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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. 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
9:08-cv-80736-KAM Document 62 Entered on FLSD Docket 04/08/2011 Page 50 of 54 Court should consider a comment from Washington Supreme Court Justice James M. Dolliver: "[E]mphasizing the conflict between the victim and the accused and placing the victim in the role of a quasi-prosecutor or co-counsel . . . repres
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
9:08-cv-80736-KAM Document 62 Entered on FLSD Docket 04/08/2011 Page 50 of 54 Court should consider a comment from Washington Supreme Court Justice James M. Dolliver: "[E]mphasizing the conflict between the victim and the accused and placing the victim in the role of a quasi-prosecutor or co-counsel. . . represe
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
8-cv-80736-KAM Document 57-1 Entered on FLSD Docket 04/07/2011 Page 50 of 54 Court should consider a comment from Washington Supreme Court Justice James M. Dolliver: "[E]mphasizing the conflict between the victim and the accused and placing the victim in the role of a quasi-prosecutor or co-counsel. . . represe
reference 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
etitioners, or the defense attorneys representing Jeffrey Epstein. Nor are the subjective beliefs of DOJ e
ed to the remedy that they at one time disavowed — setting aside the NPA — the Court should consider a comment from Washington Supreme Court Justice James M. Dolliver: "[E]mphasizing the conflict between the victim and the accused and placing the victim in the role of a quasi-prosecutor or co-counsel ... represen
the initial hearing on the Emergency Petition, Petitioners stated that their desired result was the setting aside of the NPA and the prosecution of Epstein. At the second hearing on the matter, counsel stated that they no longer wanted that remedy and stated that they would inform the Court of their de
ed to the remedy that they at one time disavowed — setting aside the NPA — the Court should consider a comment from Washington Supreme Court Justice James M. Dolliver: "[E]mphasizing the conflict between the victim and the accused and placing the victim in the role of a quasi-prosecutor or co-counsel . . . represe
Entities connected to both Jeffrey Epstein and James M. Dolliver
Leon Black
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Prince Andrew
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Eric Trump
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Bradley Edwards
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United States
LOCATIONJane Doe
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Martha Stewart
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Department of Justice
ORGANIZATIONMaria Farmer
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Kenneth Marra
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Paul Cassell
PERSONFBI
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Virginia Giuffre
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Scarlett Johansson
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Michael Jackson
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Eric Holder
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Southern District of New York
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Salt Lake City
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Michigan
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