Epstein Secrets

rk of the Court using CM/ECF. According to the Court's website, counsel for all parties are able to receive notice via the CM/ECF system. Assistant United United States Attorney SERVICE LIST Jane Does 1 and 2 United States, Case No. 08-80736-CIV-MARRA/MATTHEWMAN United States District Court, Southern District of

of 2 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 08-80736-Civ-Marra/Matthewman JANE DOE #1 AND JANE DOE #2, Petitioners, I. UNITED STATES OF AMERICA, Respondent. UNITED STATES' NOTICE OF FILING SECOND SUPPLEMENTAL PRIVILEGE LOG Pursuant to the Court's June 18, 2013 Omnibus Order (DE 190), the R

entified individuals." The letter further proposed that the attorney representative for the victims be instructed that "[Otte details regarding the United States's investigation of this matter and its resolution with Mr. Epstein is confidential. You may not make public statements regarding this matter."" 62. O

espondent. UNITED STATES' NOTICE OF FILING SUPPLEMENTAL PRIVILEGE LOG Pursuant to the Court's June 18, 2013 Omnibus Order (DE 190), the Respondent, United States of America, by and through the undersigned Assistant United States Attorney, hereby gives notice of its filing of its Privilege Log, which is attached hereto.

etter did not inform the victims of how this applied to them. '66 150. The victim notification letters also state that there was "litigation between the United States and two other victims regarding the disclosure of the entire agreement between the United States and Mr. Epstein." The letters did not explain that

letters were reviewed by my office and Jay Lefkowitz and Roy Black before they went out."" 155. In 2010, Jane Doe I met with the new U.S. Attorney, Wilfredo Ferrer. She explained to him how the NPA had been concealed from her. Nothing ever came of the meeting, and Mr. Ferrer has continued to fight efforts by J

tl. Stare, 407 So. 2d 1007, 1010 (Fla. 5th DCA 1981). And "motive is always relevant in a criminal case, even if it is not an element of the crime." United Stalest. Hill, 643 F.3d 807, 843 (11th Cir. 2011) (internal quotation omitted). When speaking not to the Court but rather to the media, Dershowitz has clearl

agent's ensuing report, Rodriguez "discussed in detail the information contained within the book, and identified important information to the UCE." See United States'. Rodriguez, No. 9:10-cr- 80015-KAM, DE 3 at 5 (S.D. Fla. Dec. 9, 2009). While all of the details of the verbal information explained by Rodriguez to

Senate Judiciary Committee held a hearing regarding child endangerment via the Internet. See H.R. Conf. Rep. No. 104-458, at 193 (1996), quoted in United States ' Searcy, 418 F.3d 1193, 1197 (11th Cir. 2005); see also K. Seto, "Note: How Should Legislation Deal with Children and the Victims and Perpetrators

Whoever, using the mail or any facility or means of interstate or foreign commerce, or within the special maritime and territorial jurisdiction of the United States knowingly persuades, induces, entices or coerces any individual who has not attained the age of 18 years, to engage in prostitution or any sexual

victim to this case: a young woman Jeffrey Epstein sexual abused when she was under age. On August 20, 2014, counsel sent a letter to U.S. Attorney Wilfredo Ferrer requesting the Govermnent's consent to a stipulated motion to simply add her into the case (as had been done earlier with Jane Doe No. 2). Counsel

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

ileged Confidential Page 50 of 51 Contains 6(e) Material EFTA00225477 EPSTEIN INVESTIGATION TIMELINE Date To From Re: Exhibit # 8/24/2011 Wilfredo Ferrer (U.S. Attorney, SDFL), Robert O'Neill (U.S. Attorney, MDFL), Benjamin Greenberg (FAUSA, SDFL), and Lee Bentley (FAUSA, MDFL) Richard Sud

Reach, FL 33401 (56!) 82047/! rocssmile: (561)820-8777 September 3, 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 WIT

here he could get passports or other travel documents for young girls. He would then bring these young girls (girls ranging in age from 12 to 24) to the United States for sexual purposes and farm them out to his friends, including Epstein. 49. Brunel would offer the girls "modeling" jobs. A lot of the girls came

agent's ensuing report. Rodriguez "discussed in detail the information contained within the book. and identified important information to the UCE." See United States'. Rodriguez, No. 9:1 0-cr- 800I5-KAM. DE 3 at 5 (S.D. Fla. Dec. 9, 2009). While all of the details of the verbal information explained by Rodriguez t

ictim to this case.: a young woman Jeffrey Epstein sexual abused when she was under age. On August 20, 2014. counsel sent a letter to U.S. Attorney Wilfredo Ferrer requesting the Government's consent to a stipulated motion to simply add her into the case (as had been done earlier with Jane Doe No. 2). Counsel

entified individuals." The letter further proposed that the attorney representative for the victims be instructed that "[t]he details regarding the United States's investigation of this matter and its resolution with Mr. Epstein is confidential. You may not make public statements regarding this matter."' 62. O

letter did not inform the victims of how this applied to them.'66 150. The victim notification letters also state that there was "litigation between the United States and two other victims regarding the disclosure of the entire agreement between the United States and Mr. Epstein." The letters did not explain that

etters were reviewed by my office and Jay Lefkowitz and Roy Black before they went out.""' 155. In 2010, Jane Doe 1 met with the new U.S. Attorney, Wilfredo Ferrer. She explained to him how the NPA had been concealed from her. Nothing ever came of the meeting, and Mr. Ferrer has continued to fight efforts by J

entified individuals." The letter further proposed that the attorney representative for the victims be instructed that "[t]he details regarding the United States's investigation of this matter and its resolution with Mr. Epstein is confidential. You may not make public statements regarding this matter."' 62. O

letter did not inform the victims of how this applied to them.'66 150. The victim notification letters also state that there was "litigation between the United States and two other victims regarding the disclosure of the entire agreement between the United States and Mr. Epstein." The letters did not explain that

etters were reviewed by my office and Jay Lefkowitz and Roy Black before they went out.""' 155. In 2010, Jane Doe 1 met with the new U.S. Attorney, Wilfredo Ferrer. She explained to him how the NPA had been concealed from her. Nothing ever came of the meeting, and Mr. Ferrer has continued to fight efforts by J

mail chain from Jeff Sloman to Andrew Oosterbaan, Marie Villafana, and Alex Acosta regarding Epstein meeting 8/ 7/ 200- Reply of Jeffrey Epstein to United States' Response to His Motion to Intervene and to Quash Grand Jury Subpoenas and Cross-Motion to Compel and Sealed Document Tracking Form 8/8/2007 Andre

leged Confidential Page 50 of 51 Contain)) 6(u) Material EFTA00224992 EPSTEIN INVESTIGATION TIMELINE Date To From Re: Exhibit # 8/24/2011 Wilfredo Ferrer (U.S. Attorney, SDFL), Robert O'Neill (U.S. Attorney, MDFL), Benjamin Greenberg (FAUSA, l)1,1.), and Lee Bentley (FAUSA, MDFL) Richard S

to this website. If you wish to make a request for information, you may contact our office at 305-961-9001, or you may send a written inquiry to the United States Attorney's Office, Southern District of Flonda, 99 NE 4th Street, Miami, F'. 33132. http://www.usdoj.gov/usao/f1s/PressReleases/090610-01.html 6/11

ge Ilona Holmes. head of the criminal division, Miami-Dade Circuit Judge Daryl Trawick. and Palm Beach County Court Judge Reginald Corlew Hispanics Wilfredo Ferrer, an assistant Miami-Dade County attorney, and Lilly Ann Sanchez, a criminal litigator with Fowler White Burnett in Miami also have put their names i

e identified individuals." The letter further proposed that the attorney representative for the victims be instructed that "[t]he details regarding the United States's investigation of this matter and its resolution with Mr. Epstein is confidential. You may not make public statements regarding this matter." Id. at

e reviewed by my office and Jay Lefkowitz and Roy Black before they went out." Id. at 46,1 154. In 2010, Jane Doe I met with the new U.S. Attorney, Wilfredo Ferrer. She explained to him how the NPA had been concealed from her. Id. at 46,1 154. At no time while it negotiated and executed the NPA did the Governm