Epstein Secrets

portions of the Agreement. As I previously observed, our intent has been to place the victims in the same position as they would have been had Mr. Epstein been convicted at trial. No more; no less. From our meeting, it appears that the defense agrees that this was the intent. During the course of nego

lm Beach, FL 33401 (561) 820-8711 Facsimile: (56!) 820-8777 August 4, 2009 VIA ELECTRONIC MAIL Spencer T. Kuvin, Esq. Leopold—Kuvin, P.A. Re: Jeffrey Epstein/B.B. — Requested Disclosure of Non-Prosecution Agreement Dear Mr. Kuvin: Thank you for your letter regarding the disclosure of the Non-Prosecution Agree

ORTH. FL 334614 Page 2 of 8 Form Revised 01.18-08 EFTA00233452 11/25/2008 15:28 3553626 elKt.LII I LICIMINAL STATE OF FLORIDA Plaintiff -vs- JEFFREY E. EPSTEM Defendant IN THE FIFTEENTH JUDICIAL CIRCUIT COURT, IN AND FOR PALM BEACH COUNTY CASE NUMBER DIVISION DC NUMBER CIRCUITNUMBER: zalitcavawanua

E Disposition Amount: Docket Text: AGREED ORDER CONTINUING CASE DISPO 13 AGOR - AGREED ORDER Filing Date: 05-MAR-2007 Filing Party: EPSTEIN, JEFFREY E IRisposition Amount: Docket Text: I(JUDGE MCSORLEY) CONTINUING CASE DISPO PREVIOUSLY- 1 SET FOR 08-MAR-2007 AND RESETTING FOR CASE DISPO ON 16-MAY

mmissioner CASE DISPOSITION MAIN BRANCH COURTROOM 11F COLBATH, JUDGE JEFFREY CASE DISPOSITION MAIN BRANCH COURTROOM] 11F COLBATH, JUDGE JEFFREY Case Parties Expn Date Type ID Name DEFENDANT 24167391 EPSTEIN, JEFFREY E. Aliases: none 3 1 22-AUG- ATTORNEY ATTY MALINSKI, NORMAN 2006 Alia

FREY CASE DISPOSITION MAIN BRANCH COURTROOM] 11F COLBATH, JUDGE JEFFREY Case Parties Expn Date Type ID Name DEFENDANT 24167391 EPSTEIN, JEFFREY E. Aliases: none 3 1 22-AUG- ATTORNEY ATTY MALINSKI, NORMAN 2006 Aliases: none hup://courtcon.co.palm-beach.flais/p1s/jiwp/ek_public_qry_docup_dkt

24 FAHIS - HISTORY FELONY/MISD ARRAIGN Filing Date: 06-OCT-2006 Filing Party: Disposition Amount: Docket Text: X/JIFA FELONY-MISDEMEANOR IS EPSTEIN JEFFREY E LEGACY 41673917332767 PRAECIPE AND 082206 DATE: JUDGE: COURT: DEFENDANT PRESENT: PLEA: ARRAIGNMENT PASSED TO: DATE: RELEASED, FAILURE OF STATE

, Plaintiff, vs. JEFFERY EPSTEIN, Defendant. DEFENDANT EPSTEIN'S MOTION TO DISMISS, & FOR MORE DEFINITE STATEME

in the same position as they would have been had Mr. Epstein been convicted at trial. No more; no less. From

imposed minimum. Notwithstanding the above legal analysis, in the recent case of Individual Known to Defendant As 08M1ST096.JPG and 08mist067.iog Falso, 2009 WI, 4807537 (N.D. N.Y. Dec. 9, 2009), United States District Court for the Northern District of New York Plaintiff has attempted to allege 6

sts the legitimate concern that the agreement could be so used and the reality that any concern about such use significantly and unfairly burdens Mr Epstein's right to resort to the courts to resolve outstanding legal Issues regarding the criteria for payment and the amount of payment owed. I hope this

Jane Doe No. 103 1 0 - 80 (b) County of Residency of First Listed Plaintiff West Palm Beach (EXCEPT IN U.S. PLAINTIPP CASES) S int. NTS 0 it Fey stein (c) Attorney's (Tina Nam, Address. nod Telephone Hornbill) Robert C..losefsbag, Esq./Katherine W. Ezell, Esq. Podhurst Orseck, P.A. 25 W. Flag' e

, Plaintiff, vs. JEFFERY EPSTEIN, Defendant. DEFENDANT EPSTEIN'S MOTION TO DISMISS, & FOR MORE DEFINITE STATEME

Biscayne Blvd, Suite 1300 Miami, FL 33131 Re: Jeffrey Epstein Dear Mr. Black: Thank you for meeting w

it a breach of the Non- Prosecution Agreement for Mr. Epstein to file suit against the victim's attorney-repres

imposed minimum. Notwithstanding the above legal analysis, in the recent case of Individual Known to Defendant As 08MIST096.JPG and 08mist067.ipg Falso, 2009 WL 4807537 (N.D. N.Y. Dec. 9, 2009), United States District Court for the Northern District of New York s Plaintiff has attempted to allege 6

Order On or about April 9, 2019, the Government advised Judge Netbum, who had not yet ruled on the Government's other application in Jane Doe 43 v. Epstein, et at, 17 Civ. 0616 (JGK) (SN), of Chief Judge McMahon's decision via a pane and sealed letter. (Def. Mot. 3, Ex. I). Subsequently, on April 16, 2

rational juror, after hearing the evidence, could find that the question called for the names of minors that the defendant interacted with at any of Jeffrey Epstein's properties, that the defendant answered that she was aware of no such minors other than , and therefore that her answer was false. And even if the d

out whether the defendant brought women to Epstein, which the defendant resisted by observing that she hired "people across the board" to "work for Jeffrey." (Id. at 245:7-18). counsel asked whether any minors worked as exercise instructors or masseuses at Epstein's home, and the defendant testified t

sex toys or devices used in sexual activities in Mr. Epstein's Palm Beach house? A. No. not that I recall. q

ts' claims of Government Franks violations. To obtain a Franks hearing, a defendant must make a "substantial preliminary showing," United States v. Falso, 544 F.3d 110, 125 (2d Cir. 2008) (quoting Franks v. Delaware, 438 U.S. 154, 155-56 (1978)), that (i) there were "inaccuracies or omissions" in the

tantial preliminary showing" requirement explained above exists to "avoid fishing expeditions into affidavits that are otherwise presumed truthful." Falso, 544 F.3d at 125. "[C]onclusory allegations cannot support a Franks challenge as a matter of law." United States v. Pizarro, No. 17 Cr. 151 (AJN),

, 2016 meeting (the "Daily News Article" or the "Article").35 The Article stated, among other things, that defense attorneys representing victims of Epstein and Maxwell "urged" the USAO-SDNY to "open an investigation of the duo" during that meeting. Citing two anonymous sources, the Article described th

rational juror, after hearing the evidence, could find that the question called for the names of minors that the defendant interacted with at any of Jeffrey Epstein's properties, that the defendant answered that she was aware of no such minors other than and therefore that her answer was false. And even if the def

out whether the defendant brought women to Epstein, which the defendant resisted by observing that she hired "people across the board" to "work for Jeffrey." (Id. at 245:7-18). 'ounsel asked whether any minors worked as exercise instructors or masseuses at Epstein's home, and the defendant testified t

, the following colloquy occurred: When you and Mr. Epstein were engaged in sexual activity that included th

ts' claims of Government Franks violations. To obtain a Franks hearing, a defendant must make a "substantial preliminary showing," United States v. Falso, 544 F.3d 110, 125 (2d Cir. 2008) (quoting Franks v. Delaware, 438 U.S. 154, 155-56 (1978)), that (i) there were "inaccuracies or omissions" in the

tantial preliminary showing" requirement explained above exists to "avoid fishing expeditions into affidavits that are otherwise presumed truthful." Falso, 544 F.3d at 125. "[C]onclusory allegations cannot support a Franks challenge as a matter of law." United States v. Pizarro, No. 17 Cr. 151 (AJN),

Order On or about April 9, 2019, the Government advised Judge Netbum, who had not yet ruled on the Government's other application in Jane Doe 43 v. Epstein, et at, 17 Civ. 0616 (JGK) (SN), of Chief Judge McMahon's decision via a pane and sealed letter. (Def. Mot. 3, Ex. I). Subsequently, on April 16, 2

rational juror, after hearing the evidence, could find that the question called for the names of minors that the defendant interacted with at any of Jeffrey Epstein's properties, that the defendant answered that she was aware of no such minors other than Giuffre, and therefore that her answer was false. And even i

out whether the defendant brought women to Epstein, which the defendant resisted by observing that she hired "people across the board" to "work for Jeffrey." (Id. at 245:7-18). Giuffre's counsel asked whether any minors worked as exercise instructors or masseuses at Epstein's home, and the defendant te

e following colloquy occurred: Er. When you and Mr. Epstein were engaged in sexual activity that included th

ts' claims of Government Franks violations. To obtain a Franks hearing, a defendant must make a "substantial preliminary showing," United States v. Falso, 544 F.3d 110, 125 (2d Cir. 2008) (quoting Franks v. Delaware, 438 U.S. 154, 155-56 (1978)), that (i) there were "inaccuracies or omissions" in the

tantial preliminary showing" requirement explained above exists to "avoid fishing expeditions into affidavits that are otherwise presumed truthful." Falso, 544 F.3d at 125. "[C]onclusory allegations cannot support a Franks challenge as a matter of law." United States v. Pizarro, No. 17 Cr. 151 (AJN),

Order On or about April 9, 2019, the Government advised Judge Netbum, who had not yet ruled on the Government's other application in Jane Doe 43 v. Epstein, et at, 17 Civ. 0616 (JGK) (SN), of Chief Judge McMahon's decision via a pane and sealed letter. (Def. Mot. 3, Ex. I). Subsequently, on April 16, 2

rational juror, after hearing the evidence, could find that the question called for the names of minors that the defendant interacted with at any of Jeffrey Epstein's properties, that the defendant answered that she was aware of no such minors other than Giuffre, and therefore that her answer was false. And even i

out whether the defendant brought women to Epstein, which the defendant resisted by observing that she hired "people across the board" to "work for Jeffrey." (Id. at 245:7-18). Giuffre's counsel asked whether any minors worked as exercise instructors or masseuses at Epstein's home, and the defendant te

e following colloquy occurred: Er. When you and Mr. Epstein were engaged in sexual activity that included th

ts' claims of Government Franks violations. To obtain a Franks hearing, a defendant must make a "substantial preliminary showing," United States v. Falso, 544 F.3d 110, 125 (2d Cir. 2008) (quoting Franks v. Delaware, 438 U.S. 154, 155-56 (1978)), that (i) there were "inaccuracies or omissions" in the

tantial preliminary showing" requirement explained above exists to "avoid fishing expeditions into affidavits that are otherwise presumed truthful." Falso, 544 F.3d at 125. "[C]onclusory allegations cannot support a Franks challenge as a matter of law." United States v. Pizarro, No. 17 Cr. 151 (AJN),

2016 meeting (the "Daily News Article" or the "Article") .36 The Article stated, among other things, that defense attorneys representing victims of Epstein and the defendant "urged" the USAO-SDNY to "open an investigation of the duo" during that meeting. Citing two anonymous sources, the Article descri

underage girls that the defendant met and brought to Epstein. Specifically: Q. Can you list for me all the girls that you have met and brought to Jeffrey Epstein's house that were under the age of 18? MR. PAGLIUCA: Objection to the form and foundation. A. I could only recall my family members that were there a

out whether the defendant brought women to Epstein, which the defendant resisted by observing that she hired "people across the board" to "work for Jeffrey." (Id. at 245:7-18). Giuffre's counsel asked whether any minors worked as exercise instructors or masseuses at Epstein's home, and the defendant te

Q. Were you ever involved in sexual activities in Mr. Epstein's Palm Beach house that included the use of sex

ts' claims of Government Franks violations. To obtain a Franks hearing, a defendant must make a "substantial preliminary showing," United States v. Falso, 544 F.3d 110, 125 (2d Cir. 2008) (quoting Franks v. Delaware, 438 U.S. 154, 155-56 (1978)), that (i) there were "inaccuracies or omissions" in the

tantial preliminary showing" requirement explained above exists to "avoid fishing expeditions into affidavits that are otherwise presumed truthful." Falso, 544 F.3d at 125. "[C]onclusory allegations cannot support a Franks challenge as a matter of law." United States v. Pizarro, No. 17 Cr. 151 (AJN),

ir. 1996) 2 Young v. United States, 481 U.S. 787 (1987) 24 Other Authorities Stephen Rex Brown, Manhattan federal prosecutors declined to pursue Jeffrey Epstein and Ghislaine Maxwell case in 2016, New York Daily News (Oct. 13, 2020) 11 U.S. Dept. of Justice, JUSTICE MANUAL, JM § 9-11.151 15 Rules Fed.

al abuse and trafficking by Jeffrey Epstein and Maxwell. Ex. J, pp 1-3. • At the meeting, attorneys told AUSA the following: o That Maxwell was Epstein's "head recruiter" of underage victims. Id. at 2. o That =vas underage when she was brought to New York "for training by Maxwell and Epstein [in]

OLES SCHILLER AND TO DISMISS COUNTS FIVE AND SIX Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN &

20 United States v. Bout, 731 F.3d 233 (2d Cir. 2013) 23 United States v. Cortina, 630 F.2d 1207 (7th Cir. 1980) 20, 22, 25, 26 United States v. Falso, 544 F.3d 110 (2d Cir. 2008) 22 United States v. Lambus, 897 F.3d 368 (2d Cir. 2018) 23, 25 United States v. Ming He, 94 F.3d 782 (2d Cir. 1996)

applies, Maxwell has easily met her burden. To obtain a Franks hearing, a defendant must make a "substantial preliminary showing," United States v. Falso, 544 F.3d 110, 125 (2d Cir. 2008) (quoting Franks, 438 U.S. at 155-56), that (i) there were "inaccuracies or omissions" in the affidavit, (ii) "the

OLES SCHILLER AND TO DISMISS COUNTS FIVE AND SIX Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN &

20 United States v. Bout, 731 F.3d 233 (2d Cir. 2013) 23 United States v. Cortina, 630 F.2d 1207 (7th Cir. 1980) 20, 22, 25, 26 United States v. Falso, 544 F.3d 110 (2d Cir. 2008) 22 United States v. Lambus, 897 F.3d 368 (2d Cir. 2018) 23, 25 United States v. Ming He, 94 F.3d 782 (2d Or. 1996)

h Cir. 1996) 2 Young v. United States, 481 U.S. 787 (1987) 24 Other Authorities Stephen Rex M, Manhattan federal prosecutors declined to pursue Jeffrey Epstein and Ghislaine Maxwell case in 2016, New York Daily News (Oct. 13, 2020) 11 U.S. Dept. of Justice, JUSTICE MANUAL, JM § 9-11.151 15 Rules Fed.

OLES SCHILLER AND TO DISMISS COUNTS FIVE AND SIX Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN &

20 United States v. Bout, 731 F.3d 233 (2d Cir. 2013) 23 United States v. Cortina, 630 F.2d 1207 (7th Cir. 1980) 20, 22, 25, 26 United States v. Falso, 544 F.3d 110 (2d Cir. 2008) 22 United States v. Lambus, 897 F.3d 368 (2d Cir. 2018) 23, 25 United States v. Ming He, 94 F.3d 782 (2d Or. 1996)

ir. 1996) 2 Young v. United States, 481 U.S. 787 (1987) 24 Other Authorities Stephen Rex Brown, Manhattan federal prosecutors declined to pursue Jeffrey Epstein and Ghislaine Maxwell case in 2016, New York Daily News (Oct. 13, 2020) 11 U.S. Dept. of Justice, JUSTICE MANUAL, JM § 9-11.151 15 Rules Fed.