Epstein Secrets

ant had successfully adjusted to pris- op, was genuinely interested m several reli- gions, and filed grievances for entirely le- gitimate purposes. U.S.C.A. Const.Amends. 1, 5. [33] Constitutional Law 92 4 1170 92 Constitutional Law 92X First Amendment in General 92X(B) Particular Issues and Applic-

U.S. 225, 95 S.Ct. 2160, 45 L.Ed.2d 141, 20 Fed.R.Serv.2d 547 (Cite as: 422 U.S. 225, 95 S.O. 2160) Supreme Court of the United States Reversed. UNITED ST ES, Petitioner, Robert Lee NOBLES. No. 74-634. Argued April 23, 1975. Decided June 23, 1975. Defendant was convicted in the United States District

rk an implied waiver of all confidential communications on the same subject mat- ter. Accord von Bulow, 82$ F.2d at 102-03; Yankee Atomic Elec. Co. I. United States, 54 Fed. Cl. 306, 316 (2002). The rationale behind our holding is self-evident. When an attorney participates in an extrajudicial meeting or nego

. 0042201 23 EFTA00177962 Page I of 55 Westlaw Page I 531 F.3d 197 (Cite as: 531 F.3d 197) United States Court of Appeals, Second Circuit. UNITED STATES America, Appellee, Donald FELL, Defendant-Appellant. Docket No. 06-2882-cr. Argued: June 27, 2007. Decided: June 27, 2008. Background: Defendant was con

s Reversed. UNITED ST ES, Petitioner, Robert Lee NOBLES. No. 74-634. Argued April 23, 1975. Decided June 23, 1975. Defendant was convicted in the United States District Court for the Central Dis- trict of California of bank robbery and the Court of Appeals, 501 F.2d 146, affumed in part, reversed in part,

er a particular plea is desirable, since "[e]ffective assistance of counsel includes counsel's informed opinion as to what pleas should be entered." United Stalest Pillar, 416 F. Supp. 887, 889 (S.D.N.Y. 1976); Borial. Keane, 99 F.3d 492, 497 (2d Cir. 1996), citing ABA Model Code of Professional Responsibility

in- stance. The court authorized no general `fishing expedition' into the defense files ji or indeed even into the defense 'nvestigat- or's report. a. United States . Wright, 160 U.S.App.D.C. 57, 489 .2d 1181 O 2011 Thomson Reuters. No Claim to Orig. US Gov. Works. https://web2.westlaw.com/print/printstream.a

nt to Epstein's residence approximately 25 times from the age of 14 or 15 until the age of 16 or 17. Rivera was introduced to Epstein by her friend Tatum Miller. Rivera met Miller at a middle school in Jupiter, Florida, but they did not become friends until later when they lived near each other in West Pal

ictim of a violation of lenumemtod $04)(1011x of Title l8) and who suffers personal injury as a m utt of such violation ...may sue In any oppropioto United Stales 011trint Court and shall recover the actual damages such person sustains and the cost of the suit, includingii reasonable attorney's fee." toot U

litigant. to contest allegations made against him seem to contradict the principles of justice and fairness that fire embedded in the tenets of the United Slates Attorney's Office. I also assert that on both a principled and practical level. the mere involvement of your Office in the matter with respect to

NETT MIAMI • F00 LAUDERDALE • WraT PALM UfA01 • 5T. PETER5OLMO 3067800201 December 7, 2007 Jeffrey Sloman First Assisiam United States Attorney United Stales Attorney's Office Southern District of Florida Re: Jeffrey Epstein Dear Jeff: 1-(466 P.002/004 F-016 Callnac) 5810 FIALA FouNi0arni nowt 130

d victims. This letter is meant to assist you in performing your duties by providing you with background information regarding the agreement between the United States and Jeffrey Epstein and the duties that the attorney representative will have to perform. The Federal Bureau of Investigation and the U.S. Attorney

e Petitioners have not been attempting to negotiate with the government for more than 30 months. As set forth in the Procedural I Iistory Section of the United States' Opposition to Jane Doe #1 and Jane Doe #2's Motion for Finding of Violations of the Crime Victim Rights Act ("CVRA"), at the last hearing on the Pet

arly hooking at least IS years old. 'worn Statement at 38-39). In fact. there is no evidence that Mr. At the December 14 meeting. we also discussed Tatum Miller as emblematic of our concerns surrounding 11w government's selection or "victims," As you are aware. Ms. Miller RFP MIA 000042 EFTA00184925 12/2

n in county jail; (3) a methodology to compensate the victims identified by the United States; (4) entry EFTA00225699 U.S. Department of Justice United Slates Attorney Southern District of Florida First As,ramt US Attorney DELIVERY BY FACSIMILE Jay P. Lefkowitz, Esq. Kirkland & Ellis LLP Cifigroup Ce

or calls unless AUSA Villafana and/or her supervisors advise him otherwise. Furthermore, you make reference to "our July 8 deadline." Respectfully, the United States Attorney's Office for the Southern District of Florida ("SDFL") has never agreed to any such deadline. Should you decide to provide the SDFL with an

ations which ultimately resulted in United States Attorney R. Alexander Acosta's' December 19, 2007 letter to Lilly Ann Sanchez. In that letter, the United States Attorney tried to eliminate all concerns which, quite frankly, the SDFL was not obligated to address, let alone consider. He proposed the following

ederal prosecutors during the negotiations of a deterred prosecution agreement. The consistent representations of key Government wimesses (such as Tatum Miller. Brittany Beak, Saige Gonzalez. and Jennifer Laduke) confirm the following critical points: First, there was no communication, telephonic or otherw

ough such misconduct was, as we contend it is, inextricably intenwined with the credibility of the accusations being made against Mr. Epstein by the United States Attorney's Office in Miami ("USAO"). Moreover, CEOS did not assess the terms of the Deferred Prosecution Agreement now in effect, nor did CEOS revie

deral prosecutors during the negotiations of a detbrred prosecution agreement. The consistent representations of key Government witnesses (such as Tatum Miller. Brittany Beale, Saige Gonzalez, and Jennifer Laduke) confirm the following critical points: rips!, there was no communication, telephonic or othcn

ions. LIMITED OFFICIAL USE Previous editions and Form OBD-111A are obsolete FORM OBD-111 JAN. 93 EFTA00234719 06/18/2008 15:16 FAX 5618059848 USA0 WPB CONFRM lit007 (16) Basis for Belief that Witness Will Assert Fifth Amendment Privilege: As explained above, the witness's attorney has inform

Witness Previously Immunized? ( ) Ycs (X) No If yes, give details: (28) Witnesses for whom Immunity has been Authorized in this Proceeding: and Tatum Miller (two other girls who were both victims and recruiters). (29) Date Investigation Began: July 2006 (30) Witness Subject to Electronic Surveillance

of an enumerated federal crime. This requires Mr. Epstein to in essence admit guilt, though he believes he did not commit the requisite offense. The United States Attorney Manual ("USAM") 9-27.440, Principles of Federal Prosecution, sets forth a clear requirement when a defendant tenders a plea of guilty but s

s" contradicts claims made by federal prosecutors during the negotiations of a deterred prosecution agreement. re )resumat. ent witnesses (such as Tatum Miller. confirm the following critical points: WI, there was no T O CJWISC, that meets the requirements of § 2422(4 For instance. Ms confirmed that Mr

mate, including but not limited to, eligibility for gain time credit based on standard rules and regulations that apply in the State of Florida. At the United States' request, Epstein agrees to provide an accounting of the gain time he earned during his period of incarceration. 13. The parties anticipate that t

so to the public on her web page where she posted a nude photo clearly looking at least IX years old. At the December 14 meeting. we also discussed Tatum Miller as emblematic of our concerns surrounding the government's selection of "victims." As you are mare, Ms. Miller Case No. 08-80736-CV-MARRA P-013355