Epstein Secrets

2:44 PM NOT A CERTIFIED COPY Case 9:08-cv,80736-KA.ocurnen\ 48-5 Emered on FLSD Do.03/21/2011 I I :sentenced not later y,an October 26, 2007-. the UnitedjStates bas 110 objection to J;:pstein seJfsreporting to begin ~rving hls sentence ·not later than January 4, 2008. • 12. Epstein agrees that.he will no

lty and to ·provide compensation in the tQanner aescribed ab()ye, ifEpsteirt successfully fulfills allt>fthe tenns ~ _conditi9M of this agreement, the United Stat~s 1,1~0 agrees that it will niH institute: BilY criminal charges against any potential ~~onspirators ofEpstein, inclµding but not limited toi Sarah Ke

offense includcs; ;but is net limitadto; a conviction liy a foderabor miUtary'tribunal,-including courts-martial conducted by the Armed Forcos of tho United Status,, >and includes a conviction-orentry of a ploa of',guilty or nolo contendere resulting in a-sanctiun in anyistato of dio United-States or other juris

he gain time he earned during his period of incarceration. 13. The parties anticipate that this agreement will not be made part of any public record. Ifthe United States receives a Freedom ofInformation Act request or any compulsory process commanding the disclosure of the agreement, it will provide notice to Epstein

ll.· .. attempt to obstruct justice, or ... to threaten, injure, or intimidate, a prospective witness or juror." 18 U.S.C. § 3142(t)(2)(B); see also United States v. Friedman, 837 F.2d 48 (2d Cir. 1988). The Bail Reform Act lists four factors to be considered in the detention analysis: (1) the nature and circ

text of the agreement purports to bind “the Government.” See Annabi, Tl\ F.2d at 672. This analysis similarly extends to a non-prosecution agreement. See United States v. Laskow, 688 F. Supp. 851, 854 (E.D.N.Y. 1988) (“Defendant’s argument, in effect, is that unless there is an explicit statement to the contrary, it

ic records, including publicly released records of the Palm Beach Police Department, the State Attorney's Office for the 15th Judicial Circuit, and the Palm Beach Sheriff's Office; documents pertaining to the CVRA litigation and other court proceedings involving Epstein and related individuals; and books and media reports. B.

k that physical force against the person . . . or another may be used in t the course of committing the offense." 18 U.S.C. § 16(b). Post-Johnson v. United Sta , U.S. 135 S. Ct. 2551 (2015), a court might decide differently. See, e.g., Menendez Whitaker, 908 F.3d 467 (9'b Cir. 2018). Even if not a crime

considered for work release. At some point after the NPA was signed, USA Acosta was recused from the Epstein matter. AUSA John McMillan (still at USA0): Early in the investigation, I asked AUSA McMillan if he would serve as co-counsel on the case. Before I joined the West Palm Beach Office, AUSA M

rate contact with Epstein. (See Exhibit A-1.) One of the subpoenaed victims was Individual #28, who is referred to as Jane Doe #2 in the Jane Doe' United Stales litigation. When approached for an interview, Individual #28 refused to speak with the agents, and I remember S/A Kuyrkendall telling me that she fe

GRAND JURY PROCEEDINGS SEALED ORDER GRANTING APPLICATION FOR PERMISSION TO DISCLOSE GRAND JURY MATERIAL THIS MATTER has come before the Court on the United States' Sealed Application for Permission to Disclose Grand Jury Material and for Entry of a Protective Order. The Court has considered the Motion and find

rew Lourie, Criminal Chief Matt Menchel, First Assistant Jeff Sloman, and U.S. Attorney Alex Acosta. AUSA Atkinson did participate in meetings with the Palm Beach Sheriff's Office about Epstein's work release and several conference calls with defendant attorney Roy Black and others about Epstein's breaches of the Non-Prosecut

lm Beach, FL 33401 (561) 820-8711 Facsimile: (56!) 820-8777 July 10, 2008 NOTIFICATION OF IDENTIFIED VICTIM NOTICE: IN ACCORDANCE WITH TITLE 18, UNITED STATES CODE, SECTION 3509(d) AND FLORIDA LAW, THE ATTACHED DOCUMENT IS TO BE TREATED AS CONFIDENTIAL AND SHALL NOT BE DISCLOSED EXCEPT IN CONNECTION WITH

e victim all asked to address the Court. I cited the CVRA and other statutes to support the Court's authority to hear from them. The second case was United States' Oliver, which was the Office's first case seeking the appointment of a guardian ad litem (GAL). Through these cases, I researched statutes, cases,

, and London, England. Ms. Villafafia remained in civil practice, specializing in intellectual property litigation until 2001, when she was hired by the United States Attorney's Office in Miami. While she enjoyed civil practice, Ms. Villafafia for many years had wanted to be an Assistant United States Attorney. T

bit 76 at 2). On November 16, 2007, the case agents met with ASA Belohlavek who said that Epstein would be housed at the Palm Beach County Jail, so the Palm Beach Sheriff's Office would be in charge of whether Epstein would be eligible for work release (id. at I). Special Agent Richards confirmed on November 16, 2007 that Eps

whether pursuant to state, federal, or common law. Notwithstanding this waiver, as to those individuals whose names appear on the list provided by the United Slates, Epstein's signature on this agreement is not to be construed as an admission of any criminal or civil liability other than that contained in 18 U.

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

tion for the work release program demonstrated that Mr. Epstein made several false statements in his application and made threatening statements to the Palm Beach Sheriff's Office about legal repercussions if he was not admitted to the program. I also discovered—again, not from Mr. Epstein or his attorneys—that Judge McSorley

whether pursuant to state, federal, or common law. Notwithstanding this waiver, as to those individuals whose names appear on the list provided by the United Slates, Epstein's signature on this agreement is not to be construed as an admission of any criminal or civil liability other than that contained in 18 U.

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

tion for the work release program demonstrated that Mr. Epstein made several false statements in his application and made threatening statements to the Palm Beach Sheriff's Office about legal repercussions if he was not admitted to the program. I also discovered—again, not from Mr. Epstein or his attorneys—that Judge McSorley

e victims in the U.S. District Court, using the following language: Upon the execution of this agreement, the United States will file a motion with the United States District Court for the Southern District of Florida for the appointment of a guardian ad litem for these persons [referring to the victims]. On Sep

pect to the second term, regarding a jail sentence, we later learned that Epstein's attorneys had been trying to arrange with the State Attorney and the Palm Beach Sheriff's Office to allow Epstein to serve his term on "work release," which would allow him to be out of custody all day, just returning to a "halfway house" to sl

internal as I tried to deal professionally with opposing counsel. In the midst of all of the post-NPA back-and-forth with Epstein, was the Jane Doe. United States litigation.4 Despite the Office's request to be recused from the case, the Justice Department decided that there was no conflict of interest and I w

directing their communications to MAUSA9 , Criminal Chief First Assistant Jeff and U.S. Attorney Alex Acosta. did participate in meetings with the Palm Beach Sheriff's Office about Epstein's work release and several conference calls with defendant attorney Roy Black and others about Epstein's breaches of the Non-Prosecut