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ndersigned Assistant United States Attorney, and files this response to the Court's Order requesting the position of the United States on Defendant Jeffrey Epstein's Motion to Stay Proceedings [DE 99]. For the reasons set forth below, it is the United States' position that a stay of the proceedings is not necessa
f the civil proceedings in the "interests of justice" until the "expiration" of the Non- Prosecution Agreement ["NPA"] between the United States and Epstein? By filing this response, the United States does not make itself a party to this litigation and takes no position with respect to the outcome of an
Y. 1655 Pike DeleePh.„,.. .ML lt Fst!ii!lefleach, IR. »CI 1 0 C) Par 1 sprat your tether rear*, taw fifty sullierdoller 2 leoseit arrest Jeffrey ipater says that pH, lir with 3 your aunt and tale ad bar bra liar trots le that I Cerrees7 S Us. 6 0. Iles ray have you bra lira with P
es the United States take any position regarding Defendant Epstein's performance of hi s obligations pursuant to th
have prepared documents to charge at least one of Mr. Epstein's lady friends in state court. If they can push
thei't NW ass. sir. O. 00 yea know who Doff fey Slow NI A. N. Pie. 0. Clo yet hew who J'effroy Mnia 14/ A. 0. That.. the layer who flest and Spytein os ynr nYlf. tleht7 500•11 au In. Noun •Pmetted piet hally any M. LIN101.0i hey coriertetlere that ~et had with At. Soso 'Nordin.; Not Issue. y
, Suite 400 West Palm Beach. FL 33401-6235 Tel: Fax: *If not applicable, enter "nom." TOM ampw litoorA0110 FORM ORD-227 JAN.86 EFTA00185225 EISENBERG & FOUTS, P.A. Attorneys At Law JAMES L. EISENBERG Florida Bar Board Certified Criminal Trial Lawyer National Board Of Trial Advocacy Certified Criminal T
tion of Jeffrey Epstein to Intervene and to Quash Grand Jury Subpoenas 6(e) Box #3 P-012089 Thru P-012129 United States' Response to Motion of Jeffrey Epstein to Intervene and to Quash Grand Jury Subpoenas and Cross-Motion to Compel 6(e) Box #3 P-012130 Thru P-012150 Declaration o i 6(e) Box #3 P-
hibit 6. 17. In the declaration, Ms. makes a number of assertions, including that "there could not have been any doubt in anyone's mind .. . that Epstein sexually molested me as a minor"; "I believed that if I told the truth about what happened at Epstein's house, the police "; "I had been greatly in
/2013 Page 19 of 23 Bates Range Description Privilege(s) Asserted Box #3 P-011923 Thru P-011966 Folder entitled "Responses to Arguments from JE Counsel" containing: Work product Deliberative process 6(e) Attorney-Client Privilege ■ 7/13/2007 letter from to with handwritten attorney (
tified as a potential victim of the lead target, Jeffrey Epstein. 2. After service of the subpoena, Ms.=
have prepared documents to charge at least one of Mr. Epstein's lady friends in state court. If they can push
West Palm Beach, Florida. DONALD M. MIDDLEBROOKS UNITED STATES DISTRICT JUDGE cc: , AUSA 2 Case No. 08-80736-CV-MARRA P-003729 EFTA00086399 EISENBERG & FOUTS, P.A. Attorneys At Law JAMES L. EISENBERG Florida Bar Board Certified Criminal Trial Lawyer National Board Of Trial Advocacy Cellfiled Criminal M
Continued) responded to also known as the I located the I located inside the foundation and informed her that I was inves igatin a case against Jeffrey Epstein and knew she had been at the house. started to cry and advised she had put that part of her life e in er. I explained that although she is sevent
I informed her that although she did not wish to speak with us, I had sufficient information at this point in the investigation to know she was at Epstein's house and provided girls to Epstein to work. I also explained that prior to our arrival at her residence I had telephone contact with her father
ormed her that I was inves igatin a case against Jeffrey Epstein and knew she had been at the house. sta
have prepared documents to charge at least one of Mr. Epstein's lady friends in state court. If they can push
' • ' http://www.dola.state.fi.us/chdpalmbeach/vitals/birthdeathloc.html 7/28/2006 EFTA01693152 APR.16.22O7 5:40PM U54:10 WPB FL N0.697 P.2 EISENBERG & FOUTS, P.A. Attorneys At Law JAMES L. EISEIN13ERG Florida Bar Board Certified Criminal Trial Lawyer National Board Of Trial Advocacy Certified Crinneal
alm Beach Mall. I located the Simon Youth Foundation. I located la inside the foundation and informed her that I was investigating a case against Jeffrey Epstein and knew she had been at the house. started to cry and advised she had put that part of her life in her. I explained that although she is sevente
I informed her that although she did not wish to speak with us, I had sufficient information at this point in the investigation to know she was at Epstein's house and provided girls to Epstein to work. I also explained that prior to our arrival at her residence I had telephone contact with her father,
rmed her that I was investigating a case against Jeffrey Epstein and knew she had been at the house. sta
have prepared documents to charge at least one of Mr. Epstein's lady friends in state court. If they can push
006 1O5 http://www.doh.state.fl.us/chdpalmbeach/vitals/birthdeathloc.html 7/28/2006 EFTA01712184 APR.16.2007 5:40PN USA0'kPB FL N0.697 P.2 EISENBERG & FOUTS, P.A. Attorneys At Law JAMES L. EISENEERG Florida Bar Board Certified Criminal Thal Lawyer National Board Ot Trial Advocacy Certified Criminal Tr
alm Beach Mall. I located the Simon Youth Foundation. I located In inside the foundation and informed her that I was investigating a case against Jeffrey Epstein and knew she had been at the house. started to cry and advised she had put that part of her life in her. I explained that although she is sevente
I informed her that although she did not wish to speak with us, I had sufficient information at this point in the investigation to know she was at Epstein's house and provided girls to Epstein to work. I also explained that prior to our arrival at her residence I had telephone contact with her father,
rmed her that I was investigating a case against Jeffrey Epstein and knew she had been at the house. sta
have prepared documents to charge at least one of Mr. Epstein's lady friends in state court. If they can push
006 1O5 http://www.doh.state.fl.us/chdpalmbeach/vitals/birthdeathloc.html 7/28/2006 EFTA01727907 APR.16.2007 5:40PN USA0'kPB FL N0.697 P.2 EISENBERG & FOUTS, P.A. Attorneys At Law JAMES L. EISENEERG Florida Bar Board Certified Criminal Thal Lawyer National Board Ot Trial Advocacy Certified Criminal Tr
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.
a really good plea deal because he is rich and powerful. That doesn't seem fair either. Executed this O h , day of January, 2015. EFTA00086498 EISENBERG & FOUTS, P.A. Attorneys At Law JAMES L EISENBERG Florida Bar Board Certified Criminal Trial Lawyer National Board Of Trial Advocacy Certified Criminal Tr
Entities connected to both Jeffrey Epstein and EISENBERG & FOUTS

Marc Rich
PERSONLeon Black
PERSON
Alan Dershowitz
PERSON
George W. Bush
PERSON
Donald Trump
PERSON
United States
LOCATIONJack Goldberger
PERSONJane Doe
PERSON
Department of Justice
ORGANIZATION
Kenneth Marra
PERSON
Alexander Acosta
PERSONthe Southern District
LOCATIONFBI
ORGANIZATION
Virginia Giuffre
PERSON
Jay Lefkowitz
PERSON
Palm Beach
LOCATIONRoy Black
PERSON
Eric Holder
PERSON
Dallas
LOCATION
West Palm Beach
LOCATION