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I don't think we are very far apart on this language. I had also suggested some language, to be included in the agreement on finality, provided that Jeffrey abided by all the terms of the agreement. Please let me know your thoughts on these. I will continue to review the document and speak with you tomor
JEFFREY EPSTEIN RAL EEC° ESQ. OUNSEL TO JEFFR Y EPSTEIN EFTA00184724 Case 9:08-cv-80736-KAM Document 3
f his clients is the purported victim. Accordingly. I will address facts related to C.W., T.M.. and S R. All three of those clients were victims of Jeffrey Epstein's while they were minors beginning when they were fifteen years old. Incase note that the dates on the U.S. Attorney's Office letters to C.W. and T.M
of course, is a defense attorney who represented defendant Epstein. Recording information provided by a defense att
EDWARDS: Your Honor, as a factual 2 background, Mr. Epstein is a billionaire that 3 sexually abused and mol
States Attorney's Office will be instituted in this District, and the charges against Epstein if any, will be dismissed. Terms of the Agreement: I. Epstein shall plead guilty (not nob contendere) to an Information filed by the State Attorney's Office charging Epstein with an offense that requires him t
ge 3 of 5 US_Atty_Cor_0085 EFTA00184713 Case 9:08-cv-80736-KAM Document 361-61 Entered on FLSD Docket 02/10/2016 Page 7 of 8 In consideration of Epsteln's agreement to plead guilty and to provide compensation to victims, if Epstein successfully fiilfills all of the terms and conditions of this agreem
te to undisputed facts — no such stipulation would be forthcoming. Ins on March 15, 2011, the U.S. Attorney for the th Souern District of Florida, Wifredo A. sent a letter to the victims declining to reach any agreement on the facts: Because, as a matter of law, the CVRA is inapplicable to this matter i
of course, is a defense attorney who represented defendant Epstein. Recording information provided by a defense att
lian Ave S. West Palm Beach, FL 33401-5015 Re: Jeffrey Epstein Dear Mr. Goldberger: In accordance with
riminal prosecution commensurate with the crimes Mr. Epstein has committed, and we further urge you to take th
vernment's CVRA violation in this case. See, e.g., DE 48 at 13. 31. RFP No. 4 requests documents relating to negotiations between the Government and Jeffrey Epstein concerning the court and/or location in which Jeffrey Epstein would enter any guilty plea (including in particular any negotiations concerning concl
d under Section 2255 as she would have had, if Mr..Epstein had been tried federally and convicted of an enu
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 Bruce Reinhart, a senior prosecutor w
to undisputed facts — no such stipulation would be forthcoming. Instead, on March 15, 2011, the U.S. Attorney for the Southern District of Florida, Wifredo A. , sent a letter to the victims declining to reach any agreement on the facts: Because, as a matter of law, the CVRA is inapplicable to this matter
o: "Ferrer, Wifredo A. (USAFLS)" <wferrer®usa.doj.gov>, C Subject: LITIGATION HOLD REMINDER - Jane Does v. U.S. - Case No.: 9:08-cv-80736-ICAM -re Jeffrey Epstein) Date: Wed, 02 May 2012 17:04:19 +0000 Importance: Normal In accordance with USAP USAP 3-13.300.003, this is a reminder that the Litigation Hold i
U.S. - Case No.: 9:08-cv-80736-ICAM -re Jeffrey Epstein) Date: Wed, 02 May 2012 17:04:19 +0000 Importan
Does v. U.S. - Case No.: 9:08-cv-80736-ICAM -re Jeffrey Epstein) Date: Wed, 02 May 2012 17:04:19 +0000
From: To: "Ferrer, Wifredo A. (USAFLS)" <wferrer®usa.doj.gov>, C Subject: LITIGATION HOLD REMINDER - Jane Does v. U.S. - Case No.: 9:08-cv-80736-ICAM -re Jeffrey Epstein) Date
Mr. =, Our office is currently litigating a Crime Victims Rights Act (CVRA) lawsuit filed by Jane Does 1 and 2, who were victims of sexual abuse by Jeffrey Epstein, a multi-millionaire investor living in Palm Beach, Florida. Jane Does 1 and 2 v. United States Case No. 08-80736-CIV-MARRA (S.D.Fla.). We are seeki
ment take no position on whether the CVRA granted rights to the victims, when the U.S. Attorney's Office negotiated a non-prosecution agreement with Epstein. In 2006, the Palm Beach Police Department began investigating allegations that Jeffrey Epstein was enticing underage girls into prostitution. Eps
oes 1 and 2, who were victims of sexual abuse by Jeffrey Epstein, a multi-millionaire investor living in P
they seek is a set aside by the court of the Non-Prosecution Agreement, and a prosecution of Epstein. On December 10, 2010, United States Attorney Wifredo A. and I, met with Cassell, Edwards, and S one of the victims. We discussed the posture of the case, and told us her views of what occurred and her
Attorney's Office for the Southern District of Florida (SDFL) from all matters, to include the investigation and potential prosecution, relating to Jeffrey Epstein's alleged sexual activities with minor females. The ADAG authorized this recusal in accordance with United States Attorney's Manual (USAM) 3-2.170 an
igation and Potential Prosecution of Mr. Jeffery Epstein (GCO File No. REC-11-4159) THIS IS FORMAL NOTICE
estigation and potential prosecution, relating to Jeffrey Epstein's alleged sexual activities with minor f
Lee, Dexter (USAFLS) From: (USAEO) Sent: Wednesday, August 24, 2011 3:32 PM To: Ferrer, Wifredo A. (USAFLS); (USAFLM); (USAFLS); (USAFLM) Cc: (ODAG) 0MD • (USAEO); (USAEO); (USAEO); (USAEO) Subject: FORMAL NOTICE of Office-wide Recusal o
Attorney's Office for the Southern District of Florida (SDFL) from all matters, to include the investigation and potential prosecution, relating to Jeffrey Epstein's alleged sexual activities with minor females. The ADAG authorized this recusal in accordance with United States Attorney's Manual (USAM) 3-2.170 an
igation and Potential Prosecution of Mr. Jeffery Epstein (GC° File No. REC-I14159) THIS IS FORMAL NOTICE
estigation and potential prosecution, relating to Jeffrey Epstein's alleged sexual activities with minor f
From: Sent: To: Cc: Subject: Wednesday, August 24, 2011 3:32 PM Ferrer, Wifredo A. (USARS); O'Neill, Robert (USAFLM); (USAFLM) David (ODAG) (JMD); (USARS); FORMAL NOTICE of Office-wide Recusal of Southern District of Florida (GC
y. Also by waiting until there is a public charge, there can be no claim of the type of "conflict of interest" that has arisen in this case — where Epstein could manufacture a claim that we are investigating him due to pressure brought to bear by the victims' suit. As to the second point, Cassell's cla
0 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 561-209-1047 Fax 561-802-1787 From: Sent: Tuesday, August 16, 2011 9:39 AM To: Ferrer, Wifredo A. (USAFLS);. , ( I" - -), tl - • ' ( ti - -1, ti .„ I r 1' — -) Cc: Subject: RE: Jane Does 1 and 2 United States - Hearing on Friday, August 12
From: FLS)" alMIE> To: Subject: Re: Epstein Pre-Meet Date: Thu, 09 Dec 2010 20:58:59 +0000
ance: Normal Ok. I will let them know --- Original Message From: Atkinson, Karen (USAFLS) Sent: Thursday, December 09, 2010 03:53 PM To: Ferrer, Wifredo A. (USAFLS); Greenberg, Benjamin (USAFLS); (USAFLS); (USAFLS); Jacobus, Robert G (DEA-US) Subject: Epstein Pre-Meet Rating meeting for students at
such as memos or e-mails which show the decisional process for determining whether this Office should enter into the Non-Prosecution Agreement with Epstein. This would include opposing views within the office, as well as supporting views; and (2) documents showing whether the FBI was, or was not, made
I was advised up to the SAC. From: Lee, Dexter (USAFLS) Sent: Tuesday, January 04, 2011 03:27 PM To: Villafana, Ann Marie C. (USAFLS) Cc: Ferrer, Wifredo A. (USAFLS); Greenberg, Benjamin (USAFLS) Subject: Call from OPR I've just spoken with at OPR, regarding the request for investigation submitted by
withhold the other half of the U.S. Attorney's correspondence, correspondence between the Department and Ken Starr and Lillian Sanchez on behalf of Epstein, and information about role in the Epstein case. In short, we understand you to be asserting a blanket position that you can withhold informati
From: Sent: To: Cc: Subject: Tracking: Tuesday. March 15. 2011 7:38 PM Ferrer. Wifredo A. (USAFLS):1' r 'd i t in "ri r ) (tinAri r • r- -I (1 Ir. r I el " • rl I -I (I IC A ri An • I/ ( " C A CI n ) ,. • —Edwar41-flaArt
Entities connected to both Jeffrey Epstein and Wifredo A.

Prince Andrew
PERSON
Alan Dershowitz
PERSON
Bradley Edwards
PERSON
United States
LOCATIONJack Goldberger
PERSONJane Doe
PERSON
Department of Justice
ORGANIZATION
Kenneth Marra
PERSON
Bill Clinton
PERSONthe Southern District
LOCATION
Paul Cassell
PERSON
A. Marie Villafana
PERSON
Jay Lefkowitz
PERSON
Scarlett Johansson
PERSON
Ken Starr
PERSON
Dexter Lee
PERSON
Palm Beach Police Department
ORGANIZATION
Karen Atkinson
PERSONAce Greenberg
PERSONBruce E. Reinhart
PERSON