Epstein Secrets

8-cv-80736-KAM Document 417 Entered on FLSD Docket 08/11/2017 Page 5 of 33 On about September 24, 2007, the U.S. Attorney's Office sent an e-mail to Jay Lefkowitz, one of Epstein's attorneys, stating that the Government and Epstein's counsel would negotiate about what information would be disclosed to the vict

the outcome to anyone. Id. at 20, 1 52 (citing Ex. 66) (emphases added). And further, on September 25, 2007, the line prosecutor sent an e-mail to Lefkowitz stating: "And can we have a conference call to discuss what I may disclose to . . . the girls regarding the agreement." Id. at 20, 1 53 (citing Ex.

eement" so that the Government would know exactly what needed to be produced to the victims in this CVRA case. Id. at 43,1 142. On August 18, 2008, Letkowitz wrote the line prosecutor that Epstein objected to disclosure of the terms of the NPA, but that Epstein would "cooperate with the government to rea

ims' S.J. Mot."), DE 361 at 7-47 (listing 157 proposed undisputed facts). The Government has responded by contesting some facts, but not others. See Gov't Resp. to 2 EFTA00597319 Case 9:08-cv-80736-KAM Document 417 Entered on FLSD Docket 08/11/2017 Page 3 of 33 Petitioners' Statement of Undisputed Mater

UNITED STATES JANE DOE #1 AND JANE DOE #2'S RESPONSE TO SUPPLEMENTAL BRIEFING IN SUPPORT OF MOTION TO INTERVENE OF ROY BLACK. MARTIN WEINBERG, AND JAY LEFKOWITZ COME NOW Jane Doe #1 and Jane Doe #2 (also referred to as "the victims"), by and through undersigned counsel, to respond in opposition to the suppl

INTERVENE OF ROY BLACK. MARTIN WEINBERG, AND JAY LEFKOWITZ COME NOW Jane Doe #1 and Jane Doe #2 (also refer

2). Epstein's lawyers, To be sure, as the Government points out, effective defense counsel should always explore plea bargaining opportunities. See Gov't Resp. at 7 (citing Padilla v. Kentucky, 130 S.C.t 1473, 1485 (2010)). But this is a far cry from proving there is a "right" to plea bargaining or that p

rs" within the meaning of Rule 6(e), then it likewise violated grand jury secrecy for government attorneys to make such disclosures to (for example) Jay Lefkowitz. Disclosures of confidential grand jury matters can only be made upon court order. See Fed. R. Crim. P. 6(e)(3)(E). Everything the victims are disc

eys to make such disclosures to (for example) Jay Lefkowitz. Disclosures of confidential grand jury matters

arding the correspondence, consistent with an earlier order of the magistrate judge. In response, the Government "takes no position" on the motion. Gov't Resp. at 1. Accordingly, this part of the victims' motion should be granted. II. NONE OF THE MATERIALS IN THE CORRESPONDENCE ARE BARRED FROM DISCLOSUR

rs" within the meaning of Rule 6(e), then it likewise violated grand jury secrecy for government attorneys to make such disclosures to (for example) Jay Lefkowitz. Disclosures of confidential grand jury matters can only be made upon court order. See Fed. R. Crim. P. 6(e)(3)(E). Everything the victims are disc

eys to make such disclosures to (for example) Jay Lefkowitz. Disclosures of confidential grand jury matters

ed by evidence in the record." The Government has briefly recounted a few facts in opposition to a small sliver of the victims' proposed facts. See Gov't Resp. to Victims' Motion to Have Facts Accepted at 11-13. But none of these facts are supported by any evidence at all. The Government should have at le

rs" within the meaning of Rule 6(e), then it likewise violated grand jury secrecy for government attorneys to make such disclosures to (for example) Jay Lefkowitz. Disclosures of confidential grand jury matters can only be made upon court order. See Fed. R. Crim. P. 6(c)(3)(E). Everything the victims are disc

eys to make such disclosures to (for example) Jay Lefkowitz. Disclosures of confidential grand jury matters

against Jeffrey Epstein in the U.S. District Court, Southern District of Florida, . . [the victims] cannot invoke any protections under the CVRA." Gov't Resp. at 8. This sweeping position is simply irreconcilable with § 3771(c)(I) of the CVRA. If an indictment is a prerequisite to CVRA rights, then depar