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I don't think we are very far apart on this language. I had also suggested some language, to be included in the agreement on finality, provided that Jeffrey abided by all the terms of the agreement. Please let me know your thoughts on these. I will continue to review the document and speak with you tomor
JEFFREY EPSTEIN RAL EEC° ESQ. OUNSEL TO JEFFR Y EPSTEIN EFTA00184724 Case 9:08-cv-80736-KAM Document 3
f his clients is the purported victim. Accordingly. I will address facts related to C.W., T.M.. and S R. All three of those clients were victims of Jeffrey Epstein's while they were minors beginning when they were fifteen years old. Incase note that the dates on the U.S. Attorney's Office letters to C.W. and T.M
of course, is a defense attorney who represented defendant Epstein. Recording information provided by a defense att
EDWARDS: Your Honor, as a factual 2 background, Mr. Epstein is a billionaire that 3 sexually abused and mol
States Attorney's Office will be instituted in this District, and the charges against Epstein if any, will be dismissed. Terms of the Agreement: I. Epstein shall plead guilty (not nob contendere) to an Information filed by the State Attorney's Office charging Epstein with an offense that requires him t
ge 3 of 5 US_Atty_Cor_0085 EFTA00184713 Case 9:08-cv-80736-KAM Document 361-61 Entered on FLSD Docket 02/10/2016 Page 7 of 8 In consideration of Epsteln's agreement to plead guilty and to provide compensation to victims, if Epstein successfully fiilfills all of the terms and conditions of this agreem
also potentially a motive to violate the victims' rights as explained previously. The Government's privilege log has numerous entries showing that Menchal was substantially and personally involved in makingslecisions related to the Epstein prosecution. See, e.g., page 19 of the first privilege log (DE
of course, is a defense attorney who represented defendant Epstein. Recording information provided by a defense att
lian Ave S. West Palm Beach, FL 33401-5015 Re: Jeffrey Epstein Dear Mr. Goldberger: In accordance with
riminal prosecution commensurate with the crimes Mr. Epstein has committed, and we further urge you to take th
vernment's CVRA violation in this case. See, e.g., DE 48 at 13. 31. RFP No. 4 requests documents relating to negotiations between the Government and Jeffrey Epstein concerning the court and/or location in which Jeffrey Epstein would enter any guilty plea (including in particular any negotiations concerning concl
d under Section 2255 as she would have had, if Mr..Epstein had been tried federally and convicted of an enu
provide notice to the victims. It is also needed to demonstrate why the victims at first received inaccurate information about the NPA, as well as Jeffrey Epstein's involvement in that inaccurate notice. See, e.g., DE 48 at 15-16. 43. RFP No. 16 requests documents regarding Bruce Reinhart, a senior prosecutor w
also potentially a motive to violate the victims' rights as explained previously. The Government's privilege log has numerous entries showing that Menchal was substantially and personally involved in malcinislecisions related to the Epstein prosecution. See, e.g., page 19 of the first privilege log (DE
provide notice to the victims. It is also needed to demonstrate why the victims at first received inaccurate information about the NPA, as well as Jeffrey Epstein's involvement in that inaccurate notice. See, e.g., DE 48 at 15-16. 43. RFP No. 16 requests documents regarding Bruce Reinhart, a senior prosecutor w
not necessary" (DE 17 at 1). 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. 6. On August 1, 2008, the victims filed a response to the Government's "Notice," giving a proposed statement of facts surroun
Epstein," _ ' "Morrison," "Visoki," "Rogers," "Hammond," Roxburgh," "Villafana, " "Florida Science Foundation," "Starr," "Black," "Goldberger," "Jeffrey," "Australian," "Lewis," "Sanchez," "358 El Brillo Way" appears and which are connected to or related to Jeffrey Epstein, Jack Goldberger, or the J
of course, is a defense attorney who represented defendant Epstein. Recording information provided by a defense att
riminal prosecution commensurate with the crimes Mr. Epstein has committed, and we further urge you to take th
also potentially a motive to violate the victims' rights as explained previously. The Government's privilege log has numerous entries showing that Menchal was substantially and personally involved in making decisions related to the Epstein prosecution. See, e.g., page 19 of the first privilege log (DE
provide notice to the victims. It is also needed to demonstrate why the victims at first received inaccurate information about the NPA, as well as Jeffrey Epstein's involvement in that inaccurate notice. See, e.g., DE 48 at 15-16. 43. RFP No. 16 requests documents regarding a senior prosecutor who was present
not necessary" (DE 17 at 1). 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. 6. On August 1, 2008, the victims filed a response to the Government's "Notice," giving a proposed statement of facts surroun
stein," "Kllen "Ruboyo," "Morrison," "Visoki," "Rogers," "Hammond," Roxburgh," S, " "Florida Science Foundation," "Starr," "Black," "Goldberger," "Jeffrey," "Australian," "Lewis," "Sanchez," "358 El Brillo Way" appears and which are connected to or related to Jeffrey Epstein, Jack Goldberger, or the J
of course, is a defense attorney who represented defendant Epstein. Recording information provided by a defense att
riminal prosecution commensurate with the crimes Mr. Epstein has committed, and we further urge you to take th
also potentially a motive to violate the victims' rights as explained previously. The Government's privilege log has numerous entries showing that Menchal was substantially and personally involved in making decisions related to the Epstein prosecution. See, e.g., page 19 of the first privilege log (DE
provide notice to the victims. It is also needed to demonstrate why the victims at first received inaccurate information about the NPA, as well as Jeffrey Epstein's involvement in that inaccurate notice. See, e.g., DE 48 at 15-16. 43. RFP No. 16 requests documents regarding Bruce Reinhart, a senior prosecutor w
ch re Travel for Prostitution" containing attorney (Villafafta) handwritten notes regarding grand jury presentation, chart entitled "Brought to Epstein's House" with handwritten notes, Message Pad meta- analysis chart, summary of evidence related to one victim/witness, and relevant grand jury inf
serted Victims' Objections Box #3 Folder entitled "Responses to Arguments Work product No Factual Underpinnings; Fiduciary Duty; P-011923 from JE Counsel" containing: Deliberative process Crime-Fraud-Misconduct; Crime-Fraud- Thru ■ 7/13/2007 letter from Lilly Ann 6(e) Misconduct; Not in A
of course, is a defense attorney who represented defendant Epstein. Recording information provided by a defense att
net (617) 338-9538 Criminal Defense Counsel for Jeffrey Epstein /s/ Bradley J. Edwards 3 EFTA00179621
07 letter from Gerald Public Prosecutor, Attorney Conduct at Issue; Lefeourt to Jeffrey Sloman, Matt Factual Materials; Court Authorized Under Menchal, Andrew Lourie, and 6(e)(3)(E); Court Inherent Power to Release; Marie Vi Ilafarla with handwritten attorney (Villafarla) notes; Proper Victim's
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
also potentially a motive to violate the victims' rights as explained previously. The Government's privilege log has numerous entries showing that Menchal was substantially and personally involved in making decisions related to the Epstein prosecution. See, e.g., page 19 of the first privilege log (DE
Entities connected to both Jeffrey Epstein and Menchal
Larry Visoski
PERSONLeon Black
PERSON
Prince Andrew
PERSON
Ghislaine Maxwell
PERSON
Alan Dershowitz
PERSON
Bradley Edwards
PERSON
United States
LOCATIONJack Goldberger
PERSONJane Doe
PERSON
Department of Justice
ORGANIZATIONMaria Farmer
PERSONMartin Weinberg
PERSON
Kenneth Marra
PERSON
Bill Clinton
PERSON
Alexander Acosta
PERSONthe Southern District
LOCATION
Paul Cassell
PERSONFBI
ORGANIZATION
A. Marie Villafana
PERSON
Virginia Giuffre
PERSON