Epstein Secrets

ling to pay for the transcript. 2. Your proposed stipulation indicates that in September 2007 the U.S. Attorney's Office reached an agreement with Epstein to resolve the case, which was then modified in Ontober and December of that year. While this seems plausible, to stipulate to the facts, I would o

0 0002 5519 8503 West Palm Beach, Florida 33401 Dear As you are aware, we represent several of the young girls that were victimized and abused by Jeffrey Epstein. While we are aware of his recent guilty plea and conviction in his State Court case, the sentence imposed in that case is grossly inadequate for a

his desire that federal charges be filed against defendant Epstein. In particular, he wrote on behalf of his client

e young girls that were victimized and abused by Jeffrey Epstein. While we are aware of his recent guilty

criminal prosecution commensurate with the crimes Mr. Epstein has committed, and we further urge you to take t

SE NO. 08-80736-Civ-MARRA/JOHNSON CERTIFICATION OF EMERGENCY FILPFAike D.C. ELECTRONIC JULY 7, 2008 STEVEN M. LARIMORE CLERK U.S. OUST. CT. S. D. Of FLA. • MIAMI I hereby certify that, as a member of the Bar of this Court, I have carefully examined this matter and it is a true emergency. I f

It has utterly failed to even offer any such cause — much less show that it is good cause. Second, the Government — with the apparent contrivance of Jeffrey Epstein's attorneys — has made inaccurate representations about the nature of the non-prosecution agreement in its notices to the victims and in its filing b

well as to the Court — lies with Jeffrey Epstein's attorneys'. See Gov't Response at 5 ("the [inaccurate] victim notification letter was provided to Epstein's attorneys prior to being sent, who approved the language of which the petitioners now complain."). The apparent approval by Jeffrey Epstein's at

-2006 Amendments version of the law applies. See Defendant Epstein's Motion to Dismiss, for More Definite Statement

he terms of the non-prosecution agreement between Jeffrey Epstein and the United States Government. Jeffre

made a part of the record and the extent to which Mr. Epstein, through his attorneys, was culpable. Sincerely

s 1-32. For the Plaintiff: Bradley Edwards, Esquire For the Defendant: Dexter Lee, AUSA Maria Villafana, AUSA STEVEN M. IARIM CLERK U. S. GIST. S. D. of FLA-MV GJT C. sedans ,v • •••I, • .hrt/...•0•1•••41•, OFFICIAL REPO NG SERVICES, LLC (954) -8204 EFTA00177297 Case 9:08-cv-i ,-KAM Doc

y Lefkowitz in Support of Their Motion for a Protective Order Concerning Production, Use, and Disclosure of Plea Negotiations (Doc. 161); Intervenor Jeffrey Epstein's 3 EFTA00177813 A. The Applicability of Rule 410. Any assessment of the merits of the intervenors' contentions must begin with an understanding

tion agreement" ("the agreement") between the United States Attorney's Office for the Southern District of Florida (USAO/SDFL) and Jeffrey Epstein (Epstein) pursuant to the Crime Victims' Rights Act of 2004 (CVRA), 18 U.S.C. §3771. Under the agreement, Epstein agreed to (1) plead guilty to two then pend

the Southern District of Florida (USAO/SDFL) and Jeffrey Epstein (Epstein) pursuant to the Crime Victims'

ould render Rule 410 ambiguous and would violate Mr. Epstein's Fifth Amendment rights. The rule's central fea

1 and JANE DOE #2, petitioners, VS. UNITED STATES OF AMERICA, respondent. FILED by D.C. JUN 1 8 2013 STEVEN ht. LARNOFIE CL ERK U S DIST L.T S. D. of FIA - WILL — ORDER DENYING GOVERNMENT'S MOTION TO DISMISS FOR LACK OF SUBJECT MATTER JURISDICTION & ORDER LIFTING STAY OF DISCOVERY THIS CAUSE

WAIVED ANY PRIVILEGE THAT IT MIGHT OTHERWISE POSSESS 5 11. THE QUALIFIED JOURNALIST PRIVILEGE IS OVERCOME BY EDWARDS' COMPELLING NEED TO OBTAIN JEFFREY EPSTEIN'S OWN WORDS ABOUT HIS SEXUAL ABUSE OF MINOR GIRLS AND HIS LACK OF REMORSE 8 A. Edwards Needs Epstein's Own Words to Defend Against Epstein's Civil

Damages 8 B. Epstein's Statements Are Not Available from Any Other Source CONCLUSION 12 EFTA00729036 TABLE OF AUTHORMES Cases Doe No. 102 v. Epstein, No. 9:09-CV-80656-KAM (S. D. FIa. 2009) 4 Altemose Constr. Cot v. Building & Constr. Trades Council, 443 F. Supp. 489 (ED. Pa. 1977) 7 Flores

S OVERCOME BY EDWARDS' COMPELLING NEED TO OBTAIN JEFFREY EPSTEIN'S OWN WORDS ABOUT HIS SEXUAL ABUSE OF MI

le sources" since "the record is quite clear that Mr. Epstein has regularly been asserting, and will continue

ts Are Not Available from Any Other Source CONCLUSION 12 EFTA00729036 TABLE OF AUTHORMES Cases Doe No. 102 v. Epstein, No. 9:09-CV-80656-KAM (S. D. FIa. 2009) 4 Altemose Constr. Cot v. Building & Constr. Trades Council, 443 F. Supp. 489 (ED. Pa. 1977) 7 Flores v. Cooper Tire and Rubber Co.,

iversity of California at Los Angeles. Dr. W. E. Jeffrey, Chairperson. X. PUBLICATIONS Greitzer (aka, Go

-75. Howe, M., Goodman, G. S., & Cicchetti, D. (2008). Stress, trauma, and memory development. NY: Cambridge University Press. Ogle, C. M., Block, S. D., Culver, M., Harris, L. T., Augusti, E. M., & Goodman, G. S. (2008). Accuracy and specificity of autobiographical memory in childhood trauma victims

ed States Code, Section 853. // eil-dOnfaete.• JEFFREY it SLOMAN ACTING UNITED STATES ATTORNEY PAUL F.

v. SCOTT W. ROTHSTEIN, Defendant. CR - COHN mAsts.ri,ATii jUU4i Maga FILED by 0 D. DEC 0 1 2009 STEVEN M. LARIMORE CLERK U. S. DIST. CT. S. D. Of FLA - F T LAUD. INFORMATION The United States Attorney charges that, at all times relevant to this Information: GENERAL ALLEGATIONS I. Scott