Epstein Secrets

y be executed in counterparts or via facsimile and shall be as binding as if an original. AGREED UPON and EXECUTED as of the date indicated above: Virginia L. Mortara Date: , 2013 4 of 5 EFTA00300120 Laurel, Inc. By: Name: Its: Date: 2013 5 of 5 EFTA00300121

ts Petition for Formal Administrative Hearing ("Petition") with the FDEP challenging issuance of the Notice of Determination of Exemption. c) The Petition has not been referred to DOAH. The case is currently being held in abeyance by the FDEP. 2. Settlement Actions Entry into this Agreement shall no

llow the Fifth Circuit's holding in Dean (and the view of the U.S. District Courts for the Eastern District of New York and the Eastern District of Virginia) and conclude that the CVRA extends rights to Jane Doe #1 and Jane Doe #2 under the facts of this case. C. The U.S. Attorney's Office Has Previous

t without her participation and knowledge. WHEREFORE, for the reasons outlined above, the Petitioner respectfully requests this Court to grant her Petition, and to order the United States Attorney to comply with the provisions of the CVRA prior to and including any plea or other agreement with the Defen

action based on the same operative allegations), Jane Doe #3 v. Epstein, No. 08-CV-80232-KAM (S.D. Fla. filed

imity among the defendants. In accordance with 28 U.S.C. § I446(b) the undersigned are authorized to represent that all of the defendants join this Petition and consent to removal. Conclusion Because this is a civil action between citizens of different states, excluding any fraudulently joined parties,

charges, would register as a sex offender for life, and "he had made certain concessions related to the payment of damages to the victims, including Jane Doe #I." (DE48 at 12.) Despite this, Petitioners suggest that it was "quite reasonable" for Jane Doe #1 to believe that "Jane Doe #1 also understood her ow

t without her participation and knowledge. WHEREFORE, for the reasons outlined above, the Petitioner respectfully requests this Court to grant her Petition, and to order the United States Attorney to comply with the provisions of the CVRA prior to and including any plea or other agreement with the Defe

New York University School of Law, University of Virginia School of Law, and Benjamin N. Cardozo School of

n reports the value of the real and personal property in The Estate located in the Virgin Islands at $577,672,654.00 dollars. 10. According to the Petition, the assets in the Virgin Islands thus far includes: a. $56.5 million in cash; EFTA00074773 GVI v. Estate of Jeffrey E. Epstein GVI's Complaint

llow the Fifth Circuit's holding in Dean (and the view of the U.S. District Courts for the Eastern District of New York and the Eastern District of Virginia) and conclude that the CVRA extends rights to Jane Doe #1 and Jane Doe #2 under the facts of this case. C. The U.S. Attorney's Office Has Previous

t without her participation and knowledge. WHEREFORE, for the reasons outlined above, the Petitioner respectfully requests this Court to grant her Petition, and to order the United States Attorney to comply with the provisions of the CVRA prior to and including any plea or other agreement with the Defe

ulevard Miami, FL 33160 For Jane Doe BRADLEY J. EDWARDS, ESQ. Rothstein Rosenfeldt Adler 401 East Las Olas Boulevard Fort Lauderdale, FL 33301 Jane Doe 3, 4, 5, 6, 7 ISIDRO M. GARCIA, ESQ. Garcia Elkins Boehringer 224 Datura Avenue West Palm Beach, FL 33401 Jane DOE II RICHARD H. WILLITS, ESQ. 2

L 33394 on this 10th day of July, 2009. Att ey 26 EFTA00183991 CERTIFICATE OF TYPE. SIZE AND STYLE Counsel for Petitioners certifies that this Petition is typed in 14 point (proportionately spaced) Times New Roman. , 27 EFTA00183992 - Not an Official Document Page 1 of II ReporLSeJection Crit

action based on the same operative allegations), Jane Doe #3 v. Epstein, No. 08-CV-80232-KAM (S.D. Fla. filed

imity among the defendants. In accordance with 28 U.S.C. § 1446(b) the undersigned are authorized to represent that all of the defendants join this Petition and consent to removal. Conclusion Because this is a civil action between citizens of different states, excluding any fraudulently joined parties,

action based on the same operative allegations), Jane Doe #3 v. Epstein, No. 08-CV-80232-KAM (S.D. Fla. filed

imity among the defendants. In accordance with 28 U.S.C. § 1446(b) the undersigned are authorized to represent that all of the defendants join this Petition and consent to removal. Conclusion Because this is a civil action between citizens of different states, excluding any fraudulently joined parties,

THE PLAINTIFFS: ADAM D. HOROWITZ, ESQ. Mermelstein & Horowitz 15 16 For Jane Doe 17 BRADLEY J. EDWARDS, ESQ. Rothstein Rosenfeldt Adler 18 Jane Doe 3, 4, 5, 6, 7 19 Jbc). 20 ISIDRO M. GARCIA, Garcia Elkins Boehringer 21 22 23 RICHARD H. WILLITS, ESQ. 24 25 For C.M.A. TOTAL ACCESS COURT

eldt Adler, 4 day of July, 2009. 26 on this 10ffi EFTA00233638 CERTIFICATE OF TYPE, SIZE AND STYLE Counsel for Petitioners certifies that this Petition is typed in 14 point (proportionately spaced) Times New Roman. 27 EFTA00233639 - Not an Official Document Page 1 of 11 Report Selection criter