Epstein Secrets

Edwards, Fistos Et Lehrman, P.L. August 20, 2014 Wifredo A. Ferrer United States Attorney Southern District of Florida RE: Jane Does I and 21 United Stales Case No. : 08-80736-Civ-Marra/Johnson Dear Mr. Ferrer: As you know, we have been in litigation for more than six years on a case under the Crime

ce. She was sexually trafficked and abused by Mr. Epstein (and others at the direction of Mr. Epstein) not only in this jurisdiction but throughout the United Slates and beyond. Unlike Jane Doe #3. Jane Doe #4 was included as a named victim in the NPA. There is no statute of limitations in bringing such claims,

or filing an action to enforce rights under the statute. Accordingly, her motion should be granted. Jane Doe #1 and Jane Doe #2 support the motion. The United States 'insert position xxxxxxxxxxxxxxxx I. CONCLUSION Jane Doe #3 should be allowed to join this action. A proposed order allowing her to join is attache

e Electronic Communication Privacy Act, 18 U.S.C. 52510-2521. The information contained in this E-mail message is privileged and confidential under Fla. R. Jud. Admin. 2.420 and information intended only for the use of the individual(s) named above. If the reader of this message is not the intended recipie

er a victim under the CVRA. It should be emphasized that the CVRA "was designed to be a 'broad and encompassing' statutory victims' bill of rights." United Slates I 5 EFTA00180684 Case 9:08-ov-80736-KAM Document 1 Entered on FLSD Docket 07/07/2008 Page 6 of 10 Degenhardt, 405 F.Supp.2d 1341, 1342 (D. Ut

thers. In September 2008, Jane Doe 1 and Jane Doe 2 filed motions in the federal action to unseal the non-prosecution agreement and addendum (A-3). The United States Attorney's Office opposed disclosure noting its confidentiality provision, the movant's right to access the agreement, and Judge Marra's protective

place nee supplement the filing and service of pleadinset or other papers a by local nolcsof cant. This form, approved by iheJudklal Contaeneeor the Uniled Sates in September 1974, Is rewired for the use or the Clerk theolyil e cad dwa. IS CI INSTRUCTIONS ON THE REVERS( Of THE FOAMS NOTICE: Altorneys MUST In

o motions that seek to make court records in non-criminal cases confidential in accordance with subdivision (c)(9)."); see also In re Amendments to Fla. R. Jud. Admin. 2.420--Sealing of Court Records & Dockets, 954 So. 2d 16, 17 & 23 (Fla. 2007) (declining to adopt specific procedure regarding the sealing

thers. In September 2008, Jane Doe 1 and Jane Doe 2 filed motions in the federal action to unseal the non-prosecution agreement and addendum (A-3). The United States Attorney's Office opposed disclosure noting its confidentiality provision, the movant's right to access the agreement, and Judge Marra's protective

er a victim under the CVRA. It should be emphasized that_the CVRA "was designed to be a 'broad and encompassing' statutory victims' bill of rights." United States' 5 lot 00 EFTA00231181 Case 9:08-cv-80736-KAM Document 1 Entered on FLSD Docket 07/07/2008 Page 6 of 10 v Degenhardt, 405 F.Supp.2d 1341, 13

to motions that seek to make court records in non-criminal cases confidential in accordance with subdivision (cX9)."); see also In re Amendments to Fla. R. Jud. Admin. 2.420--Sealing of Court Records & Dockets, 954.. 2d 16, 17 & 23 (Fla. 2007) (declining to adopt specific procedure regarding the sealing of

e any matter occurring before the grand jury except in accordance with Fed. R. Crim. P. 6(e)(3). Notification of this disclosure will be provided to the United States District Court who empaneled the federal grand jury in accordance with Fed. R. Crim. P. 6(e)(3)(B). Ft 7. The United States respectfully requests th

es respectfully requests that this Motion and all other pleadings and orders filed in relation to this matter be kept under seal, in accordance with Fla. R. Jud. Admin. 2.051(7), 2.051(9)(A)(iii), 2.051(9)(A)(iv), and 2.051(9)(A)(vii), and in accordance with Fed. R. Crim. P. 6(e)(6). 8. If the Court require

thers. In September 2008, Jane Doe 1 and Jane Doe 2 filed motions in the federal action to unseal the non-prosecution agreement and addendum (A-3). The United States Attorney's Office opposed disclosure noting its confidentiality provision, the movant's right to access the agreement, and Judge Marra's protective

o motions that seek to make court records in non-criminal cases confidential in accordance with subdivision (c)(9)."); see also In re Amendments to Fla. R. Jud, Admin. 2.420--Sealing of Court Records & Dockets, 954 So. 2d 16, 17 & 23 (Fla. 2007) (declining to adopt specific procedure regarding the sealing

t page? Q. Page 19. You were asked: "I'm wondering, have you spoken to Jeffrey Epstein about this since these allegations came out in this suit in the United States? Have conversations happened there?" Oo On KH MP WN BP PRR PP Pe RH to OW HU PWN REO communication with Jeffrey Epstein, correct? A. I disclosed

ounting the overarching principle that “t]he public shall have access to all records of the judicial branch of government, except as provided below.” Fla. R. Jud. Admin. 2.420(a). This rule is a codification of the Florida Supreme Court’s admonition that a “a strong presumption of openness exists for all court

thers. In September 2008, Jane Doe 1 and Jane Doe 2 filed motions in the federal action to unseal the non-prosecution agreement and addendum (A-3). The United States Attorney's Office opposed disclosure noting its confidentiality provision, the movant's right to access the agreement, and Judge Marra's protective

o motions that seek to make court records in non-criminal cases confidential in accordance with subdivision (c)(9)."); see also In re Amendments to Fla. R. Jud. Admin. 2.420--Sealing of Court Records & Dockets, 954 So. 2d 16, 17 & 23 (Fla. 2007) (declining to adopt specific procedure regarding the sealing