Epstein Secrets

, Intervenor/Appellants hereby certify that the following persons have an interest in the outcome of this case: 1. Marra, The Honorable Kenneth 2. Acosta, R. Alexander 3. Black, Roy 4. Cassell, Paul G. 5. Edwards, Bradley J. 6. Epstein, Jeffrey 7. Ferrer, Wifredo A. 8. Howell, Jay 9. 10 11 12

tion. B. The Private Interests at Stake Are Profoundly Important. Plea negotiations are "rooted in the imperative need for confidence and trust," Jaffee, 518 U.S. at 10, and maintaining their confidentiality advances significant private as well as public interests. There is an "imperative need" that

ure, they will necessarily refrain from making admissions and concessions, either of fact or law, which could later harm their clients. Thus, as in Jaffee, the "evidence" which would be available for later discovery would likely never come into being. Fourth, there is a strong consensus in the states

gress rejected in enacting Rule 501, only one of which appears on this Court's summary in Adkins of the most important considerations identified in Jaffee - over the most important consideration, the strong public and private interests at stake. The Goodyear Tire analysis is far more consonant with th

ure; THEREFORE, on the authority of R. Alexander Acosta, United States Attorney for the Southern Distric

e interests of the United States, the State of Florida, and the Defendant will be served by the following procedure; THEREFORE, on the authority of R. Alexander Acosta, United States Attorney for the Southern District of Florida, prosecution in this District for these offenses shall be deferred in favor of prosecu

350 444 West Railroad Avenue West Palm Beach FL 33401 Co-Counsel for Defendant/Counter-Plaintiff Bradley J. Edwards Bradley J. Edwards Farmer, Jaffee, Weissing, Edwards, Fistos & Lehrman, P.L. 425 N. Andrews Avenue, Suite 2 Fort Lauderdale FL 33401 Marc S. Nurik Law Offices of Marc S. Nurik O

f Utah law professor who is representing the two women. The U.S. attorney's office in Miami would not comment. But the U.S. attorney at the time. R. Alexander Acosta, said in a 2011 letter defending his office that more evidence came to light after Epstein made his deal. "Many victims have spoken out. filing deta

ein made his deal. "Many victims have spoken out. filing detailed statements in civil cases seeking damages. Physical evidence has been discovered," Acosta wrote. "Had these additional statements and evidence been known, the outcome may have been different.” Epstein has settled lawsuits for undisclosed

ionship, unlike the confidential relationship of a doctor and patient or attorney and client, warrants no privilege beyond the terms of Rule 410. See Jaffee, 518 U.S. at 10. But the victims would enjoy an evidentiary benefit from the disclosure of plea negotiations to prove whether the United States viola

ALOW 400 14. Ashley DrivesSuite I 100aTampa. FL 33602 813-984-3060 (Phone)•813-984-3010 (Fax) Toll Free: 866-395-7100 facsimile transmittal To: R. Alexander Acosta, Eiq. Judith Stevenson Arco, Esq. Michael McAuliffe, Esq. Jack Alan Coldberger, Esq. Bradley J. Edwards, Esq. William J. Berger, Esq. From: »mi

95-7100 facsimile transmittal To: R. Alexander Acosta, Eiq. Judith Stevenson Arco, Esq. Michael McAuli

the Parent-Child Center, Inc. and Dr. Serge Thys are protected by the psychotherapist-patient privilege pursuant to the Supreme Court's decision in Jaffee'. Redmond, 518 U.S. 1, 116 S.Ct. 1923 3 EFTA00182846 Case 9:08-cv-80811-KAM Document 114 Entered on FLSD Docket 06/05/2009 Page 4 of 8 a k. v

Utah law professor who is representing the two women. The U.S. attorney's office in Miami would not comment. But the U.S. attorney at the time. R. Alexander Acosta. said in a 2011 letter defending his office that more evidence came to light after Epstein made his deal. "Many victims have spoken out. filing det

in made his deal. "Many victims have spoken out. filing detailed statements in civil cases seeking damages. Physical evidence has been discovered." Acosta wrote. "Had these additional statements and evidence been known. the outcome may have been different." Epstein has settled lawsuits for undisclosed

nship. unlike the confidential relationship of a doctor and patient or attorney and client, warrants no privilege beyond the terms of Rule 410. See Jaffee, 518 M. at 10. But the victims would enjoy an evidentiary benefit from the disclosure of plea negotiations to prove whether the United States violat

ed States was prepared to name in an indictment. SO STIPULATED AND AGREED. Dated: BRADLEY EDWARDS, ESQ. Attorney for Plaintiffs Jane Does #1 & 2 R. ALEXANDER ACOSTA UNITED STATES ATTORNEY Dated: By: ASSISTANT U.S. ATTORNEY DEXTER LEE Attorney for Defendant United States -5- EFTA00191289 Case 9:08-cv-

ney for Plaintiffs Jane Does #1 & 2 R. ALEXANDER ACOSTA UNITED STATES ATTORNEY Dated: By: ASSISTANT

ionship, unlike the confidential relationship of a doctor and patent or attorney and client, warrants no privilege beyond the terms of Rtle 410. See Jaffee. 518 U.S. at 10, 116 S. Cf. at 1928. But the victims would enjoy an evidentiary benefit from the disclosure of plea negotiations to prove whether th