Epstein Secrets

33401 Dear Alex: Facaimaa: mint kirklancl.cOM Dlr. Fax: ConfidentlaL For Settlement Purposes Only, Pursuant to Rule 408. October 10, 2007 Re: Jeffrey Epstein I write as' follow up to our conversation yesterday regarding the open issues that remain Si stein matter. As you are aware, we continue to have se

he conduct at issue, in an effort to avoid long drawn out disputes over liability in public adversarial litigations. Initially, we proposed that Mr. Epstein create' trust whereby' trustee would be appointed by the Circuit Court to disperse the funds to the identified individuals based on' good faith sho

ance and statements or a member of your Office or the pB12 2 We arc concerned with the fact that some of the victims were previously notified, as Mr. Jeffrey slates in his letter of December 6 letter. In your letter of December 4. you state that you would not issue the Victim Notification lamer until De

h as we pprcciate your willingness to revisit the § 2255 issues, we cannot accept your language as proposed, because we believe that the conduct of Mr_ Epstein with respect to these alleged i ictinis fails to satisfy the requisite elements of any of the enumerated offenses, including 18 U.S.C. § 2422(b) or

nited Stales shall provide F.pstein's attorney's with a list of individuals whom it has identified as victims, as defined in IS U.S.C. f 2255. alter Epsicin has signed this agreement and has been sentenced. Upon the execution of this agreement. the United States. in consultation with und subject to the

nes definition. To be' "crime victim", I person or entity must be harmed by an offense that has peen charged in Federal district court. See U.S. I. Guevara-Toloso, 2005 WL 1210982 at '12 (E.D.N.Y. May 23, zoosi (noting that § 3771's reference to "the crime" suggests 'I focus only on the crime with which I def

ctims" and given our understanding that Ms. as well was one of those who is also on the list of persons the Utivernment contends were Mc MIN of Mr. Epstein's alleged violation of federal law, we have a principled concern about adopting your recommended language which would leave Mr. Epstein without a b

ND AITILIATLD PAVINIItSHIPS Citigroup Canter 153 Elam 53rd SWIM New York, Now 'font 10022.4811 ass.saoo www.hlrilsnd.00m December 26, 2007 Re: Jefflay Epstein For the purpose of enforcing the rights enumerated in article 1.13, a victim is 'a person directly and proximately harmed as a result of the commis

istration of criminal justice with profound consequences beyond the resolution in the matter at hand. • in a precedent-shattering investigation of Jeffrey Epstrein that raises important policy questions—and serious issues as to the fair and honorable enforcement of federal law—the USA.° in Miami is considering

ion that no telephonic or Internet persuasion, inducement, enticement or coercion of a minor, or of any other individual, occurred. In addition, Mr. Jeffrey Harmful. the former law partner of one of the federal prosecutors involved in this matter and die attorney for most of the civil complainants (as d

f persons the Utivernment contends were Mc MIN of Mr. Epstein's alleged violation of federal law, we have a pr

lines definition. To be a "crime victim", a person or entity must be harmed by an offense that has peen charged in Federal district court. See U.S. I. Guevara-Toloso, 2005 WL 1210982 at *2 (E.D.N.Y. May 23, 2005) (noting that § 3771's reference to "the crime" suggests "a focus only on the crime with which a defe

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

U.S.C. § 3771(a)(2)(A), (C) (curtailing notice rights and obligations even for federal proceedings when they involve a state crime); United States I. Guevara-Toloso, 2005 WL 1210982, *2 (E.D.N.Y. 2005) (recognizing that the CVRA does not require notice of public court proceedings based on violations of state cr