Epstein Secrets

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

ng into a settlement agreement.")); United States v. Drier, 682 F. Supp. 2d 417, 421 (S.D.N.Y. 2010) (same); see further United States v. BP Prods. N. Am. Inc., 610 F. Supp. 2d 655, 727 (S.D. Tex. 2009) ("The purpose of the conferral right is not to give victims a right to approve or disapprove a proposed

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

ng into a settlement agreement.")); United States v. Drier, 682 F. Supp. 2d 417, 421 (S.D.N.Y. 2010) (same); see further United States v. BP Prods. N. Am. Inc., 610 F. Supp. 2d 655, 727 (S.D. Tex. 2009) ("The purpose of the conferral right is not to give victims a right to approve or disapprove a proposed

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

ng into a settlement agreement.")); United States v. Drier, 682 F. Supp. 2d 417, 421 (S.D.N.Y. 2010) (same); see further United States v. BP Prods. N. Am. Inc., 610 F. Supp. 2d 655, 727 (S.D. Tex. 2009) ("The purpose of the conferral right is not to give victims a right to approve or disapprove a proposed

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

ng into a settlement agreement.")); United States v. Drier, 682 F. Supp. 2d 417, 421 (S.D.N.Y. 2010) (same); see further United States v. BP Prods. N. Am. Inc., 610 F. Supp. 2d 655, 727 (S.D. Tex. 2009) ("The purpose of the conferral right is not to give victims a right to approve or disapprove a proposed

RA rights to confer and fairness in cases involving white- collar and other wealthy defendants who commonly engage in pro-charge plea negotiations. Jeffrey Epstein's case illustrates my point. The U.S. Attorney's Office assigned specific attorneys, with AUSA Villafana being the lead prosecutor and primary attorn

rey Epstein. In her petition, Ms. Wild alleges that when federal prosecutors secretly negotiated and entered into a non- prosecution agreement with Epstein in 2007, they violated her rights under the CVRA—in particular, her rights to confer with the government's lawyers and to be treated fairly by the

ized by notorious sex trafficker and child abuser Jeffrey Epstein. In her petition, Ms. Wild alleges that

t resolves the federal investigation by allowing Mr. Epstein to plead to a state offense. The victims identif

t to confer and C a § 3771(c)'s related notice obligation apply to the period before a charging instrument is filed. See United States v. BP Prods. N. Am. Inc., No. H-07.433, WESTLAW @ 2020 Thomson Reuters. No claim to original U.S. Government Works. 30 EFTA00073522 In re Wild, 955 F.3d 1196 (2020) 28

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

tering into a settlement agreement.")); United States Drier, 682 F. Supp. 2d 417, 421 (S.D.N.Y. 2010) (same); see further United States, BP Prods. N. Am. Inc., 610 F. Supp. 2d 655, 727 (S.D. Tex. 2009) ("The purpose of the conferral right is not to give victims a right to approve or disapprove a proposed

kground 2 I. DBZ's Investment Strategy 3 2. Mr. Zwirn's Role at DBZ 3 3. Mr. Dubin's Involvement with DBZ 4 4. DBZ's Lock-Ups 4 C. Mr. Epstein's Relationship with Mr. Dubin 6 D. FTC's Investments in the Fund 7 E. Accounting Improprieties at DBZ 8 F. DBZ's Discovery of Accounting Imp

Third-Party Claimants Financial Trust Company, Inc. and Jeepers, Inc. (together, "FTC"). Preliminary Statement At no time did Daniel Zwim promise Jeffrey Epstein that FTC could immediately withdraw $80 million of its investments in DBZ's Fund. Mr. Epstein's claim that Mr. Zwim made such a promise is a newly

ary Statement At no time did Daniel Zwim promise Jeffrey Epstein that FTC could immediately withdraw $80

volvement with DBZ 4 4. DBZ's Lock-Ups 4 C. Mr. Epstein's Relationship with Mr. Dubin 6 D. FTC's Inves

0970 (Del. Ch. Nov. 26, 2002) 29 Anglo Amen Sec. Fund, L.P. v. S.R. Global Int'! Fund, L.P., 2006 WL 1494360 (Del. Ch. May 24, 2006) 20 BAE Sys. N. Am. Inc. v. Lockheed Martin Corp., 2004 WL 1739522 (Del. Ch. Aug. 3, 2004) 23 Bay Center Apartments Owner, LLC v. Einery Bay PKI, LLC, 2009 WL 1124451 (De

PEL NON-PRIVILEGED DOCUMENTS Laura A. Menninger Jeffrey S. Pagliuca HADDON, MORGAN, AND FOREMAN. P.C. E

ble at times to conduct a media campaign, but that does not transform their coordination of a campaign into legal advice." Haugh v. Schroder Mgmt. N. Am. Inc., 2003 WL 21998674, at *3 (S.D.N.Y. Aug. 25, 2003). Plaintiff simply has not carried her burden of showing that the logged communications meet the r