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

reasonable opportunity for further investigation or discovery. Fed. R. Civ. P. 11(b). Rule 11 uses an objective standard. Kaplan'. Daimleravysler, A.G., 331 F.3d I251, 1255 (11th ar. 2003). The analysis is whether "a reasonable attorney in like circumstances could believe that his actions were factu

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

sonable opportunity for further investigation or discovery. Fed. R. Civ. P. I1(b). Rule 1 1 uses an objective standard. Kaplan v. DaimlerChrysler, A.G., 331 F.3d I251, 1255 (11th ar. 2003). The analysis is whether "a reasonable attorney in like circumstances could believe that his actions were factu

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

ecified in paragraphs (fXI) (i) through (f)(l)(iv) of this section, e.g., as when a former employee directs remarks to an employee representing the United Slates as a party or intervenor in a Federal or non-Federal judicial proceeding. A Conner employee does not direct his communication or appearance to a bys

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 v. Anderson, 528 F.2d 590, 591 (5th Cir. 1976) (in prosecution for assault with intent to commit murder within territorial jurisdiction of United St

easonable opportunity for further investigation or discovery. Fed. R. Civ. P. 11(b). Rule 11 uses an objective standard. Kaplan v. Dainderarysler, A.G., 331 F.3d 1251, .1255 (11th Cir. 2003). The analysis is whether "a reasonable • attorney in like circumstances could believe that his actions were

the University of Pennsylvania Law School. 4. After graduating from law school, I served as judicial law clerk to the Honorable Norma L. Shapiro, Unites' 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

bstantially in the matter. (j) United States is a party or has a direct and substantial interest— (1) United States. For purposes of this paragraph, the "United States" means: (i) The executive branch (including a Government corporation); (ii) The legislative branch; or (iii) The judicial branch. WestlavvNexe ©

partment of Justice about Epstein, and (3) Movant did not use confidential information obtained during his Government employment to the detriment of the United States. See Declaration of Bruce E. Reinhart at ¶111-12, 17. Rather than conducting the required inquiry, Plaintiffs simply make two irresponsible and uns

asonable opportunity for further investigation or discovery. Fed. R. Civ. P. 11(b). Rule 11 uses an objective standard. Kaplan v. DaimlerChrysler, A.G., 331 F.3d 1251, 1255 (11th Cir. 2003). The analysis is whether "a reasonable attorney in like circumstances could believe that his actions were fact

the University of Pennsylvania Law School. 4. After graduating from law school, I served as judicial law clerk to the Honorable Norma L. Shapiro, Unites' 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

bstantially in the matter. (j) United States is a party or has a direct and substantial interest— (1) United States. For purposes of this paragraph, the "United States" means: (i) The executive branch (including a Government corporation); (ii) The legislative branch; or (iii) The judicial branch. WestlavvNexe ©

partment of Justice about Epstein, and (3) Movant did not use confidential information obtained during his Government employment to the detriment of the United States. See Declaration of Bruce E. Reinhart at ¶111-12, 17. Rather than conducting the required inquiry, Plaintiffs simply make two irresponsible and uns

asonable opportunity for further investigation or discovery. Fed. R. Civ. P. 11(b). Rule 11 uses an objective standard. Kaplan v. DaimlerChrysler, A.G., 331 F.3d 1251, 1255 (11th Cir. 2003). The analysis is whether "a reasonable attorney in like circumstances could believe that his actions were fact

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

asonable opportunity for further investigation or discovery. Fed. R. Civ. P. 11(b). Rule 11 uses an objective standard. Kaplan ! DaintlerChrysler, A.G., 331 F.3d 1251, .1255 (11th Cir. 2003). The analysis is whether "a reasonable • attorney in like circumstances could believe that his actions were

25 1 sex slave? 2 MR. YAREMA: Object to the form. 3 A The 4 Q Are you aware that the reports about you 5 indicate that you were brought to the United States by Jeffrey Epstein when you were roughly 13 or 14 years old to be his Yugoslavian lesbian sex slave? MR. YAREMA: Object to the form. A The Fifth.

12 13 14 15 16 17 18 19 20 21 22 23 24 25 in either 2001 or 2002? MR. YAREMA: Object to the form. A Fifth. Q Did you, in fact, call A.G. to come to Jeffrey Epstein's home and give him a massage in a sexual nature in 2001 or 2002? MR. YAREMA: Object to the form. A Fifth. Q Dld you

for a massage of a sexual nature? MR. YAREMA: Object to the Iona. A Fifth. Q Did Jeffrey Epstein tell you it was his intent during the course of A.G.'s visit to his home to persuade, induce or entice her to engage in sexual activity? MR. YAREMA: Object to the form. A Fifth. Q Didn't Jeffrey Ep