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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
ein case. This investigation was undertaken at the request of the victims in this case. On December 10, 2010, co-counsel, Professor Paul Cassell of the University of Utah College of Law, and I met with the U.S. Attorney for the Southern District of Florida regarding this case in the U.S. Attorney's Office in Miami, Florida. At on t
rth is in the hundreds of millions of dollars - if not, indeed, a billion dollars. See, e.g., New York Time, July 1, 2008, at A2 ("Over the weekend Jeffrey E. Epstein, who after years of advising billionaires became a billionaire himself, left his estate on Little St. James Island, with its staff of 70 and its fl
ant PLAINTIFF, JANE DOE'S MOTION FOR INJUNCTION RESTRAINING FRAUDULENT TRANSFER OF ASSETS, APPOINTMENT OF A RECEIVER TO TAKE CHARGE OF PROPERTY OF EPSTEIN, AND TO POST A $15 MILLION BOND, TO SECURE POTENTIAL JUDGMENT COMES NOW Plaintiff Jane Doe, by and through undersigned counsel, and hereby files t
IS ASSETS. As noted in the material facts above, defendant Epstein is currently making fraudulent transfers of his
ork Time, July 1, 2008, at A2 ("Over the weekend Jeffrey E. Epstein, who after years of advising billionair
ork Time, July 1, 2008, at A2 ("Over the weekend Jeffrey E. Epstein, who after years of advising billionaire
#23. 14. Epstein has blocked all discovery, in this and other related cases, regarding his assets. Affidavit of Paul Cassell at ¶¶ 7, 8. ARGUMENT I. EPSTEIN IS FRAUDULENTLY TRANSFERRING HIS ASSETS. As noted in the material facts above, defendant Epstein is currently making fraudulent transfers of his as
ve person knowledge of the matters set forth herein. I am an attorney licensed to practice in the State of Utah since 1992. My office is located at the University of Utah College of Law, where I am a law professor. Along with other attorneys, I represent plaintiff Jane Doe in this matter. 2. It appears that defendant Jeffrey Epstei
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 M, a senior prosecutor who was pre
not necessary" (DE 17 at 1). 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. 6. On August 1, 2008, the victims filed a response to the Government's "Notice," giving a proposed statement of facts surroun
ic record that while still a prosecutor at the Office Mr. established his criminal defense office at the exact address (and exact Suite number) as Jeffrey 's personal business address. However, I did not have any direct ■ of contradicting sworn statement. Since then, however, in answering the victims'
the word "Epstein," ' " "Morrison," "Visoki," "Rogers," "Hammond," Roxburgh," " "Florida Science Foundation," "Starr... " "Black" "Goldberger," "Jeffrey," "Australian," "Lewis," "Sanchez," appears and which are connected to or related to Jeffrey Epstein, Jack Goldberger, or the Jeffrey Epstein inves
of course, is a defense attorney who represented defendant Epstein. Recording information provided by a defense att
riminal prosecution commensurate with the crimes Mr. Epstein has committed, and we further urge you to take th
ein case. This investigation was undertaken at the request of the victims in this case. On December 10, 2010, co-counsel, Professor Paul Cassell of the University of Utah College of Law, and I met with the U.S. Attorney for the Southern District of Florida regarding this case in the U.S. Attorney's Office in Miami, Florida. At on t
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
ein case. This investigation was undertaken at the request of the victims in this case. On December 10, 2010, co-counsel, Professor Paul Cassell of the University of Utah College of Law, and I met with the U.S. Attorney for the Southern District of Florida regarding this case in the U.S. Attorney's Office in Miami, Florida. At on t
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
not necessary" (DE 17 at 1). 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. 6. On August 1, 2008, the victims filed a response to the Government's "Notice," giving a proposed statement of facts surroun
Epstein," _ ' "Morrison," "Visoki," "Rogers," "Hammond," Roxburgh," "Villafana, " "Florida Science Foundation," "Starr," "Black," "Goldberger," "Jeffrey," "Australian," "Lewis," "Sanchez," "358 El Brillo Way" appears and which are connected to or related to Jeffrey Epstein, Jack Goldberger, or the J
of course, is a defense attorney who represented defendant Epstein. Recording information provided by a defense att
riminal prosecution commensurate with the crimes Mr. Epstein has committed, and we further urge you to take th
ein case. This investigation was undertaken at the request of the victims in this case. On December 10, 2010, co-counsel, Professor Paul Cassell of the University of Utah College of Law, and I met with the U.S. Attorney for the Southern District of Florida regarding this case in the U.S. Attorney's Office in Miami, Florida. At on t
r in good standing of the Bar of the State of Florida. Along with co-counsel, I have represented Jane Doe #1 and Jane Doe #2 in civil suits against Jeffrey Epstein for sexually abusing them. I have also represented other girls who were sexually abused by Epstein. As a result of that representation, I have becom
1 and Jane Doe #2 in civil suits against Jeffrey Epstein for sexually abusing them. I have also represented other girls who were sexually abused by Epstein. As a result of that representation, I have become familiar with many aspects of the criminal investigation against Epstein and have reviewed disco
t's desire that federal charges be filed against defendant Epstein. In particular, I wrote on behalf of my clients:
ne Doe #1 and Jane Doe #2 in civil suits against Jeffrey Epstein for sexually abusing them. I have also re
criminal prosecution commensurate with the crimes Mr. Epstein has committed, and we further urge you to take t
correspondence with the prosecutors. 23. Between July 2008 and September 2010, my co-counsel working on this matter (Professor Paul G. Cassell at the University of Utah College of Law) and I had numerous formal and informal contacts with the U.S. Attorney's Office regarding Epstein-related matters. In none of those contacts did t
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 a senior prosecutor who was present
not necessary" (DE 17 at 1). 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. 6. On August 1, 2008, the victims filed a response to the Government's "Notice," giving a proposed statement of facts surroun
stein," "Kllen "Ruboyo," "Morrison," "Visoki," "Rogers," "Hammond," Roxburgh," S, " "Florida Science Foundation," "Starr," "Black," "Goldberger," "Jeffrey," "Australian," "Lewis," "Sanchez," "358 El Brillo Way" appears and which are connected to or related to Jeffrey Epstein, Jack Goldberger, or the J
of course, is a defense attorney who represented defendant Epstein. Recording information provided by a defense att
riminal prosecution commensurate with the crimes Mr. Epstein has committed, and we further urge you to take th
ein case. This investigation was undertaken at the request of the victims in this case. On December 10, 2010, co-counsel, Professor Paul Cassell of the University of Utah College of Law, and I met with the U.S. Attorney for the Southern District of Florida regarding this case in the U.S. Attorney's Office in Miami, Florida. At on t
A00599889 Jeffrey Epstein's Level 3 sex offender status upheld by NY appeals court By Dareh Gregorian November 18, 2011 5:00am Multimillionaire pery Jeffrey Epstein may not consider his Florida conviction for soliciting a minor a big deal, but New York does. A state appeals court yesterday upheld the financier'
office in Dade County. The causes of action and damages against Defendant Jeffrey Epstein accrued in Dade County, Florida, due to specific acts by Epstein there, and accordingly, venue is appropriate there. Florida Statute 47.011. 2. Florida Statute 48.193(1)(a)(I) ("long-arm") authorizes service on
. Plaintiffs have been damaged by the conduct of Defendant Epstein, and have accordingly retained undersigned couns
nal Service on a Natural Person VS. DEFENDANT(' JEFFREY EPSTEIN. TYLER MCDONALD. TYLER MCDONALD D/B/A
ot be any pending criminal investigations, given Mr. Epstein's complete fulfillment of all the terms of his no
al with the . Justice Department (1986-88), and an Assistant M. Attorney for the Eastern District of (1988 to 1991). Cassell joined the faculty at the University of Utah College of Law in 1992, where he taught full time until he was sworn in as a E. District Court Judge for the District of Utah in 2002.1n 2007. he resigned his jud
n’s private jets. The U.S. Attorney General’s Office in Florida says that it is against policy to confirm or deny the existence of an investigation. Jeffrey Epstein’s lawyer, Jack Goldberger, says he has no knowledge of an ongoing probe, and he told The Daily Beast, "Jeffrey Epstein has fully complied with all stat
an office in Dade County. The causes of action and damages against Defendant Jeffrey Epstein accrued in Dade County, Florida, due to specific acts by Epstein there, and accordingly, venue is appropriate there. Florida Statute 47.011. Ds Florida Statute 48.193(1)(a)(1) (‘long-arm”’) authorizes service on b
4. Plaintiffs have been damaged by the conduct of Defendant Epstein, and have accordingly retained undersigned counse
Natural Person VS. DEFENDANT(S) JEAN-LUC BRUNEL JEFFREY EPSTEIN, TYLER MCDONALD, TYLER MCDONALD D/B/A Y
not be any pending criminal investigations, given Mr. Epstein’s complete fulfillment of all the terms of his no
U.S. Justice Department (1986-88), and an Assistant U.S. Attorney for the Eastern District of Virginia (1988 to 1991). Cassell joined the faculty at the University of Utah College of Law in 1992, where he taught full time until he was sworn in as a U.S. District Court Judge for the District of Utah in 2002. In 2007, he resigned his ju
nt to the victims in this case is clear. In 2007, the FBI determined that both Jane Doe No. I and Jane Doe No. 2 were victims of sexual assaults by Epstein while they were minors beginning when they were approximately fourteen years of age and approximately thirteen years of age respectively. These sexu
of Epstein's sex offenses in Federal Court — Jane Doe No. 1, Jane Doe No. 2, and a victim I will refer to as "S.R." and "M.J.", and other victims of Jeffrey Epstein's abuse as well. If further information is disclosed about this case, that will not discourage them from providing information, but rather will encou
he word "Epstein," " "Morrison," "Visoki," "Rogers," "Hammond," Roxburgh,' r afana, " "Florida SS Foundation," "Starr," "Black," "Goldberger," "Jeffrey," "Australian,"' "Sanchez," "358 El Brillo Way" appears and which are connected to or related to Jeffrey Epstein, Jack Goldberger, or the Jeffrey
t's desire that federal charges be filed against defendant Epstein. In particular, I wrote on behalf of my clients:
riminal prosecution commensurate with the crimes Mr. Epstein has committed, and we further urge you to take th
ein case. This investigation was undertaken at the request of the victims in this case. On December 10, 2010, co-counsel, Professor Paul Cassell of the University of Utah College of Law, and I met with the U.S. Attorney for the Southern District of Florida regarding this case in the U.S. Attorney's Office in Miami, Florida. At on t
Entities connected to both Jeffrey Epstein and the University of Utah College of Law

Lesley Groff
PERSON
Marc Rich
PERSONLarry Visoski
PERSONLeon Black
PERSON
Prince Andrew
PERSON
Ghislaine Maxwell
PERSON
Alan Dershowitz
PERSON
Donald Trump
PERSON
Bradley Edwards
PERSON
United States
LOCATION
Stephen Hawking
PERSONJack Goldberger
PERSON
Joe Biden
PERSON
Michael Wolff
PERSONJane Doe
PERSON
Department of Justice
ORGANIZATIONMaria Farmer
PERSON
Jean-Luc Brunel
PERSONMartin Weinberg
PERSON
Kenneth Marra
PERSON