Epstein Secrets

to 29 Response in Opposition to Motion to Unseal Non-Prosecution Agreement filed by Jane Doe. (Attachments: # 1 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: 10/16/20

nt to the victims included this proposed stipulation: On July 9, 2008, AUSA Villafafla sent a victim notification to Jane Doe # I via her attorney, Bradley Edwards, which is attached as Exhibit 6 to the Villafafia Declaration. That notification contains a written explanation of the full terms of the agreement

JUDGE 14 Appearances: 15 FOR THE PETITIONER Bradley J. Edwards, ESQ., and 16 Paul G. Cassell, ESQ. 1? FOR THE RESP

s based in the Lewis & Clark College of Law. During the call, Ms. Garvin was not advised about the Non-Prosecution Agreement. In mid-June 2008, Mr. Edwards contacted Assistant U.S. Attorney Villafafia to inform her that he represented Jane Doe #1 and, later, Jane Doe #2. Mr. Edwards asked to meet to pro

the improper deposition. 12. In mid-June 2008, Attorney Edwards contacted AUSA Villafafia to inform her that he

(D.E. 19), petitioners seek an order compelling the Government to produce the Non- Prosecution Agreement with Jeffrey Epstein (D.E. 19 at 11-13), and the Report of Interview with Jane Doc # 1 (D.E. 19 at 13-14). The Government is unable to voluntarily produce the Non-Prosecution Agreement because the Agreement contains

ey SERVICE LIST Jane Does 1 and 21 United States, Case No. 08-80736-CIV-MARRA/JOHNSON United States District Court, Southern District of Florida Brad Edwards, Esq., The Law Offices of Brad Edwards & Associates, LLC 2028 Street, Suite 202 Hollywood, Florida 33020 (954) 414-8033 Fax: (954) 924-1530 EF

istrict Court, Southern District of Florida Brad Edwards, Esq., The Law Offices of Brad Edwards & Associa

D.E. 19), petitioners seek an order compelling the Government to produce the Non-Prosecution Agreement with Jeffrey Epstein (D.E. 19 at 11-13), and the Report of Interview with Jane Doe # 1 (D.E. 19 at 13-14). The Government is unable to voluntarily produce the Non-Prosecution Agreement because the Agreement contains

SERVICE LIST Jane Does I and 2 v. United States, Case No. 08-80736-CIV-MARRA/JOHNSON United States District Court, Southern District of Florida Brad Edwards, Esq., The Law Offices of Brad Edwards & Associates, LLC EFTA00067257

istrict Court, Southern District of Florida Brad Edwards, Esq., The Law Offices of Brad Edwards & Associa

D.E. 19), petitioners seek an order compelling the Government to produce the Non-Prosecution Agreement with Jeffrey Epstein (D.E. 19 at 11-13), and the Report of Interview with Jane Doe # 1 (D.E. 19 at 13-14). The Government is unable to voluntarily produce the Non-Prosecution Agreement because the Agreement contains

istrict Court, Southern District of Florida Brad Edwards, Esq., The Law Offices of Brad Edwards & Associa

y SERVICE LIST Jane Does 1 and 21. United States, Case No. 08-80736-CIV-MARRA/JOHNSON United States District Court, Southern District of Florida Brad Edwards, Esq., The Law Offices of Brad Edwards & Associates, LLC 2028 Harrison Street, Suite 202 Hollywood, Florida 33020 (954) 414-8033 Fax: (954) 924-

(D.E. 19), petitioners seek an order compelling the Government to produce the Non- Prosecution Agreement with Jeffrey Epstein (D.E. 19 at 11-13), and the Report of Interview with Jane Doe # 1 (D.E. 19 at 13-14). The Government is unable to voluntarily produce the Non-Prosecution Agreement because the Agreement contains

y (USAFLS) Subject: Jane Doe Litigation Alex and Jeff, We have a status conference with Judge Marra today at 3:30 p.m. When Marie and I met with Brad Edwards last Thursday, we agreed there was no need for an evidentiary hearing. He did want the government to disclose the non- prosecution agreement with E

is disclosed pursuant to a court order, that disclosure be accomplished pursuant to a protective order which would prevent further dissemination by Edwards. Marie spoke with Edwards yesterday, and he agreed that a protective order could be issued by the Court. I anticipate that the parties will advise

ent filed a response stating that it could not voluntarily disclose the non-prosecution agreement since it contained a confidentiality clause. As to the Report of Interview, we stated that no such document existed. Epstein's counsel has requested that, if the agreement is disclosed pursuant to a court order, that discl

(USAFLS); Jacobus, Wendy (USAFLS) Subject: Draft Response to Victims' Motion for Production Alex and Jeff, Marie and I had a cordial meeting with Brad Edwards on August 7. The parties agreed that an evidentiary hearing was not necessary, and we advised Edwards that we could not voluntarily disclose the Non

, Marie and I had a cordial meeting with Brad Edwards on August 7. The parties agreed that an evidentiary hearing was not necessary, and we advised Edwards that we could not voluntarily disclose the Non-Prosecution Agreement since it contained a confidentiality clause. Edwards had a number of questions

ort of Interview with Jane Doe # 1. We cited the confidentiality clause as precluding the government's voluntary production of the Agreement. As to the Report of Interview, FBI Agents Kurykendall and Richardson have advised that no such report was prepared after the late September 2007 meeting with C.W. Please feel fr

(USAFLS); Jacobus, Wendy (USAFLS) Subject: Draft Response to Victims' Motion for Production Alex and Jeff, Marie and I had a cordial meeting with Brad Edwards on August 7. The parties agreed that an evidentiary hearing was not necessary, and we advised Edwards that we could not voluntarily disclose the Non

, Marie and I had a cordial meeting with Brad Edwards on August 7. The parties agreed that an evidentiary hearing was not necessary, and we advised Edwards that we could not voluntarily disclose the Non-Prosecution Agreement since it contained a confidentiality clause. Edwards had a number of questions

ort of interview with Jane Doe # 1. We cited the confidentiality clause as precluding the government's voluntary production of the Agreement. As to the Report of Interview, FBI Agents Kurykendall and Richardson have advised that no such report was prepared after the late September 2007 meeting with C.W. Please feel fr