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ring on Appropriate Remedies (unredacted), and a complete set of exhibits, including the e-mails in Exhibit A. The e-mails in Exhibit A are between Epstein's defense attorney and AUSA Villafalta. They were produced in civil litigation between Epstein and some of his victims. Epstein's attorneys redacted
e 15th Judicial Circuit in and for Palm Beach County (tereinaRer, the "State Attorney's Office") have conducted an investigation into the conduct of Jeffrey Epstein (hereinafter "Epstein"); IT APPEARING that the State Attorney's Of fice has charged Epstein by indictment with solicitation of prostitution, in vio
t's desire that federal charges be filed against defendant Epstein. In particular, he wrote on behalf of his clients
formally signed a non-prosecution agreement with Jeffrey Epstein that barred his I The victims are contem
criminal prosecution commensurate with the crimes Mr. Epstein has committed, and we further urge you to take t
, the Court must find that the attorney's conduct is ' "'tantamount to bad faith.'" Arniong & Amiong, 500 F.3d 1230, 1239 (11th Cir. 2007) (quoting Avirgan v. Hull, 932 F2d 1572, 1582 (11th Cir. 1991)). "[Tjhe attorney must knowingly or recklessly pursue a frivolous claim." Id at 1242. The finding of bad faith
ment 79 Entered on FLSD Docket 05/012011 Page 2 of 4 violated Florida Bar rules and Department of Justice regulations by representing employees of Jeffrey Epstein ("Epstein") in civil litigation after the undersigned retired from the United States Attorney's Office for the Southern District of Florida (the "Of
n FLSD Docket 05/012011 Page 2 of 4 violated Florida Bar rules and Department of Justice regulations by representing employees of Jeffrey Epstein ("Epstein") in civil litigation after the undersigned retired from the United States Attorney's Office for the Southern District of Florida (the "Office"). Th
Justice regulations by representing employees of Jeffrey Epstein ("Epstein") in civil litigation after the
s retained to represent several other members of Mr. Epstein's staff in their civil depositions. 15. After
927, the Court must find that the attorney's conduct is "'tantamount to bad faith."' Amlong & Amlong, 500 F.3d 1230, 1239 (11th Cir. 2007) (quoting Avirgan v. Hull, 932 F.2d 1572, 1582 (11th Cir. 1991)). "[T]he attorney must knowingly or recklessly pursue a frivolous claim." Id. at 1242. The finding of bad fait
s claims by Plaintiffs that Defendant violated the Crime Victims Rights Act (CVRA), 18 U.S.C. §3771, in its handling of a criminal investigation of Jeffrey Epstein ("Epstein") and others. The investigation ultimately resulted in a non-prosecution agreement between the United States and Epstein. On EFTA00205075
iffs that Defendant violated the Crime Victims Rights Act (CVRA), 18 U.S.C. §3771, in its handling of a criminal investigation of Jeffrey Epstein ("Epstein") and others. The investigation ultimately resulted in a non-prosecution agreement between the United States and Epstein. On EFTA00205075 Case 9:
, in its handling of a criminal investigation of Jeffrey Epstein ("Epstein") and others. The investigation
s retained to represent several other members of Mr. Epstein's staff in their civil depositions. 15. After
927, the Court must find that the attorney's conduct is "'tantamount to bad faith."' Amlong & Amlong, 500 F.3d 1230, 1239 (11th Cir. 2007) (quoting Avirgan v. Hull, 932 F.2d 1572, 1582 (11th Cir. 1991)). "[T]he attorney must knowingly or recklessly pursue a frivolous claim." Id. at 1242. The finding of bad fait
l relevant times, the Office had approximately 20 Assistant U.S. Attorneys assigned to the West Palm Beach location. The prosecutor assigned to the Epstein case, I I end I were assigned to different sections within the Office. We reported to different supervisors. 11. I did not participate in any way
ent 79 Entered on FLSD Docket 05/03/2011 Page 2 of 4 violated Florida Bar rules and Department of Justice regulations by representing employees of Jeffrey Epstein ("Epstein") in civil litigation after the undersigned retired from the United States Attorney's Office for the Southern District of Florida (the "Of
Justice regulations by representing employees of Jeffrey Epstein ("Epstein") in civil litigation after the
s retained to represent several other members of Mr. Epstein's staff in their civil depositions. I5.. After
1927, the Court must find that the attorney's conduct is "'tantamount to bad faith.'" Amlong & Amlong, 500 F.3d 1230, 1239 (111 Cir. 2007) (quoting Avirgan v. Hull, 932 F.2d 1572, 1582 (11th Cir. 1991)). "Mhe attorney must knowingly or recklessly pursue a frivolous claim." Id at 1242. The finding of bad faith
Entities connected to both Jeffrey Epstein and Avirgan v. Hull

Joi Ito
PERSON
Bradley Edwards
PERSON
United States
LOCATIONJane Doe
PERSON
Department of Justice
ORGANIZATION
Kenneth Marra
PERSONthe Southern District
LOCATION
Paul Cassell
PERSONFBI
ORGANIZATION
Scarlett Johansson
PERSON
the Internal Revenue Service
ORGANIZATION
Dexter Lee
PERSON
Supreme Court
ORGANIZATIONRubin
PERSON
Maine
LOCATIONFlorida Bar
ORGANIZATION
the United States Government
ORGANIZATION
Kaplan
PERSONthe Eleventh Circuit
ORGANIZATIONOffice for the Southern District of Florida
ORGANIZATION