Epstein Secrets

03/21/2011 Page 1 of 42 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 08-80736-CW-Marra/Johnson JANE DOE #1 and JANE DOE #2 I. UNITED STATES JANE DOE #1 AND JANE DOE #2'S MOTION FOR FINDING OF VIOLATIONS OF THE CRIME VICTIMS' RIGHTS ACT AND REQUEST FOR A HEARING ON APPROPRIATE REMEDIES

3 07/09/2008 15:13 FAX 5818059848 115110 WPB CONFRM Case 8:08-Cv-80736-KAM •ument 48-3 Entered on FLSD Diie1 03/21/ U.S. Department of Justice United Slates Attorney Southern District of Florida SOO South Australian Ave.. Suite 400 West Palm Beach. FL 3)401 (561)820-8711 Facsimile- (361)820-8777 Jun

1 of 4 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 013-80736-Civ-Marrellohnson JANE DOE #1 AND JANE DOE #2, Plaintiffs, I. UNITED STATES OF AMERICA, Defendant. MOTION TO INTERVENE OR IN THE ALTERNATIVE FOR A SUA SPONTE RULE I I ORDER Comes now, Movant Bruce E. Reinhart, pursuant to Federal Ru

he agreement secret. In particular, the agreement stated: "The parties anticipate that this agreement will not be made part of any public record. If the United States receives a Freedom of Information Act request or any compulsory process commanding the disclosure of the agreement, it will provide notice to Epstei

overnment claims is troublesome, the Filth Circuit cited to the district court opinion under review, which had quoted all the words in the statute. See United States'. BP Products, 2008 WL 501321 at '7 (noting victims right to confer "in the case"), cited in In re Dean, 527 F.3d at 394. 28 08-80736-CV-MARRA 000

rifi-nationi to the Nom Prosecution Agreement and agrees to comply with than. Dated: BY: Dated: Dated: Dated: ifrjfa Ft. ALEXANDER ACOSTA UN: TED STATES ATTORNEY A. MARIE VILLAFJA ASSISTANT' U.S. A ITORNEY JEFFREY EPSTEIN GERALD LEECOURT, ESQ. COUNSEL 713 JEFFREY EPSTELN LILLY ATTORNEY FOR JEFF

y and non-monetary sanctions against both the lawyer filing the pleading and the lawyer's client. Fed: R. Civ. P. 11(c). 28 U.S.C. 61927 Title 28, United States Cod; Section 1927 states: Any attorney or other person admitted to conduct cases in any court of the United States or any Territory thereof who so mult

the University of Pennsylvania Law School. 4. After graduating from law school, I served as judicial law clerk to the Honorable Norma L. Shapiro, Unitqd States District Judge for the Eastern District of Pennsylvania. 5. In 1988, I began working at the Criminal Division of the United States Department of

to you and to answer any questions you may have regarding the criminal justice process throughout the kivestmetion. Our program is part of the FBI's Stott to ensure the victims are treated with respect and are provided information about their rights under federal law. These rights include notification

n federal income tax returns stated cause of action for dis- crimination among religions prohibited by establishment clause of First Amendment. 26 U.S.C.A. § 170; Fed.Rules Civ.Proc. Rule 12(b)(6), 28 U.S.C.A.; U.S.C.A. Conan. Amend. 1. 4. Constitutional Law 4=,84(I) Establishment clause of First Ame

injunction 36. United Stater v. Dionino, 410 US. 1, 17, 93 S.Ct. 764, 773, 35 L-Edid 67 (1973). 37. /I at 16, 93 S.Q. at 772 (quoting Stirone v. United Stater, 361 US. 212, 218, 80 S.Ct. 270, 273. 4 L.Ed.2d 252 (1960)). EFTA00191835 U.S. I BURZYNSKI CANCER RESEARCH INSTITUTE 1313 ateas5M F.2d 1301 (Mb

ce which a prison has not commenced to serve. Ellison r. United State 263 F.2d 395 (10 Cir. 1969); Cain United States, 49 870 (8 Cir. 1 ). In Heflin United States, 868 U.S. 416, 79 S.Ct. 461, 3 L.Ed.2d 407 (1959), the Supreme Court stated that: "Section 2255 is available only to attack a sentence under which

violations, brought action to enforce terms of immunity agreement under United States Department of Justice's (DOJ's) corporate leniency program. The United States District Court for the Eastern Dis- trict of Pennsylvania, Timothy J. Savage, J., 352 F.Supp2d 553, enjoined prosecu- tion, and government appealed.

The Supreme Court has observed that the executive branch "has exclusive authority and absolute discretion to decide whether to prosecute a case," United States v. Nixon, 418 U.S. 683, 693, 94 S.Ct. 3090, 41 L.Ed2d 1039 (1974), and the Gov- ernment therefore argues that courts lack jurisdiction to enjoin a

r dis- crimination among religions prohibited by establishment clause of First Amendment. 26 U.S.C.A. § 170; Fed.Rules Civ.Proc. Rule 12(b)(6), 28 U.S.C.A.; U.S.C.A. Conan. Amend. 1. 4. Constitutional Law 4=,84(I) Establishment clause of First Amend- ment prohibits denominational preferences, includi

ms Against the Government 131 Neither the United States, its agen- cies, nor its officials acting in their official capacities, may be sued without the United States' specific consent's The Federal Tort Claims Act 7 permits certain claims to be asserted against the United States, as sov- ereign, and its agents bu

with Stolt-Niel- sen on January 16, 2003. Under the terms of the Agreement, the Government agreed "not to bring any criminal prosecution against [Stott-Niel- sen] for any act or offense it may have committed prior to the date of this [Agreement] in connection with the anti- competitive activity bei

presenting a ticket as set forth in sub- paragraph (d) of paragraph 1 of this Agreement and 8 CFR 231 and 217 (a). 2. The carrier will transport to the United Slates nonimmigrant aliens intending to travel by Sr or sea under the Visa Waiver Program who have received, prior to embarking on an air a sea carrier for

of Customs and Border Protection?, on behalf of the United States of America, in conjunction with the transport of certain nonimmigrant visitors to the United States end the wallor of the roqukoment of nonimmigrant visas for the admission of such nonimmigrant visitors into the United States under a Visa Waiver Pr

rtation sportation Lin By. Signed this tic 1) 1 1iN W At For a tayofOtiObe/ Lei/ Signature Jeffrey Epstein Printed Name President Title United State America U.S. Customs an Protection Paperwork Reduction Act Statement: An agency may not conduct or sponsor on information collection end n person la not r

k, New Y rk By: President TITLE Signed this At: By Exetutio late Commis>i Operations, Customs and Border Not ion Department of I location Stott:it Rem 1-120 (3/31/92) EFTA00301627

a IM end of ttws dxurnem for more infornnon. Cash Cash and money balances Cash and mosey balances may Ind tcle avaltile cash balances, UBS Sant. USA &posit account balances, UBS AG Standard Branch deposit account balances and money market mut rad fund sweep balances. UBS Bank USA deposit account b

with the ereartion of yaks. ncbRing coon valsnons has been melded co ardinwrons owougy fondled to you. aid wit be ranked to you prompt/ on reared Stott selling you wen-gaged in short .the a warty. yea may Nora (age due To moan Damson° cows foe that palcula starry Open ended Rearding open a *grad

Australia, along with the Australian police for the debriefing. On March 9 9011 AURA' (protect identity) and writer met for the interview at the United States Attorney's Office in Fort Lauderdale, Florida. UNCLASSIFIED b6 b7C b7D -P4 0-70u-G302 -EC b6 b7C EFTA00790045 '14 UNCLASSIFIED To: Miami

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do not hesitate to contact me. Sincerely, United States Attorney By: Assistant United States Attorney EFTA00233096 U.S. Department of Justice United Slates Attorney Southern District of Florida 500 South Australian Ave., Suite 400 West Palm Beach, FL 33401 Facsimile: Direct Dial: September 6, 2007

Insurance proceeds 13 Excess golden persebute porno= 14 Gross premeds paid to on attorney 15 15 State tax unlink! 17 stete/Poyees5tuo no. 'IS Stott Income ono 1099-MISC FEGO41 $ Ottputment of the Treasury • ;Mental Revenue Santee EFTA00233155 • dR 0M9 No. 1515-0104 Fa911 1 i • DoNrIcriont

ent prosecution. I Para 5 of Sch 1 to CICA 2003. 2 R v Director of the Serious And Office ex p Smith 11993) AC I. 3 Lyons 120031 1 AC 976: Brown v Stott (Procurator Fund, Dunfermline) 120031 2 AC 68 I; R v Hertfordshire County Council ex p (Awn Environmental Industries Ltd12000) 2 AC 412. (iv) Use o

ever it was committed.' The application is usually made without notice although there is an obligation to make material disclosure.2 Government oft& United States ofAmorica si Montgomery (2001) 1 WLR 196. pan 30. in relation to the Criminal Janice Act 1988 (Designated Countries and Territories) Order 1991, SI 199112873.