Epstein Secrets

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 M, a senior prosecutor who was pre

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

ic record that while still a prosecutor at the Office Mr. established his criminal defense office at the exact address (and exact Suite number) as Jeffrey 's personal business address. However, I did not have any direct ■ of contradicting sworn statement. Since then, however, in answering the victims'

the word "Epstein," ' " "Morrison," "Visoki," "Rogers," "Hammond," Roxburgh," " "Florida Science Foundation," "Starr... " "Black" "Goldberger," "Jeffrey," "Australian," "Lewis," "Sanchez," appears and which are connected to or related to Jeffrey Epstein, Jack Goldberger, or the Jeffrey Epstein inves

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

tification letter. The notification promises that the Justice Department would make its "best efforts" to protect Jane Doe No. 1's rights, including Ville reasonable right to confer with the attorney for the United States in the case" and "to be reasonably heard at any public proceeding in the distric

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

tification letter. The notification promises that the Justice Department would make its "best efforts" to protect Jane Doe No. 1's rights, including Ville reasonable right to confer with the attorney for the United States in the case" and "to be reasonably heard at any public proceeding in the distric

e, in violation of 18 U.S.C. §§ 2423 and 2. Counts Five and Six charge the defendant with perjury, in violation of 18 U.S.C. § 1623. 1 ARGUMENT I. Jeffrey Epstein's Non-Prosecution Agreement Is Irrelevant to This Case The defendant seeks to dismiss the Indictment based on a 2007 non-prosecution agreement ("NPA"

in illegal sex acts, and aiding and abetting the same, in violation 18 U.S.C. §§ 2422 and 2. Count Three charges the defendant with conspiring with Epstein and others to transport minors to participate in illegal sex acts, in violation of 18 U.S.C. § 371. Count Four charges the defendant with transporti

NARY STATEMENT 1 BACKGROUND 2 ARGUMENT 3 I. Jeffrey Epstein's Non-Prosecution Agreement Is Irrelevant

f America Assistant United States Attorneys - Of Counsel - EFTA00099941 TABLE OF CONTENTS PRELIMINARY STATEMENT 1 BACKGROUND 2 ARGUMENT 3 I. Jeffrey Epstein's Non-Prosecution Agreement Is Irrelevant to This Case. 3 A. The NPA Does Not Bind the Southern District of New Yolk 4 1. The Text of the Agreement

med in the proposed agreement, because the USAO was not interested in prosecuting those individuals if Epstein entered a plea. Villafana told OPR, [Ville considered Epstein to be the top of the food chain, and we wouldn't have been interested in prosecuting anyone else.' She did not consider the possi

To: Subject: Re: LASTMINUTE - Confirmation de réservation No: V529536 Date: Mon, 03 Mar 2014 19:49:53 +0000 Ok sounds good. Are you forwarding to JE? I can organize Jojo and Citicar as well as apartment once I know this is the trip Jeffrey wants her to take... On Mar 3, 2014, at 2:46 PM, wrote:

Mar 2014 19:49:53 +0000 Ok sounds good. Are you forwarding to JE? I can organize Jojo and Citicar as well as apartment once I know this is the trip Jeffrey wants her to take... On Mar 3, 2014, at 2:46 PM, wrote: made the reservation. I can cancel it if necessary! ----- Forwarded message ------- From

vous serez tenu de communiquer a la compagnie aeiienne votre lieu de residence aux USA en precisant les elements suivants : Numero et nom de la rue, Ville, Etat et Code postal. Lembarquement pourra etre refuse a tout passager qui ne pourra fournir ces informations. Dans le cadre de fachat de billets d

. On Mar 3, 2014, at 2:52 PM, > wrote: He said ok Sent from my iPhone On Mar 3, 2014, at 2:49 PM, wrote: Ok sounds good. Are you forwarding to JE? I can organize Jojo and Citicar as well as apartment once I know this is the trip Jeffrey wants her to take... On Mar 3, 2014, at 2:46 PM, > wrot

14, at 2:49 PM, wrote: Ok sounds good. Are you forwarding to JE? I can organize Jojo and Citicar as well as apartment once I know this is the trip Jeffrey wants her to take... On Mar 3, 2014, at 2:46 PM, > wrote: made the reservation. I can cancel it if necessary! ----- Forwarded message From: <las

vous serez tenu de communiquer a la compagnie aerienne votre lieu de residence aux USA en precisant les elements suivants : Numero et nom de la rue, Ville, Etat et Code postal. Cembarquement pourra etre refuse a tout passager qui ne pourra fournir ces informations. Dans le cadre de rachat de billets d

e flight details and the price. Waiting to hear back Sent from my iPhone On Mar 3, 2014, at 2:49 PM, wrote: Ok sounds good. Are you forwarding to JE? 1 can organize Jojo and Citicar as well as apartment once 1 know this is the trip Jeffrey wants her to take... On Mar 3, 2014, at 2:46 PM, made t

14, at 2:49 PM, wrote: Ok sounds good. Are you forwarding to JE? 1 can organize Jojo and Citicar as well as apartment once 1 know this is the trip Jeffrey wants her to take... On Mar 3, 2014, at 2:46 PM, made the reservation. I can cancel it if necessary! Forwarded message From: <lastminute com-vo

vous serez tenu de communiquer a la compagnie aerienne votre lieu de residence aux USA en precisant les elements suivants : Numero et nom de la rue, Ville, Etat et Code postal. Lembarquement pourra etre refuse a tout passager qui ne pourra fournir ces informations. Dans le cadre de l'achat de billets

6 Date: Mon, 03 Mar 2014 19:52:39 +0000 He said ok Sent from my iPhone On Mar 3, 2014, at 2:49 PM, wrote: Ok sounds good. Are you forwarding to JE? I can organize Jojo and Citicar as well as apartment once I know this is the trip Jeffrey wants her to take... On Mar 3, 2014, at 2:46 PM, made t

14, at 2:49 PM, wrote: Ok sounds good. Are you forwarding to JE? I can organize Jojo and Citicar as well as apartment once I know this is the trip Jeffrey wants her to take... On Mar 3, 2014, at 2:46 PM, made the reservation. I can cancel it if necessary! Forwarded message From: -cletininute corn-

vous serez tenu de communiquer a la compagnie aerienne votre lieu de residence aux USA en precisant les elements suivants : Numero et nom de la rue, Ville, Etat et Code postal. Lembarquement pourra etre refuse a tout passager qui ne pourra fournir ces informations. Dans le cadre de l'achat de billets