Epstein Secrets

03/21/2011 Page 1 of 42 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 08-80736-CW-Marra/Johnson JANE DOE #1 and JANE DOE #2 I. UNITED STATES JANE DOE #1 AND JANE DOE #2'S MOTION FOR FINDING OF VIOLATIONS OF THE CRIME VICTIMS' RIGHTS ACT AND REQUEST FOR A HEARING ON APPROPRIATE REMEDIES

3 07/09/2008 15:13 FAX 5818059848 115110 WPB CONFRM Case 8:08-Cv-80736-KAM •ument 48-3 Entered on FLSD Diie1 03/21/ U.S. Department of Justice United Slates Attorney Southern District of Florida SOO South Australian Ave.. Suite 400 West Palm Beach. FL 3)401 (561)820-8711 Facsimile- (361)820-8777 Jun

1 of 4 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 013-80736-Civ-Marrellohnson JANE DOE #1 AND JANE DOE #2, Plaintiffs, I. UNITED STATES OF AMERICA, Defendant. MOTION TO INTERVENE OR IN THE ALTERNATIVE FOR A SUA SPONTE RULE I I ORDER Comes now, Movant Bruce E. Reinhart, pursuant to Federal Ru

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

overnment claims is troublesome, the Filth Circuit cited to the district court opinion under review, which had quoted all the words in the statute. See United States'. BP Products, 2008 WL 501321 at '7 (noting victims right to confer "in the case"), cited in In re Dean, 527 F.3d at 394. 28 08-80736-CV-MARRA 000

rifi-nationi to the Nom Prosecution Agreement and agrees to comply with than. Dated: BY: Dated: Dated: Dated: ifrjfa Ft. ALEXANDER ACOSTA UN: TED STATES ATTORNEY A. MARIE VILLAFJA ASSISTANT' U.S. A ITORNEY JEFFREY EPSTEIN GERALD LEECOURT, ESQ. COUNSEL 713 JEFFREY EPSTELN LILLY ATTORNEY FOR JEFF

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, Unitqd 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

k for Millise Life was not going well for Wile during the time she was providing EPSTEIN with massages. Wawa° buying and taking drugs, i.e. Xanax, Lorcets, and Percosets. Wee said that she stayed on pills. Weill'explained that she wanted to feel numb. Wiestopped attending school at age fifteen. Her pa

ant had successfully adjusted to pris- op, was genuinely interested m several reli- gions, and filed grievances for entirely le- gitimate purposes. U.S.C.A. Const.Amends. 1, 5. [33] Constitutional Law 92 4 1170 92 Constitutional Law 92X First Amendment in General 92X(B) Particular Issues and Applic-

U.S. 225, 95 S.Ct. 2160, 45 L.Ed.2d 141, 20 Fed.R.Serv.2d 547 (Cite as: 422 U.S. 225, 95 S.O. 2160) Supreme Court of the United States Reversed. UNITED ST ES, Petitioner, Robert Lee NOBLES. No. 74-634. Argued April 23, 1975. Decided June 23, 1975. Defendant was convicted in the United States District

rk an implied waiver of all confidential communications on the same subject mat- ter. Accord von Bulow, 82$ F.2d at 102-03; Yankee Atomic Elec. Co. I. United States, 54 Fed. Cl. 306, 316 (2002). The rationale behind our holding is self-evident. When an attorney participates in an extrajudicial meeting or nego

. 0042201 23 EFTA00177962 Page I of 55 Westlaw Page I 531 F.3d 197 (Cite as: 531 F.3d 197) United States Court of Appeals, Second Circuit. UNITED STATES America, Appellee, Donald FELL, Defendant-Appellant. Docket No. 06-2882-cr. Argued: June 27, 2007. Decided: June 27, 2008. Background: Defendant was con

s Reversed. UNITED ST ES, Petitioner, Robert Lee NOBLES. No. 74-634. Argued April 23, 1975. Decided June 23, 1975. Defendant was convicted in the United States District Court for the Central Dis- trict of California of bank robbery and the Court of Appeals, 501 F.2d 146, affumed in part, reversed in part,

er a particular plea is desirable, since "[e]ffective assistance of counsel includes counsel's informed opinion as to what pleas should be entered." United Stalest Pillar, 416 F. Supp. 887, 889 (S.D.N.Y. 1976); Borial. Keane, 99 F.3d 492, 497 (2d Cir. 1996), citing ABA Model Code of Professional Responsibility

in- stance. The court authorized no general `fishing expedition' into the defense files ji or indeed even into the defense 'nvestigat- or's report. a. United States . Wright, 160 U.S.App.D.C. 57, 489 .2d 1181 O 2011 Thomson Reuters. No Claim to Orig. US Gov. Works. https://web2.westlaw.com/print/printstream.a

for WILD. Life was not going well for WILD during the time she was providing EPSTEIN with massages. WILD was buying and taking drugs, i.e. Xanax, Lorcets, and Percosets. WILD said that she stayed on pills. WILD explained that she wanted to feel numb. WILD stopped attending school at age fifteen. Her

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

ork for IS Life was not going well for Wile during the time she was providing EPSTEIN with massages. NOMMIwas buying and taking drugs, i.e. Xanax, Lorcets, and Percosets. We said that she stayed on pills. Willpexplained that she wanted to feel numb. Wiestopped attending school at age fifteen. Her pare

l Agent F.B.I. R. Alexander Acosta s United States Attorney Assistant United Slates Attorney If EFTA00185351 Ns, U.S. Department of Justice United Stales Attorney Southern District of Florida 500 South Australian Ave., Suite 400 West Palm °each, FL 33401 Facsirnek: August I f, 2006 DELIVERY BY HA

RDERED the this Order shall be SEALED in accordance with Fed. R. Crim. P. 6(e)(6), except that a copy of this Order shall be provided to counsel for the United States, who may disclose the existence of the Order to members of the Grand Jury, to the witness, to counsel for the witness, and to law enforcement office

F AMERICA, Respondent. UNITED STATES' NOTICE OF FILING 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.

stein been convicted at trial. No more; no less." Through this letter, this Office hereby provides Notice that your client,' is an individual whom the United Slates was prepared to name as a victim of an enumerated offense. et Should your client decide to file a claim against Jeffrey Epstein, his attorney, Jac

your case is under investigation! If anyone is charged in connection with the investigation, you will be notified. Sincerely, R. Alexander Acosta United Stales Attorney By: Assistant United States Attorney cc: Special Agent F.B.I. ff EFTA00185359 Case 9:08-cv-80736-KAM Document 14 Entered on FLSD D

work for PS Life was not going well for WM/during the time she was providing EPSTEIN with massages. Willawas buying and taking drugs, i.e. Xanax, Lorcets, and Percosets. WURS said that she stayed on pills. WOOexplained that she wanted to feel numb. WOO stopped attending school at age fifteen. Her par

DISTRICT OF FLORIDA Case No. 08-80736-CIV-Marra/Matthewman JANE DOE #1 and JANE DOE #2, Petitioners, 1. UNITED STATES OF AMERICA, Respondent. UNITED STATES' RESPONSE TO PETITIONERS' FIRST REOUEST FOR ADMISSIONS TO THE GOVERNMENT The United States (hereinafter the "government") hereby responds to Jane Do

uling work for Life was not going well for during the time she was providing EPSTEIN with massages. ..- was buying and taking drugs, i.e. Xanax, Lorcets, and Percosets. said that she stayed on pills. lexplained that she wanted to feel numb. MRWMIstopped attending school at age fifteen. Her parents