Epstein Secrets

33401 Dear Alex: Facaimaa: mint kirklancl.cOM Dlr. Fax: ConfidentlaL For Settlement Purposes Only, Pursuant to Rule 408. October 10, 2007 Re: Jeffrey Epstein I write as' follow up to our conversation yesterday regarding the open issues that remain Si stein matter. As you are aware, we continue to have se

he conduct at issue, in an effort to avoid long drawn out disputes over liability in public adversarial litigations. Initially, we proposed that Mr. Epstein create' trust whereby' trustee would be appointed by the Circuit Court to disperse the funds to the identified individuals based on' good faith sho

ance and statements or a member of your Office or the pB12 2 We arc concerned with the fact that some of the victims were previously notified, as Mr. Jeffrey slates in his letter of December 6 letter. In your letter of December 4. you state that you would not issue the Victim Notification lamer until De

h as we pprcciate your willingness to revisit the § 2255 issues, we cannot accept your language as proposed, because we believe that the conduct of Mr_ Epstein with respect to these alleged i ictinis fails to satisfy the requisite elements of any of the enumerated offenses, including 18 U.S.C. § 2422(b) or

nited Stales shall provide F.pstein's attorney's with a list of individuals whom it has identified as victims, as defined in IS U.S.C. f 2255. alter Epsicin has signed this agreement and has been sentenced. Upon the execution of this agreement. the United States. in consultation with und subject to the

fendant is gljugggI in the case in which' victim seeks to assert her statutory rights.") (emphasis added) Since there has been no offense charged in Federal district court in this matter, the identified individuals necessarily do not qualify as "crime victims". In addition, the Attorney General Guidelines furthe

ctims" and given our understanding that Ms. as well was one of those who is also on the list of persons the Utivernment contends were Mc MIN of Mr. Epstein's alleged violation of federal law, we have a principled concern about adopting your recommended language which would leave Mr. Epstein without a b

ND AITILIATLD PAVINIItSHIPS Citigroup Canter 153 Elam 53rd SWIM New York, Now 'font 10022.4811 ass.saoo www.hlrilsnd.00m December 26, 2007 Re: Jefflay Epstein For the purpose of enforcing the rights enumerated in article 1.13, a victim is 'a person directly and proximately harmed as a result of the commis

istration of criminal justice with profound consequences beyond the resolution in the matter at hand. • in a precedent-shattering investigation of Jeffrey Epstrein that raises important policy questions—and serious issues as to the fair and honorable enforcement of federal law—the USA.° in Miami is considering

ion that no telephonic or Internet persuasion, inducement, enticement or coercion of a minor, or of any other individual, occurred. In addition, Mr. Jeffrey Harmful. the former law partner of one of the federal prosecutors involved in this matter and die attorney for most of the civil complainants (as d

f persons the Utivernment contends were Mc MIN of Mr. Epstein's alleged violation of federal law, we have a pr

fendant is charged in the case in which a victim seeks to assert her statutory rights.") (emphasis added) Since there has been no offense charged in Federal district court in this matter, the identified individuals necessarily do not qualify as "crime victims". In addition, the Attorney General Guidelines furthe

PS Cinema Cantor 163 Ent SSW Street New York, New York 10022-1411 Facsimile: (M 446.4800 le 446-4000 vnicklitlend.com December 26, 2007 Re: Jeffrey Epstein I write to address the questions you posed to me during a conversation we had late last week. Specifically, you requested a clarification of our po

now, we believe we have shown that at least some (if not all) of the identified individuals did not suffer any injury at all in connection with Mr. Epstein's alleged conduct.' in addition, under the Attorney General Guidelines, notification must be balanced against a w action that may impinge on Mr. Ep

46-4000 vnicklitlend.com December 26, 2007 Re: Jeffrey Epstein I write to address the questions you pos

balanced against a w action that may impinge on Mr. Epstein's due process rights. The Attorney General Guide

fendant is charted in the case in which a victim seeks to assert her statutory rights.") (emphasis added) Since there has been no offense charged in Federal district court in this matter, the identified individuals necessarily do not qualify as "crime victims". In addition, the Attorney General Guidelines furthe

ITIONERS ARE EQUITABLY ESTOPPED FROM CHALLENGING THE NPA On September 10, 2008, Jane Doe No. 1 filed an action in Palm Beach County, Florida, E.W. I. Jeffrey Epstein, Case No. 50-2008-CA-028058-XXXXMB, seeking money damages from Jeffrey Epstein for sexually abusing her. Ex. P. On September 11, 2008, Jane Doe No.

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 Id. at 57

agreement entered into by the United States and Mr. Epstein in a timely fashion." Ex. N, Nov. 27, 2007 email

armed as a result of the commission of a Federal 20 EFTA00211737 offense or an offense in the District of Columbia, "if the offense is charged in Federal district court." Thus, if there was no offense charged in Federal district court, then a person could not be a crime victim for purposes of enforcing the ri

132 Dear Alex: AND Anmann rosTmiunos Coagroup Cellar 159 East WO 94teot Now York, Slow Van 10022.4611 www.kirkioncl.00m December 26, 2007 Re: Jeffrey Epstein I write to address the questions you posed to me during a conversation we had late last week. Specifically, you requested a clarification of our po

's alleged conduct.' in addition, under the Attorney General Guidelines, notification roust be balanced against a iy action that may impinge on Mr. Epstein's due process rights. The Attorney Crinieral Guidelines clearly call into question the wisdom and practicality of giving notice" to a "possible u i

2.4611 www.kirkioncl.00m December 26, 2007 Re: Jeffrey Epstein I write to address the questions you pos

balanced against a iy action that may impinge on Mr. Epstein's due process rights. The Attorney Crinieral Gui

endant is gliargz1 in the case in which a victim seeks to assert her statutory rights.") (emphasis added) Since there has been no offense charged in Federal district court in this matter, the identified individuals necessarily do not qualify as "crime victims". In addition, the Attorney General Guidelines furthe

33132 Dear Alex: AND AntiAnn rioninains Cola/cup Cara/ 159 East San Snot New York, Now Van 10022.4611 www.kirkiond.00m December 26, 2007 Re: Jeffrey Epstein I write to address the questions you posed to me during a conversation we had late last week. Specifically, you requested a clarification of our po

's alleged conduct.' in addition, under the Attorney General Guidelines, notification roust be balanced against a iy action that may impinge on Mr. Epstein's due process rights. The Attorney Crinieral Guidelines clearly call into question the wisdom and practicality of giving notice" to a "possible u i

22.4611 www.kirkiond.00m December 26, 2007 Re: Jeffrey Epstein I write to address the questions you pos

balanced against a iy action that may impinge on Mr. Epstein's due process rights. The Attorney Crinieral Gui

endant is gliargz1 in the case in which a victim seeks to assert her statutory rights.") (emphasis added) Since there has been no offense charged in Federal district court in this matter, the identified individuals necessarily do not qualify as "crime victims". In addition, the Attorney General Guidelines furthe

132 Dear Alex: AND Anmann riormiuroos Calgroup Cantor 159 East Said S0441 New York, Now Van 10022.4611 www.kirldend.00m December 26, 2007 Re: Jeffrey Epstein I write to address the questions you posed to me during a conversation we had late last week. Specifically, you requested a clarification of our po

's alleged conduct.' in addition, under the Attorney General Guidelines, notification roust be balanced against a iy action that may impinge on Mr. Epstein's due process rights. The Attorney Crinieral Guidelines clearly call into question the wisdom and practicality of giving notice" to a "possible u i

22.4611 www.kirldend.00m December 26, 2007 Re: Jeffrey Epstein I write to address the questions you pos

balanced against a iy action that may impinge on Mr. Epstein's due process rights. The Attorney Crinieral Gui

fendant is charged in the case in which a victim seeks to assert her statutory rights.") (emphasis added) Since there has been no offense charged in Federal district court in this mater, the identified individuals necessarily do not qualify as "crime victims". In addition, the Attorney General Guidelines further

le R. Alexander Acosta United States Attorney United States Attorney's Office Southern District of Florida 99 NE 4th Street Miami, FL 33132 Re: Jeffrey Epstein Dear Alex: Facsimile: I write to address the questions you posed to me during a conversation we had late last week. Specifically, you requested a

now, we believe we have shown that at least some (if not all) of the identified individuals did not suffer any injury at all in connection with Mr. Epstein's alleged conduct.' In addition, under the Attorney General Guidelines, notification must be balanced against any action that may impinge on Mr. Ep

f Florida 99 NE 4th Street Miami, FL 33132 Re: Jeffrey Epstein Dear Alex: Facsimile: I write to addre

balanced against any action that may impinge on Mr. Epstein's due process rights. The Attorney General Guide

fendant is charged in the case in which a victim seeks to assert her statutory rights.") (emphasis added) Since there has been no offense charged in Federal district court in this matter, the identified individuals necessarily do not qualify as "crime victims". In addition, the Attorney General Guidelines furthe

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

y and proximately harmed as a result of the commission of a Federal offense or an offense in the District of Columbia, "if the offense is charged in Federal district court." Thus, if there was no offense charged in Federal district court, then a person could not be a crime victim for purposes of enforcing the ri

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

y and proximately harmed as a result of the commission of a Federal offense or an offense in the District of Columbia, "if the offense is charged in Federal district court." Thus, if there was no offense charged in Federal district court, then a person could not be a crime victim for purposes of enforcing the ri