Epstein Secrets

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w about if I call you at 2 tomorrow? 1. The CVRA case is a Complaint about whether certain statutory rights were violated by the Govt. The Govt not JE is the defendant. Whether JD 3 or JD 4 are or are not victims is not the test of whether they are proper petitioners: they also must allege a basis

. . in the original pleading." Because the original petition in this case alleged that the Government violated the rights of all the girls who were Jeffrey Epstein's victims, the proposed amendment in this case would relate back to the date the petition was filed: July 7, 2008. This relation back eliminates any s

ered on FLSD Docket 02/06/2015 Page 24 of 28 1, SHOPPERS TRAVEL, INC. SHOPPERS TRAVEL AGENT RS/RS BOOKING RFF ZXL1 07 303 5TH AVENUE NEW YORK J EPSTEIN 457 MADISON AVE 4TH FLOOR NEWYORK NY 10027 DATE: SEP 27 2002 DOE 3 RECORD TERMS; PAYMENT OUE UPON PRESENTATION SINGAPORE AIRLINES 27SEP NEW

nt violated the rights of all the girls who were Jeffrey Epstein's victims, the proposed amendment in this

e entire agreement between the United States and Mr. Epstein." DE 290-I at 3 (emphasis added). This descriptio

ket 02/06/2015 Page 19 of 20 DATED: February 6. 2015 Respectfully Submitted, /s/ Bradley J. Edwards Bradley J. Edwards FARMER. JAFFE, WEISSING. EDWARDS FISTOS & LEHRMAN, P.L. and Paul G. Cassell Pro Hac Vice S.J. Quinney College of Law at the University of Utah Attorneys, or the victims This daytime business a

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

ways to reduce any such burden. DATED: June 24, 2013 Respectfully Submitted, 5/ Bradley J. Edwards Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS FISTOS & LEHRMAN Paul G. Cassell Pro Hac Vice S.J. Quinney College of Law at the University of Utah and EFTA00615913 Case 9:08-cv-80736-KAM Document 265-1 Ent

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

ys to reduce any such burden. DATED: October 3, 2011 Respectfully Submitted, s/ Bradley J. Edwards Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS FISTOS & LEHRMAN, P.L. Fort Lauderdale, Florida 33301 Telephone Facsimile Florida Bar No.: E-mail: EFTA00208644 Case 9:08-cv-80736-KAM Document 225-1 Entered o

Epstein developed a case for a federal prosecution against Epstein for many federal sex offenses. 2. Regarding notifications provided to victims of Jeffrey Epstein's sexual abuse: (a) (b) (c) The U.S. Attorney's Office negotiated with Jeffrey Epstein's defense attorneys concerning the notifications to be prov

U.S. Attorney's Office for the Southern District of Florida's investigation into Jeffrey Epstein developed a case for a federal prosecution against Epstein for many federal sex offenses. 2. Regarding notifications provided to victims of Jeffrey Epstein's sexual abuse: (a) (b) (c) The U.S. Attorney's

outhern District of Florida's investigation into Jeffrey Epstein developed a case for a federal prosecutio

ation of Jeffrey Epstein has been completed, and Mr. Epstein and the U.S. Attorney's Office have reached an a

the privilege. EFTA00205113 DATED: December 1, 2011 Respectfully Submitted, 5/ Bradley J. Edwards Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS FISTOS & LEHRMAN, P.L. and Paul G. Cassell Pro Hac Vice S.J. Quinney College of Law at the University of Utah Attorneys for Jane Doe #1 and Jane Doe #2 CERTIFI

Epstein developed a case for a federal prosecution against Epstein for many federal sex offenses. 2. Regarding notifications provided to victims of Jeffrey Epstein's sexual abuse: (a) (b) (c) The U.S. Attorney's Office negotiated with Jeffrey Epstein's defense attorneys concerning the notifications to be prov

U.S. Attorney's Office for the Southern District of Florida's investigation into Jeffrey Epstein developed a case for a federal prosecution against Epstein for many federal sex offenses. 2. Regarding notifications provided to victims of Jeffrey Epstein's sexual abuse: (a) (b) (c) The U.S. Attorney's

outhern District of Florida's investigation into Jeffrey Epstein developed a case for a federal prosecutio

ation of Jeffrey Epstein has been completed, and Mr. Epstein and the U.S. Attorney's Office have reached an a

the privilege. EFTA00208177 DATED: December 1, 2011 Respectfully Submitted, 5/ Bradley J. Edwards Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS FISTOS & LEHRMAN, P.L. and Paul G. Cassell Pro Hac Vice S.J. Quinney College of Law at the University of Utah Attorneys for Jane Doe #1 and Jane Doe #2 CERTIFI

ice arranging a highly unusual and secretive non-prosecution agreement. The victims have already explained at length why the correspondence between Epstein's lawyers and government prosecutors is simply not confidential material to which any kind of privilege or other protection could attach. See Jane

able here because it would, at most, bar admissibility of the correspondence into evidence "against the defendant who made the plea" — i.e., against Jeffrey Epstein. But the victims intend to obtain and use the correspondence to seek relief from the Government. Accordingly, the Rule cannot be used to bar the vic

ughly litigated by the defense attorneys' client (Jeffrey Epstein) more than a year ago, and Epstein's arg

nt 106 Entered on FLSD Docket 10/10/2011 Page 26 of 27 Respectfully Submitted, s/ Bradley J. Edwards Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS FISTOS & LEHRMAN, P.L. Fort Lauderdale, Florida 33301 and Paul G. Cassell Pro Hac Vice S.J. Quinney College of Law at the University of Utah Salt Lake City, UT

n the victims' currently-pending summary judgment motion, the victims contend that the Government conducted an extensive criminal investigation into Jeffrey Epstein's sexual exploitation of young girls, including Jane Doe #1 and Jane Doe #2 between 2001 and 2008. The victims also contend that the FBI and other fe

irls, including Jane Doe #1 and Jane Doe #2 between 2001 and 2008. The victims also contend that the FBI and other federal agencies established that Epstein operated a large criminal enterprise that used paid employees and underlings to repeatedly find and bring minor girls to him. In deferring ruling o

rd "Epstein," ' "Ruboyo," "Morrison," "Visoki," "Rogers," "Hammond," Roxburgh," " "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

ys to reduce any such burden. DATED: October 3, 2011 Respectfully Submitted, s/ Bradley J. Edwards Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS FISTOS & LEHRMAN, P.L. Fort Lauderdale, Florida 33301 Telephone Facsimile Florida Bar No.: E-mail: EFTA00205878 and Paul G. Cassell Pro Hac Vice S.J. Quinne

ay, the Court entered an order granting the victims' motion to compel and directing the Government to produce (1) all correspondence between it and Epstein; (2) all communications between the Government and outside entities; and (3) every other document requested by the victims. DE 190 at 2. With respe

to the issue. As another illustration, consider the victims' request for information about former prosecutor personal business relationship with Jeffrey Epstein. See, e.g., Victims' First RFP's at 1 16(f). Here again, the victims know that the Government possesses such information, because it admitted to ha

prosecutor personal business relationship with Jeffrey Epstein. See, e.g., Victims' First RFP's at 1 16

such a responsive document. DATED: August 16, 2013 Respectfully Submitted, /s/ Bradley J. Edwards Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS FISTOS & LEHRMAN, P.L. Fort Lauderdale Florida 33301 Telephone Facsimile E-mail: and Paul G. Cassell Pro Hac Vice S.J. Quinney College of Law at the Universi

ice's treatment of the victims from other sources. This has been an arduous process, since the only remaining source for much of the information was Jeffrey Epstein. As you know, he is a politically-connected billionaire that employs legions of attorneys to obstruct any efforts to obtain information from him. F

e regarding the case. The victims also advised that they had only recently received important correspondence between the U.S. Attorney's Office and Epstein proving that there had been an orchestrated decision to deny them their rights. On October 8, 2010, the Court entered an order directing the victim

e #2 had recently settled their civil cases with Jeffrey Epstein as the basis for closure. On September 13

erits as the victims propose. DATED: October 27, 2010 Respectfully Submitted, s/ Bradley J. Edwards Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS FISTOS & LEHRMAN, P.L. and Paul G. Cassell Pro Hac Vice Attorneys for Jane Doe #1 and Jane Doe #2 8 EFTA00235186 Case 9:08-cv-80736-KAM Document 41 Entered o