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011 Pages w/cover: 4 Fax #: Direct #: Please see the attached letter, in response to your letter to Martin Weinberg of July 27, 2011, concerning Jeffrey Epstein. Thank you. Documena EFTA00180294 07/29/2011 13: 12 FAX a 002/004 Jay P. LeatowItz. P.C. To ilaiactly: jay.lefkowitzekirklend.cOm KIRKLAND &
oncerning the request by the New York District Attorney for copies of the Non-Prosecution Agreement ("NPA") and the "victim list" in regards to Mr. Epstein. We continue for the reasons stated herein to believe that any such disclosure would violate the confidentiality agreement between your Office and
Jack 2:114:5 jackpot 32:9 jail 41:7 Jane 1:4,15,18,22 2:3,7 3:5,5,7,11 5:17 6:8,9,16 11:12 21:4 29:14 29:22 33:5 35:13 42:22 Jay 2:20 4:18 Jeffrey 1/ 37:12 jeopardize 9:15 Jeopardy 15:17 join 26:11,15 Josefsberg 2:1,2,5 3:18,20,21,23 19:7 19:7,1021:25 23:1 24:5 25:25 26:7,11 26:12,16 27:
ourt. I was• later 20 informed that it was a deposition. 21 Q. I'm going to ask you some questions now 22 about what happened when you went to Jeff Epstein's house 23 three years ago. Okay? 24 A. Oh-huh. 25 Q. When the police interviewed you one month Ph. 561.682.0905 - Fax. 561.682.1771 1655 Pal
. § 1446, this notice of removal is timely. Only defendant Epstein has been served with process. Defendants 21 Lew
ment ("NPA") and the "victim list" in regards to Mr. Epstein. We continue for the reasons stated herein to be
United States Court of Appeals for the Filth Circuit handed down prior to September 30, 1981, are binding as precedent in the Eleventh Circuit. $.0 Bonner v. City of Prichard, Ala , 661 F.2d 1206, 1207 (11th Cir. 1981). K&E 19439748.2 EFTA00180297 Rov BLACK HOWARD M. SREBNICK Scorer A. KORNSPAN LARRY A. STUMPF MAR
nt to the victims in this case is clear. In 2007, the FBI determined that both Jane Doe No. I and Jane Doe No. 2 were victims of sexual assaults by Epstein while they were minors beginning when they were approximately fourteen years of age and approximately thirteen years of age respectively. These sexu
of Epstein's sex offenses in Federal Court — Jane Doe No. 1, Jane Doe No. 2, and a victim I will refer to as "S.R." and "M.J.", and other victims of Jeffrey Epstein's abuse as well. If further information is disclosed about this case, that will not discourage them from providing information, but rather will encou
he word "Epstein," " "Morrison," "Visoki," "Rogers," "Hammond," Roxburgh,' r afana, " "Florida SS Foundation," "Starr," "Black," "Goldberger," "Jeffrey," "Australian,"' "Sanchez," "358 El Brillo Way" appears and which are connected to or related to Jeffrey Epstein, Jack Goldberger, or the Jeffrey
t's desire that federal charges be filed against defendant Epstein. In particular, I wrote on behalf of my clients:
riminal prosecution commensurate with the crimes Mr. Epstein has committed, and we further urge you to take th
aries of its actions with the stockholders. Id Since that 7 See Knight v. Thompson, ---F.3d---, 2013 WI, 3843803 at *5 n.5 (11th Cir. 2013) (citing Bonner v. City of Prichard, 661 F.2d 1206, 1209 (11th Cir. 1981) (en bane) (11th Circuit adopts as binding precedent all decisions of the former Fifth Circuit handed down prio
' Rights Act ("CVRA"), 18 U.S.C. § 3771, that affect all crime victims in this Circuit. After over a decade of litigation, the Majority holds that Jeffrey Epsteie's victims were not authorized to bring this petition because the CVRA does not permit stand- alone suits, and, therefore, it should have been dismisse
pstein. In her mandamus petition, Ms. Wild asserts that when federal prosecutors secretly negotiated and executed a non- prosecution agreement with Epstein in 2007, they violated her rights under the CVRA—in particular, her rights to confer with and to be treated fairly by the government's lawyers. We
ida to some extent). While he was in custody on these charges, Epstein was found dead. Statement of Attorney General William P. Barr on the Death of Jeffrey Epstein (Aug. 10, 2018), available at https://www.justice.gov/opa/pristatement-attorney-general-william-p- barr-death-jeffrey-epstein. In June 2020,
t resolves the federal investigation by allowing Mr. Epstein to plead to a state offense. The victims identifi
ides a platform for members of the public to falsely accuse individuals of committing federal crimes under the guise of filing a lawsuit. 21 In ()Bonner v. City of Prichard, 661 F.2d 1206. 1209 (11th Cir. 1981) (en banc), this court adopted as binding precedent all decisions of the former Fifth Circuit handed down prior
hout success, including allowing the Petitioners, that is Jane Does #1 and #2, and their counsel, the opportunity to meet with the U.S. Attorney, as Jeffrey Epstein's attorneys did.' Despite the Petitioners' earlier statement to the Court that no additional facts were needed, many hours were spent trying to revi
t with significant political connections) sexually abused more than 30 minor girls at his mansion in West Palm Beach (sic), Florida, and elsewhere. Epstein performed repeated lewd, lascivious, and sexual acts on them, including (but not limited to) masturbation, touching of their sexual organs, using v
he opportunity to meet with the U.S. Attorney, as Jeffrey Epstein's attorneys did.' Despite the Petitione
me was listed among 246 unindicted coconspirators 'This opinion of the Fifth Circuit was made binding precedent in the Eleventh Circuit pursuant to Bonner v. City of Prichard, 661 F.2d 1206, 1209 (11th Cir. 1981) (en banc). 8 EFTA00208098 Case 9:08-cv-80736-KAM Document 58 Entered on FLSD Docket 0470712011 Page 9 of 1
. CRIM. P. 6(e) AND/OR CONSTITUTIONAL MANDATES. Several of the "facts" that Petitioners include in their Statement of Undisputed Facts allege that Jeffrey Epstein ("Epstein") and others have committed crimes for which they were never charged or convicted. Others refer to matters that were occurring before the
ND/OR CONSTITUTIONAL MANDATES. Several of the "facts" that Petitioners include in their Statement of Undisputed Facts allege that Jeffrey Epstein ("Epstein") and others have committed crimes for which they were never charged or convicted. Others refer to matters that were occurring before the grand jury
their Statement of Undisputed Facts allege that Jeffrey Epstein ("Epstein") and others have committed cri
t all of the pleadings in the case be sealed. Id. 'This opinion of the Fifth Circuit was made binding precedent in the Eleventh Circuit pursuant to Bonner v. City of Prichard, 661 F.2d 1206, 1209 (11th Cir. 1981) (en bane). 6 EFTA00208120 Case 9:08-cv-80736-KAM Document 60 Entered on FLSD Docket 04/07/2011 Page 7 of 1
ay, the Court entered an order granting the victims' motion to compel and directing the Government to produce (1) all correspondence between it and Epstein; (2) all communications between the Government and outside entities; and (3) every other document requested by the victims. DE 190 at 2. With respe
to the issue. As another illustration, consider the victims' request for information about former prosecutor personal business relationship with Jeffrey Epstein. See, e.g., Victims' First RFP's at 1 16(f). Here again, the victims know that the Government possesses such information, because it admitted to ha
prosecutor personal business relationship with Jeffrey Epstein. See, e.g., Victims' First RFP's at 1 16
aries of its actions with the stockholders. Id. Since that 7 See Knight v. Thompson, ---F.3d---, 2013 WL 3843803 at *5 n.5 (11th Cir. 2013) (citing Bonner v. City of Prichard, 661 F.2d 1206, 1209 (11th Cir. 1981) (en banc) (11th Circuit adopts as binding precedent all decisions of the former Fifth Circuit handed down prio
hout success, including allowing the Petitioners, that is Jane Does #1 and #2, and their counsel, the opportunity to meet with the U.S. Attorney, as Jeffrey Epstein's attorneys did.' Despite the Petitioners' earlier statement to the Court that no additional facts were needed, many hours were spent trying to revi
t with significant political connections) sexually abused more than 30 minor girls at his mansion in West Palm Beach (sic), Florida, and elsewhere. Epstein performed repeated lewd, lascivious, and sexual acts on them, including (but not limited to) masturbation, touching of their sexual organs, using v
he opportunity to meet with the U.S. Attorney, as Jeffrey Epstein's attorneys did.' Despite the Petitione
me was listed among 246 unindicted coconspirators 'This opinion of the Fifth Circuit was made binding precedent in the Eleventh Circuit pursuant to Bonner v. City of Prichard, 661 F.2d 1206, 1209 (11th Cir. 1981) (en banc). 8 EFTA00212579 Case 9:08-cv-80736-KAM Document 58 Entered on FLSD Docket 0470712011 Page 9 of 1
inal Division , MAUSA, Northern Region Chief, Northern Region I. Introduction This memorandum seeks approval for the attached indictment charging Jeffrey Epstein, MI, and . The proposed indictment contains counts and seeks the forfeiture of Epstein's Palm Beach home and two airplanes. The investigation in
eeks approval for the attached indictment charging Jeffrey Epstein, MI, and . The proposed indictment contains counts and seeks the forfeiture of Epstein's Palm Beach home and two airplanes. The investigation initially was undertaken by the City of Palm Beach Police Department in response to a corn l
eks approval for the attached indictment charging Jeffrey Epstein, MI, and . The proposed indictment cont
ty of interstate commerce was used to induce the girl to engage in prostitution . In such a case, the third element probably could be deleted. EIn Bonner v. City of Prichard, 661 F. 2d 1206 (11th Cir. 1981), the Eleventh Circuit adopted as binding precedent all Fifth Circuit decisions rendered prior to October 1, 1981.
Entities connected to both Jeffrey Epstein and Bonner v. City of Prichard
Leon Black
PERSON
Ghislaine Maxwell
PERSON
Alan Dershowitz
PERSON
George W. Bush
PERSON
Bradley Edwards
PERSON
United States
LOCATIONJack Goldberger
PERSONSouthern District
LOCATIONJane Doe
PERSON
Barry Diller
PERSON
Department of Justice
ORGANIZATIONMaria Farmer
PERSONMartin Weinberg
PERSON
Kenneth Marra
PERSON
Alexander Acosta
PERSONthe Southern District
LOCATION
Paul Cassell
PERSON
A. Marie Villafana
PERSON
Virginia Giuffre
PERSON
Jay Lefkowitz
PERSON