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

6. The correspondence further discussed a possible plea disposition that would make it hard for a judge to see what was happening: Andy [i.e., AUSA Andrew Laurie] recommended that some of the timing issues be addressed only in the state agreement, so that it isn't obvious to the judge that we are trying to c

onally governed by state regulation). real Rather, its is limited t trafficking that jgntig,0Nop or is accomplished by force, fraud, or coercion". United Stales Evans, 476 ■3d 1176, 1179 it I (I l• Ctr. 2007). Nor, has the Department of Justice deemed it appropriate. e e.g. Unit tates Department of Justic

of several men for conspiracy to hold young women in peonage, and to traffic them for commercial sex acts, involving force and threats; bail issue); United Stares v. 4 A review of the Linked Sutes Department of Justice Civil Rights Division Anti-Trafficking News Bulktins confirms that this same pattern exists

many instances, due to the lack of uniform regulation, these businesses have served to transfer funds which were the proceeds of illegal activity. See United States' Valdes, 2006 U.S. Dist. LEXIS 12432 (S.D.N.Y. 2006) (defendants transmitted proceeds of drug trafficking to Colombia); see also P.L. 103-325, Title

d to protect women agai t conduct, commercial whethv commercial or no t involves transportation and is exploitive or violent. See, e.g., De Vault I United States, 338 2d 179,180 (10th Cir. 1964) (applying the Act to protect girl who was raped). j r The Mann Act is a relatively antiquated morality statute th

d States! Hearn( 381 .3d 80 (2d Cir. 2004) (woman running prostitution business convicted for recruiting and transport of prostitutes under § 2421); United States' Footman, 215 1.3d 145 (I" Cir. 2000) (pimp who ran a prostitution ring convicted of violating § 2421). Likewise, in keeping with its purpose and tit

nsion already requested by Ms. Sanche2 prior to Mr. Richey's appearance as counsel for Mr. Riley. Sincerely, Assistant United States Anorncy cc; Andrew Laurie, Esq. William Richey, Esq. Lilly Ann Sanchez, Esq. Case No. 08-80736-CV-MARRA P-011927 EFTA00226715 LAW O1•1Of • Of GISliALD 13. Incotrirr,

this procedure because. as I mentIona I think It to probably in their best WOWS. In terms of plea agreement language. let me suggest the following: Thu United Slates agrees to make a minion seeking the appointment of a Guardian ad titan to mpresent the identified victims, Following the appointment of such Guardia

mber I I, 2007 Page 4 The final agreement was very similar to what was proposed by Ms. Villotbna in her initial draft agreement on July 31. 2007: The United Stoles shall provide l3poein's anomey's with u list of individuals whom ii fins identified as victims, as defined in IR U.S.C. § 2255. alter Epstein has si

hich point they were eliminated by your Office: IT APPEARING, idler an invizligation of the offenses and Epstcin's background, thin the interest or the United Stales pursuant to the Petite policy will be served by the Following procedure ... Epstein understands that the United Stales Attorney has no authority to

tter have no relation to the allegations against Mr. Epstein. Notably, after we objected to these overly broad and intrusive requests. Deputy Chief Andrew Laurie denied knowledge of Ms. Villalima's actions and Mr. Laurie commendably sought to significantly narrow the list of documents requested. In a subsequ

erson can be charged with a criminal 39 EFTA01718615 . offense, that is a violation of Florida Statutes Section 794.05; in violation of Title 18, United States Code, Sections 2422(b) and 2. COUNT 14 (Enticement of a Minor: 18 U.S.C. § 2422(b)) 49. Paragraphs 1 through 19 of this Indictment are re-alleged

ity or process of the prior prosecution. not the sentencing outcome. Second, the state plea agreement offered was not "manifestly inadequate" tinder U.S.A.M. § 9- 2.03ID. indeed, the only real difference hews= the state and federal plea proposals was whether Mr. Epstein served his sentence in jail or comm

n to undertake discussion with the $tate Attorney's Office In ensure compliance with these procedures, which compliance will be necessary to satisfy the United States' interest. pursuant to the Perire policy. We reiterate that this case was at heart a local matter that was being fully addressed by the state crimi

ter have no relation to the allegations against Mr. ISpstein. Notably. affix we objected to these overt broad and intrusive requests. Deputy Chief Andrew Laurie denied knowledge of Ms. s actions and Mr Laurie commendably so t igni tiara ly narrow the list of documen requested. In a subsequent court filin

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

6. The correspondence further discussed a possible plea disposition that would make it hard for a judge to see what was happening: Andy [i.e., AUSA Andrew Laurie] recommended that some of the timing issues be addressed only in the state agreement, so that it isn't obvious to the judge that we are trying to c

ATES, Respondent. OPINION AND ORDER This cause is before the Court upon Jane Doe 1 and Jane Doe 2's Motion for Partial Summary Judgment (DE 361); the United States's Cross-Motion for Summary Judgment (DE 408); Jane Doe 1 and Jane Doe 2's Motion to Compel Answers (DE 348) and Jane Doe 1 and Jane Doe 2's Motion fo

osecutorial agreement, including a non-prosecution agreement, reached in violation of a prosecutor's conferral obligations under the statute. Doe v. United States, 950 F. Supp. 2d 1262, 1267 (S.D. Fla. 2013). Third, section 3771(d)(5) of the CVRA authorizes the setting aside of pre-charge prosecutorial agreeme

e Office was "not investigating Mr. Epstein [for] abusing his girlfriend." (DE 407 at 11- 25.) The correspondence further stated: Andy [i.e., AUSA Andrew Laurie] recommended that some of the timing issues be addressed only in the state agreement, so that it isn't obvious to the judge that we are tying to cr

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

6. The correspondence further discussed a possible plea disposition that would make it hard for a judge to see what was happening: Andy [i.e., AUSA Andrew Laurie] recommended that some of the timing issues be addressed only in the state agreement, so that it isn't obvious to the judge that we are trying to c

ATES, Respondent. OPINION AND ORDER This cause is before the Court upon Jane Doe 1 and Jane Doe 2's Motion for Partial Summary Judgment (DE 361); the United States's Cross-Motion for Summary Judgment (DE 408); Jane Doe 1 and Jane Doe 2's Motion to Compel Answers (DE 348) and Jane Doe 1 and Jane Doe 2's Motion fo

osecutorial agreement, including a non-prosecution agreement, reached in violation of a prosecutor's conferral obligations under the statute. Doe v. United States, 950 F. Supp. 2d 1262, 1267 (S.D. Fla. 2013). Third, section 3771(d)(5) of the CVRA authorizes the setting aside of pre-charge prosecutorial agreeme

e Office was "not investigating Mr. Epstein [for] abusing his girlfriend." (DE 407 at 11- 25.) The correspondence further stated: Andy [i.e., AUSA Andrew Laurie] recommended that some of the timing issues be addressed only in the state agreement, so that it isn't obvious to the judge that we are tying to cr