Epstein Secrets

the crime or, if no prosecution is underway, in the district court in which the crime occurred." Since no federal criminal charge was filed against Epstein, petitioners sought relief under the second clause, by filing their emergency petition in the Southern District of Florida on July 7, 2008. Petitio

st Epstein, using the Podhurst Orseck, P.A. law firm, which had been suggested to her in the September 3, 2008 letter. Exhibit B Jane Doe No. 102'. Jeffrey Epstein, Case No. 09-80656-CIV-MARRA (S.D.Fla.). In her complaint against Epstein, Jane Doe #3 stated that she received numerous phone calls from one of Ep

ber 3, 2008 letter. Exhibit B Jane Doe No. 102'. Jeffrey Epstein, Case No. 09-80656-CIV-MARRA (S.D.Fla.).

e entire agreement between the United States and Mr. Epstein." Exhibit A at 3. In January 2009, Jane Doe #3 r

nt to the petition is futile since the claim is subject to dismissal under Fed.R.Civ.P. 12(b)(6). DATED: January 20, 2015 Respectfully submitted, WILFREDO A. FERRER UNITED STATES ATTORNEY CERTIFICATE OF SERVICE I HEREBY CERTIFY that on January 20, 2015, I electronically filed the foregoing document with the Cle

Jane Doe No. I and Jane Doe No. 2 became familiar enough with the non-prosecution agreement to both invoke its provisions in their lawsuits against Jeffrey Epstein under 18 U.S.C. § 2255.' United States' Reply in Support of Its Motion to Dismiss for Lack of Subject matter Jurisdiction, D.E. 205-6, Exhibits A —

wsuit was that the government failed to consult with them prior to what they believed would be the disposition of the federal investigation against Epstein. D.E. 1,11 3,4. They knew, at the time their petition was filed, that Epstein had "recently been prosecuted and pleaded guilty, on June 30, 2008, i

h invoke its provisions in their lawsuits against Jeffrey Epstein under 18 U.S.C. § 2255.' United States'

end their petition to reflect that a non-prosecution agreement was negotiated in September 2007. DATED: February 23, 2015 Respectfully submitted, WILFREDO A. FERRER UNITED STATES ATTORNEY By: ATTORNEY FOR RESPONDENT CERTIFICATE OF SERVICE I HEREBY CERTIFY that on February 23, 2015, I electronically filed the f

Jane Doe No. 1 and Jane Doe No. 2 became familiar enough with the non-prosecution agreement to both invoke its provisions in their lawsuits against Jeffrey Epstein under 18 U.S.C. § 2255.1 From its inception, the premise of their CVRA lawsuit was that the government failed I Jane Doe No. 3, who seeks to be add

d I Jane Doe No. 3, who seeks to be added as a party, also wasted little time in utilizing the non-prosecution agreement to seek money damages from Epstein. After receiving written notice in January 2009 from the U.S. Attorney's Office of Epstein's guilty pleas and the potential of obtaining compensatio

h invoke its provisions in their lawsuits against Jeffrey Epstein under 18 U.S.C. § 2255.1 From its incept

ion to reflect that a non-prosecution agreement was negotiated in September 2007. 19 EFTA00210638 DATED: February 2015 Respectfully submitted, WILFREDO A. FERRER UNITED STATES ATTORNEY By: ATTORNEY FOR RESPONDENT CERTIFICATE OF SERVICE I HEREBY CERTIFY that on February 2015, I electronically filed the fore

ARE IRRELEVANT TO THE INQUIRY BEFORE THIS COURT In Request for Production No. 1, petitioners seek the Federal Bureau of Investigation file on the Epstein case, to include documents, correspondence, witness statements, FBI 302s and other similar information "collected as part of its case against and/or

n initial disclosures under Rule 26(a)(1) by simply incorporating it into a request for production. DATED: August 2, 2013 Respectfully submitted, WILFREDO A. FERRER UNITED STATES ATTORNEY By: Il• 4 EFTA00209332 ATTORNEY FOR RESPONDENT CERTIFICATE OF SERVICE I HEREBY CERTIFY that on August 2, 2013, I electro

sons or entities outside the federal government (including without limitation all correspondence generated by or between the federal government and Epstein's attorneys); and (c) produce all other responsive documents in response to all outstanding requests for production of documents. D.E. 190 at 2. 2.

sought petitioners' position on the instant motion. Petitioners stated that they oppose the motion. DATED: July 19, 2013 Respectfully submitted, WILFREDO A. FERRER UNITED STATES ATTORNEY By: ATTORNEY FOR RESPONDENT CERTIFICATE OF SERVICE 2 EFTA00209335 I HEREBY CERTIFY that on August 2, 2013, I electronica

ARE IRRELEVANT TO THE INQUIRY BEFORE THIS COURT In Request for Production No. 1, petitioners seek the Federal Bureau of Investigation file on the Epstein case, to include documents, correspondence, witness statements, FBI 302s and other similar information "collected as part of its case against and/or

initial disclosures under Rule 26(a)(1) by simply incorporating it into a request for production. DATED: October 6, 2014 Respectfully submitted, WILFREDO A. FERRER UNITED STATES ATTORNEY By: DEXTER A. LEE Assistant U.S. Attorne Fla. Bar No. 99 N.E. 4th Street, Suite 300 ATTORNEY FOR RESPONDENT CERTIFICATE