Epstein Secrets

ine, based on reliable evidence, that, during the period of the Agreement, Epstein willfully violated any of the conditions of this Agreement, then the United Slates Attorney may, within ninety (90) days following the expiration of the term of home confinement discussed below, provide Epstein with timely notice

nection with the investigation, you will bo nal t By: cc: Special Agent -F.B.I Sincerely, R. Alexander Acosta United States Attorney Assistant United Stales Attorney 7 7 EFTA00229970 7 :-- Case 9:08-cv-80736-KAM Document 48-5 Entered on FLSD Docket 03/21/2011 Page 1 of 15 JANE DOE #1 AND JANE DOE SO'

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

pstein hereby flits that he undersea-4s the cluifications to the Non- Prosecution Agreement and agrees to comply with than. R. ALEXANDER ACOSTA UN: TED STATES ATTORNEY Dated: BY: Dated: Dated: Dated: ifrja JEFFREY EPSTEIN GERALD LF,FCOURT, &SQ. COUNSEL TO JEFFREY EPSTELN LILLY ATTORNEY FOR JEFFREY

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, Uniteed 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

Submitted, s/ Bradley I. Edwards Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L. and Paul G. Cassell Pro MX Vice Quinney College of Law at the University of Utah Attorneys for Jane Due 01 and Jane Doe 02 41 EFTA00229957 Case 9:08-cv-80736-KAM Document 48 Entered on FLSD Docket 0

URT SOUTHERN DISTRICT OF FLORIDA CASE NO. 08-80736-CIV-MARRA/JOHNSON JANE DOE #1 AND JANE DOE #2, Petitioners, vs. UNITED STATES, Respondent. UNITED STATES' SEALED MOTION TO DISMISS FOR LACK OF SUBJECT MATTER JURISDICTION The United States hereby requests that this Court enter an order dismissing these

nsel and with Petitioner Jane Doe #1 and entertained discussion about Petitioners' desires to see Epstein criminally prosecuted on federal charges.? The United States Attorney and prosecutors in the USAO-SDFL have also corresponded with Petitioners' counsel on multiple occasions about Petitioners' desires to have

a promise or agreement of the prosecutor, so that it can be said to be part of the inducement or consideration, such promise must be fulfilled."); United Slates v. Harvey, 869 F.2d 1439, 1443 (11th Cir. 1989) ("Due process requires the government to adhere to the terms of any plea bargain or immunity agreem

urt, Southern District of Florida Brad Edwards. Esq.. The Law Offices of Brad Edwards & Associates. LLC Hollywood, Florida 33020 Paul G. Cassell Quinney College of Law at the Universit of Utah Salt Lake City, Utah 84112 Attorneys for Jane Doe N 1 and Jane Doe # 2 16 EFTA00205169 UNITED STATES DISTRICT COURT

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

& LEHRMAN, P.L. 425 North Andrews Avenue, Suite 2 Fort Lauderdale Florida 33301 Telephone Facsimile E-mail: And Paul G. Cassell Pro Hac Vice Quinney College of Law at the University of Utah' 332 S. 1400 E. Salt Lake Cit 4112 Telephone: Facsimile: 'This daytime business address is provided for identificati

ank you. From: (USAFLS) [ Sent: Friday, June 28, 2013 2:37 PM To: Cc: rS); Brad Edwards ( ); Paul Cassell Subject: Proposed Order, Jane Does I. United States, 08-80736-Civ-Marra Good afternoon. Pursuant to the Local Rules, attached please find a copy of the proposed order on the United States' unopposed

er, Jane Does I. United States, 08-80736-Civ-Marra Good afternoon. Pursuant to the Local Rules, attached please find a copy of the proposed order on the United States' unopposed motion for extension of time, in MS Word format. Thank you so much. EFTA00209596

as you can. Brad Edwards and Paul Cassell for Jane Doe #1 and Jane Doe #2 Paul G. Cassell Ronald N. Boyce Presidential Professor of Criminal Law Quinney College of Law at the University of Utah 332 S. 1400 E. , Room 101 Salt Lake Ci , UT 84112-0730 (phone) EFTA00209595 (fax You can access my publications on h

ified which party is misjoined, or which party needs to be joined in order for this CVRA proceeding to properly go forward. With only one defendant, the United States of America, there cannot be any issue regarding severing any claim against a party. On the specific issue of adding a new party, and whether Rule 15 or Rule 21

e act, although within the letter, is not within the intention of the legislature, and therefore cannot be within the statute. Holy Trinity Church I. United States, 143 U.S. 457, 516-17 (1892). In Webb i. United States, 21 CI.Ct. 137 (1990), the Court of Claims was presented with a 17 EFTA00210613 claim for

rn District of Florida Bradley J. Edwards, Esq., Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, 4.74 Ninrih A tin* c AN / Paul G. Cassell Quinney College of Law at the Attorneys for Jane Doe # 1 and Jane Doe # 2 Roy Black Jackie Perczek Black, Srebnick, Komspan & Stumpf, P.A. Imo Attorneys for Intervenor

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

& LEHRMAN, P.L. 425 North Andrews Avenue, Suite 2 Fort Lauderdale Florida 33301 Telephone Facsimile E-mail: And Paul G. Cassell Pro Hac Vice Quinney College of Law at the University of Utah' 332 S. 1400 E. Salt Lake Cit 4112 Telephone: Facsimile: 'This daytime business address is provided for identificati

and, of eiti-zea-ef-the-14nite€1-States (within the Southern District of New York). 8. At all times material to this cause of action was residinga United States citizen, employed by New York based company and regularly conducting business in New York, New York and, on information and belief, was a citizen o

ll called Plaintiff-'s parents in South Africa to tell them that DefendentsDefendant Epstein would take good care of Plaintiff when she returned to the United State; and that theyDefendants Maxwell and Epstein would use their connections and influence EFTA00296300 Case 1:17-cv-00616-JGK Document 45 Filed 06/0

LLPPry4 David Boies_ David Boies- Boies Schiller & Flexner LLP Sigrid McCawley Meredith Schultz Boies Schiller & Flexner LLP Paul C Cassell • Quinney College of Law at the University of Utah EFTA00296309 Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page 30 of 31 20 This daytime business address is prov

, Jane Does I United States, 08-80736-Civ-Marra Good afternoon. Pursuant to the Local Rules, attached please find a copy of the proposed order on the United States' unopposed motion for extension of time, in MS Word format. Thank you so much. EFTA00208570

ou can. Brad Edwards and Paul Cassell for Jane Doe #1 and Jane Doe #2 Paul G. Cassell Ronald N. Boyce Presidential Professor of Criminal Law S.). Quinney College of Law at the University of Utah Sent: Friday, June 28, 2013 2:37 PM ofainslibminliallilSolirad Edwards ([email protected]); Paul Cassell Subject: P