Epstein Secrets

dure do not allow them to intervene as parties to a prosecution." In re Amy Unknown, F.3d 2011 WL 988882 at *2 (5th Cir. Mar. 22, 2011). See also United Stases' Aguirre-Gonzalez, 597 F.3d 46, *Fed. R. Crim. P. 60 was adopted on April 23, 2008 and made effective on December 1, 2008. While this was after most

3/21/2011 Page 1 of 42 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 08-80736-Civ-Marra/Johnson JANE DOE #1 and JANE DOE #2 I. UNITED STATES I 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 REMEDI

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

d the government. Movants rely on a decision from the Southern District of Texas for the notion that CVRA rights apply prior to any prosecution. In United States' BP Products North America, Inc., the district court reasoned that because § 3771(d)(3) provided for the assertion of CVRA rights "in the district c

egations in depositions and other court filings. (See, e.g., Jane Doe' Jeffrey Epstein, Haley Robson, and Sarah Kellen, Court File No. 08-80804-Civ- Marra/Johnson, DEl at 44-52.) 42 EFTA00177092 Case 9:08-cv-80736-KAM Document 62 Entered on FLSD Docket 04/08/2011 Page 43 of 54 Petitioners' allegations pro

e less than $5,000,000.00; 10. That this Court has jurisdiction over said assets as they originated in the United States; That the treaties between the United Stales and the Cayman Islands and related governments clearly establishes the right of the United Slates to seize such assets. That counsel for MORSE has

d to as RRA) was a legal entity organized under the laws of the State of Florida and constituted an Enterprise as that term is defined in Title 18, United States Cod; Section 1961(4). The Enterprise engaged in, and the activities of which affected, interstate and foreign commerce. THE RACKETEERING CONSPIRACY 3.

t of Florida and elsewhere, the defendant, SCOTT W. ROTHSTEIN, did knowingly conspire, confederate, and agree with persons known and unknown to the United States Attorney, to commit offenses against the United States in violation of Title 18, United States Code, Sections 1956 and I957, that is: i. to knowing

d in the United States; That the treaties between the United Stales and the Cayman Islands and related governments clearly establishes the right of the United Slates to seize such assets. That counsel for MORSE has facilitated the contact between the relative governments and as a Page 2 of 6 EFTA00223350 resu

ver to Take Charge of Property of Epstein, and to Post a $15 million Bond to Secure Potential Judgment, in Jane Doe Epstein, Case No. 08-CV-80893- Marra/Johnson. The motion was reported in the press as was the ultimate goal (i.e., to "pump" the cases for investor following). However, the Court found "Plaint

) Whoever, using the mail or any facility or means of interstate or foreign commerce, or within the special maritime and territorial jurisdiction of the United States knowingly persuades, induces, entices, or coerces any individual who has not attained the age of 18 years, to engage in prostitution or any sexual a

in Santos, supra, at 2025: ... The rule of lenity requires ambiguous criminal laws to be interpreted in favor of the defendants subjected to them. See United States v. Gradwell, 243 U.S. 476, 485, 37 S.Ct. 407, 61 L.Ed. 857 (1917); AfcBoyle v. United States, 283 U.S. 25, 27, 51 S.Ct. 340, 75 L.Ed. 816 (1931); U

al. Aug. 19, 2009); U.S. v. Monk, 2009 WL 2567831, fn. 1 (ED. Cal. Aug. 18, 2009); U.S. v. Zane, 2009 WL 2567832, fill (E.D. Cal. Aug. 18 2009). 18 U.S.C.A. §2255 - Civil Remedy for Personal Injuries, creates a federal cause of action or "civil remedy" for a minor victim of sexual, abuse, molestation and

ages in order to property preserve all issues pertaining to the proper application of §2255 for appeal. See C.MA. v. Epstein, Case No. 08-CIV-80811 Marra/Johnson; and Jane Doe II v. Epstein, Case No. 09-CW-80489 Marra/Johnson. EFTA00207698 Case 9:08-cv-80893-KAM Document 128 Entered on FLSD Docket 03 05 20

employee as the source of the information. (2) Appearance. A former employee makes an appearance when he is physically present before an employee of the United Slates, in either a formal or informal setting. Although an appearance also may be accompanied by certain communications, an appearance need not involve an

id not participate as a Government employee. Example 7 to paragraph (hX2): An employee of the Department of State participated in the development of the United States' position with respect to a proposed treaty with a foreign government concerning transfer of ownership with respect to a parcel of real property and

esolving prisoner disputes. Construing the CVRA in the way that "See 18 U.S.C. § 113 (assault within territorial jurisdiction of the United States); United States. Anderson, 528 F.2d 590, 591 (5th Cir. 1976) (in prosecution for assault with intent to commit murder within territorial jurisdiction of United Stat

egations in depositions and other court filings. (See, e.g., Jane Doei Jeffrey Epstein, Haley Robson, and Sarah Kellen, Court File No. 08-80804-Civ- Marra/Johnson, DEl at 44-52.) 42 08-80736-CV-MARRA 000861 EFTA00230685 fmney,'" Case 9:08-cv-80736-KAM Document 62 Entered on FLSD Docket 04/08/2011 Page 4

e months before trial, Epstein filed the underlying Motion to Continue and indicated that he would be moving to stay these proceedings until Doe v. United States is resolved. Thus, after assuming the burden of proof for three years, Epstein now claims that he cannot defend this case and will "be forced

records was to obtain them for use in a separately filed Criminal Victims Rights Act (CVRA) suit, Jane Doe I and Jane Doe 2, Case No. 08-80736-CIV, Marra/Johnson, which was brought for several purposes, including invalidating the /Non-Prosecution) Agreement . . . Amended Complaint at paragraph 29(4) (emphasi

e months before trial, Epstein filed the underlying Motion to Continue and indicated that he would be moving to stay these proceedings until Doe v. United States is resolved. Thus, after assuming the burden of proof for three years, Epstein now claims that he cannot defend this case and will "be force

records was to obtain them for use in a separately filed Criminal Victims Rights Act (CVRA) suit, Jane Doe I and Jane Doe 2, Case No. 08-80736-CIV, Marra/Johnson, which was brought for several purposes, including invalidating the /Nor-Prosecution/Agreement Agreement... Amended Complaint at paragraph 29(4) (e

witz (noted Harvard Law professor, constitutional attorney and one of EPSTEIN'S criminal defense attorneys); (iii)Bill Clinton (Former President of the Untied States); EFTA00725302 Epstein v. RRA, et al. Page 15 (iv)Tommy Mottola (former President of Sony Record); and (v) David Copperfield (illusionist). 48

er to Take Charge of Property of Epstein, and to Post a $15 million Bond to Secure Potential Judgment, in Jane Doe v. Epstein Case No. 08-CV-80893- Marra/Johnson. The motion was reported in the press as was the ultimate goal (i.e., to "pump" the cases for investor following). However, the Court found "Plaint

has changed tactics and asserted a new position: he cannot defend the malicious prosecution claims at the upcoming trial because of the 2008 Doe v. United States proceeding, which was filed before Epstein initiated this litigation. If that is true, how did Epstein intend to prove his claims against Mr. Edward

records was to obtain them for use in a separately filed Crime Victims' Rights Act ("CVRA") suit, Jane Doe I and Jane Doe 2, Case No. 08-80736-CIV, Marra/Johnson which was brought for several purposes, including invalidating the [Non-Prosecution] Agreement . . . (Emphasis added). Despite now expressly acknow

t of Florida and elsewhere, the defendant, SCOTT W. ROTHSTEIN, did knowingly conspire, confederate, and agree with persons known and unknown to the United States Attorney, to commit offenses against the United States in violation of Title 18, United States Code, Sections 1956 and 1957, that is: i. to knowing

er to Take Charge of Property of Epstein, and to Post a $15 million Bond to Secure Potential Judgment, in Jane Doe v. Epstein Case No. 08-CV-80893- Marra/Johnson. The motion was reported in the press as was the ultimate goal (i.e., to "pump" the cases for investor following). However, the Court found "Plaint

t of Florida and elsewhere, the defendant, SCOTT W. ROTHSTEIN, did knowingly conspire, confederate, and agree with persons known and unknown to the United States Attorney, to commit offenses against the United States in violation of Title 18, United States Code, Sections 1956 and 1957, that is: i. to knowing

er to Take Charge of Property of Epstein, and to Post a $15 million Bond to Secure Potential Judgment, in Jane Doe v. Epstein Case No. 08-CV-80893- Marra/Johnson. The motion was reported in the press as was the ultimate goal (i.e., to "pump" the cases for investor following). However, the Court found "Plaint