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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
the petition has been filed." 23 EFTA00177073 Case 9:08-cv-80736-KAM Document 62 Entered on FLSD Docket 04/08/2011 Page 24 of 54 In Sieverding United States Dept of Justice, 693 F. Supp. 2d 93 (D.D.C. 2010), the district court discussed a series of claims brought by the Sieverdings, a husband and wife so well known to
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
crecy. This attorney could neither confirm nor deny the information presented by the 'external party.'" Senate of the Commonwealth of Puerto Rico'. United States Dept of Justice, 1992 WL 119127 at '3 (D.D.C. May 13, 1992) (citing Bony. United States, 740 F. Supp. 888, 891 (D.D.C. 1990) ("Rule 6(e) does not create a type of
necessary" (doc. #17 at I). The Office asserted that the Court need only take judicial notice of the fact that no indictment had been filed against Epstein to resolve the case. On August I, 2008, the victims filed a response to the Government's "Notice" (doe. #19), giving a proposed statement of facts
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
ecrecy. This attorney could neither confirm nor deny the information presented by the 'external party!" Senate of the Commonwealth of Puerto Rico'. United States Dept of Justice, 1992 WL 119127 at *3 (D.D.C. May 13, 1992) (citing Barry United States, 740 F. Supp. 888, 891 (D.D.C. 1990) ("Rule 6(c) does not create a type of se
dar Online submitted a FOIA requests to the FBI collectively seeking "all documents relating to the FBI's investigation and prosecution of financier Jeffrey Epstein, who plead guilty to one count of felony solicitation of prostitution in August 2006. Dkt. No. 12-2, Ex. B; see Declaration of Michael G. Seidel, da
(b)(7)(A). Many of the records sought by the Radar Online fall at the heart of this exemption, and the FBI has withheld them individually, prior to Esptein's arrest, and categorically, after Esptein's arrest. Other FOIA exemptions also justify the FBI's withholding of records in response to the FOIA re
ecords at the core of the criminal prosecution of Jeffrey Epstein, prior to his passing, and the current p
provided information under an express assurance of confidentiality or in circumstances from which such an assurance could be reasonably inferred.'" United States Dept of Justice v. Landano, 508 U.S. 165, 165 (1993). The promised confidentiality can only be waived by the source. Adamowicz v. IRS, 402 Fed. App'x 648, 653 (2d
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
ntence reduction violated his right under the CVRA to be treated with fairness. See id. , 338 Fed. Appx. at 113-14. EFTA00208525 In Sieverding v. United States Dept of Justice , 693 F. Supp. 2d 93 (D.D.C. 2010), the district court discussed a series of claims brought by the Sieverdings, a husband and wife so well known to
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