Epstein Secrets

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 08-80736-Civ-Marra/Johnson JANE DOES #1 and #2 I. UNITED STATES JOINT STATEMENT OF UNDISPUTED FACTS The parties hereby stipulate and agree that the following facts are not in dispute and may be accepted as true

ensued between the United States and Epstein. Despite the investigation revealing that Epstein had molested more than 40 minor girls, in Late 2007, the United Stales entered into a non- prosecution agreement (NPA) with Epstein - esseNiatly egree:ng to immunize Epstein for al of the Federal Sex crimes he committed

copy of the terms was not provided. A notification was not provided to Jane Doe #2 because the agreement limited Epstein's liability to victims whom the United States was prepared to name in an indictment. As a result, Jane Doe #2 never received a notification a letter about the agreement. The-rietifieation4id-net

on the [NPA] when seeking civil relief against Epstein . . . and affirmatively advanced the terms of the [NPA] as a basis for relief from Epstein." United States' Reply in Support of its Motion to Dismiss for Lack of Subject Matter Jurisdiction, Doc. 205-6 at 12-13. After reaping the benefits of the NPA, the

ed on Rule 501 on the ground that Congress has already addressed the issue in Fed. R. Crim. P. 11(0 and Fed. R. Evid. 410 and likewise rejected the Intervenors' request that the Court recognize a privilege for plea negotiation communications. Id. at 8-9. The Intervenors appealed the Court's ruling to the E

In the Court's Order of September 26, 2011, granting in part the Petitioners' Motion for finding violations of the CVRA, the Court did not address the United States' argument that there is no remedy available for the Petitioners due in part to their failure to seek a prompt resolution of the case. However, in lig

andled the civil suits filed against Jeffrey Epstein pursuant to the Non-Prosecution Agreement-and this actions filed by Jane Does #1 and #2 against the United States. For purposes of this Supplemental Briefing, the relevant facts are that, through the civil litigation between the Jane Does and Jeffrey Epstein, th

and information should be privileged under a common law plea negotiations privilege. In addition, in its initial briefing and at oral argument, the Intervenors argued that the communications were governed by the attorney work-product privilege. ARGUMENT A. The Petitioners Appear to Be Seeking to Use the P

In the Court's Order of September 26, 2011, granting in part the Petitioners' Motion for finding violations of the CVRA, the Court did not address the United States' argument that there is no remedy available for the Petitioners due in part to their failure to seek a prompt resolution of the case. However, in li

d information should be privileged under a common law plea negotiations privilege. In addition, in their initial briefing and at oral argument, the Intervenors argued that the communications were governed by the attorney work-product privilege. ARGUMENT A. The Petitioners Appear to Be Seeking to Use the

NDUM OF LAW IN SUPPORT OF INTERVENORS' MOTIONS FOR LEAVE TO INTERVENE AND TO MODIFY THE PROTECTIVE ORDER STEPTOE & JOHNSON LLP 1114 Avenue of the Americas New York, New York 10036 (212) 506-3900 October 5, 2017 CONFIDENTIAL - FILED UNDER SEAL EFTA00805389 TABLE OF CONTENTS PRELIMINARY STATEMENT

of the issues the Intervenors intend to raise in the Motion to Dismiss. To use the Jane Doe Evidence to support the Motion to Dismiss, however, the Intervenors need relief from the Protective Order. Judge Koeltl instructed the Intervenors to "make their application for relief from the Protective Order to th

In the Court's Order of September 26, 2011, granting in part the Petitioners' Motion for finding violations of the CVRA, the Court did not address the United States' argument that there is no remedy available for the Petitioners due in part to their failure to seek a prompt resolution of the case. However, in li

d information should be privileged under a common law plea negotiations privilege. In addition, in their initial briefing and at oral argument, the Intervenors argued that the communications were governed by the attorney work-product privilege. ARGUMENT A. The Petitioners Appear to Be Seeking to Use the

on the [NPA] when seeking civil relief against Epstein . . . and affirmatively advanced the terms of the [NPA] as a basis for relief from Epstein." United States' Reply in Support of its Motion to Dismiss for Lack of Subject Matter Jurisdiction, Doc. 205-6 at 12-13. After reaping the benefits of the NPA, the

d on Rule 501 on the ground that Congress has already addressed the issue in Fed. R. Crim. P. 11(f) and Fed. R. Evid. 410 and likewise rejected the Intervenors' request that the Court recognize a privilege for plea negotiation communications. Id. at 8-9. The Intervenors appealed the Court's ruling to the E

reement). 5 EFTA00617884 Case 9:08-cv-80736-KAM Document 207 Entered on FLSD Docket 07/08/2013 Page 6 of 11 from contesting liability.; See also United States' Reply in Support of Its Motion to Dismiss for Lack of Subject Matter Jurisdiction (Doc. 205-6), Exhibit F at 11-12 (detailing reliance of plaintiff

harm him," Motion to Dismiss Non-Party Interlocutory Appeal (filed by plaintiffs in Jane Doe #1 and Jane Doe #2 v. United States, Roy Black, et at, Intervenors, Eleventh Circuit No. 13-12923, citing Doc.108 at 13 n.3 (Mr. Epstein's assertion that he has an interest in the non-prosecution agreement which wo

imants due in significant part to the requirements of the non-prosecution agreement that prohibited Mr. Epstein from contesting liability? See also United States' Reply in Support of Its Motion to Dismiss for Lack of Subject Matter Jurisdiction (Doc. 205-6), Exhibit F at 11-12 (detailing reliance of plaintiffs

arm him," Motion to Dismiss Non-Party Interlocutory Appeal (filed by plaintiffs in Jane Doe #1 and Jane Doe #2 v. United States, Roy Black, et al., Intervenors, Eleventh Circuit No. 13-12923, citing Doc.108 at 13 n.3 (Mr. Epstein's assertion that he has an interest in the non-prosecution agreement which wo