Epstein Secrets

privacy. 5. This is strictly a "fishing expedition" unrelated to any aspect of this case. A similar Request to Produce was served in the casel v. Jeffrey E. Epstein and , Case No. 502008CA025129XXXXMB Al, in front of Judge Garrison. A copy of the objection to the Notice is attached as Exhibit "B" and Judge Garr

BOARD CERTIFIED CVO-TRIAL LAWYER Sent by Fax and U.S. Mail Isidro M. Garcia, Esq. A LIMITED LIABILITY PARTNERSHIP April 13, 2009 Re: Doe II v. Epstein, et al. Case No. 09-80469-Civ-MARRA/JOHNSON ADELQUI.LBENAVENTE rmukumALINVBSTIOMOR BARBARA M. NkKENNA ASHLIE STOKEN-BARING BETTY STOKES PARALE

kKENNA ASHLIE STOKEN-BARING BETTY STOKES PARALEGALS RITA H. BUDNYK OP COUNSEL Dear Sid: Please be informed thal subpoenaed deposition in thel.L. Epstein case on April 16th, 2009 is hereby cancelled. Cordially Robert D. Critton, Jr. RDC/clz cc: Jack A. Goldberger, Esq. L•A•W•Y•E •R•S TELEPHONE

py of the case law and Florida Statutes cited in Defendant Epstein' otion to Dismiss, For More Definite Statement, a

ar Request to Produce was served in the casel v. Jeffrey E. Epstein and , Case No. 502008CA025129XXXXMB Al,

ar Request to Produce was served in the casel v. Jeffrey E. Epstein and , Case No. 502008CA025129XXXXMB Al,

OW CAB Defendant, Jeffrey Epstein, (hereinafter "Mr. Epstein"), by and through his undersigned attorneys, pur

988) 7. Bond v. Koscot Interplanetary, Inc., 246 So.2d 631 (Fla. 4th DCA 1971 8. Churruca v. Miami Jai-Alai, Inc. 353 So.2d 547 (Fla. 1977). 9. Snipes v. West Flaciler Kennel Club, 105 So.2d 164 (Fla. 1958) EFTA00722695 v. Epstein Page 2 10. Buchanan v. Miami Herald Publishing Co., 230 So.2d 9

o privacy. 5. This is strictly a "fishing expedition" unrelated to any aspect of this case. A similar Request to Produce was served in the caa v. Jeffrey E. Epstein and Case No. 502008CA025129XXXXMB Al, in front of Judge Garrison. A copy of the objection to the Notice is attached as Exhibit "B" and Judge Garris

RIAL LAWYER Sent by Fax and U.S. Mail Isidro M. Garcia, Esq. Garcia Law firm P.A. A LIMITED LIABILITY PARTNERSHIP April 13, 2009 Re: Doe II v. Epstein, et al. Case No. 09-80469-Civ-MARRA/JOHNSON ADELQUI.LBENAVENTE rmemeom. I INVBSTIOMOR BARBARA M. NkKENNA ASHLER STOKEN-BARING BETTY STOKES PAR

OW CAB Defendant, Jeffrey Epstein, (hereinafter "Mr. Epstein"), by and through his undersigned attorneys, pur

ilar Request to Produce was served in the caa v. Jeffrey E. Epstein and Case No. 502008CA025129XXXXMB Al, i

py of the case law and Florida Statutes cited in Defendant Epstein' otion to Dismiss, For More Definite Statement, a

CASE NO. 502008CA037319XXXXMB AB Plaintiff, v. JE an Defendants. DEFENDANT'S, JEFFREY EPSTEIN, O

ilar Request to Produce was served in the caa v. Jeffrey E. Epstein and Case No. 502008CA025129XXXXMB Al, in

988) 7. Bond v. Koscot Interplanetary, Inc., 246 So.2d 631 (Fla. 4th DCA 1971 8. Churruca v. Miami Jai-Alai, Inc. 353 So.2d 547 (Fla. 1977). 9. Snipes v. West Flaciler Kennel Club, 105 So.2d 164 (Fla. 1958) EFTA00614425 • v. Epstein Page 2 10. Buchanan v. Miami Herald Publishing Co., 230 So.2

' Rights Act ("CVRA"), 18 U.S.C. § 3771, that affect all crime victims in this Circuit. After over a decade of litigation, the Majority holds that Jeffrey Epsteie's victims were not authorized to bring this petition because the CVRA does not permit stand- alone suits, and, therefore, it should have been dismisse

pstein. In her mandamus petition, Ms. Wild asserts that when federal prosecutors secretly negotiated and executed a non- prosecution agreement with Epstein in 2007, they violated her rights under the CVRA—in particular, her rights to confer with and to be treated fairly by the government's lawyers. We

ida to some extent). While he was in custody on these charges, Epstein was found dead. Statement of Attorney General William P. Barr on the Death of Jeffrey Epstein (Aug. 10, 2018), available at https://www.justice.gov/opa/pristatement-attorney-general-william-p- barr-death-jeffrey-epstein. In June 2020,

t resolves the federal investigation by allowing Mr. Epstein to plead to a state offense. The victims identifi

Delta Air Lines, 310 F.3d 1347, 1358-59 (11th Cir. 2002) (conducting C R Sandoval analysis of Air Carrier Access Act); see also, e.g., Bellitto it Snipes, 935 F.3d 1192, 1202-03 (11th Cir. 2019) (Help America Vote Act); *1256 Alabama PCI Gaming Auth., 801 F.3d 1278, 1296-97 (1 1 th Cir. 2015) (Indi

the victims explained in their motion for summary judgment (DE 361), the undisputed facts of this case show that for nine months, the Government and Epstein conspired to conceal a non-prosecution agreement (NPA) from Epstein's victims in order to prevent them from voicing any objection to the agreement.

ed Jane Doe 1 and Jane Doe 2 (and several other victims) in civil suits against Jeffrey Epstein for injuries my clients suffered as a consequence of Jeffrey Epstein's sexual abuse of them. 2. I have previously filed an affidavit in this matter (see DE 225-1). This affidavit repeats some of the information contai

Undisputed Fact 1 ("Between about 1999 and 2007, Jeffrey Epstein sexually abused more than 30 minor girls,

she, herself] procured additional young women for Mr. Epstein and [was] paid commissions or referral fees for

ct court's disposition of cross-motions for summary . . . employs the same legal standards applied when only one party files a motion." Bellitto v. Snipes, No. 16-CV-61474, 2017 WL 2972837, at *7 (S.D. Fla. July 12, 2017) (citing United States v. Oakley, 744 F.2d 1553, 1555 (11th Cir. 1984) ("Cross-mo

From: To: Jeffrey Epstein <[email protected]> Subject: Date: Sun, 23 Dec 2012 16:47:15 +0000 lane-Images: Screen_Shot_2012-12-23_at_11.45.01_AM.png; Screen_Shot_2012-12

From: To: Jeffrey Epstein <[email protected]> Subject: Date: Sun, 23

From: To: Jeffrey Epstein <[email protected]> Subject: Date:

ded Contents: 95% Conon. 5% Poynter ms: Available Bordered Or Origin: USA COMM: Yellow, Saver Sage. Lime, Ctrus, LL Blue, Cambbean, and others Snipes: Round, Runner, Oval, Cross Sown Rectangle Capel Rugs recommends rug padding and me Capel Care one of rug cleaning and tresnen.ng produce. OSECR