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I don't think we are very far apart on this language. I had also suggested some language, to be included in the agreement on finality, provided that Jeffrey abided by all the terms of the agreement. Please let me know your thoughts on these. I will continue to review the document and speak with you tomor
JEFFREY EPSTEIN RAL EEC° ESQ. OUNSEL TO JEFFR Y EPSTEIN EFTA00184724 Case 9:08-cv-80736-KAM Document 3
f his clients is the purported victim. Accordingly. I will address facts related to C.W., T.M.. and S R. All three of those clients were victims of Jeffrey Epstein's while they were minors beginning when they were fifteen years old. Incase note that the dates on the U.S. Attorney's Office letters to C.W. and T.M
of course, is a defense attorney who represented defendant Epstein. Recording information provided by a defense att
EDWARDS: Your Honor, as a factual 2 background, Mr. Epstein is a billionaire that 3 sexually abused and mol
States Attorney's Office will be instituted in this District, and the charges against Epstein if any, will be dismissed. Terms of the Agreement: I. Epstein shall plead guilty (not nob contendere) to an Information filed by the State Attorney's Office charging Epstein with an offense that requires him t
ge 3 of 5 US_Atty_Cor_0085 EFTA00184713 Case 9:08-cv-80736-KAM Document 361-61 Entered on FLSD Docket 02/10/2016 Page 7 of 8 In consideration of Epsteln's agreement to plead guilty and to provide compensation to victims, if Epstein successfully fiilfills all of the terms and conditions of this agreem
with regard to Suppl. Box #3 P-013940 to P-013942. The description there reads: "Draft Letter marked `Confidential: To Be Opened by Addressee Only,' Robin C. Ashton to Wifredo A. = with handwritten corrections." No date is provided regarding this letter. Nor is there any indication as to whether the letter was
of course, is a defense attorney who represented defendant Epstein. Recording information provided by a defense att
lian Ave S. West Palm Beach, FL 33401-5015 Re: Jeffrey Epstein Dear Mr. Goldberger: In accordance with
riminal prosecution commensurate with the crimes Mr. Epstein has committed, and we further urge you to take th
vernment's CVRA violation in this case. See, e.g., DE 48 at 13. 31. RFP No. 4 requests documents relating to negotiations between the Government and Jeffrey Epstein concerning the court and/or location in which Jeffrey Epstein would enter any guilty plea (including in particular any negotiations concerning concl
d under Section 2255 as she would have had, if Mr..Epstein had been tried federally and convicted of an enu
provide notice to the victims. It is also needed to demonstrate why the victims at first received inaccurate information about the NPA, as well as Jeffrey Epstein's involvement in that inaccurate notice. See, e.g., DE 48 at 15-16. 43. RFP No. 16 requests documents regarding Bruce Reinhart, a senior prosecutor w
h regard to Suppl. Box #3 P-013940 to P-013942. The description there reads: "Draft Leteri_ marked `Confidential: To Be Opened by Addressee Only,' Robin C. Ashton to Wifredo A. =, with handwritten corrections." No date is provided regarding this letter. Nor is there any indication as to whether the letter wa
provide notice to the victims. It is also needed to demonstrate why the victims at first received inaccurate information about the NPA, as well as Jeffrey Epstein's involvement in that inaccurate notice. See, e.g., DE 48 at 15-16. 43. RFP No. 16 requests documents regarding Bruce Reinhart, a senior prosecutor w
not necessary" (DE 17 at 1). The Office asserted that the Court need only take judicial notice of the fact that no indictment had been filed against Epstein to resolve the case. 6. On August 1, 2008, the victims filed a response to the Government's "Notice," giving a proposed statement of facts surroun
Epstein," _ ' "Morrison," "Visoki," "Rogers," "Hammond," Roxburgh," "Villafana, " "Florida Science Foundation," "Starr," "Black," "Goldberger," "Jeffrey," "Australian," "Lewis," "Sanchez," "358 El Brillo Way" appears and which are connected to or related to Jeffrey Epstein, Jack Goldberger, or the J
of course, is a defense attorney who represented defendant Epstein. Recording information provided by a defense att
riminal prosecution commensurate with the crimes Mr. Epstein has committed, and we further urge you to take th
ith regard to Suppl. Box #3 P-013940 to P-013942. The description there reads: "Draft Letter, marked `Confidential: To Be Opened by Addressee Only,' Robin C. Ashton to Wifredo A. Ferrer, with handwritten corrections." No date is provided regarding this letter. Nor is there any indication as to whether the lette
provide notice to the victims. It is also needed to demonstrate why the victims at first received inaccurate information about the NPA, as well as Jeffrey Epstein's involvement in that inaccurate notice. See, e.g., DE 48 at 15-16. 43. RFP No. 16 requests documents regarding a senior prosecutor who was present
not necessary" (DE 17 at 1). The Office asserted that the Court need only take judicial notice of the fact that no indictment had been filed against Epstein to resolve the case. 6. On August 1, 2008, the victims filed a response to the Government's "Notice," giving a proposed statement of facts surroun
stein," "Kllen "Ruboyo," "Morrison," "Visoki," "Rogers," "Hammond," Roxburgh," S, " "Florida Science Foundation," "Starr," "Black," "Goldberger," "Jeffrey," "Australian," "Lewis," "Sanchez," "358 El Brillo Way" appears and which are connected to or related to Jeffrey Epstein, Jack Goldberger, or the J
of course, is a defense attorney who represented defendant Epstein. Recording information provided by a defense att
riminal prosecution commensurate with the crimes Mr. Epstein has committed, and we further urge you to take th
with regard to Suppl. Box #3 P-013940 to P-013942. The description there reads: "Draft Letter marked 'Confidential: To Be Opened by Addressee Only,' Robin C. Ashton to with handwritten corrections." No date is provided regarding this letter. Nor is there any indication as to whether the letter was or was not ci
nt to the victims in this case is clear. In 2007, the FBI determined that both Jane Doe No. I and Jane Doe No. 2 were victims of sexual assaults by Epstein while they were minors beginning when they were approximately fourteen years of age and approximately thirteen years of age respectively. These sexu
of Epstein's sex offenses in Federal Court — Jane Doe No. 1, Jane Doe No. 2, and a victim I will refer to as "S.R." and "M.J.", and other victims of Jeffrey Epstein's abuse as well. If further information is disclosed about this case, that will not discourage them from providing information, but rather will encou
he word "Epstein," " "Morrison," "Visoki," "Rogers," "Hammond," Roxburgh,' r afana, " "Florida SS Foundation," "Starr," "Black," "Goldberger," "Jeffrey," "Australian,"' "Sanchez," "358 El Brillo Way" appears and which are connected to or related to Jeffrey Epstein, Jack Goldberger, or the Jeffrey
t's desire that federal charges be filed against defendant Epstein. In particular, I wrote on behalf of my clients:
riminal prosecution commensurate with the crimes Mr. Epstein has committed, and we further urge you to take th
ith regard to Suppl. Box #3 P-013940 to P-013942. The description there reads: "Draft Letter, marked 'Confidential: To Be Opened by Addressee Only,' Robin C. Ashton to Wifredo A. Ferrer, with handwritten corrections." No date is provided regarding this letter. Nor is there any indication as to whether the lette
to Intervene on a Limited Basis filed by United States of America. Replies due by 2/2/2015. ( ) (Entered: 01/22/2015) 295 MOTION Limited Intervenor Jeffrey Epstein's Response to Order Requesting Justification for Supplemental Protective Order re 286 Order by Jeffrey Epstein. (Black, Roy) Modified to re- docket, s
iled by Jane Doe. (Edwards, Bradley) (Entered: 10/28/2013) MOTION to Expedite Jane Doe #1 and Jane Doe #2 Unopposed Motion for Expedited Ruling on Epstein's Unopposed Motion for Intervention in Advance of Eleventh Circuit Argument by Jane Doe. (Attachments: # 1 Text of Proposed Order)(Edwards, Bradley)
t Palm Beach, Fl 33401 561-202-6360 Intervenor Jeffrey Epstein Intervenor Alan M. Dershowitz Interven
nt conference 385 386 388 , the Court finds that Mr. Epstein's interest in this case is adequately preserved b
13) NOTICE by United States of America of Filing Declaration of OPR Counsel Ro in . A h on (Attachments: # 1 Exhibit B - Declaration of OPR Counsel Robin C. Ashton) ) (Entered: 10/18/2013) REPLY to Response to Motion re 226 Renewed MOTION for Order Directing the U.S. Attorney's Office Not to Withhold Relevan
nt's failure to identify any documents among the 13,468 pages that it is withholding that concern AUSA Bruce Reinhart's internal knowledge about the Epstein prosecution before he left the U.S. Attorney's Office and became employed by Epstein. DE 226 at 8-9. The victims pointed out that the Government ha
New York Telephone Email: Martin G. Weinberg, P.C. 20 Park Plaza, Suite 1000 Boston, MA 02116 Telephone: Email: Criminal Defense Counsel for Jeffrey Epstein /s/ Bradley J. Edwards 9 EFTA00616108
Telephone: Email: Criminal Defense Counsel for Jeffrey Epstein /s/ Bradley J. Edwards 9 EFTA00616108
tantive information that was "collected" during the OPR investigation. Where in the log is the information that was collected? The declaration from Robin C. Ashton, Counsel of OPR, only deepens the mysteries swirling around the Government's privilege log. For example, Ashton asserts "deliberative process" priv
t the victims' pleadings are facially deficient, the Court must assume the truth of the victims' allegations — specifically that the Government and Epstein deliberately conspired to enter into a secret non- prosecution agreement in violation of the victims' rights under the Crime Victims' Rights Act (CV
ld have been addressed in the course of litigation, unless a court has made a specific finding of misconduct by a DOJ attorney . . . ." Letter from Robin C. Ashton to Professor Paul G. Cassell, May 6, 2001, attached as Exhibit 1 to Victim's Mot. File Supp. Auth. DE #82. Accordingly, an order by this Court makin
t the victims' pleadings are facially deficient, the Court must assume the truth of the victims' allegations — specifically that the Government and Epstein deliberately conspired to enter into a secret non- prosecution agreement in violation of the victims' rights under the Crime Victims' Rights Act (CV
ld have been addressed in the course of litigation, unless a court has made a specific finding of misconduct by a DOJ attorney . . . ." Letter from Robin C. Ashton to Professor Paul G. Cassell, May 6, 2001, attached as Exhibit 1 to Victim's Mot. File Supp. Auth. DE #82. Accordingly, an order by this Court makin
Entities connected to both Jeffrey Epstein and Robin C. Ashton

Marc Rich
PERSONLarry Visoski
PERSONLeon Black
PERSON
Prince Andrew
PERSON
Ghislaine Maxwell
PERSON
Woody Allen
PERSON
Alan Dershowitz
PERSON
Bradley Edwards
PERSON
United States
LOCATIONJack Goldberger
PERSONJane Doe
PERSON
Michael Cohen
PERSON
Department of Justice
ORGANIZATIONMaria Farmer
PERSONMartin Weinberg
PERSON
Kenneth Marra
PERSON
Julie K. Brown
PERSON
Bill Clinton
PERSON
Alexander Acosta
PERSONthe Southern District
LOCATION