Epstein Secrets

nted. Continental Casualty Co.'. Fibreboard Corp., 4 F.3d 777, 778 (' Cir. 1993). The non-prosecution agreement in this case was signed in 2007, and Epstein entered his pleas of guilty in July 2008, in Florida circuit court. I k was sentenced by the state court, and has served his sentence. Individuals

n for sexually abusing them. During the course of that litigation, in June 2001, they obtained correspondence between the U.S. Attorney's Office and Jeffrey Epstein's legal counsel. Jane Doe #1 and Jane Doe #2 ultimately settled their civil suits in July 2010. During the settlement discussions, they informed Epste

hether a charging document was ever filed against Jeffrey Epstein in the United States District Court for

in "the same position as they would have been had Mr. Epstein been convicted at trial." Declaration of Marie V

21/2011 Page 6 of 15 information contrary to its position in court. For criminal defendants, this principle traces back to the landmark decision of Brady I. Maryland, 373 U.S. 83, 87 (1963), in which the Court explained the production of exculpatory evidence is a principle designed for avoidance of an unfair tri

necessary" (doc. #17 at I). 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. On August I, 2008, the victims filed a response to the Government's "Notice" (doe. #19), giving a proposed statement of facts

n for sexually abusing them. During the course of that litigation, in June 2001, they obtained correspondence between the U.S. Attorney's Office and Jeffrey Epstein's legal counsel. Jane Doe #1 and Jane Doe #2 ultimately settled their civil suits in July 2010. During the settlement discussions, they informed Epste

hether a charging document was ever filed against Jeffrey Epstein in the United States District Court for

in "the same position as they would have been had Mr. Epstein been convicted at trial." Declaration of Marie V

and "respect for the victim's dignity and privacy" have created a substantive due process right. Similarly unavailing is petitioners' reliance upon Brady I. Maryland, 373 U.S. 83 (1963), and other criminal law cases finding a due process obligation on the government's part to disclose exculpatory and impeachment

for the Southern District of Florida. 2. All recordings of the deposition(s) of Alfredo Rodriguez in connection with any civil suit pending against Jeffrey Epstein in the United States District Court (or the Southern District of Florida, including transcripts, videorecordings, and audiorecordings. 3. All docum

ecution Agreement between Jeffrey Epstein and the U.S. Attorney's Office for the Southern District of Florida. No federal charges were filed against Epstein or any of his co- conspirators. While there were a multitude of reasons for that decision, one sentiment was that federal nexus was not as strong as

Cooperating Attorney Date October 28, 2009 To Jeffrey Sloman Acting U.S. Attorney Acting First Assist

l information and material known to the Government which may be favorable to the defendant on the issues of guilt or punishment within the scope of Brady I. Maryland 373 U.S. 83 (1963), and United States'. Azurs, 427 U.S. 97 (1976). D. The Government shall disclose to the defendant(s) the existence and substanc

her notification should be made to the victims. This would include letters, memos, and e-mail traffic. No. 8: Plaintiffs seek documents relating to Epstein's efforts, after the execution of the NPA in September 2007, to appeal to Main Justice to obtain a more favorable outcome. I understand he first ap

ation, the victims claimed the government had an obligation to provide information helpful to their case, just as the government is obligated under Brady I. Maryland to provide exculpatory information in its possession. I view this request as covering any documents which would assist the victims, and hurt the go