Epstein Secrets

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 EFTA00799496 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 EFTA00799582 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

a Water Management Dist., 647 F.3d 1296, 1302 (11th Cir. 2011); Phoenix of Broward, Inc. v. McDonald's Corp., 489 F.3d 1156, 1161 (11th Cir. 2007); Scott v. Taylor, 470 F.3d 1014, 1018 (11th Cir. 2006); National Parks Conservation Ass'n v. Norton, 324 F.3d 1229, 1242 (11th Cir. 2003). A. This Court Must Addr

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 EFTA00208824 Petitioners' righ

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, also needed (directly or indirectly) to make transportation arrangements for many of the girls, as they were often too yo

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 EFTA00208910 Epstein, is thus estopped by his plea and agreement with the Federal Government from denying the acts alleged in this Compla

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

a Water Management Dist., 647 F.3d 1296, 1302 (11th Cir. 2011); Phoenix of Broward, Inc. v. McDonald's Corp., 489 F.3d 1156, 1161 (11th Cir. 2007); Scott v. Taylor, 470 F.3d 1014, 1018 (11th Cir. 2006); National Parks Conservation Ass'n v. Norton, 324 F.3d 1229, 1242 (11th Cir. 2003). A. This Court Must Addr

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

a Water Management Dist., 647 F.3d 1296, 1302 (11th Cir. 2011); Phoenix of Broward, Inc. v. McDonald's Corp., 489 F.3d 1156, 1161 (11th Cir. 2007); Scott v. Taylor, 470 F.3d 1014, 1018 (11th Cir. 2006); National Parks Conservation Ass 'n v. Norton, 324 F.3d 1229, 1242 (11th Cir. 2003). A. This Court Must Add

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 EFTA00795172 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 EFTA00795258 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

a Water Management Dist., 647 F.3d 1296, 1302 (11th Cir. 2011); Phoenix of Broward, Inc. v. McDonald's Corp., 489 F.3d 1156, 1161 (11th Cir. 2007); Scott v. Taylor, 470 F.3d 1014, 1018 (11th Cir. 2006); National Parks Conservation Ass'n v. Norton, 324 F.3d 1229, 1242 (11th Cir. 2003). A. This Court Must Addr

15th Judicial Circuit in and for Palm Beach County (hereinafter, the "State Attorney's Office") have conducted an investigation into the conduct of Jeffrey Epstein (hereinafter "Epstein"); IT APPEARING that the State Attorney's Office has charged Epstein by indictment with solicitation of prostitution, in viol

he relitigation of which is barred by a prior federal nonprosecution agreement (the "NPA"). The government makes this drastic demand even though Mr. Epstein has never once attempted to flee the United States — despite a Florida federal judge's stated belief that he could void the NPA in appropriate circ

Street New York, NY 10007 RE: United States v. Jeffrey Epstein, Criminal No. 19-490 Dear Judge Berman:

government makes this drastic demand even though Mr. Epstein has never once attempted to flee the United Stat

or lack of standing because Petitioners simply have no injury that is likely to be redressed by a favorable ruling in these proceedings. See, e.g., Scott v. Taylor, 470 F.3d 1014, 1018 (11th Cir. 2006) (holding that there was no standing where it was speculative that remedy that Plaintiff sought 5 Significant

15th Judicial Circuit in and for Palm Beach County (hereinafter, the "State Attorney's Office") have conducted an investigation into the conduct of Jeffrey Epstein (hereinafter "Epstein"); IT APPEARING that the State Attorney's Office has charged Epstein by indictment with solicitation of prostitution, in viol

he relitigation of which is barred by a prior federal nonprosecution agreement (the "NPA"). The government makes this drastic demand even though Mr. Epstein has never once attempted to flee the United States — despite a Florida federal judge's stated belief that he could void the NPA in appropriate circ

Street New York, NY 10007 RE: United States v. Jeffrey Epstein, Criminal No. 19-490 Dear Judge Berman:

government makes this drastic demand even though Mr. Epstein has never once attempted to flee the United Stat

or lack of standing because Petitioners simply have no injury that is likely to be redressed by a favorable ruling in these proceedings. See, e.g., Scott v. Taylor, 470 F.3d 1014, 1018 (11th Cir. 2006) (holding that there was no standing where it was speculative that remedy that Plaintiff sought 5 Significant

legal relief that Petitioners have sought pursuant to the CVRA is the setting aside of the Non-Prosecution Agreement that was entered into between Jeffrey Epstein and the U.S. Attorney's Office for the Southern District of Florida ("USAO-SDFL"). See, e.g., DE 99 at 6 (recognizing that the relief Petitioners se

oners seek "is to invalidate the non-prosecution agreement"). But even assuming arguendo that Petitioners' rights under the CVRA were violated when Epstein and the USAO-SDFL entered into the Non- Prosecution Agreement, constitutional due process guarantees do not allow either the Non- Prosecution Agreeme

secution Agreement that was entered into between Jeffrey Epstein and the U.S. Attorney's Office for the So

or lack of standing because Petitioners simply have no injury that is likely to be redressed by a favorable ruling in these proceedings. See, e.g., Scott v. Taylor, 470 F.3d 1014, 1018 (11th Cir. 2006) (holding that there was no standing where it was speculative that remedy that Plaintiff sought 5 Significant

legal relief that Petitioners have sought pursuant to the CVRA is the setting aside of the Non-Prosecution Agreement that was entered into between Jeffrey Epstein and the U.S. Attorney's Office for the Southern District of Florida ("USAO-SDFL"). See, e.g., DE 99 at 6 (recognizing that the relief Petitioners se

oners seek "is to invalidate the non-prosecution agreement"). But even assuming arguendo that Petitioners' rights under the CVRA were violated when Epstein and the USAO-SDFL entered into the Non- Prosecution Agreement, constitutional due process guarantees do not allow either the Non- Prosecution Agreeme

secution Agreement that was entered into between Jeffrey Epstein and the U.S. Attorney's Office for the So

or lack of standing because Petitioners simply have no injury that is likely to be redressed by a favorable ruling in these proceedings. See, e.g., Scott v. Taylor, 470 F.3d 1014, 1018 (11th Cir. 2006) (holding that there was no standing where it was speculative that remedy that Plaintiff sought 5 Significantl

legal relief that Petitioners have sought pursuant to the CVRA is the setting aside of the Non-Prosecution Agreement that was entered into between Jeffrey Epstein and the U.S. Attorney's Office for the Southern District of Florida ("USAO-SDFL"). See, e.g., DE 99 at 6 (recognizing that the relief Petitioners se

oners seek "is to invalidate the non-prosecution agreement"). But even assuming arguendo that Petitioners' rights under the CVRA were violated when Epstein and the USAO-SDFL entered into the Non- Prosecution Agreement, constitutional due process guarantees do not allow either the Non- Prosecution Agreeme

secution Agreement that was entered into between Jeffrey Epstein and the U.S. Attorney's Office for the So

or lack of standing because Petitioners simply have no injury that is likely to be redressed by a favorable ruling in these proceedings. See, e.g., Scott v. Taylor, 470 F.3d 1014, 1018 (11th Cir. 2006) (holding that there was no standing where it was speculative that remedy that Plaintiff sought 5 Significantl

legal relief that Petitioners have sought pursuant to the CVRA is the setting aside of the Non-Prosecution Agreement that was entered into between Jeffrey Epstein and the U.S. Attorney's Office for the Southern District of Florida ("USAO-SDFL"). See, e.g., DE 99 at 6 (recognizing that the relief Petitioners se

oners seek "is to invalidate the non-prosecution agreement"). But even assuming arguendo that Petitioners' rights under the CVRA were violated when Epstein and the USAO-SDFL entered into the Non- Prosecution Agreement, constitutional due process guarantees do not allow either the Non- Prosecution Agreeme

secution Agreement that was entered into between Jeffrey Epstein and the U.S. Attorney's Office for the So

or lack of standing because Petitioners simply have no injury that is likely to be redressed by a favorable ruling in these proceedings. See, e.g., Scott v. Taylor, 470 F.3d 1014, 1018 (11th Cir. 2006) (holding that there was no standing where it was speculative that remedy that Plaintiff sought 5 Significantl