene and to Quash Grand Jury Sub
ains information subject to privacy rights of victims who are not parties to this litigation regarding Lefkowitz email about lawsuit filed against Epstem by one of the victims identified during the state investigation. Page 12 of 18 EFTA00185441 Case 9:08-cv-80736-KAM Document 329-1 Entered on FLS
-015028 7/8/2008 email from . to A. Acosta, and Work Product Deliberative Process regarding victim notification letter provided to counsel for J. Epstein on 11/28/2007 with attachment (NB: The 11/28/2007 email to J. Leflcowitz with attachment will be produced to petitioners' counsel contemporaneously
letters were reviewed by my office and Jay Lefkowitz and Roy Black before they went out."" 155. In 2010, Jane Doe I met with the new U.S. Attorney, Wilfredo Ferrer. She explained to him how the NPA had been concealed from her. Nothing ever came of the meeting, and Mr. Ferrer has continued to fight efforts by J
EPSTEIN INVESTIGATION TIMELINE Date To From Re: Exhibit # 5/1/2006 State Attorney Barry E. ICrischer Michael S. Reiter, Chief of Police for Town
McSorley. B-15 12/7/2007 Sloman Lilly Ann Sanchez Letter - 1 pages with Affirmation signed by Epstein and Notice of Hearing, State of Florida I. Jeffrey Epstein, attached 12/7/2007 Victim notification letter prepared 12/7/2007 at 9:10 pm B-6 12/7/2007 Unmailed victim notification letters B-14 12/10/200
hat there are some inaccuracies and omissions in Mr. Epstein's fde. i 12/ 11/2008 Villafatia, cc: Senior
a 9/2/2008 Richard H. Willits), #4, #13, #8 (via Jeffrey Herman), #9, #10, #11, #14, #16, #17 (via Theodore Leopold), #20, #21, #23, #24, #25 (via Jeffrey B \ , ' Herman), #26 (via Jeffrey Herman), #30, #31, #32, #33, #37 (via Michael E. Dutko), #38, #44 (via Jeffrey Herman) 9/3/2008 Victim notific
Vitiator-1a Critton Letter re NPA with attached Defendant Epstein's Motion to Dismiss Plaintiffs Complaint (Jane D
. Marie Villafafia Lilly Ann Sanchez Because of the Palm Beach Police Department and the State Attorney's ti investigation for almost two years, E stein hired counsel for all employees so contact Ms. Sanchez for contact information for the attorneys. I 1/22/2007 Andrew Lourie Lilly Ann Sanchez
leged Confidential Page 50 of 51 Contain)) 6(u) Material EFTA00224992 EPSTEIN INVESTIGATION TIMELINE Date To From Re: Exhibit # 8/24/2011 Wilfredo Ferrer (U.S. Attorney, SDFL), Robert O'Neill (U.S. Attorney, MDFL), Benjamin Greenberg (FAUSA, l)1,1.), and Lee Bentley (FAUSA, MDFL) Richard S
) From: Sloman. Jeff (USAFLS) Sent: Monday, October 22, 2007 5:26 PM To: Villafana, Ann Marie C. (USAFLS); Acosta, Alex (USAFLS) Subject: Fw: Epstein Fyi Sent from my BlackBerry Wireless Handheld Original Message From: Sloman, Jeff (USAFLS) To: '[email protected]. <JLefkowitz@kirklan
[email protected]> To: Sloman, Jeff (USAFLS) Cc: Acosta, Alex (USAFLS); Villafana, Ann Marie C. (USAFLS) Sent: Mon Oct 22 17:10:00 2007 Subject: Re: Epstein Jeff -- I will review these materials this evening and be in touch with you tomorrow with the expectation of wrapping this up by nd of the day. One que
McSorley. R I s 12/7/2007 Sloman Lilly Ann Sanchez Letter -1 pages with Affirmation signed by Epstein and Notice of Heating, State of Florida I. Jeffrey Epstein, attached 12/7/2007 Victim notification letter prepared 12/7/2007 at 9:10 pm B-6 12/7/2007 Unmailed victim notification letters B-14 12/10/200
the attorney representative be told clearly that Mr. Epstein has agreed to pay the lawyer's hourly rate only f
a 9/2/2008 Richard H. Willits), #4, #13, #8 (via Jeffrey Herman), #9, #10, #11, #14, #16, #17 (via Theodore Leopold), #20, #21, #23, #24, #25 (via Jeffrey B-89 Herman), #26 (via Jeffrey Herman), #30, #31, #32, #33, #37 (via Michael E. Dutko), #38, #44 (via Jeffrey Herman) 9/3/2008 Victim notificatio
Villafafia Critton Letter rc NPA with attached Defendant Epstein's Motion to Dismiss Plaintiffs Complaint (Jane D
ileged Confidential Page 50 of 51 Contains 6(e) Material EFTA00225477 EPSTEIN INVESTIGATION TIMELINE Date To From Re: Exhibit # 8/24/2011 Wilfredo Ferrer (U.S. Attorney, SDFL), Robert O'Neill (U.S. Attorney, MDFL), Benjamin Greenberg (FAUSA, SDFL), and Lee Bentley (FAUSA, MDFL) Richard Sud
and privacy."' The undisputed evidence begins in 2005, when the Palm Beach Police Department ("PBPD") had identified numerous girls as victims of Jeffrey Epstein's sexual crimes. In 2006, the PBPD turned the case over to federal authorities for further investigation. As early as March 15, 2007 and throughout t
cv-80736-KAM Document 361 Entered on FLSD Docket 02/10/2016 Page 3 of 57 prepared an 82-page prosecution memorandum and a 53-page indictment against Epstein and his co-conspirators.4 At that time, rather than confer with the victims about how to proceed, the Government began conferring about this issue
BPD") had identified numerous girls as victims of Jeffrey Epstein's sexual crimes. In 2006, the PBPD turne
e victims. The letter also falsely claimed that "Mr. Epstein never targeted minors," and urged the Government
etters were reviewed by my office and Jay Lefkowitz and Roy Black before they went out.""' 155. In 2010, Jane Doe 1 met with the new U.S. Attorney, Wilfredo Ferrer. She explained to him how the NPA had been concealed from her. Nothing ever came of the meeting, and Mr. Ferrer has continued to fight efforts by J
and privacy."' The undisputed evidence begins in 2005, when the Palm Beach Police Department ("PBPD") had identified numerous girls as victims of Jeffrey Epstein's sexual crimes. In 2006, the PBPD turned the case over to federal authorities for further investigation. As early as March 15, 2007 and throughout t
cv-80736-KAM Document 361 Entered on FLSD Docket 02/10/2016 Page 3 of 57 prepared an 82-page prosecution memorandum and a 53-page indictment against Epstein and his co-conspirators.4 At that time, rather than confer with the victims about how to proceed, the Government began conferring about this issue
BPD") had identified numerous girls as victims of Jeffrey Epstein's sexual crimes. In 2006, the PBPD turne
e victims. The letter also falsely claimed that "Mr. Epstein never targeted minors," and urged the Government
etters were reviewed by my office and Jay Lefkowitz and Roy Black before they went out.""' 155. In 2010, Jane Doe 1 met with the new U.S. Attorney, Wilfredo Ferrer. She explained to him how the NPA had been concealed from her. Nothing ever came of the meeting, and Mr. Ferrer has continued to fight efforts by J
simple one. The Government cannot contest that it concealed from the victims a non-prosecution agreement (NPA) that it reached with a sex offender, Jeffrey Epstein, who had committed federal crimes against dozens of minor victims. I EFTA00597318 Case 9:08-cv-80736-KAM Document 417 Entered on FLSD Docket 08/1
Florida, located in the Southern District of Florida, and elsewhere in the United States and overseas. Victims' S.J. Mot., DE 361 at 8, 1 1. Because Epstein and his co-conspirators knowingly traveled in interstate and international commerce to sexually abuse Jane Doe 1, Jane Doe 2, and other similarly s
ement (NPA) that it reached with a sex offender, Jeffrey Epstein, who had committed federal crimes against
er about the money issue, just about what crimes Mr. Epstein is pleading guilty to and the amount of time tha
e reviewed by my office and Jay Lefkowitz and Roy Black before they went out." Id. at 46,1 154. In 2010, Jane Doe I met with the new U.S. Attorney, Wilfredo Ferrer. She explained to him how the NPA had been concealed from her. Id. at 46,1 154. At no time while it negotiated and executed the NPA did the Governm
case By SUSAN SPENCER WENDEL 'Wm Bawl Thst Ste Was WEST PALM BEACH — A circuit Judge on Wednes- day did not unseal the deal that money manager Jeffnsy Epstein of Palm Beach struck with fed- eral prosecutors to avoid charges, opting instead to give Epsteirib lawyers a thaom to demonstrate why it should
sealed in state court In ac- cordance with the rules. 'I don't see where any of the procedures were ever followed," he said. Colbath has given Epstein defense attorney. Jack Goldberger, an op- portunity to argue that the document was properly sealed and asked lawyers to submit briefs to him by
UD SCHEME June 10, 7009 FOR IMMEDIATE RELEASE Jeffrey H. Sloman, Acting United States Attorney for the
ge Ilona Holmes. head of the criminal division, Miami-Dade Circuit Judge Daryl Trawick. and Palm Beach County Court Judge Reginald Corlew Hispanics Wilfredo Ferrer, an assistant Miami-Dade County attorney, and Lilly Ann Sanchez, a criminal litigator with Fowler White Burnett in Miami also have put their names i
ein as a minor on dozens of occasions in his mansion in Palm Beach, Florida from around 2002 to 2005. I understand that evidence collected from Mr. Epstein's home showed conclusively that I was there as a minor, along with many other underage girls. Given how many girls Epstein was abusing, there coul
Page: EFTA00020758 →o 2005. I understand that evidence collected from Mr. Epstein's home showed conclusively that I was there as a
Page: EFTA00020758 →My name is and I was born 2. I was molested by Jeffrey Epstein as a minor on dozens of occasions in his
Page: EFTA00020758 →BREAK --- Case 9:08-cv-80736-KAM Document 361-26 Entered on FLSD Docket 02/10/2016 Page 4 of 5 13. Towards the end of June, 2008, I did not attend Jeffrey Epstein's guilty plea hearing in state court involving another victim of Epstein's abuse. I did not have reasonable notice of the hearing, and I did not ha
Page: EFTA00020760 →e clear that without ever talking to me, they had bargained my case away. 17. In about 2010, I had the chance to meet with the U.S. Attorney, Mr. Wilfredo Ferrer. I told him all about how I had been mistreated in the process. Mr. Ferrer seemed to be interested in this, but nothing ever came of the meeting. A
Page: EFTA00020761 →Entities connected to both Jeffrey Epstein and Wilfredo Ferrer

Lesley Groff
PERSON
Marc Rich
PERSONLarry Visoski
PERSONLeon Black
PERSON
Prince Andrew
PERSON
Ghislaine Maxwell
PERSON
Eric Trump
PERSON
George Mitchell
PERSON
Alan Dershowitz
PERSON
George W. Bush
PERSON
Bradley Edwards
PERSON
United States
LOCATIONJack Goldberger
PERSON
Sarah Kellen
PERSON
Joe Biden
PERSONJanusz Banasiak
PERSON
FedEx
ORGANIZATIONHarry Beller
PERSONJane Doe
PERSON
Barry Diller
PERSON