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notice of court proceedings as required by 18 U.S.C. § 3771(a)(2) are frivolous; the only court proceedings that have taken place in connection with Epstein's criminal offenses were state court proceedings involving state criminal offenses, for which the CVRA does not 2 EFTA00799496 Case 9:08-cv-8073
ling was also necessary to ensure secrecy, so that as few persons as possible were aware that minor girls were coming at unusual hours to Defendant, Jeffrey Epstein's mansion. 48. Defendant, Sarah Kellen, also needed (directly or indirectly) to make transportation arrangements for many of the girls, as they were
f is included in the list of victims identified by the Federal Government as victims of the Defendant, Jeffrey Epstein's illegal conduct. Defendant, Jeffrey Page 5 of 17 EFTA00799582 Case 9:08-cv-80736-KAM Document 205-6 Entered on FLSD Docket 07/05/2013 Page 90 of 101 Epstein, is thus estopped by his ple
ert[ing] a cause of action against the Defendant, Jeffrey Epstein, pursuant to [18 U.S.C. § 2255] and the
nd we are going to be filing civil cases against Mr. Epstein, and this agreement, undoubtedly it will play a b
scuss ... allegations of criminal acts and [DDT's] decisions to prosecute or not prosecute"') (citing 18 U.S.C. § 3771(d)(3)); see also, e.g., In re Antrobus, 563 F.3d 1092, 1097 (10th Cir. 2009) ("The CVRA contemplates that individuals asserting victim status may bring a motion in the district court eve
notice of court proceedings as required by 18 U.S.C. § 3771(a)(2) are frivolous; the only court proceedings that have taken place in connection with Epstein's criminal offenses were state court proceedings involving state criminal offenses, for which the CVRA does not 2 EFTA00208824 Petitioners' righ
ling was also necessary to ensure secrecy, so that as few persons as possible were aware that minor girls were coming at unusual hours to Defendant, Jeffrey Epstein's mansion. 48. Defendant, also needed (directly or indirectly) to make transportation arrangements for many of the girls, as they were often too yo
f is included in the list of victims identified by the Federal Government as victims of the Defendant, Jeffrey Epstein's illegal conduct. Defendant, Jeffrey Page 5 of 17 EFTA00208910 Epstein, is thus estopped by his plea and agreement with the Federal Government from denying the acts alleged in this Compla
ert[ing] a cause of action against the Defendant, Jeffrey Epstein, pursuant to [18 U.S.C. § 2255] and the
nd we are going to be filing civil cases against Mr. Epstein, and this agreement, undoubtedly it will play a b
scuss ... allegations of criminal acts and [DDT's] decisions to prosecute or not prosecute"') (citing 18 U.S.C. § 3771(d)(3)); see also, e.g., In re Antrobus, 563 F.3d 1092, 1097 (10th Cir. 2009) ("The CVRA contemplates that individuals asserting victim status may bring a motion in the district court eve
notice of court proceedings as required by 18 U.S.C. § 3771(a)(2) are frivolous; the only court proceedings that have taken place in connection with Epstein's criminal offenses were state court proceedings involving state criminal offenses, for which the CVRA does not 2 EFTA00081017 Case 9:08-cv-8073
ling was also necessary to ensure secrecy, so that as few persons as possible were aware that minor girls were coming at unusual hours to Defendant, Jeffrey Epstein's mansion. 48. Defendant, Sarah Kellen, also needed (directly or indirectly) to make transportation arrangements for many of the girls, as they were
f is included in the list of victims identified by the Federal Government as victims of the Defendant, Jeffrey Epstein's illegal conduct. Defendant, Jeffrey Page 5 of 17 EFTA00081103 Case 9:08-cv-80736-KAM Document 205-6 Entered on FLSD Docket 07/05/2013 Page 90 of 101 Epstein, is thus estopped by his ple
ert[ing] a cause of action against the Defendant, Jeffrey Epstein, pursuant to [18 U.S.C. § 2255] and the
nd we are going to be filing civil cases against Mr. Epstein, and this agreement, undoubtedly it will play a b
scuss ... allegations of criminal acts and [DOJ's] decisions to prosecute or not prosecute"') (citing 18 U.S.C. § 3771(d)(3)); see also, e.g., In re Antrobus, 563 F.3d 1092, 1097 (10th Cir. 2009) ("The CVRA contemplates that individuals asserting victim status may bring a motion in the district court eve
notice of court proceedings as required by 18 U.S.C. § 3771(a)(2) are frivolous; the only court proceedings that have taken place in connection with Epstein's criminal offenses were state court proceedings involving state criminal offenses, for which the CVRA does not 2 EFTA00795172 Case 9:08-cv-8073
ling was also necessary to ensure secrecy, so that as few persons as possible were aware that minor girls were coming at unusual hours to Defendant, Jeffrey Epstein's mansion. 48. Defendant, Sarah Kellen, also needed (directly or indirectly) to make transportation arrangements for many of the girls, as they were
f is included in the list of victims identified by the Federal Government as victims of the Defendant, Jeffrey Epstein's illegal conduct. Defendant, Jeffrey Page 5 of 17 EFTA00795258 Case 9:08-cv-80736-KAM Document 205-6 Entered on FLSD Docket 07/05/2013 Page 90 of 101 Epstein, is thus estopped by his ple
ert[ing] a cause of action against the Defendant, Jeffrey Epstein, pursuant to [18 U.S.C. § 2255] and the
nd we are going to be filing civil cases against Mr. Epstein, and this agreement, undoubtedly it will play a b
scuss ... allegations of criminal acts and [DDT's] decisions to prosecute or not prosecute"') (citing 18 U.S.C. § 3771(d)(3)); see also, e.g., In re Antrobus, 563 F.3d 1092, 1097 (10th Cir. 2009) ("The CVRA contemplates that individuals asserting victim status may bring a motion in the district court eve
notice of court proceedings as required by 18 U.S.C. § 3771(a)(2) are frivolous; the only court proceedings that have taken place in connection with Epstein's criminal offenses were state court proceedings involving state criminal offenses, for which the CVRA does not 2 EFTA00205603 Petitioners' righ
D) see also First Am. Compl. 1 32-33, Doe'. Epstein, Case No. 08-80893-CIV-MARRA (S.D. Fla.) ("assert[ing] a cause of action against the Defendant, Jeffrey Epstein, pursuant to [18 U.S.C. § 2255] and the [Non-Prosecution] agreement between the Defendant, Jeffrey Epstein, and the United States Government"); Comp
ert[ing] a cause of action against the Defendant, Jeffrey Epstein, pursuant to [18 U.S.C. § 2255] and the
nd we are going to be filing civil cases against Mr. Epstein, and this agreement, undoubtedly it will play a b
iscuss ... allegations of criminal acts and [DOJ's] decisions to prosecute or not prosecute') (citing 18 U.S.C. § 3771(d)(3)); see also, e.g., In re Antrobus, 563 F.3d 1092, 1097 (10th Cir. 2009) ("The CVRA contemplates that individuals asserting victim status may bring a motion in the district court eve
notice of court proceedings as required by 18 U.S.C. § 3771(a)(2) are frivolous; the only court proceedings that have taken place in connection with Epstein's criminal offenses were state court proceedings involving state criminal offenses, for which the CVRA does not 2 EFTA00205625 Petitioners' righ
D) see also First Am. Compl. 1 32-33, Doe'. Epstein, Case No. 08-80893-CIV-MARRA (S.D. Fla.) ("assert[ing] a cause of action against the Defendant, Jeffrey Epstein, pursuant to [18 U.S.C. § 2255] and the [Non-Prosecution] agreement between the Defendant, Jeffrey Epstein, and the United States Government"); Comp
ert[ing] a cause of action against the Defendant, Jeffrey Epstein, pursuant to [18 U.S.C. § 2255] and the
nd we are going to be filing civil cases against Mr. Epstein, and this agreement, undoubtedly it will play a b
iscuss ... allegations of criminal acts and [DOJ's] decisions to prosecute or not prosecute') (citing 18 U.S.C. § 3771(d)(3)); see also, e.g., In re Antrobus, 563 F.3d 1092, 1097 (10th Cir. 2009) ("The CVRA contemplates that individuals asserting victim status may bring a motion in the district court eve
the 1 EFTA00206751 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
I trust that you will agree that our recitations of the e-mails are correct and that they accurately reflect communications between your Office and Epstein's legal counsel during the plea negotiation process. As you will note, Epstein's legal counsel redacted half of the correspondence — specifically,
remaining source for much of the information was Jeffrey Epstein. As you know, he is a politically-connect
request the same conferral rights that you gave Mr. Epstein with the First Assistant, the U.S. Attorney, and
for these courts (including courts of this Circuit). See, e.g., In re Stewart (I Ph Cir. 2008) (CVRA enforcement action commenced by motion); In re Antrobus (10th Circuit 2008) (same); In re Dean (5th Cir. 2008) (same). Indeed, in an important case in the District of Montana involving enforcement of vict
the 1 EFTA00235747 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
I trust that you will agree that our recitations of the e-mails are correct and that they accurately reflect communications between your Office and Epstein's legal counsel during the plea negotiation process. As you will note, Epstein's legal counsel redacted half of the correspondence — specifically,
remaining source for much of the information was Jeffrey Epstein. As you know, he is a politically-connect
request the same conferral rights that you gave Mr. Epstein with the First Assistant, the U.S. Attorney, and
for these courts (including courts of this Circuit). See, e.g., In re Stewart (I Ph Cir. 2008) (CVRA enforcement action commenced by motion); In re Antrobus (10th Circuit 2008) (same); In re Dean (5th Cir. 2008) (same). Indeed, in an important case in the District of Montana involving enforcement of vict
to do anything at all to unearth all the hurt and pain it has taken me this long to process." Julie K. Brown, Prosecutors finally want to hear from Jeffrey Epstein's victims, MIAMI HERALD, 2019, https://www.miamiherald.com/news/state/florida/article230275434.html (last visited June 21, 2019). 18 EFTA00085726
osecutor's conferral obligations; and the government violated the CVRA by failing to advise the victims that it intended to enter into the NPA with Epstein. The government will not EFTA00085709 Case 9:08-cv-80736-KAM Document 462 Entered on FLSD Docket 06/24/2019 Page 2 of 32 what they call "rescissi
ring into a non-prosecution agreement (NPA) with Jeffrey Epstein? Petitioners seek 1 This Court previousl
cuss ... allegations of criminal acts and [DOJ's] decisions to prosecute or not prosecute"') (citing 18 U.S.C. § 3771(d)(3)); see also, e.g., In re Antrobus, 563 F.3d 1092, 1097 (10th Cir. 2009) ("The CVRA contemplates that individuals asserting victim status may bring a motion in the district court eve
most importantly, Professor Cassell has been working closely with Ms. as her attorney for nearly two years on issues related to her sexual abuse by Jeffrey Epstein and his co-conspirators -- including active work in legal research and other aspects of this case. Professor Cassell is a valuable part of Ms. lega
on issues related to her sexual abuse by Jeffrey Epstein and his co-conspirators -- including active work
wo years on issues related to her sexual abuse by Jeffrey Epstein and his co-conspirators -- including act
. United States, 134 S. Ct. 1710 (2014) (arguing before the Supreme Court on behalf of "Amy," a child pornography victim seeking restitution); In re Antrobus, 519 F.3d 1123 (10th Cir. 2008) (arguing for opportunity for victim to deliver a victim impact statement). His previous experience will be valuable
Entities connected to both Jeffrey Epstein and Antrobus

Marc Rich
PERSON
Alan Dershowitz
PERSON
George W. Bush
PERSON
Donald Trump
PERSON
Bradley Edwards
PERSON
United States
LOCATION
Sarah Kellen
PERSON
Joe Biden
PERSON
Prince Charles
PERSONJane Doe
PERSON
Martha Stewart
PERSON
Department of Justice
ORGANIZATIONMaria Farmer
PERSON
Kenneth Marra
PERSONthe Southern District
LOCATION
Paul Cassell
PERSON
New York
LOCATION
A. Marie Villafana
PERSON
Scarlett Johansson
PERSONEmmy Taylor
PERSON