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ry Request 2. The Non-Prosecution Agreement in this case contains a provision that provides immunity in the Southern District of Florida not only to Epstein, but also to "any potential co-conspirators of Epstein." Please provide (a) all documents, correspondence, and other information pertaining to whe
ane Does received as a result of the NPA; (c) indicating that the 4 EFTA00184106 immunity of the Jane Does as co-conspirators was contingent upon Jeffrey Epstein's performance of the conditions of the NPA. DEFINITIONS For the purpose of construing the foregoing discovery requests. the following terms are def
or more of Jane Does 1 - 33 have been harmed by Jeffrey Epstein or any of his potential co-conspirators,
ceed under Section 2255 as she would have had, if Mr. Epstein had been tried federally and convicted of an enu
District of New Mexico, and the District of the U.S. Virgin Islands, and the Federal Bureau of Investigation), the Federal Aviation Administration, the Bureau of Immigration and Customs Enforcement, and any other federal government agencies with law enforcement responsibilities related to the Epstein case (such as the I
he Southern District of Florida received a letter from defense attorneys Gerald Lefcourt and Alan Dershowitz arguing against federal prosecution of Epstein. 6. As reflected in the July 6, 2007, letter, Alan Dershowitz had met with the U.S. Attorney's Office as Epstein's defense counsel on or about June
2011, the exact date being unknown to the victims), the Government collected or became aware of information that Alan Dershowitz has been to: (a) Jeffrey Epstein's mansion in Palm Beach, Florida; (b) Jeffrey Epstein's mansion in New York City; (c) Jeffrey Epstein's "Zorro" ranch in New Mexico; (d) Jeffrey Eps
federal sex offenses committed against them by Jeffrey Epstein and his potential co- conspirators: (a)
e entire agreement between the United States and Mr. Epstein"; and (b) Decided not to describe this CVRA case
District of New Mexico, and the District of the U.S. Virgin Islands, and the Federal Bureau of Investigation), the Federal Aviation Administration, the Bureau of Immigration and Customs Enforcement, and any other federal government agencies with law enforcement responsibilities related to the Epstein case (such as the I
he Southern District of Florida received a letter from defense attorneys Gerald Lefcourt and Alan Dershowitz arguing against federal prosecution of Epstein. 6. As reflected in the July 6, 2007, letter, Alan Dershowitz had met with the U.S. Attorney's Office as Epstein's defense counsel on or about June
2011, the exact date being unknown to the victims), the Government collected or became aware of information that Alan Dershowitz has been to: (a) Jeffrey Epstein's mansion in Palm Beach, Florida; (b) Jeffrey Epstein's mansion in New York City; (c) Jeffrey Epstein's "Zorro" ranch in New Mexico; (d) Jeffrey Eps
federal sex offenses committed against them by Jeffrey Epstein and his potential co- conspirators: (a)
e entire agreement between the United States and Mr. Epstein"; and (b) Decided not to describe this CVRA case
District of New Mexico, and the District of the U.S. Virgin Islands, and the Federal Bureau of Investigation), the Federal Aviation Administration, the Bureau of Immigration and Customs Enforcement, and any other federal government agencies with law enforcement responsibilities related to the Epstein case (such as the I
he Southern District of Florida received a letter from defense attorneys Gerald Lefcourt and Alan Dershowitz arguing against federal prosecution of Epstein. 6. As reflected in the July 6, 2007, letter, Alan Dershowitz had met with the U.S. Attorney's Office as Epstein's defense counsel on or about June
2011, the exact date being unknown to the victims), the Government collected or became aware of information that Alan Dershowitz has been to: (a) Jeffrey Epstein's mansion in Palm Beach, Florida; (b) Jeffrey Epstein's mansion in New York City; (c) Jeffrey Epstein's "Zorro" ranch in New Mexico; (d) Jeffrey Eps
federal sex offenses committed against them by Jeffrey Epstein and his potential co- conspirators: (a)
e entire agreement between the United States and Mr. Epstein"; and (b) Decided not to describe this CVRA case
District of New Mexico, and the District of the U.S. Virgin Islands, and the Federal Bureau of Investigation), the Federal Aviation Administration, the Bureau of Immigration and Customs Enforcement, and any other federal government agencies with law enforcement responsibilities related to the Epstein case (such as the I
, the Bureau of Immigration and Customs Enforcement, and any other federal government agencies with law enforcement responsibilities related to the Epstein case (such as the Internal Revenue Service). This request for production seeks all documents, correspondence, and other information held by all of
ny offense committed by Epstein) that the non-prosecution agreement would block prosecution of the federal offenses committed against that person by Jeffrey Epstein and his potential co-conspirators. The Respondent further admits that, during the period from September 24, 2007, through June 2008, the USAO-SDFL
DFL entered into a non-prosecution agreement with Jeffrey Epstein which restricted the possibility of a la
he entire agreement between the United States and Mr. Epstein" and further identified those proceedings as "th
District of New Mexico, and the District of the U.S. Virgin Islands, and the Federal Bureau of Investigation), the Federal Aviation Administration, the Bureau of Immigration and Customs Enforcement, and any other federal government agencies with law enforcement responsibilities related to the Epstein case (such as the I
- captioned case. Recently, however, it appears that the Government may attempting to argue that they were somehow "accused" of the crimes involving Epstein. The Government may also take a similar position with regard to other young women who may wish to participate in this case. Accordingly, Jane Doe 1
ane Doe 30. EE. Jane Doe 31. FF. Jane Doe 32. GG. Jane Doe 33. 3. On the date on which each of the following persons was first sexually abused by Jeffrey Epstein in the Southern District of Florida, they were not "[a] person accused of the crime," 18 U.S.C. § 3771(d)(1), of their sexual abuse: A. Jane Doe 1.
18 U.S.C. § 3771(d)(1), committed by or involving Jeffrey Epstein in the Southern District of Florida: A.
District of New Mexico, and the District of the U.S. Virgin Islands, and the Federal Bureau of Investigation), the Federal Aviation Administration, the Bureau of Immigration and Customs Enforcement, and any other federal government agencies with law enforcement responsibilities related to the Epstein case (such as the I
Entities connected to both Jeffrey Epstein and the Bureau of Immigration

Ghislaine Maxwell
PERSON
Alan Dershowitz
PERSON
George W. Bush
PERSON
Bradley Edwards
PERSON
United States
LOCATIONJane Doe
PERSON
Barry Diller
PERSONMaria Farmer
PERSON
Jean-Luc Brunel
PERSON
Kenneth Marra
PERSONthe Southern District
LOCATION
Paul Cassell
PERSONFBI
ORGANIZATION
Virginia Giuffre
PERSON
Jay Lefkowitz
PERSON
Scarlett Johansson
PERSON
Zorro
LOCATIONGerald Lefcourt
PERSON
Salt Lake City
LOCATION
the Internal Revenue Service
ORGANIZATION