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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
51 EFTA00177101 Case 9:08-cv-80736-KAM Document 62 Entered on FLSD Docket 04/08/2011 Page 52 of 54 cannot be granted. Continental Casualty Co.l Fibreboard Corp., 4 F.3d 777, 778 (9i° Cir. 1993). The non-prosecution agreement in this case was signed in 2007, and Epstein entered his pleas of guilty in July 20
ted. Continental Casualty Co. v. Fibreboard Corp., 4 F.3d 777, 778 (' Cir. 1993). The non-prosecution agreement in this case was signed in 2007, and Epstein entered his pleas of guilty in July 2008, in Florida circuit court. I k was sentenced by the state court, and has served his sentence. Individuals
n for sexually abusing them. During the course of that litigation, in June 2001, they obtained correspondence between the U.S. Attorney's Office and Jeffrey Epstein's legal counsel. Jane Doe #1 and Jane Doe #2 ultimately settled their civil suits in July 2010. During the settlement discussions, they informed Epste
hether a charging document was ever filed against Jeffrey Epstein in the United States District Court for
in "the same position as they would have been had Mr. Epstein been convicted at trial." Declaration of Marie V
51 EFTA00230116 Case 9:08-cv-80736-KAM Document 62 Entered on FLSD Docket 04/08/2011 Page 52 of 54 cannot be granted. Continental Casualty Co. v. Fibreboard Corp., 4 F.3d 777, 778 (' Cir. 1993). The non-prosecution agreement in this case was signed in 2007, and Epstein entered his pleas of guilty in July 2008
nted. Continental Casualty Co.'. Fibreboard Corp., 4 F.3d 777, 778 (' Cir. 1993). The non-prosecution agreement in this case was signed in 2007, and Epstein entered his pleas of guilty in July 2008, in Florida circuit court. I k was sentenced by the state court, and has served his sentence. Individuals
n for sexually abusing them. During the course of that litigation, in June 2001, they obtained correspondence between the U.S. Attorney's Office and Jeffrey Epstein's legal counsel. Jane Doe #1 and Jane Doe #2 ultimately settled their civil suits in July 2010. During the settlement discussions, they informed Epste
hether a charging document was ever filed against Jeffrey Epstein in the United States District Court for
in "the same position as they would have been had Mr. Epstein been convicted at trial." Declaration of Marie V
870 EFTA00230694 Case 9:08-cv-80736-KAM Document 62 Entered on FLSD Docket 04/08/2011 Page 52 of 54 cannot be granted. Continental Casualty Co.'. Fibreboard Corp., 4 F.3d 777, 778 (' Cir. 1993). The non-prosecution agreement in this case was signed in 2007, and Epstein entered his pleas of guilty in July 2008
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
51 EFTA00078885 Case 9:08-cv-80736-KAM Document 62 Entered on FLSD Docket 04/08/2011 Page 52 of 54 cannot be granted. Continental Casualty Co. v. Fibreboard Corp., 4 F.3d 777, 778 (9ih Cir. 1993). The non-prosecution agreement in this case was signed in 2007, and Epstein entered his pleas of guilty in July 20
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
EFTA00208087 Case 9:08-cv-80736-KAM Document 57-1 Entered on FLSD Docket 04/07/2011 Page 52 of 54 cannot be granted. Continental Casualty Co. v. Fibreboard Corp., 4 F.3d 777, 778 (9ih Cir. 1993). The non-prosecution agreement in this case was signed in 2007, and Epstein entered his pleas of guilty in July 20
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
is not always the case. Indeed, courts have recognized that a controversy is moot if effective relief cannot be granted. Continental Casualty Co. v. Fibreboard Corp. , 4 F.3d 777, 778 (9 di Cir. 1993). The non-prosecution agreement in this case was signed in 2007, and Epstein entered his pleas of guilty in July
Entities connected to both Jeffrey Epstein and Fibreboard Corp.
Leon Black
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Prince Andrew
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Woody Allen
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Eric Trump
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George W. Bush
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Bradley Edwards
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United States
LOCATIONJane Doe
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Martha Stewart
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Barry Diller
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Department of Justice
ORGANIZATIONMaria Farmer
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Kenneth Marra
PERSONthe Southern District
LOCATION
Paul Cassell
PERSONFBI
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A. Marie Villafana
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Virginia Giuffre
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Scarlett Johansson
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Michael Jackson
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