Epstein Secrets

f Corporations' documents show that the Florida Science Foundation was incorporated in November 2007, not a "couple of years ago" as reported by Mr. Epstein. Me address provided for the "office" of the Florida Science Foundation is Jack Goldberger's office suite, and neither the office building director

) & (8). It is now beyond dispute, for example, that in September 2007, the U.S. Attorney's Office formally signed a non-prosecution agreement with Jeffrey Epstein that barred his The victims are contemporaneously filing a motion to have their facts accepted by the Court. EFTA00185009 Case 9.03-evallf/35-Il

2007, not a "couple of years ago" as reported by Mr. Epstein. Me address provided for the "office" of the Flo

s of the CVRA and, indeed, pressured the U.S. Attorney's Office to commit these violations. Tr. July 11, 2008, at 9. 26. On about December 6, 2007, Jeffrey H. First Assistant U.S. Attorney sent a letter to Jay Lefkowitz, noting the U.S. Attorney's Office's legal obligations to keep victims informed of th

ome sort of objection from defendant Epstein. The U.S. Attorney's Office, however, rejected those objections In a letter on about December 6, 2007, Jeffrey First Assistant U.S. Attorney again sent a letter to Jay Lefkowitz, reiterating the U.S. Attorney's Office's legal obligations to keep victims The

t's desire that federal charges be filed against defendant Epstein. In particular, he wrote on behalf of his clients

nce with regard to the acts, Conduct, or acquiescence; (3) detrimental reliance; and (4) affirmative misconduct by the Government. United States'. McCorkle, 321 F.3d 1292 (I l" Cir. 2003). Each of these four factors is easily met here. 33 EFTA00185041 Case 90B-cava7236-11CMil Banuarand 3162- etas* R

ring on Appropriate Remedies (unredacted), and a complete set of exhibits, including the e-mails in Exhibit A. The e-mails in Exhibit A are between Epstein's defense attorney and AUSA Villafaba. They were produced in civil litigation between Epstein and some of his victims. Epstein's attorneys redacted

e 15th Judicial Circuit in and for Palm Beach County (tereinaRer, the "State Attorney's Office") have conducted an investigation into the conduct of Jeffrey Epstein (hereinafter "Epstein"); IT APPEARING that the State Attorney's Of fice has charged Epstein by indictment with solicitation of prostitution, in vio

criminal prosecution commensurate with the crimes Mr. Epstein has committed, and we further urge you to take t

t's desire that federal charges be filed against defendant Epstein. In particular, he wrote on behalf of his clients

formally signed a non-prosecution agreement with Jeffrey Epstein that barred his I The victims are contem

li also stated that KELLEN ,has twin, boys . recalled seeing sculptures of kids in the library. naked Women and lots stated that everybody thought Epsteirt SI was a 08-80736-CV-MARRA 000748' EFTA00230572 Case 9:08-cv-80736-KAM Document 48-9 Entered on FLSD Docket 03/21/2011 Page 1 of 3 JANE DOE #

ement barring federal prosecution of their oases because of a deliberate decisions by the U.S. Attorney's Office, not mere "negligence or inaction." McCorkle, 321 F.3d at 1297. Accordingly, the Government is stopped from arguing that the Crime Victims' Rights Act does not apply to this case. IL THE COU

) & (8). It is now beyond dispute, for example, that in September 2007, the U.S. Attorney's Office formally signed a non-prosecution agreement with Jeffrey Epstein that barred his The victims are contemporaneously filing a motion to have their facts accepted by the Court. EFTA00078993 Case 9:08-cv-80736-KAM

ein agreed to a "confidentiality" provision in the agreement barring its disclosure to anyone — including the victims. For the next nine months, as Epstein was well aware, the U.S. Attorney's Office assiduously concealed from the victims the existence of this signed non-prosecution agreement. Indeed, th

t's desire that federal charges be filed against defendant Epstein. In particular, he wrote on behalf of his clients

formally signed a non-prosecution agreement with Jeffrey Epstein that barred his The victims are contempo

criminal prosecution commensurate with the crimes Mr. Epstein has committed, and we further urge you to take t

ce with regard to the acts, conduct, or acquiescence; (3) detrimental reliance; and (4) affirmative misconduct by the Government. United States v. McCorkle, 321 F.3d 1292 (11th Cir. 2003). Each of these four factors is easily met here. 33 EFTA00079025 Case 9:08-cv-80736-KAM Document 48 Entered on FL

tz, defense counsel for Jeffrey Epstein. The notification letter would have explained: "I am writing to inform you that the federal investigation of Jeffrey Epstein has been completed, and Mr. Epstein and the U.S. Attorney's Office have reached an agreement containing the following terms . . . ." The letter then

ein agreed to a "confidentiality" provision in the agreement barring its disclosure to anyone — including the victims. For the next nine months, as Epstein was well aware, the U.S. Attorney's Office assiduously concealed from the victims the existence of this signed non-prosecution agreement. Indeed, th

t's desire that federal charges be filed against defendant Epstein. In particular, he wrote on behalf of his clients

formally signed a non-prosecution agreement with Jeffrey Epstein that barred his ' The victims are contem

l: "On an 'avoid the press' note, I believe that Mr. Epstein's airplane was in Miami on the day of the Ms. Gro

ce with regard to the acts, conduct, or acquiescence; (3) detrimental reliance; and (4) affirmative misconduct by the Government. United States v. McCorkle, 321 F.3d 1292 (11'" Cir. 2003). Each of these four factors is easily met here. First, the Government made statements to the victims that induced r

) & (8). It is now beyond dispute, for example, that in September 2007, the U.S. Attorney's Office formally signed a non-prosecution agreement with Jeffrey Epstein that barred his The victims are contemporaneously filing a motion to have their facts accepted by the Court. EFTA00208374 Case 9:08-cv-80736-KM/

ein agreed to a "confidentiality" provision in the agreement barring its disclosure to anyone — including the victims. For the next nine months, as Epstein was well aware, the U.S. Attorney's Office assiduously concealed from the victims the existence of this signed non-prosecution agreement. Indeed, th

t's desire that federal charges be filed against defendant Epstein. In particular, he wrote on behalf of his clients

formally signed a non-prosecution agreement with Jeffrey Epstein that barred his The victims are contempo

criminal prosecution commensurate with the crimes Mr. Epstein has committed, and we further urge you to take t

ce with regard to the acts, conduct, or acquiescence; (3) detrimental reliance; and (4) affirmative misconduct by the Government. United States v. McCorkle, 321 F.3d 1292 (11th Cir. 2003). Each of these four factors is easily met here. 33 EFTA00208406 Case 9:08-cv-80736-KAM Document 48 Entered on F

t's desire that federal charges be filed against defendant Epstein. In particular, he wrote on behalf of his clients

ls the victims of federal sex crimes committed by Jeffrey Epstein ...." As you know, in 2008 your Office d

criminal prosecution commensurate with the crimes Mr. Epstein has committed, and we further urge you to take t

confer with the attorney for the Government in the case"). Two days later (July 91h), the Government sent her a notice that, in light of defendant, Jeffrey Epstein's entry of guilty pleas to various state charges and 18-month jail sentence, the Government had agreed to defer all federal prosecution — including a

y Epstein ...." As you know, in 2008 your Office did not object to adding Jane Doe No. 2 into this litigation, recognizing that she was a victim of Epstein's crimes and had interests at stake in the case. We continue to be perplexed that you are not extending the same consideration to Jane Doe No. 3 an

ce with regard to the acts, conduct, or acquiescence; (3) detrimental reliance; and (4) affirmative misconduct by the Government. United States v. McCorkle, 321 F.3d 1292 (11a ' Cir. 2003). Each of these four factors is easily met here. 33 EFTA00210822 Case 9:08-cv-80736-KAM Document 48 Entered on F

tz, defense counsel for Jeffrey Epstein. The notification letter would have explained: "I am writing to inform you that the federal investigation of Jeffrey Epstein has been completed, and Mr. Epstein and the U.S. Attorney's Office have reached an agreement containing the following terms . . . ." The letter then

ein agreed to a "confidentiality" provision in the agreement barring its disclosure to anyone — including the victims. For the next nine months, as Epstein was well aware, the U.S. Attorney's Office assiduously concealed from the victims the existence of this signed non-prosecution agreement. Indeed, th

l: "On an 'avoid the press' note, I believe that Mr. Epstein's airplane was in Miami on the day of the la tel

t's desire that federal charges be filed against defendant Epstein. In particular, he wrote on behalf of his clients

formally signed a non-prosecution agreement with Jeffrey Epstein that barred his ' The victims are contem

ence with regard to the acts, conduct, or acquiescence; (3) detrimental reliance; and (4) affirmative misconduct by the Government. United States. McCorkle, 321 F.3d 1292 (11'" Cir. 2003). Each of these four factors is easily met here. First, the Government made statements to the victims that induced r

ring on Appropriate Remedies (unredacted), and a complete set of exhibits, including the e-mails in Exhibit A. The e-mails in Exhibit A are between Epstein's defense attorney and AUSA Villafalta. They were produced in civil litigation between Epstein and some of his victims. Epstein's attorneys redacted

e 15th Judicial Circuit in and for Palm Beach County (tereinaRer, the "State Attorney's Office") have conducted an investigation into the conduct of Jeffrey Epstein (hereinafter "Epstein"); IT APPEARING that the State Attorney's Of fice has charged Epstein by indictment with solicitation of prostitution, in vio

t's desire that federal charges be filed against defendant Epstein. In particular, he wrote on behalf of his clients

formally signed a non-prosecution agreement with Jeffrey Epstein that barred his I The victims are contem

criminal prosecution commensurate with the crimes Mr. Epstein has committed, and we further urge you to take t

ement barring federal prosecution of their oases because of a deliberate decisions by the U.S. Attorney's Office, not mere "negligence or inaction." McCorkle, 321 F.3d at 1297. Accordingly, the Government is stopped from arguing that the Crime Victims' Rights Act does not apply to this case. IL THE COU

) & (8). It is now beyond dispute, for example, that in September 2007, the U.S. Attorney's Office formally signed a non-prosecution agreement with Jeffrey Epstein that barred his The victims are contemporaneously filing a motion to have their facts accepted by the Court. EFTA00177009 Case 9:08-cv-80736-KAM

ein agreed to a "confidentiality" provision in the agreement barring its disclosure to anyone — including the victims. For the next nine months, as Epstein was well aware, the U.S. Attorney's Office assiduously concealed from the victims the existence of this signed non-prosecution agreement. Indeed, th

t's desire that federal charges be filed against defendant Epstein. In particular, he wrote on behalf of his clients

formally signed a non-prosecution agreement with Jeffrey Epstein that barred his The victims are contempo

criminal prosecution commensurate with the crimes Mr. Epstein has committed, and we further urge you to take t

ence with regard to the acts, conduct, or acquiescence; (3) detrimental reliance; and (4) affirmative misconduct by the Government. United States' McCorkle, 321 F.3d 1292 (11th Cir. 2003). Each of these four factors is easily met here. 33 EFTA00177041 Case 9:08-cv-80736-KAM Document 48 Entered on F

S. 427, 87 S.Ct. 1 , 18 L. Ed.2d 865 (1967); Buchanan Rhodes. 885 U.S. 3, 87 S.Ct. 83, 17 .Ed.2d 9 (1966); Idlewild Bon Voyage Liquor Corp. v. Epstein, 370 U.S. 713, 82 S.Ct. 1294, 8 L.Ed2d 794 (1962). Since in this case we affirm that refusal, we need not now decide whether or not there is juri

, Gary A. Hughes, J.D, Steven D. Najarian, J.D., Jeffrey A. Schafer, J.D., and Jeffrey J. Shampo, J.D. II

tion of the chal- lenged activity if the actions are capable (1) of repetition and (2) of evading review. See, e.g., Super Tire Engineering Co. v. McCorkle, 416 U.S. 115, 122, 94 S.Ct. 1694, 1698, 40 L.Ed.2d 1 (1974). Finally, the existence of "a public interest in having the legality of the practice