Epstein Secrets

portions of the Agreement. As I previously observed, our intent has been to place the victims in the same position as they would have been had Mr. Epstein been convicted at trial. No more; no less. From our meeting, it appears that the defense agrees that this was the intent. During the course of nego

lm Beach, FL 33401 (561) 820-8711 Facsimile: (56!) 820-8777 August 4, 2009 VIA ELECTRONIC MAIL Spencer T. Kuvin, Esq. Leopold—Kuvin, P.A. Re: Jeffrey Epstein/B.B. — Requested Disclosure of Non-Prosecution Agreement Dear Mr. Kuvin: Thank you for your letter regarding the disclosure of the Non-Prosecution Agree

ORTH. FL 334614 Page 2 of 8 Form Revised 01.18-08 EFTA00233452 11/25/2008 15:28 3553626 elKt.LII I LICIMINAL STATE OF FLORIDA Plaintiff -vs- JEFFREY E. EPSTEM Defendant IN THE FIFTEENTH JUDICIAL CIRCUIT COURT, IN AND FOR PALM BEACH COUNTY CASE NUMBER DIVISION DC NUMBER CIRCUITNUMBER: zalitcavawanua

E Disposition Amount: Docket Text: AGREED ORDER CONTINUING CASE DISPO 13 AGOR - AGREED ORDER Filing Date: 05-MAR-2007 Filing Party: EPSTEIN, JEFFREY E IRisposition Amount: Docket Text: I(JUDGE MCSORLEY) CONTINUING CASE DISPO PREVIOUSLY- 1 SET FOR 08-MAR-2007 AND RESETTING FOR CASE DISPO ON 16-MAY

mmissioner CASE DISPOSITION MAIN BRANCH COURTROOM 11F COLBATH, JUDGE JEFFREY CASE DISPOSITION MAIN BRANCH COURTROOM] 11F COLBATH, JUDGE JEFFREY Case Parties Expn Date Type ID Name DEFENDANT 24167391 EPSTEIN, JEFFREY E. Aliases: none 3 1 22-AUG- ATTORNEY ATTY MALINSKI, NORMAN 2006 Alia

FREY CASE DISPOSITION MAIN BRANCH COURTROOM] 11F COLBATH, JUDGE JEFFREY Case Parties Expn Date Type ID Name DEFENDANT 24167391 EPSTEIN, JEFFREY E. Aliases: none 3 1 22-AUG- ATTORNEY ATTY MALINSKI, NORMAN 2006 Aliases: none hup://courtcon.co.palm-beach.flais/p1s/jiwp/ek_public_qry_docup_dkt

24 FAHIS - HISTORY FELONY/MISD ARRAIGN Filing Date: 06-OCT-2006 Filing Party: Disposition Amount: Docket Text: X/JIFA FELONY-MISDEMEANOR IS EPSTEIN JEFFREY E LEGACY 41673917332767 PRAECIPE AND 082206 DATE: JUDGE: COURT: DEFENDANT PRESENT: PLEA: ARRAIGNMENT PASSED TO: DATE: RELEASED, FAILURE OF STATE

, Plaintiff, vs. JEFFERY EPSTEIN, Defendant. DEFENDANT EPSTEIN'S MOTION TO DISMISS, & FOR MORE DEFINITE STATEME

in the same position as they would have been had Mr. Epstein been convicted at trial. No more; no less. From

ture said what it means and means what it said, and not add language or give some absurd or strained interpretation. As stated in 2 EFTA00233491 CBS Inc. supra at 1228 — "Those who ask courts to give effect to perceived legislative intent by interpreting statutory language contrary to its plain and un

' 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

v. Beck's Est., 129 F.2d 243, 245 (2d Cir. 1942))). Where, as here, the language Congress used is clear and unambiguous, our inquiry is complete. CBS Inc. it PrimeTime 24 Joint Venture, 245 F.3d 1217, 1222 (11th Cir. 2001). We are bound to "presume that Congress said what it meant and meant what it s

mmary judgment in the Ponzi Scheme Action. SJ Motion at 1 (Edwards "is entitled to summary judgment for all claims brought against him in Plaintiff Jeffrey Epstein's Complaint" because "the evidence uncontrovertibly demonstrates the propriety of every aspect of Edwards' involvement in the prosecution of legitimat

alternative sources before it may be subpoenaed from any non-party in New York. In fact, Edwards concedes in his own Florida court filings that the Epstein interview is, at best, cumulative of "overwhelming evidence" he has already obtained from several alternative sources. Second, even if Edwards were

made of a confidential unpublished interview of Jeffrey Epstein. PRELIMINARY STATEMENT In this ancillar

d not, publish the information imparted to me by Mr. Epstein during the interview. Rush Supp. Aft 17 (emphasi

5=.2d 919 (Sup. Ct... Co. 2001) In re Application to Quash Subpoena to NBC 79 F.3d 346 (2d Cir. 1996) In re Behar, 779 F. Supp. 273 1991) In re CBS Inc., 232..2d 291, 648 In re Pennzoil Co.. 108.1.2d 666, 485 29 25 14,19 22,24 21,25 26 .2d 443 (1st Dep't 1996) .2d 533 (1st Dep't 1985) In

8. Moreover, on the facts of this case, the Government's construction leads to an absurd result. As the Court is aware, the Government arranged for Epstein to execute his NPA on about September 24, 2007 — in secret. At that time, the victims could not "assert[] the right to be heard before or during th

ommenced within three years after the disability ceases." 28 U.S.C. § 2401(a) (2012) (emphasis added). In this case, Jane Doe No. 3 was hiding from Jeffrey Epstein and his co-conspirators in Australia from the time her claim accrued until October 2013, when she returned to the United States. See Ex. I at 3 ("I

d). In this case, Jane Doe No. 3 was hiding from Jeffrey Epstein and his co-conspirators in Australia from

hile a claimant is "beyond the seas," as in 28 U.S.C. 2401(a), a court lacks the power to narrow the scope of the plain meaning of that phrase. See CBS Inc. I PrimeTime 24 Joint Venture, 245 F.3d 1217, 1228 (11th Cir. 2001) (cautioning against allowing "clearly expressed legislative decisions... [to] be