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It has utterly failed to even offer any such cause — much less show that it is good cause. Second, the Government — with the apparent contrivance of Jeffrey Epstein's attorneys — has made inaccurate representations about the nature of the non-prosecution agreement in its notices to the victims and in its filing b
well as to the Court — lies with Jeffrey Epstein's attorneys'. See Gov't Response at 5 ("the [inaccurate] victim notification letter was provided to Epstein's attorneys prior to being sent, who approved the language of which the petitioners now complain."). The apparent approval by Jeffrey Epstein's at
-2006 Amendments version of the law applies. See Defendant Epstein's Motion to Dismiss, for More Definite Statement
he terms of the non-prosecution agreement between Jeffrey Epstein and the United States Government. Jeffre
made a part of the record and the extent to which Mr. Epstein, through his attorneys, was culpable. Sincerely
Page 2 of 3 As to petitioners' request for the Report of Interview with Jane Doe # I, counsel for the Government has spoken with FBI Special Agents Nesbitt Kurykendall and Jason Richards, who have advised that no Report of Interview was prepared subsequent to their meeting with Jane Doe # 1 in October 2007, to dis
ution Agreement and Report of Interview (D.E. 19), petitioners seek an order compelling the Government to produce the Non-Prosecution Agreement with Jeffrey Epstein (D.E. 19 at 11-13), and the Report of Interview with Jane Doe # 1 (D.E. 19 at 13-14). The Government is unable to voluntarily produce the Non-Prose
roduce the Non-Prosecution Agreement with Jeffrey Epstein (D.E. 19 at 11-13), and the Report of Interview
ent to produce the Non-Prosecution Agreement with Jeffrey Epstein (D.E. 19 at 11-13), and the Report of In
etitioners. As to petitioners' request for the Report of Interview with Jane Doe # I, counsel for the Government has spoken with FBI Special Agents Nesbitt Kurykendall and Jason Richardson, who have advised that no Report of Interview was prepared subsequent to their meeting with Jane Doe # 1 in late September 2007
al charge in a criminal complaint or an information, and no case was ever filed. Id. 8. On September 10, 2008, Jane Doe No. 1 filed an action (E.W. I. Jeffrey Epstein, Case No. 50-2008-CA-028058-XXXXMB) in Palm Beach County, Florida, seeking money damages from Jeffrey Epstein for sexually abusing her. Ex. P. 9.
006 to 2008, when the U.S. Attorney's Office for the Southern District of Florida investigated Jeffrey Epstein, no criminal charge was filed against Epstein in Federal district court. Ex. S, ¶ 4. Although the U.S. Attorney's Office opened a matter to conduct an investigation of Epstein and to evaluate a
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
06, Jane Doe No. 1 received a similar letter. Ex. F; Ex. S, ¶ 5. Both letters provided the name of the FBI agent handling the Epstein investigation (Nesbitt Kurykendall), her phone number, the identity of the prosecutor (AUSA ), and her phone number. Although Jane Doe No. 1 and Jane Doe No. 2 had been furnished th
charge in a criminal complaint or an information, and no case was ever filed. Id. 8. On September 10, 2008, Jane Doe No. 1 filed an action (E.W. v. Jeffrey Epstein Case No. 50-2008-CA-028058-XXXXMB) in Palm Beach County, Florida, seeking money damages from Jeffrey Epstein for sexually abusing her. Ex. P. 9. On Sep
006 to 2008, when the U.S. Attorney's Office for the Southern District of Florida investigated Jeffrey Epstein, no criminal charge was filed against Epstein in Federal district court. Ex. S,914. Although the U.S. Attorney's Office opened a matter to conduct an investigation of Epstein and to evaluate a
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
06, Jane Doe No. 1 received a similar letter. Ex. F; Ex. S, I 5. Both letters provided the name of the FBI agent handling the Epstein investigation (Nesbitt Kurykendall), her phone number, the identity of the prosecutor (AUSA Villafafia), and her phone number. Although Jane Doe No. I and Jane Doe No. 2 had been fur
Entities connected to both Jeffrey Epstein and Nesbitt Kurykendall

George W. Bush
PERSON
Bradley Edwards
PERSONJane Doe
PERSONMaria Farmer
PERSON
Kenneth Marra
PERSON
Alexander Acosta
PERSON
Paul Cassell
PERSON
A. Marie Villafana
PERSON
Jay Lefkowitz
PERSON
Scarlett Johansson
PERSON
Ken Starr
PERSON
Southern District of New York
ORGANIZATION
Dexter Lee
PERSON
Alberto Gonzales
PERSONthe District of Columbia
LOCATIONJames Eisenberg
PERSONthe Child Exploitation and Obscenity Section
ORGANIZATION
Jason Richards
PERSONThe Law Offices of
ORGANIZATION
John Roth
PERSON