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

3), and Intercontinental Thavel 44 EFTA00230109 ovenfiedry#, Case 9:08-cv-80736-KAM Document 62 Entered on FLSD Docket 04/08/2011 Page 45 of 54 Marketing, Inc. v. FDIC, 45 F.3d 1278, 1286 (9' Cir. 1994)("Estoppel may not prevent an objection to subject matter jurisdiction, because such an objection to subje

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

(611' Cir. 1993), and Intercontinental Travel 44 EFTA00078878 Case 9:08-cv-80736-KAM Document 62 Entered on FLSD Docket 04/08/2011 Page 45 of 54 Marketing, Inc. v. FDIC, 45 F.3d 1278, 1286 (9ih Cir. 1994)("Estoppel may not prevent an objection to subject matter jurisdiction, because such an objection to subj

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

Exhibit A Case No. 08-80736-CIV-MARRAMOHNSON EFTA00208080 Case 9:08-cv-80736-KAM Document 57-1 Entered on FLSD Docket 04/07/2011 Page 45 of 54 Marketing, Inc. v. FDIC, 45 F.3d 1278, 1286 (9ih Cir. 1994)("Estoppel may not prevent an objection to subject matter jurisdiction, because such an objection to subj