Epstein Secrets

) & (8). It is now beyond dispute, for example, that in September 2007, the U.S. Attorney's Office formally signed a non-prosecution agreement with Jeffrey Epstein that barred his The victims are contemporaneously filing a motion to have their facts accepted by the Court. EFTA00177009 Case 9:08-cv-80736-KAM

ein agreed to a "confidentiality" provision in the agreement barring its disclosure to anyone — including the victims. For the next nine months, as Epstein was well aware, the U.S. Attorney's Office assiduously concealed from the victims the existence of this signed non-prosecution agreement. Indeed, th

t's desire that federal charges be filed against defendant Epstein. In particular, he wrote on behalf of his clients

formally signed a non-prosecution agreement with Jeffrey Epstein that barred his The victims are contempo

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

cution agreement is the responsibility of the prosecutor alone while a plea agreement is subject to the approval of the court."), and United States. Minnesota Mining & Mfg. Co., 551 F.2d 1106, 1112 (8i° Cir. 1977)("This was not a traditional plea bargain arrangement in which the trial judge was a participant. Rather, it wa

Jeffrey Epstein had been charged by the State of Florida with solicitation of prostitution, a violation of Fla. Stat. § 796.07. State of Florida v. Jeffrey Epstein, Case No. 2006-CF-009495AXXXMB (Palm Beach Cty, Fla.). In the summer of 2007, Epstein's attorneys approached the U.S. Attorney's Office, seeking a

were gathered as part of the Grand Jury investigation. As the investigation progressed, Jane Doe 2's identity became known as a possible victim of Epstein. Jane Doe 2 was openly hostile to the idea of a criminal prosecution of Epstein. Through her attorney, James Eisenberg, Esq., Jane Doe 2 declined to

initiate an investigation into allegations that Jeffrey Epstein, and his personal assistants, had induced

retion should he authorize federal prosecution of Mr. Epstein." Epstein's attorneys then sought additional rev

a agreement is subject to the approval of the court." United States v. Dorsett 2009 WL 2386070 at *4 (D.Neb. Jul, 23, 2009), citin United States v. Minnesota Mining & Mfg. Co. 551 F.2d 1106, 1112 (8th Cir. 1977). Since the negotiation of an NPA is a pure exercise of prosecutorial discretion, not 3 EFTA00211275 requiring

sponse to Government's Cross-Motion for Summary Judgment, and states: I. JANE DOE 2 CLEARLY EXPRESSED HER DESIRE NOT TO BE TREATED AS A VICTIM OF EPSTEIN During the Government's investigation into Jeffrey Epstein in 2006, Jane Doe 2 expressed her clear and unequivocal desire not to be treated as a vi

as a victim of his conduct. 22. The Plaintiff is included in the list of victims identified by the Federal Government as victims of the Defendant, Jeffrey Epstein's illegal conduct. Defendant, Jeffrey Epstein, is thus estopped by his plea and agreement with the Federal Government from denying the acts alleged

did not want underage girls providing him massages. D.E. 403-3 at 9. She lamented that Epstein was the subject of a criminal investigation: I hope Jeffrey, nothing happens to Jeffrey because he's an awesome man and it would really be a shame. It's a shame that he has to go through this because he's an

e sole issue before the Circuit Court was whether defendant Epstein was entering pleas of guilty that were voluntary

greement is subject to the approval of the court." United States v. Dorsett, 2009 WL 2386070 at *4 (D. Neb. Jul. 23, 2009), citing United States v. Minnesota Mining & Mfg. Co., 551 F.2d 1106, 1112 (8th Cir. 1977). Congress's inclusion of two events, which both address formal criminal charges that have already been filed in

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

greement is subject to the approval of the court." United States v. Dorsett, 2009 WL 2386070 at *4 (D. Neb. Jul. 23, 2009), citing United States v. Minnesota Mining & Mfg. Co. 551 F.2d 1106, 1112 (8th Cir. 1977). Congress's inclusion of two events, which both address formal criminal charges that have already been filed in

sponse to Government's Cross-Motion for Summary Judgment, and states: I. JANE DOE 2 CLEARLY EXPRESSED HER DESIRE NOT TO BE TREATED AS A VICTIM OF EPSTEIN During the Government's investigation into Jeffrey Epstein in 2006, Jane Doe 2 expressed her clear and unequivocal desire not to be treated as a vi

as a victim of his conduct. 22. The Plaintiff is included in the list of victims identified by the Federal Government as victims of the Defendant, Jeffrey Epstein's illegal conduct. Defendant, Jeffrey Epstein, is thus estopped by his plea and agreement with the Federal Government from denying the acts alleged

did not want underage girls providing him massages. D.E. 403-3 at 9. She lamented that Epstein was the subject of a criminal investigation: I hope Jeffrey, nothing happens to Jeffrey because he's an awesome man and it would really be a shame. It's a shame that he has to go through this because he's an

e sole issue before the Circuit Court was whether defendant Epstein was entering pleas of guilty that were voluntary

greement is subject to the approval of the court." United States v. Dorsett, 2009 WL 2386070 at *4 (D. Neb. Jul. 23, 2009), citing United States v. Minnesota Mining & Mfg. Co., 551 F.2d 1106, 1112 (8th Cir. 1977). Congress's inclusion of two events, which both address formal criminal charges that have already been filed in

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

greement is subject to the approval of the court." United States v. Dorsett, 2009 WL 2386070 at *4 (D. Neb. Jul. 23, 2009), citing United States v. Minnesota Mining & Mfg. Co. 551 F.2d 1106, 1112 (8th Cir. 1977). Congress's inclusion of two events, which both address formal criminal charges that have already been filed in

l relevant times, the Office had approximately 20 Assistant U.S. Attorneys assigned to the West Palm Beach location. The prosecutor assigned to the Epstein case, I I end I were assigned to different sections within the Office. We reported to different supervisors. 11. I did not participate in any way

ent 79 Entered on FLSD Docket 05/03/2011 Page 2 of 4 violated Florida Bar rules and Department of Justice regulations by representing employees of Jeffrey Epstein ("Epstein") in civil litigation after the undersigned retired from the United States Attorney's Office for the Southern District of Florida (the "Of

Justice regulations by representing employees of Jeffrey Epstein ("Epstein") in civil litigation after the

s retained to represent several other members of Mr. Epstein's staff in their civil depositions. I5.. After

ution agreement is the responsibility of the prosecutor alone while a plea agreement is subject to the approval of the court"), and United States v. Minnesota Mining & Mfg. Co., 551 F.2d 1106, 1112 (13th Cir. 1977rThis was not a traditional plea bargain arrangement in which the trial judge was a participant. Rather, it was

l relevant times, the Office had approximately 20 Assistant U.S. Attorneys assigned to the West Palm Beach location. The prosecutor assigned to the Epstein case, Ann Marie Villafana, end I were assigned to different sections within the Office. We reported to different supervisors. 11. I did not partic

ent 79 Entered on FLSD Docket 05/03/2011 Page 2 of 4 violated Florida Bar rules and Department of Justice regulations by representing employees of Jeffrey Epstein ("Epstein") in civil litigation after the undersigned retired from the United States Attorney's Office for the Southern District of Florida (the "Of

Justice regulations by representing employees of Jeffrey Epstein ("Epstein") in civil litigation after the

s retained to represent several other members of Mr. Epstein's staff in their civil depositions. I5.. After

cution agreement is the responsibility of the prosecutor alone while a plea agreement is subject to the approval of the court"), and United States'. Minnesota Mining & Mfg. Co., 551 F.2d 1106, 1112 (13th Cir. 1977rThis was not a traditional plea bargain arrangement in which the trial judge was a participant. Rather, it was

eference to the position taken by employees of the Department of Justice (DOJ) in letters to the petitioners, or the defense attorneys representing Jeffrey Epstein. Nor are the subjective beliefs of DOJ employees relevant to the issue of whether a duty existed under § 3771(a)(5) to consult with petitioners prio

later, on July 9, 2008, the Government filed its Response and an accompanying Declaration, establishing that (1) no federal criminal case charging Epstein had ever been filed and that a non- prosecution agreement ("NPA") had been signed and (2) despite this, the U.S. Attorney's Office had used its best

titioners, or the defense attorneys representing Jeffrey Epstein. Nor are the subjective beliefs of DOJ em

ution agreement is the responsibility of the prosecutor alone while a plea agreement is subject to the approval of the court"), and United States v. Minnesota Mining & Mfg. Co., 551 F.2d 1106, 1112 (8ih Cir. 1977)("This was not a traditional plea bargain arrangement in which the trial judge was a participant. Rather, it wa

eference to the position taken by employees of the Department of Justice (DOJ) in letters to the petitioners, or the defense attorneys representing Jeffrey Epstein. Nor are the subjective beliefs of DOJ employees relevant to the issue of whether a duty existed under § 3771(a)(5) to consult with petitioners prio

later, on July 9, 2008, the Government filed its Response and an accompanying Declaration, establishing that (1) no federal criminal case charging Epstein had ever been filed and that a non- prosecution agreement ("NPA") had been signed and (2) despite this, the U.S. Attorney's Office had used its best

titioners, or the defense attorneys representing Jeffrey Epstein. Nor are the subjective beliefs of DOJ em

tion agreement is the responsibility of the prosecutor alone while a plea agreement is subject to the approval of the court."), and United States v. Minnesota Mining & Mfg. Co., 551 F.2d 1106, 1112 (8ih Cir. 1977)("This was not a traditional plea bargain arrangement in which the trial judge was a participant. Rather, it wa