Epstein Secrets

tervenor Date Filed: 07/07/2008 Jury Demand: None Nature of Suit: 440 Civil Rights: Other Jurisdiction: U.S. Government Defendant represented by Bradley James Edwards Farmer Jaffe Wcissing Edwards Fistos &Lehrman PL 425 N Andrews Avenue Suite 2 Fort Lauderdale, FL 33301 954-524-2820 Fax: 954-524-2822 Email:

toj2 Response in Opposition to Motion to Unseal Non—Prosecution Agreement filed by Jane Doe. (Attachments: fll. Exhibit October 9, 2008 letter from Brad Edwards, Esquire to AUSA Dexter Lee, #.2 Exhibit October 15, 2008 Letter from Brad Edwards, Esquire to AUSA Dexter Lee)(Edwards, Bradley) (Entered: 10/16/2

otion to Unseal Document. Signed by Judge- on 2/12/2009. (ir) (Entered: 02/12/2009) 04/09/2009 E NOTICE by Jane Doe of Change of Finn Affiliation (Edwards, Bradley) (Entered: 04/09/2009) 09/08/2010 a Administrative Order Closing Case. Signed by Judge on 9/8/2010. (tb) (Entered: 09/09/2010) 09/13/

e admitted in evidence as proof of guilt." Herman, 544 F.2d at 797. Plea negotiations are "rooted in the imperative need for confidence and trust," Jaffee v. Redmond, 518 U.S. 1, 10 (1996), and maintaining their confidentiality advances significant public and private ends. Discovery and use of plea negotiations

21 at 9:41 am On Friday the 1 1 th Circuit ruled that discovery can move forward in an important Crime Victims' Rights Act case that my co-counsel, Brad Edwards, and I are pursuing. The narrow issue before the court was whether prosecutors and defense attorneys could assert some sort of "privilege" to preve

agreement and that the pleas would bar a federal prosecution. As a result, the victims did not attend the state court proceedings. On July 7, 2008, Edwards and I filed a petition alleging that Jane Doe No. 1 was a victim of federal sex crimes committed by Epstein and that the United States had wrongful

ge is rooted in the imperative for confidence and trust, the evidentiary benefit of the denial of the privilege, and any consensus among the states, Jaffee v. Redmond, 518 U.S. 1, 10-15 (1996)—but none of these considerations weighs in favor of recognizing a new privilege to prevent discovery of the plea negotiat

llionaire sex offender Jeffrey Epstein link Epstein and Jean Luc Brunel, owner of modeling agency MC2. The documents say MC2 employees told attorney Brad Edwards that Epstein’s condos at 301 E. 66th St. in New York City were used to house young models. Edwards, who has sued Epstein on behalf of several women

he documents say MC2 employees told attorney Brad Edwards that Epstein’s condos at 301 E. 66th St. in New York City were used to house young models. Edwards, who has sued Epstein on behalf of several women claiming to be victims of sex abuse by Epstein, was told MC2 brought underage girls in from all over

ege is rooted in the imperative for confidence and trust, the evidentiary benefit of the denial of the privilege, and any consensus among the states, Jaffee v. Redmond, 518 U.S. 1, 10-15 (1996}—but none of these considerations weighs in favor of recognizing a new privilege to prevent discovery of the plea negotiatio

lionaire sex offender Jeffrey Epstein link Epstein and Jean Luc Brunel. owner of modeling agency MC2. The documents say MC2 employees told attorney Brad Edwards that Epstein's condos at 301 E. 66th St. in New York City were used to house young models. Edwards, who has sued Epstein on behalf of several women

e documents say MC2 employees told attorney Brad Edwards that Epstein's condos at 301 E. 66th St. in New York City were used to house young models. Edwards, who has sued Epstein on behalf of several women claiming to be victims of sex abuse by Epstein, was told MC2 brought underage girls in from all ove

lege is rooted in the imperative for confidence and trust, the evidentiary bit of the denial of the privilege, and any consensus among the states, Jaffee v. Redmond, 518 I. 10-15 (1996)—but none of these considerations weighs in favor of recognizing a new privilege to prevent discovery of the plea negotiations

rsons 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 13 14 15 11 Page C-1 of 2 EFTA00209658 Case: 13-12923

dentiality on which defense counsel have reasonably relied for many decades in negotiating with government attorneys on behalf of their clients. In Jaffee v. Redmond, 518 U.S. 1 (1996), the Supreme Court focused on four primary considerations governing the recognition of privileges under Rule 501: the needs of t