Epstein Secrets

and privacy."' The undisputed evidence begins in 2005, when the Palm Beach Police Department ("PBPD") had identified numerous girls as victims of Jeffrey Epstein's sexual crimes. In 2006, the PBPD turned the case over to federal authorities for further investigation. As early as March 15, 2007 and throughout t

cv-80736-KAM Document 361 Entered on FLSD Docket 02/10/2016 Page 3 of 57 prepared an 82-page prosecution memorandum and a 53-page indictment against Epstein and his co-conspirators.4 At that time, rather than confer with the victims about how to proceed, the Government began conferring about this issue

BPD") had identified numerous girls as victims of Jeffrey Epstein's sexual crimes. In 2006, the PBPD turne

e victims. The letter also falsely claimed that "Mr. Epstein never targeted minors," and urged the Government

quires that there be no disputed issues that are genuine or material for the moving party to be entitled to judgment as a matter of law. See, e.g., Joseph v. Napolitano, 839 F. Supp. 2d 1324, 1333 (S.D. Fla. 2012). The undisputed facts "3 See Exhibit 88. 174 Exhibit 26; Exhibit 27; Exhibit 62; Exhibit 63 at 4-6, 18

and privacy."' The undisputed evidence begins in 2005, when the Palm Beach Police Department ("PBPD") had identified numerous girls as victims of Jeffrey Epstein's sexual crimes. In 2006, the PBPD turned the case over to federal authorities for further investigation. As early as March 15, 2007 and throughout t

cv-80736-KAM Document 361 Entered on FLSD Docket 02/10/2016 Page 3 of 57 prepared an 82-page prosecution memorandum and a 53-page indictment against Epstein and his co-conspirators.4 At that time, rather than confer with the victims about how to proceed, the Government began conferring about this issue

BPD") had identified numerous girls as victims of Jeffrey Epstein's sexual crimes. In 2006, the PBPD turne

e victims. The letter also falsely claimed that "Mr. Epstein never targeted minors," and urged the Government

quires that there be no disputed issues that are genuine or material for the moving party to be entitled to judgment as a matter of law. See, e.g., Joseph v. Napolitano, 839 F. Supp. 2d 1324, 1333 (S.D. Fla. 2012). The undisputed facts "3 See Exhibit 88. 174 Exhibit 26; Exhibit 27; Exhibit 62; Exhibit 63 at 4-6, 18

simple one. The Government cannot contest that it concealed from the victims a non-prosecution agreement (NPA) that it reached with a sex offender, Jeffrey Epstein, who had committed federal crimes against dozens of minor victims. I EFTA00597318 Case 9:08-cv-80736-KAM Document 417 Entered on FLSD Docket 08/1

Florida, located in the Southern District of Florida, and elsewhere in the United States and overseas. Victims' S.J. Mot., DE 361 at 8, 1 1. Because Epstein and his co-conspirators knowingly traveled in interstate and international commerce to sexually abuse Jane Doe 1, Jane Doe 2, and other similarly s

ement (NPA) that it reached with a sex offender, Jeffrey Epstein, who had committed federal crimes against

er about the money issue, just about what crimes Mr. Epstein is pleading guilty to and the amount of time tha

equires that there be no disputed issues that are genuine or material for the moving party to be entitled to judgment as a matter of law. See, e.g., Joseph v. Napolitano, 839 F. Supp. 2d 1324, 1333 (E. Fla. 2012). If the evidence offered by the nonmoving party is 17 EFTA00597334 Case 9:08-cv-80736-KAM Document 41

and privacy."' The undisputed evidence begins in 2005, when the Palm Beach Police Department ("PBPD") had identified numerous girls as victims of Jeffrey Epstein's sexual crimes. In 2006, the PBPD turned the case over to federal authorities for further investigation. As early as March 15, 2007 and throughout t

cv-80736-KAM Document 361 Entered on FLSD Docket 02/10/2016 Page 3 of 57 prepared an 82-page prosecution memorandum and a 53-page indictment against Epstein and his co-conspirators:4 At that time, rather than confer with the victims about how to proceed, the Government began conferring about this issue

BPD") had identified numerous girls as victims of Jeffrey Epstein's sexual crimes. In 2006, the PBPD turne

e victims. The letter also falsely claimed that "Mr. Epstein never targeted minors," and urged the Government

quires that there be no disputed issues that are genuine or material for the moving party to be entitled to judgment as a matter of law. See, e.g., Joseph v. Napolitano, 839 F. Supp. 2d 1324, 1333 (S.D. Fla. 2012). The undisputed facts " 3 See Exhibit 88. IM Exhibit 26; Exhibit 27; Exhibit 62; Exhibit 63 at 4-6, 18