Epstein Secrets

n that we believe is material to the victims' CVRA case — a limited amount of information that could be swiftly located by your Office." Letter from Bradley J. Edwards & Paul G. Cassell to Wifiedo A. Ferrer, Mar. I, 2011. The victims have, for example, requested that the U.S. Attorney's Office provide to them unreda

tes District Court, Southern District of Florida Bradley J. Edwards, Esq., Farmer, Jaffe, Weissing, Edwards, Fistos & Lehr

nited States, Case No. 08-80736-CIV- United States District Court, Southern District of Florida Bradley J. Edwards, Esq., Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, P.L. Paul G. Cassell S.J. Quinney College of Law at the University of Utah Attorneys for Jane Doe # 1 and Jane Doe # 2 54 EF

urate information came to be made a part of the record and the extent to which Mr. Epstein, through his attorneys, was culpable. Sincirely, BE/sg Brad Edwards SECTS KADRDWARDSLAW COM EFTA00230161 Case 9:08-cv-80736-KAM Document 50-2 Entered on FLSD Docket 03/21/2011 Page 1 of 2 UNITED STATES DISTRICT

does not authorize an unbridled gallop to any and all information in the government's files." 558 F.Supp.2d at 425. Similarly, in United States v. Coxton, 598 F.Supp.2d 737 (W.D.N.C. 2009), several crime victims invoked the. CVRA in at attempt to obtain portions of the pit-sentence investigation repo

rejected claims by victims that one or more of the rights in section 3771(a) create a right of access to information in the government's possession; Coxton (no right 4 EFTA00230167 Case 9:08-cv-80736-KAM Document 59 Entered on FLSD Docket 04/07/2011 Page 5 of 9 to PSR); Kenna (same); and Sacane (no

n that we believe is material to the victims' CVRA case — a limited amount of information that could be swiftly located by your Office." Letter from Bradley J. Edwards & Paul G. Cassell to Wifiedo A. Ferrer, Mar. I, 2011. The victims have, for example, requested that the U.S. Attorney's Office provide to them unreda

tes District Court, Southern District of Florida Bradley J. Edwards, Esq., Farmer, Jaffe, Weissing, Edwards, Fistos & Lehr

Case No. 08-80736-CIV-MARRA/JOHNSON United States District Court, Southern District of Florida Bradley J. Edwards, Esq., Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, P.L. 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 (954) 524-2820 Fax: (954) 524-2822 E-mail: bradarloatht

urate information came to be made a part of the record and the extent to which Mr. Epstein, through his attorneys, was culpable. Sincerely, BE/sg Brad Edwards 2028 minnow 8TRXIT,8171T11 202, HOLLYWOOD, FLORIDA 33020 OFFICE: 954-414-8033/305-935-2011 FARz 954 - 924 - 1530/305-955-4227 BRORADIDWARDSLAW.0

ided ample information concerning the applicable Sentencing Guidelines and other issues related to the defendants' sentencing. The district court in Coxton found that the victims in that case were present during trial and continued to enjoy access to the United States Attorney's Office. Id. at 740. Th

rejected claims by victims that one or more of the rights in section 3771(a) create a right of access to information in the government's possession; Coxton (no right 4 08-80736-CV-MARRA 000921 EFTA00230745 Case 9:08-cv-80736-KAM Document 59 Entered on FLSD Docket 04/07/2011 Page 5 of 9 to PSR); Ke

tes District Court, Southern District of Florida Bradley J. Edwards, Esq., Farmer, Jaffe, Weissing, Edwards, Fistos & Lehr

ts that the victims have offered. DATED: March 21, 2011 Respectfully Submitted, l Bradley J. Edwards adley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L. 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 Telephone (954) 524-2820 Facsimile (954) 524-2822 Flori

n that we believe is material to the victims' CVRA case — a limited amount of information that could be swiftly located by your Office." Letter from Bradley J. Edwards & Paul G. Cassell to Wifredo A. Ferrer, Mar. I, 2011. The victims have, for example, requested that the U.S. Attorney's Office provide to them unreda

rejected claims by victims that one or more of the rights in section 3771(a) create a right of access to information in the government's possession; Coxton (no right 4 EFTA00177150 Case 9:08-cv-80736-KAM Document 59 Entered on FLSD Docket 04/07/2011 Page 5 of 9 to PSR); Kenna (same); and Sacane (no

, dots not authorize an unbridled gallop to any and all information in the government's files." 558 F.Supp.2d at 425. Similarly, in United States'. Coxton, 598 F.Supp.2d 737 (W.D.N.C. 2009), several crime victims invoked the CVRA in at attempt to obtain portions of the pre-sentence investigation repor

tes District Court, Southern District of Florida Bradley J. Edwards, Esq., Farmer, Jaffe, Weissing, Edwards, Fistos & Lehr

Case No. 08-80736-CIV-MARRA/JOHNSON United States District Court, Southern District of Florida Bradley J. Edwards, Esq., Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, P.L. 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 (954) 524-2820 Fax: (954) 524-2822 E-mail: brad@pathtoj

rejected claims by victims that one or more of the rights in section 377I(a) create a right of access to information in the government's possession• Coxton (no right 4 EFTA00208109 Case 9:08-cv-80736-KAM Document 59 Entered on FLSD Docket 04/07/2011 Page 5 of 9 to PSR)• Kenna (same); and Sacane (no

does not authorize an unbridled gallop to any and all information in the government's files." 558 F.Supp.2d at 425. Similarly, in United States v. Coxton, 598 F.Supp.2d 737 (W.D.N.C. 2009), several crime victims invoked the CVRA in at attempt to obtain portions of the pre-sentence investigation repor

uld choose the more expansive interpretation. Not only is the CVRA "remedial legislation" that should be broadly construed to achieve its purposes, Edwards v. Kia Motors of America, Inc., 554 F.3d 943, 948 (11th Cir 2008), but the sponsors of the CVRA stated that the right to confer was "intended to be

an appropriate briefing schedule and hold a hearing on the appropriate remedy for those violations. DATED: May 2, 2011 Respectfully Submitted, s/ Bradley J. Edwards Bradley J. Edwards FARMER, JAFFE, WEISSING, 27 EFTA00178083 Case 9:08-cv-80736-KAM Document 77 Entered on FLSD Docket 05/02/2011 Page 28 of 29

eed additional facts, evidence, or there's going to be a stipulation submitted to me upon which I can rely. MR. EDWARDS: Sure. Your Honor, this is Brad Edwards. I believe that you do have a sufficient record, in that I don't think that -- I think that we're in agreement that additional evidence does not ne

ctims cannot review the PSR is that the PSR is already reviewed by the Court. Thus, in the first PSR case cited by the Government, United States v. Coxton, 598 F.Supp.2d 737 (W.D.N.C. 2009), the Court declined to disclose PSR information to the victims because "[n]othing in the PSR enhances or changes

order to that effect was attached with the victims' original motion, which the Court should enter. DATED: May 2, 2011 Respectfully Submitted, s/ Bradley J. Edwards Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L. and Paul G. Cassell Pro Hac Vice Attorneys for Jane Doe #1 and Jan

ion, which the Court should enter. DATED: May 2, 2011 Respectfully Submitted, s/ Bradley J. Edwards Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L. and Paul G. Cassell Pro Hac Vice Attorneys for Jane Doe #1 and Jane Doe #2 conversations with the Government, it has bee

victims cannot review the PSR is that the PSR is already reviewed by the Court. Thus, in the first PSR case cited by the Government, United States. Coxton, 598 F.Supp.2d 737 (W.D.N.C. 2009), the Court declined to disclose PSR information to the victims because "[n]othing in the PSR enhances or changes