Epstein Secrets

-9£L08-A3-8O:6 asvo EFTA00184986 Case 9:08-cv-80736-KAM Document 362-34 Entered on FLSD Docket 02/10/2016 Page 2 of 7 U.S. Department of Justice United Stales Attorney Southern District of Florida A. Marie 500 S. Australian Ave 4th Floor Facsimile FACSIMILE COVER SHEET TO: Jack Alan Goldberger DATE:

ocument 362-34 Entered on FLSD Docket 02/10/2016 Page 4 of 7 U.S. Department of Justice OTIVI ON BFI tot NOTICE.. IN ACCORD A.NCE Wall TITLE 18, UNITED STATES CODE, SECTION 3509(d) AND FLORIDA L.ANN, TOE ATT `AC DOCUMENT IS TO RETREATED AS CON VIDF,NTIAL AND SHALL NOT BE DISCLOSED EXCEPT IN CONNECTIO

enied that one of these victims is entitled to proceed under 18 U.S.C. § 2255, that will be considered a breach of the Non-Prosecution Agreement and the United States will proceed accordingly. Sincerely, United States Attorney cc: Karen Atkinson, AUSA By: Assistant United States Attorney 08-80736-CV-MARRA R

ein case. This investigation was undertaken at the request of the victims in this case. On December 10, 2010, co-counsel, Professor Paul Cassell of the University of Utah College of Law, and I met with the U.S. Attorney for the Southern District of Florida regarding this case in the U.S. Attorney's Office in Miami, Florida. At on t

633 (E.D. Va. 2006). The Eleventh Circuit has not hesitated to support district courts that draw an adverse inference from silence. For example, in United States v. Two Parcels of Real Property, 92 F.3d 1123, 1129 (11th Cir. 1996), the district court drew an adverse inference when claimants to real property r

tions. Thus, there is a "perfect circumstantial evidence case that [Epstein] ha[s] means, motive, and opportunity" to fraudulently transfer assets. See United States v. Sparks, 265 F.3d 825, 830 (9th Cir. 2001) (finding probable cause for an arrest based solely on a showing of means, motive, and opportunity). Th

ve person knowledge of the matters set forth herein. I am an attorney licensed to practice in the State of Utah since 1992. My office is located at the University of Utah College of Law, where I am a law professor. Along with other attorneys, I represent plaintiff Jane Doe in this matter. 2. It appears that defendant Jeffrey Epstei

port of its motion to stay. DE 140. In that reply, the Government represented that it would voluntarily be providing information to the victims: "[Tjhe United States has agreed to provide some information to [the victims] even during the pendency of the stay and is undertaking a search for that information." DE

ernment which may be favorable to the defendant on the issues of guilty or punishment within the scope of Brady v. Maryland, 373 U.S. 83 (1963), and United States v. Agurs, 427 U.S. 97 (1976)." The Court should adopt that language to the case at hand here. Interesting, the Standing Discovery Order — and asso

ein case. This investigation was undertaken at the request of the victims in this case. On December 10, 2010, co-counsel, Professor Paul Cassell of the University of Utah College of Law, and I met with the U.S. Attorney for the Southern District of Florida regarding this case in the U.S. Attorney's Office in Miami, Florida. At on t

etitioner. FILED by D.0 JUL 0 9 2008 STEVEN M. tA.RIMORE C LERK U.S. DIST. CT. S O. OF FLA. • MM. DECLARATION OF A. VILLAFASIA IN SUPPORT OF UNITED STATES' RESPONSE TO yinints EMERGENCY PETITION FOR ENFORCEMENT OF CRIME VICTIM RIGHTS ACT. IS U.S.C. § 3771 1. I. A. Villafafta, do hereby declare that

mate, including but not limited to, eligibility for gain time credit based on standard rules and regulations that apply in the State of Florida. At the United States' request, Epstein agrees to provide an accounting of the gain time he earned during his period of incarceration. 13. The parties anticipate that t

ein case. This investigation was undertaken at the request of the victims in this case. On December 10, 2010, co-counsel, Professor Paul Cassell of the University of Utah College of Law, and I met with the U.S. Attorney for the Southern District of Florida regarding this case in the U.S. Attorney's Office in Miami, Florida. At on t

port of its motion to stay. DE 140. In that reply, the Government represented that it would voluntarily be providing information to the victims: "[T]he United States has agreed to provide some information to [the victims] even during the pendency of the stay and is undertaking a search for that information." DE

ein case. This investigation was undertaken at the request of the victims in this case. On December 10, 2010, co-counsel, Professor Paul Cassell of the University of Utah College of Law, and I met with the U.S. Attorney for the Southern District of Florida regarding this case in the U.S. Attorney's Office in Miami, Florida. At on t

port of its motion to stay. DE 140. In that reply, the Government represented that it would voluntarily be providing information to the victims: "[T]he United States has agreed to provide some information to [the victims] even during the pendency of the stay and is undertaking a search foi that information." DE

ein case. This investigation was undertaken at the request of the victims in this case. On December 10, 2010, co-counsel, Professor Paul Cassell of the University of Utah College of Law, and I met with the U.S. Attorney for the Southern District of Florida regarding this case in the U.S. Attorney's Office in Miami, Florida. At on t

port of its motion to stay. DE 140. In that reply, the Government represented that it would voluntarily be providing information to the victims: "[T]he United States has agreed to provide some information to [the victims] even during the pendency of the stay and is undertaking a search for that information." DE

ein case. This investigation was undertaken at the request of the victims in this case. On December 10, 2010, co-counsel, Professor Paul Cassell of the University of Utah College of Law, and I met with the U.S. Attorney for the Southern District of Florida regarding this case in the U.S. Attorney's Office in Miami, Florida. At on t