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esday, March 19, 2025 9:15:54 AM To: Campanaro, Amy E. (NY) (FBI) <[email protected]>; Payne, Teresa A. (NY) (FBI) <tapayne2Pfbi.gov>; Montanari, Jeffrey R. (NY) (FBI) [email protected]>; Hardison, Luke B. (NY) (FBI) <[email protected]>; Sedam, Benjamin James (NY) (FBI) <[email protected]>; Bezdikian, V
ie Lee (NY) (FBI)" <[email protected]> Subject: Re: Epstein Project Redaction Date: Wed, 19 Mar 2025 13:38:4
esa A. (NY) (FBI) <tapayne2Pfbi.gov>; Montanari, Jeffrey R. (NY) (FBI) [email protected]>; Hardison, Luk
From: "Hardison, Luke B. (NY) (FBI)" <[email protected]> To: "Bowe, Stephanie Lee (NY) (FBI)" <[email protected]> Subject: Re: Epstein Project Redaction Date: Wed,
t the victims' pleadings are facially deficient, the Court must assume the truth of the victims' allegations — specifically that the Government and Epstein deliberately conspired to enter into a secret non- prosecution agreement in violation of the victims' rights under the Crime Victims' Rights Act (CV
:08-cv-80736-KAM Document 127 Entered on FLSD Docket 12/05/2011 Page 6 of 25 historically had broad authority to fashion equitable remedies . . . ." Hardison. Cohen, 375 F.3d 1262, 1266 (11th Cir. 2004). The Eleventh Circuit has expressly required district courts to fashion appropriate equitable remedies
15 (quoting former First Assistant U.S. Attorney Jeffrey Sloman). Indeed, one of the experts that Interve
Page: EFTA00021449 →r determining remedy, neither party disputes that Mr. Epstein has a right to be heard . . . . Mr. Epstein resp
Page: EFTA00021451 →igation. As Epstein's own exhibits makes clear, the release covers only claims for "compensatory or punitive damages": [Jane Doe] individually, and Jeffrey Epstein, individually (jointly referred to as "Parties"), enter into this Settlement Agreement and General Release ("Settlement Agreement") in order to res
Page: EFTA00021485 →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
Page: EFTA00022547 →15 (quoting former First Assistant U.S. Attorney Jeffrey Sloman). Indeed, one of the experts that Interve
Page: EFTA00022553 →r determining remedy, neither party disputes that Mr. Epstein has a right to be heard . . . . Mr. Epstein resp
Page: EFTA00022555 →Entities connected to both Jeffrey Epstein and Hardison

Marc Rich
PERSON
Madison
LOCATION
Bradley Edwards
PERSON
United States
LOCATIONJane Doe
PERSON
Michael Cohen
PERSON
Department of Justice
ORGANIZATION
Kenneth Marra
PERSON
Alexander Acosta
PERSON
Paul Cassell
PERSON
Jeffrey Sloman
PERSONCraig Martin
PERSON
Supreme Court
ORGANIZATION
New Hampshire
LOCATION
the University of Utah
ORGANIZATIONGarcia
PERSONDistrict Court for the Southern District of New York
ORGANIZATIONU.S. Attorney's Office
ORGANIZATION
Hunter Biden
PERSONthe Eleventh Circuit
ORGANIZATION