Epstein Secrets

n United States District Court Southern District of New York United States Courthouse 500 Pearl Street New York, NY 10007 RE: United States v. Jeffrey Epstein, Criminal No. 19-490 Dear Judge Berman: Steptoe STEPTOE • JOHNSON LLP We write to outline the grounds entitling Jeffrey Epstein to pretrial releas

he relitigation of which is barred by a prior federal nonprosecution agreement (the "NPA"). The government makes this drastic demand even though Mr. Epstein has never once attempted to flee the United States — despite a Florida federal judge's stated belief that he could void the NPA in appropriate circ

Street New York, NY 10007 RE: United States v. Jeffrey Epstein, Criminal No. 19-490 Dear Judge Berman:

government makes this drastic demand even though Mr. Epstein has never once attempted to flee the United Stat

als at the Department of Justice reviewed the NPA and either authorized or helped negotiate the resolution of the matter. See, e.g., United States' Second Supplemental Privilege Log filed as Dkt. 329-1 in Jane Doe #1 and Jane Doe #2 v. United States, No. 08-CV-80736 (S.D. Fla.) (the "CVRA litigation") (illustrating the number o

15th Judicial Circuit in and for Palm Beach County (hereinafter, the "State Attorney's Office") have conducted an investigation into the conduct of Jeffrey Epstein (hereinafter "Epstein"); IT APPEARING that the State Attorney's Office has charged Epstein by indictment with solicitation of prostitution, in viol

he relitigation of which is barred by a prior federal nonprosecution agreement (the "NPA"). The government makes this drastic demand even though Mr. Epstein has never once attempted to flee the United States — despite a Florida federal judge's stated belief that he could void the NPA in appropriate circ

Street New York, NY 10007 RE: United States v. Jeffrey Epstein, Criminal No. 19-490 Dear Judge Berman:

government makes this drastic demand even though Mr. Epstein has never once attempted to flee the United Stat

als at the Department of Justice reviewed the NPA and either authorized or helped negotiate the resolution of the matter. See, e.g., United States' Second Supplemental Privilege Log filed as Dkt. 329-1 in Jane Doe #1 and Jane Doe #2 v. United States, No. 08-CV-80736 (S.D. Fla.) (the "CVRA litigation") (illustrating the number o

15th Judicial Circuit in and for Palm Beach County (hereinafter, the "State Attorney's Office") have conducted an investigation into the conduct of Jeffrey Epstein (hereinafter "Epstein"); IT APPEARING that the State Attorney's Office has charged Epstein by indictment with solicitation of prostitution, in viol

he relitigation of which is barred by a prior federal nonprosecution agreement (the "NPA"). The government makes this drastic demand even though Mr. Epstein has never once attempted to flee the United States — despite a Florida federal judge's stated belief that he could void the NPA in appropriate circ

Street New York, NY 10007 RE: United States v. Jeffrey Epstein, Criminal No. 19-490 Dear Judge Berman:

government makes this drastic demand even though Mr. Epstein has never once attempted to flee the United Stat

als at the Department of Justice reviewed the NPA and either authorized or helped negotiate the resolution of the matter. See, e.g., United States' Second Supplemental Privilege Log filed as Dkt. 329-1 in Jane Doe #1 and Jane Doe #2 v. United States, No. 08-CV-80736 (S.D. Fla.) (the "CVRA litigation") (illustrating the number o

n United States District Court Southern District of New York United States Courthouse 500 Pearl Street New York, NY 10007 RE: United States v. Jeffrey Epstein, Criminal No. 19-490 Dear Judge Berman: Steptoe STEPTOE I JOHNSON UP We write to outline the grounds entitling Jeffrey Epstein to pretrial releas

he relitigation of which is barred by a prior federal nonprosecution agreement (the "NPA"). The government makes this drastic demand even though Mr. Epstein has never once attempted to flee the United States — despite a Florida federal judge's stated belief that he could void the NPA in appropriate circ

Street New York, NY 10007 RE: United States v. Jeffrey Epstein, Criminal No. 19-490 Dear Judge Berman:

government makes this drastic demand even though Mr. Epstein has never once attempted to flee the United Stat

als at the Department of Justice reviewed the NPA and either authorized or helped negotiate the resolution of the matter. See, e.g., United States' Second Supplemental Privilege Log filed as Dkt. 329-1 in Jane Doe #1 and Jane Doe #2 v. United States, No. 08-CV-80736 (S.D. Fla.) (the "CVRA litigation") (illustrating the number o

rk product privilege. 2:010526-010641 Protected from discovery by opinion work product privilege, The correspondence between the Government and Epstein's counsel is not privileged and should be produced. The Government must certify that it has been produced. 2:010642-010650 Protected from disco

9:08-cv-80736-KAM Document 361-27 Entered on FLSD Docket 02/10/2016 Page 2 of 4 DECLARATION OF 1. My name is • and I was born in 2. I was paid by Jeffrey Epstein to interact sexually with him as a minor on dozens of occasions in his mansion in Palm Beach, Florida from around 2002 to 2005, and also to bring h

My name is • and I was born in 2. I was paid by Jeffrey Epstein to interact sexually with him as a minor

my chance to confer with the prosecutors before Mr. Epstein took a plea or the case was resolved in any way.

ted from discovery by opinion work product privilege. S:13973-13976 Protected from discovery by opinion work product privilege. The Government's Second Supplemental Privilege Log begins here. (DE 329-1). 42 EFTA00086486 Case 9:08-cv-80736-KAM Document 330 Entered on FLSD Docket 07/06/2015 Page 43 of 51 S:13977-13979 Prot

ed: The government admits that the FBI and the U.S. Attorney's Office for the Southern District of Florida ("USAO") conducted an investigation into Jeffrey Epstein ("Epstein") and developed evidence and information in contemplation of a potential federal prosecution against Epstein for many federal sex offenses

ating the Crime Victims' Rights Act (CVRA), 18 U.S.C. § 3771, by failing to involve Petitioners (and other similarly situated victims of Intervenor Epstein) in the process that ultimately led to a federal non-prosecution agreement between the Government and Epstein. (DE I). The parties and intervenors d

o every privilege asserted. (DE 265). Intervenor Jeffrey Epstein supports the Government's assertion that

ted from discovery by opinion work product privilege. S:13973-13976 Protected from discovery by opinion work product privilege. The Government's Second Supplemental Privilege Log begins here. (DE 329-1). 42 EFTA00210181 Case 9:08-cv-80736-KAM Document 330 Entered on FLSD Docket 07/06/2015 Page 43 of 51 S:13977-13979 Prot

ed: The government admits that the FBI and the U.S. Attorney's Office for the Southern District of Florida ("USAO") conducted an investigation into Jeffrey Epstein ("Epstein") and developed evidence and information in contemplation of a potential federal prosecution against Epstein for many federal sex offenses

ating the Crime Victims' Rights Act (CVRA), 18 U.S.C. § 3771, by failing to involve Petitioners (and other similarly situated victims of Intervenor Epstein) in the process that ultimately led to a federal non-prosecution agreement between the Government and Epstein. (DE I). The parties and intervenors d

o every privilege asserted. (DE 265). Intervenor Jeffrey Epstein supports the Government's assertion that

ted from discovery by opinion work product privilege. S:13973-13976 Protected from discovery by opinion work product privilege. The Government's Second Supplemental Privilege Log begins here. (DE 329-1). 42 EFTA01657793 Case 9:08-cv-80736-KAM Document 330 Entered on FLSD Docket 07/06/2015 Page 43 of 51 S:13977-13979 Prot

ed: The government admits that the FBI and the U.S. Attorney's Office for the Southern District of Florida ("USAO") conducted an investigation into Jeffrey Epstein ("Epstein") and developed evidence and information in contemplation of a potential federal prosecution against Epstein for many federal sex offenses

ating the Crime Victims' Rights Act (CVRA), 18 U.S.C. § 3771, by failing to involve Petitioners (and other similarly situated victims of Intervenor Epstein) in the process that ultimately led to a federal non-prosecution agreement between the Government and Epstein. (DE 1). The parties and intervenors d

o every privilege asserted. (DE 265). Intervenor Jeffrey Epstein supports the Government's assertion that

ted from discovery by opinion work product privilege. S:13973-13976 Protected from discovery by opinion work product privilege. The Government's Second Supplemental Privilege Log begins here. (DE 329-1). 42 EFTA_R1_01293477 EFTA02335939 Case 9:08-cv-80736-KAM Document 330 Entered on FLSD Docket 07/06/2015 Page 43 of 51 S