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

ing on those arguments because they "relate only to the remedy." (DE 435:32). 49 EFTA00299069 it when it works to [his] disadvantage .. ." In re Humana Inc. Managed Care Litigation, 285 F.3d 971, 976 (11th Cir. 2002), rev'd on other grounds, PacifiCare Health Sys., Inc. v. Book, 538 U.S. 401 (2003), quo

ITIONERS ARE EQUITABLY ESTOPPED FROM CHALLENGING THE NPA On September 10, 2008, Jane Doe No. 1 filed an action in Palm Beach County, Florida, E.W. I. Jeffrey Epstein, Case No. 50-2008-CA-028058-XXXXMB, seeking money damages from Jeffrey Epstein for sexually abusing her. Ex. P. On September 11, 2008, Jane Doe No.

r than to assert that Jeffrey Epstein sexually abused both. However, the differing circumstances of the two petitioners during the investigation of Epstein are highly relevant in determining whether each petitioner can even invoke the CVRA. Through her attorney, James Eisenberg, Esq.,' Jane Doe No. 2 r

0. When asked whether Epstein "pulled you closer to him in a sexual way," Jane Doe No. 2 replied: A. I wish. No, no, never, ever, ever, no, never. Jeffrey is an awesome man, no. Id. at 22. At the end of her interview, Jane Doe No. 2 was asked if she had any questions for the agents or AUSA Id. at 57

agreement entered into by the United States and Mr. Epstein in a timely fashion." Ex. N, Nov. 27, 2007 email

it works to [his] advantage [by establishing the claim] and repudiat[ing] it when it works to [his] disadvantage by requiring arbitration." In re Humana Inc. Managed Care Litigation, 285 F.3d 971, 976 (11th Cir. 2002) rev'd on other grounds by PacifiCare Health Sys.. Inc.. Book, 538 U.S. 401 (2003), citin

the victims explained in their motion for summary judgment (DE 361), the undisputed facts of this case show that for nine months, the Government and Epstein conspired to conceal a non-prosecution agreement (NPA) from Epstein's victims in order to prevent them from voicing any objection to the agreement.

ed Jane Doe 1 and Jane Doe 2 (and several other victims) in civil suits against Jeffrey Epstein for injuries my clients suffered as a consequence of Jeffrey Epstein's sexual abuse of them. 2. I have previously filed an affidavit in this matter (see DE 225-1). This affidavit repeats some of the information contai

Undisputed Fact 1 ("Between about 1999 and 2007, Jeffrey Epstein sexually abused more than 30 minor girls,

she, herself] procured additional young women for Mr. Epstein and [was] paid commissions or referral fees for

ly-conferred rights. The cases cited by the Government all involve courts construing the terms of contracts written by private parties. E.g., In re Humana Inc. Managed Care litigation, 285 F.3d 971, 976 (11'" Cir. 200) (construing provision in arbitration clause entered into by patient with hospital); Bunco

s from Jeffrey Epstein for sexually abusing her. Ex. P. On September 11, 2008, Jane Doe No. 2 file an action in Palm Beach County, Florida, L.M. v. Jeffrey Epstein Case No. 50-2008-CA- 28051-XXXXMB, seeking money damages from Jeffrey Epstein for sexually abusing her. Ex. Q. 6 "A judicial admission is a formal conce

r than to assert that Jeffrey Epstein sexually abused both. However, the differing circumstances of the two petitioners during the investigation of Epstein are highly relevant in determining whether each petitioner can even invoke the CVRA. Through her attorney, James Eisenberg, Esq.,' Jane Doe No. 2 r

0. When asked whether Epstein "pulled you closer to him in a sexual way," Jane Doe No. 2 replied: A. I wish. No, no, never, ever, ever, no, never. Jeffrey is an awesome man, no. Id. at 22. At the end of her interview, Jane Doe No. 2 was asked if she had any questions for the agents or AUSA Villafafia

agreement entered into by the United States and Mr. Epstein in a timely fashion." Ex. N, Nov. 27, 2007 email

it works to [his] advantage [by establishing the claim] and repudiat[ing] it when it works to [his] disadvantage by requiring arbitration." In re Humana Inc. Managed Care Litigation 285 F.3d 971, 976 (11th Cir. 2002) rev'd on other grounds by PacifiCare Health Sys., Inc. v. Book, 538 U.S. 401 (2003), citi

s from Jeffrey Epstein for sexually abusing her. Ex. P. On September 11, 2008, Jane Doe No. 2 file an action in Palm Beach County, Florida, L.M. v. Jeffrey Epstein Case No. 50-2008-CA- 28051-XXXXMB, seeking money damages from Jeffrey Epstein for sexually abusing her. Ex. Q. 6 "A judicial admission is a formal conce

r than to assert that Jeffrey Epstein sexually abused both. However, the differing circumstances of the two petitioners during the investigation of Epstein are highly relevant in determining whether each petitioner can even invoke the CVRA. Through her attorney, James Eisenberg, Esq.,' Jane Doe No. 2 r

0. When asked whether Epstein "pulled you closer to him in a sexual way," Jane Doe No. 2 replied: A. I wish. No, no, never, ever, ever, no, never. Jeffrey is an awesome man, no. Id. at 22. At the end of her interview, Jane Doe No. 2 was asked if she had any questions for the agents or AUSA Villafafia

agreement entered into by the United States and Mr. Epstein in a timely fashion." Ex. N, Nov. 27, 2007 email

it works to [his] advantage [by establishing the claim] and repudiat[ing] it when it works to [his] disadvantage by requiring arbitration." In re Humana Inc. Managed Care Litigation 285 F.3d 971, 976 (11th Cir. 2002) rev'd on other grounds by PacifiCare Health Sys., Inc. v. Book, 538 U.S. 401 (2003), citi

k Release The Palm Beach County Sheriffs Office announced on Friday an internal investigation into the Florida departments supervision of financier Jeffrey Epstein when he was jailed there a decade ago on sex crime charges, after a lawyer for some of Epstein's alleged victims implied the accused child rapist h

Florida departments supervision of financier Jeffrey Epstein when he was jailed there a decade ago on sex crime charges, after a lawyer for some of Epstein's alleged victims implied the accused child rapist had abused the privileges of his work release. Read full article » SECURITIES Judge Won't Let

the Florida departments supervision of financier Jeffrey Epstein when he was jailed there a decade ago on

On Appraiser In Easement Donation Probe Getty Images Inc. Google Inc. HSBC Holdings PLC Hertz Global Holdings Inc. Honeywell International Inc. Humana Inc. Independence Blue Cross Inc. Instagram Inc. International Brotherhood of Electrical Workers Major Lindsey & Africa McKesson Corp. NASDAQ OMX G

tlev Engel Klaus Engel Richard P. Eno David R. Epstein Mary Callahan Erdoes Charles W. Ergen Paula E

kil Beshir Ulrich L. Bettermann Erik Behermann Jeffrey L. Bewkes Donald S. Beyer Homi K. Bhabha Neera

A USA Biocon India India Royal Bank of Scotland United Kingdom AngloGold Ashanti Ltd South Africa Millennium Promise USA Pamoja Capital SA Humana Inc. CNN International Switzerland USA USA CA Technologies USA Moody's Corporation USA SAP AG USA Prudential Plc United Kingdom McGraw-Hill C

John K. Defterios John J. DeGioia Alain Dehaze Jeffrey Deitch Marijn E. Dekkers Michael S. Dell Chris

ement CNBC Africa Lawson Inc. bgc3 Toshiba Corporation Kirin Holdings Company Limited Heartfile Interpeace Harvard Business School PetroSA Humana Inc. KPMG Accenture USA Switzerland Hong Kong SAR India India South Africa USA USA United Kingdom United Kingdom USA USA South Africa Unit