Epstein Secrets

l relevant times, the Office had approximately 20 Assistant U.S. Attorneys assigned to the West Palm Beach location. The prosecutor assigned to the Epstein case, I I end I were assigned to different sections within the Office. We reported to different supervisors. 11. I did not participate in any way

ent 79 Entered on FLSD Docket 05/03/2011 Page 2 of 4 violated Florida Bar rules and Department of Justice regulations by representing employees of Jeffrey Epstein ("Epstein") in civil litigation after the undersigned retired from the United States Attorney's Office for the Southern District of Florida (the "Of

Justice regulations by representing employees of Jeffrey Epstein ("Epstein") in civil litigation after the

s retained to represent several other members of Mr. Epstein's staff in their civil depositions. I5.. After

urposes of the CVRA definition of 'crime victim,' the only material federal offenses are those for which there is a conviction or plea." M., citing Hughey v. United States, 495 U.S. 411, 418 (1979), and In Re 28 EFTA00230093 Case 9:08-cv-80736-KAM Document 62 Entered on FLSD Docket 04/08/2011 Page 29 of 54 Rendon

eference to the position taken by employees of the Department of Justice (DOJ) in letters to the petitioners, or the defense attorneys representing Jeffrey Epstein. Nor are the subjective beliefs of DOJ employees relevant to the issue of whether a duty existed under § 3771(a)(5) to consult with petitioners prio

later, on July 9, 2008, the Government filed its Response and an accompanying Declaration, establishing that (1) no federal criminal case charging Epstein had ever been filed and that a non- prosecution agreement ("NPA") had been signed and (2) despite this, the U.S. Attorney's Office had used its best

titioners, or the defense attorneys representing Jeffrey Epstein. Nor are the subjective beliefs of DOJ em

rposes of the CVRA definition of 'crime victim,' the only material federal offenses are those for which there is a conviction or plea." Id., citing Hughey v. United States, 495 U.S. 411, 418 (1979), and In Re 28 EFTA00078862 Case 9:08-cv-80736-KAM Document 62 Entered on FLSD Docket 04/08/2011 Page 29 of 54 Rendon G

eference to the position taken by employees of the Department of Justice (DOJ) in letters to the petitioners, or the defense attorneys representing Jeffrey Epstein. Nor are the subjective beliefs of DOJ employees relevant to the issue of whether a duty existed under § 3771(a)(5) to consult with petitioners prio

later, on July 9, 2008, the Government filed its Response and an accompanying Declaration, establishing that (1) no federal criminal case charging Epstein had ever been filed and that a non- prosecution agreement ("NPA") had been signed and (2) despite this, the U.S. Attorney's Office had used its best

titioners, or the defense attorneys representing Jeffrey Epstein. Nor are the subjective beliefs of DOJ em

rposes of the CVRA definition of 'crime victim,' the only material federal offenses are those for which there is a conviction or plea." Id., citing Hughey v. United States, 495 U.S. 411, 418 (1979), and In Re 28 Respondent's Exhibit A Case No. 08-80736-CIV-MARRA/JOHNSON EFTA00208064 Case 9:08-cv-80736-KAM Document