Epstein Secrets

), and the authority of the Court to administer proceedings before it, for approval of an agreed- upon protocol authorizing counsel for the Estate of Jeffrey E. Epstein (the "Epstein Estate") to review videorecorded materials and photographs in the possession, custody, or control of the Epstein Estate (the "Epstein

o assume that [there was possible] interstate transmission of child pornography...that could have changed the entire complexion of the case against Epsteinf OPR Report, p. 176. Six computer hard drives were suspiciously missing from Epstein's Florida home just before a police raid--leaving dangling wire

- investigation-into-the-u-s-attorney-s-office-for-the-southern-district-of- florida-s-resolution-of-its-2006-2008-federal-criminal-investigation-of- jeffrey-epstein-and-its-interactions-with-victims-during-the- investigation/db9373e8-22f8-4712-b4a7-be844d162de0/, p. iv. As acknowledged in the OPR Report, law enforce

on protocol authorizing counsel for the Estate of Jeffrey E. Epstein (the "Epstein Estate") to review videor

on protocol authorizing counsel for the Estate of Jeffrey E. Epstein (the "Epstein Estate") to review videore

: (954) 356-0011 Fax: (954) 356-0022 [email protected] Counsel for Plaintiflane Doe 1 STIPULATED AND AGREED TO BY: /s/John Butts John Butts Felicia H. Ellsworth WILMER CUTLER PICKERING HALE AND DORR LLP 60 State Street Boston, MA 02109 Tel: (617) 526-6687 Fax: (617) 526-5000 [email protected]

), and the authority of the Court to administer proceedings before it, for approval of an agreed- upon protocol authorizing counsel for the Estate of Jeffrey E. Epstein (the "Epstein Estate") to review videorecorded materials and photographs in the possession, custody, or control of the Epstein Estate (the "Epstein

s meant to include Responsive Media that may consist of movies or You Tube videos, for example, but does not extend to Responsive Media relating to Epstein activities or properties that may have been publicly disclosed at any time. 2 In this motion, the parties use the term "child sex abuse imagery" or

on protocol authorizing counsel for the Estate of Jeffrey E. Epstein (the "Epstein Estate") to review videor

on protocol authorizing counsel for the Estate of Jeffrey E. Epstein (the "Epstein Estate") to review videore

: (954) 356-0011 Fax: (954) 356-0022 [email protected] Counsel for Plaintiflane Doe 1 STIPULATED AND AGREED TO BY: /s/John Butts John Butts Felicia H. Ellsworth WILMER CUTLER PICKERING HALE AND DORR LLP 60 State Street Boston, MA 02109 Tel: (617) 526-6687 Fax: (617) 526-5000 [email protected]

Description of the Litigation and the Class This Notice relates to a proposed settlement of claims in a pending class action brought by victims of Jeffrey E. Epstein's ("Epstein") sex trafficking venture, which alleged, among other things, that Defendant violated the Trafficking Victims Protection Act ("TVPA") by p

is Case 5. This case grew out of our firms' long representation of the survivors of Jeffrey Epstein's sex trafficking ring. EHL began representing Epstein survivors in 2009. BSF began representing Epstein survivors in the first half of 2014. 6. By 2021, our firms had successfully brought lawsuits aga

s in a pending class action brought by victims of Jeffrey E. Epstein's ("Epstein") sex trafficking venture,

s in a pending class action brought by victims of Jeffrey E. Epstein's ("Epstein") sex trafficking venture, w

36 EFTA01652927 Case 1:22-cv-10019-JSR Document 181-1 Filed 06/22/23 Page 38 of 38 [email protected] [email protected] Felicia H. Ellsworth John J. Butts Wilmer Cutler Pickering Hale and Don LLP 60 State Street Boston, Massachusetts 02109 Tel: (617) 526-6000 felicia.ellsworth@wilmerha

ut was related to the affairs of the Epstein Enterprise in violation of CICO 14 V.I.C. §600 et seq. COUNT NINETEEN Sex Offender Registry-Estate of Jeffrey E. Epstein Violation of the Criminally Influenced and Corrupt Organizations Act, 14 V.I.C. § 600 a seq. and 14 V.I.C. § 1721 et seq. 354. The Government res

IEIRT1HIR fikozurreent3(611. FRI kitiOCIEIMME Figtige/36ailVZ'3 GVI v. Estate of Jeffrey Epstein GVI's Second Amended Complaint Page 35 of 76 with Epstein. Indyke was a signatory on Southern Trust's primary bank account to which funds were wired, primarily from a single source, as described below. Kahn

COUNT NINETEEN Sex Offender Registry-Estate of Jeffrey E. Epstein Violation of the Criminally Influenced

COUNT NINETEEN Sex Offender Registry-Estate of Jeffrey E. Epstein Violation of the Criminally Influenced a

ork, NY 10007 (t) (212) 230-8800 (f) (212) 230-8888 [email protected] [email protected] [email protected] Felicia H. Ellsworth 60 State Street Boston, MA 02109 (t) (617) 526-6687 (f) (617) 526-5000 [email protected] Dated: January 9, 2023 JEDWAKOFF, .S.D

ax benefits that had been bestowed on any Defendant; J. Pursuant to 14 V.I.C. §§ 607(a)(6) and 607(k), order all assets and funds of the Estate of Jeffrey E. Epstein be placed into receivership; K. Pursuant to 14 V.I.C. § 607(e), award the Government the maximum civil penalty for each and every violation of law

wful scheme. 385. These unlawful acts could not have been carried to the length and extent accomplished without the common understanding shared by Epstein and the Epstein Enterprise Defendants. 386. Each of the Defendants had a duty to report, stop or terminate the wrongful conduct, but instead each

(k), order all assets and funds of the Estate of Jeffrey E. Epstein be placed into receivership; K. Pursua

(k), order all assets and funds of the Estate of Jeffrey E. Epstein be placed into receivership; K. Pursuan

York, NY 10007 (t) (212) 230-8800 (f) (212) 230-8888 [email protected] [email protected] [email protected] Felicia H. Ellsworth 60 State Street Boston, MA 02109 (t) (617) 526-6687 (f) (617) 526-5000 [email protected] Dated: January 9, 2023 JED . RAKOFF, .