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) & (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
ty in his sentence until the [review by writ] is concluded ...."' LAFAVE ET AL., CRIMINAL Procedure § 26.7(b) (Nov. 2010) (quoting United States v. DiFrancesco, 449 U.S. 117, 146 (1980)). 40 EFTA00079032 Case 9:08-cv-80736-KAM Document 48 Entered on FLSD Docket 03/21/2011 Page 41 of 42 DATED: March 21,2
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
ty in his sentence until the [review by writ] is concluded ...."' LAFAVE ET AL., CRIMINAL Procedure § 26.7(b) (Nov. 2010) (quoting United States v. DiFrancesco, 449 U.S. 117, 146 (1980)). 39 EFTA00207918 reason, it makes sense for the Court to bifurcate the process and determine, first, the extent of the
) & (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
y in his sentence until the [review by writ] is concluded ...."' LAFAvs El' AL., CRIMINAL Procedure § 26.7(b) (Nov. 2010) (quoting United States v. DiFrancesco, 449 U.S. 117, 146 (1980)). 40 EFTA00208413 Case 9:08-cv-80736-KAM Document 48 Entered on FLSD Docket 03/21/2011 Page 41 of 42 DATED: March 21.
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
in his sentence until the [review by writ] is concluded . . ..'" LAFAVE ET AL., CRIMINAL Procedure § 26.7(b) (Nov. 2010) (quoting United States v. DiFrancesco, 449 U.S. 117, 146 (1980)). 40 EFTA00210829 Case 9:08-cv-80736-KAM Document 48 Entered on FLSD Docket 03/21/2011 Page 41 of 42 DATED: March 21.
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
ality in his sentence until the [review by writ] is concluded ...."' LAFAVE ET AL., CRIMINAL Procedure § 26.7(b) (Nov. 2010) (quoting United States DiFrancesco, 449 U.S. 117, 146 (1980)). 39 EFTA00235789 reason, it makes sense for the Court to bifurcate the process and determine, first, the extent of the
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
ch re Travel for Prostitution" containing attorney (Villafafta) handwritten notes regarding grand jury presentation, chart entitled "Brought to Epstein's House" with handwritten notes, Message Pad meta- analysis chart, summary of evidence related to one victim/witness, and relevant grand jury inf
serted Victims' Objections Box #3 Folder entitled "Responses to Arguments Work product No Factual Underpinnings; Fiduciary Duty; P-011923 from JE Counsel" containing: Deliberative process Crime-Fraud-Misconduct; Crime-Fraud- Thru ■ 7/13/2007 letter from Lilly Ann 6(e) Misconduct; Not in A
of course, is a defense attorney who represented defendant Epstein. Recording information provided by a defense att
net (617) 338-9538 Criminal Defense Counsel for Jeffrey Epstein /s/ Bradley J. Edwards 3 EFTA00179621
rom Stake Center and other victims, and pleaded guilty to one count of tax evasion and three counts of wire fraud. Pursuant to her plea agreement, DiFrancesco agreed to make restitution to Stake ' Stake Center previously petitioned this court for mandamus, and we denied this petition as premature. See Sta
Entities connected to both Jeffrey Epstein and DiFrancesco

Marc Rich
PERSONLarry Visoski
PERSON
Prince Andrew
PERSON
Ghislaine Maxwell
PERSON
Alan Dershowitz
PERSON
Madison
LOCATION
George W. Bush
PERSON
Bradley Edwards
PERSON
United States
LOCATIONJack Goldberger
PERSON
Sarah Kellen
PERSONJane Doe
PERSON
Department of Justice
ORGANIZATIONMaria Farmer
PERSON
Jean-Luc Brunel
PERSON
Kenneth Marra
PERSON
Bill Clinton
PERSON
Alexander Acosta
PERSONthe Southern District
LOCATION
Paul Cassell
PERSON