Epstein Secrets

, vs UNITED STATES OF AMERICA, Respondent. I JEFFREY EPSTEIN, Intervenor. I INTERVENOR JEFFREY EPST

PRECLUDE IMPOSITION OF THE EPSTEIN REMEDIES A. Mr. Epstein was not a Party to the Underlying Litigation and

o prosecuting what was, at heart, a local sex abuse case." See Jeffrey Sloman, Alex Acosta Acted with Professionalism and Integrity in Handling the Jeffrey Epstein Case, Miami Herald Op-Ed, Feb. 15, 2019. The USAO-SDFL's decision to enter into the NPA was also influenced by its consideration of the privacy interest

EEMENT 1 EFTA00299022 TABLE OF CONTENTS INTRODUCTION BACKGROUND ARGUMENT I. PRINCIPLES OF PROCEDURAL DUE PROCESS PRECLUDE IMPOSITION OF THE EPSTEIN REMEDIES A. Mr. Epstein was not a Party to the Underlying Litigation and There is no Judgment Against him B. There is no Judicial Finding of "Bad

teenth Judicial Circuit in and for Palm Beach County on one count of solicitation of prostitution, in violation of Fla. Stat. §796.07. See State v. Jeffiey E. Epstein, 50-2006-CF-009454-AXXX-MB. In or around November 2006, while the state court charge was pending, Mr. Epstein learned that the United States Attorn

el precludes a party from "asserting a claim in a legal proceeding that is inconsistent with a claim taken by that party in a previous proceeding." Burnes v. Pemco Aeroplex, Inc., 291 F.3d 1282, 1285 (11th Cir. 2002), overruled in part, Slater v. United States Steel Corp., 871 F.3d 1174, 1176-77 (11th Cir. 2017). It is "an e

the victims explained in their motion for summary judgment (DE 361), the undisputed facts of this case show that for nine months, the Government and Epstein conspired to conceal a non-prosecution agreement (NPA) from Epstein's victims in order to prevent them from voicing any objection to the agreement.

ed Jane Doe 1 and Jane Doe 2 (and several other victims) in civil suits against Jeffrey Epstein for injuries my clients suffered as a consequence of Jeffrey Epstein's sexual abuse of them. 2. I have previously filed an affidavit in this matter (see DE 225-1). This affidavit repeats some of the information contai

Undisputed Fact 1 ("Between about 1999 and 2007, Jeffrey Epstein sexually abused more than 30 minor girls,

she, herself] procured additional young women for Mr. Epstein and [was] paid commissions or referral fees for

both this CVRA action and the related civil suits. There is no concealment or unfairness that are the hallmarks for applying judicial estoppel. Cf. Burnes v. Pemco Aeroplex, Inc., 291 F.3d 1282 (11th Cir. 2002) (applying doctrine in circumstances showing deliberate concealment of assets). The Supreme Court has clearly held "

s from Jeffrey Epstein for sexually abusing her. Ex. P. On September 11, 2008, Jane Doe No. 2 file an action in Palm Beach County, Florida, L.M. v. Jeffrey Epstein Case No. 50-2008-CA- 28051-XXXXMB, seeking money damages from Jeffrey Epstein for sexually abusing her. Ex. Q. 6 "A judicial admission is a formal conce

r than to assert that Jeffrey Epstein sexually abused both. However, the differing circumstances of the two petitioners during the investigation of Epstein are highly relevant in determining whether each petitioner can even invoke the CVRA. Through her attorney, James Eisenberg, Esq.,' Jane Doe No. 2 r

0. When asked whether Epstein "pulled you closer to him in a sexual way," Jane Doe No. 2 replied: A. I wish. No, no, never, ever, ever, no, never. Jeffrey is an awesome man, no. Id. at 22. At the end of her interview, Jane Doe No. 2 was asked if she had any questions for the agents or AUSA Villafafia

agreement entered into by the United States and Mr. Epstein in a timely fashion." Ex. N, Nov. 27, 2007 email

ken by that party in a previous proceeding.' Judicial estoppel is an equitable concept intended to prevent the perversion of the judicial process." Burnes v. Pemco Aeroplex, Inc. 291 F.3d 1282, 1285 (11th Cir. 2002) (citation omitted). Judicial estoppel prohibits "parties from deliberately changing positions according to the