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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
s, the word "case" is a term of an that has long been understood to mean "a suit instituted according to the regular course of judicial procedure." Muskrat' United States, 219 U.S. 346, 356 (1911) (Article III "case" or controversy); see also Black's Law Dictionary (6th ed.) 215 ("case" is a "general te
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
s, the word "case" is a term of art that has long been understood to mean "a suit instituted according to the regular course of judicial procedure." Muskrat v. United States , 219 U.S. 346, 356 (1911) (Article III "case" or controversy); see also Black's Law Dictionary (6th ed.) 215 ("case" is a "genera
stitution, laws or treaties of the United States takes such a form that the judicial power is capable of acting upon it, then it has become a case." Muskrat , 219 U.S. at 356. A "case," in other words, is an adversarial dispute where one party purposefully invokes the judicial power seeking an adjudicati
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
titution, laws or treaties of the United States takes such a form that the judicial power is capable of acting upon it, then it has become a case." Muskrat, 219 U.S. at 356. A "case," in other words, is an adversarial dispute where one party purposefully invokes the judicial power seeking an adjudicatio
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, Ann Marie Villafana, end I were assigned to different sections within the Office. We reported to different supervisors. 11. I did not partic
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
, the word "case" is a term of art that has long been understood to mean "a suit instituted according to the regular course of judicial procedure." Muskrat' United States, 219 U.S. 346, 356 (1911) (Article HI "case" or controversy); see also Black's Law Dictionary (6th ed.) 215 ("case" is a "general ter
What was he inquiring about? 4 A. My response to Jeffrey Epstein's comments. 5 Q. Which comments? 6 A. A telephone conversation initiated by Jeffrey 7 Epstein to George Rush related to the various cases and claims against Mr. Epstein. C) Q. Did Mr. Rush call you -- I'm sorry, I will improve it. If I un
nquiring as to whether such a 4 conversation occurred with regard to any of the 5 three individuals who he is representing claims 6 against Mr. Epstein or the U.S. Attorney's Office, correct? 8 MR. CRITTON: Say that again? 9 MR. SCAROLA: Yes, sir. Are you asking 10 whether such conversations o
w long have 2 your conversations been? 3 A. Short. 4 Q. And with regard to George Rush, what, you 5 said he was interested in talking about Jeffrey 6 Epstein. What was he interested in? 7 A. I don't remember specifically the issue, but 8 it seemed to me that he came to me with an issue eac
viduals who he is representing claims 6 against Mr. Epstein or the U.S. Attorney's Office, correct? 8 MR.
a Page 2 or something with the, 2 Page 1, Page 2 of the Palm Beach Post? 3 A. No. I'm not, no. 4 Q. Okay. Have you ever spoken with Jane 5 Muskrat (phonetic)? 6 A. Again, I don't know who that is. 7 Q. Have you ever -- did you ever give or 8 allow one of your clients to give an interview
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
titution, laws or treaties of the United States takes such a form that the judicial power is capable of acting upon it, then it has become a case." Muskrat, 219 U.S. at 356. A "case," in other words, is an adversarial dispute where one party purposefully invokes the judicial power seeking an adjudicatio
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
titution, laws or treaties of the United States takes such a form that the judicial power is capable of acting upon it, then it has become a case." Muskrat, 219 U.S. at 356. A "case," in other words, is an adversarial dispute where one party purposefully invokes the judicial power seeking an adjudicatio
Entities connected to both Jeffrey Epstein and Muskrat
Leon Black
PERSON
Prince Andrew
PERSON
Joi Ito
PERSON
Eric Trump
PERSON
Bradley Edwards
PERSON
United States
LOCATION
Sarah Kellen
PERSONJane Doe
PERSON
Martha Stewart
PERSON
Department of Justice
ORGANIZATIONMaria Farmer
PERSON
Kenneth Marra
PERSONthe Southern District
LOCATION
Paul Cassell
PERSONFBI
ORGANIZATION
A. Marie Villafana
PERSON
Virginia Giuffre
PERSON
Scarlett Johansson
PERSON
Michael Jackson
PERSON
Eric Holder
PERSON