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

order lo continuo to receive notifications. it is your responsibility to keep your contact informabon current Sincerely, cz6.4 1 )i LC+. o ;TA) Twiler Smith Victim Species'! • 70764. P-87 08-80736-CV-MARRA 000751 EFTA00230575 Case 9:08-cv-80736-KAM Document 79 Entered on ['LSD Docket 05/03/2011 Pa

k that physical force against the person . . . or another may be used in t the course of committing the offense." 18 U.S.C. § 16(b). Post-Johnson v. United Sta , U.S. 135 S. Ct. 2551 (2015), a court might decide differently. See, e.g., Menendez Whitaker, 908 F.3d 467 (9'b Cir. 2018). Even if not a crime

considered for work release. At some point after the NPA was signed, USA Acosta was recused from the Epstein matter. AUSA John McMillan (still at USA0): Early in the investigation, I asked AUSA McMillan if he would serve as co-counsel on the case. Before I joined the West Palm Beach Office, AUSA M

rate contact with Epstein. (See Exhibit A-1.) One of the subpoenaed victims was Individual #28, who is referred to as Jane Doe #2 in the Jane Doe' United Stales litigation. When approached for an interview, Individual #28 refused to speak with the agents, and I remember S/A Kuyrkendall telling me that she fe

GRAND JURY PROCEEDINGS SEALED ORDER GRANTING APPLICATION FOR PERMISSION TO DISCLOSE GRAND JURY MATERIAL THIS MATTER has come before the Court on the United States' Sealed Application for Permission to Disclose Grand Jury Material and for Entry of a Protective Order. The Court has considered the Motion and find

individuals #3, 8, 17, 25, 26, 37, and I I B-68 7/14/2008- 7/15/2008 Emails between Marie Villafana, E. Nesbitt Kuyrkendall,Jason Richards. and Twiler Smith re FBI victim notifications 15-69 7/18/2008- 7/21/2008 Emails between Marie Villafana, Jeff Montan, E. Nesbitt Kuyrkendall, Jason Richards, Dext

ice United States Attorney Southern District of Florida September 2, 2008 NOTIFICATION OF IDENTIFIED VICTIM NOTICE: IN ACCORDANCE WITH TITLE 18, UNITED STATES CODE, SECTION 3509(d) AND FLORIDA LAW, THE ATTACHED DOCUMENT IS TO BE TREATED AS CONFIDENTIAL AND SHALL NOT BE DISCLOSED EXCEPT IN CONNECTION WI

District of Florida 500 South Australian Ave., Suite 400 West Palm Beach FL 3340! (561)8204711 Facsimile: (56!) 820-8777 September 15, 2008 VIA UN TE STATES MAIL Ms. to Rc: Jeffrey Epstein/ HE NOTIFICATION OF IDENTIFIED Dear Ms. 11. By virtue of this letter, the United States Attorney's Office for

and you waive any other claim for damages, whether pursuant to state, federal, or common law. Notwithstanding this waiver, Epstein's agreement with the United States, his waivers and failure to contest liability and such damages in any suit are not to be construed as an admission of any criminal or civil liabili

ned in Section 2255, shall cease. Please contact either myself at [email protected], or Justice Department Victim-Witness Specialist Twiler Smith at [email protected] with a good telephone number and/or e-mail address, so that we may provide Mr. Josefsberg with a timely means of communi

each, FL 33101 (561) 820-8711 Facsimile: (56!) 820-8777 September 2, 2008 NOTIFICATION OF IDENTIFIED VICTIM NOTICE: IN ACCORDANCE WITH TITLE 18, UNITED STATES CODE, SECTION 3509(d) AND FLORIDA LAW, THE ATTACHED DOCUMENT IS TO BE TREATED AS CONFIDENTIAL AND SHALL NOT BE DISCLOSED EXCEPT IN CONNECTION WI

District of Florida 500 South Australian Ave., Suite 400 West Palm Beach FL 3340! (561)8204711 Facsimile: (56!) 820-8777 September 15, 2008 VIA UN TE STATES MAIL Ms. to Rc: Jeffrey Epstein/ HE NOTIFICATION OF IDENTIFIED Dear Ms. 11. By virtue of this letter, the United States Attorney's Office for

and you waive any other claim for damages, whether pursuant to state, federal, or common law. Notwithstanding this waiver, Epstein's agreement with the United States, his waivers and failure to contest liability and such damages in any suit are not to be construed as an admission of any criminal or civil liabili

ned in Section 2255, shall cease. Please contact either myself at [email protected], or Justice Department Victim-Witness Specialist Twiler Smith at [email protected] with a good telephone number and/or e-mail address, so that we may provide Mr. Josefsberg with a timely means of communi

lm Beach, FL 33401 (561) 820-8711 Facsimile: (56!) 820-8777 July 10, 2008 NOTIFICATION OF IDENTIFIED VICTIM NOTICE: IN ACCORDANCE WITH TITLE 18, UNITED STATES CODE, SECTION 3509(d) AND FLORIDA LAW, THE ATTACHED DOCUMENT IS TO BE TREATED AS CONFIDENTIAL AND SHALL NOT BE DISCLOSED EXCEPT IN CONNECTION WITH

e victim all asked to address the Court. I cited the CVRA and other statutes to support the Court's authority to hear from them. The second case was United States' Oliver, which was the Office's first case seeking the appointment of a guardian ad litem (GAL). Through these cases, I researched statutes, cases,

, and London, England. Ms. Villafafia remained in civil practice, specializing in intellectual property litigation until 2001, when she was hired by the United States Attorney's Office in Miami. While she enjoyed civil practice, Ms. Villafafia for many years had wanted to be an Assistant United States Attorney. T

sors. With regard to FBI policies and practices, I understood that the FBI had its own victim notification procedures. I had previously worked with Twiler Smith on other cases (and worked with her on other cases after the Epstein investigation). I did not know the details of what FBI included in its letters

Reach, FL 33401 (561)8204711 Facsimile: (561) 820-8777 September 3, 2008 NOTIFICATION OF *IDENTIFIED VICTIM NOTICE: IN ACCORDANCE WITH TITLE 18, UNITED STATES CODE, SECTION 3509(d) AND FLORIDA LAW, THE ATTACHED DOCUMENT IS TO BE TREATED AS CONFIDENTIAL AND SHALL NOT BE DISCLOSED EXCEPT IN CONNECTION WIT

here he could get passports or other travel documents for young girls. He would then bring these young girls (girls ranging in age from 12 to 24) to the United States for sexual purposes and farm them out to his friends, including Epstein. 49. Brunel would offer the girls "modeling" jobs. A lot of the girls came

s and costs such as those contained in Section 2255, shall cease. Please contact either myself at or Justice Department Victim-Witness Specialist Twiler Smith at with a good telephone number and/or e-mail address, so that we may provide Mr. Josefsberg with a timely means of communicating with you. If you

you elect to file suit against Mr. Epstein pursuant to Title 18, United States Code, Section 2255, Mr. Epstein will not contest the jurisdiction of the United States District Court for the Southern District of Florida over his person and/or the subject matter, and Mr. Epstein waives his right to contest liability

o can assist you with any counseling or other services that you might need. You also can continue to contact the FBI's Victim Services Coordinator, Twiler Smith, at 561-833-7517. If you have already selected other counsel to represent you, or if you do so in the future, and you decide to file a claim agains

pertain to events occurring after the arrest or indictment of an individual for the crime, and it will become the responsibility of the prosecuting United States Attorney's Office to ensure you are accorded those rights. You may also seek the advice of a private attorney with respect to these rights. The Vic

program is voluntary. In order to continue to receive notifications, it is your responsibility to keep your contact information current. Sincerely, Twiler Smith Victim Specialist .• (Overall Document Classification Required) 2 EFTA00270194

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

er to continue to receive notifications, fl Is your responsibility to keep your contact information current. Sincerely, 4 1.0; (LA. 0. 1 1;tie Twiler Smith Victim Specialst TOTAL P.0? EFTA00184413 Case 9:08-cv-80736-KAM Document 361-30 Entered on FLSD Docket 02/10/2016 Page 1 of 28 EXHIBIT 30 EF

check the plane as part of their custom's check and asked me to accompany him. advised they had the legal authority to board an aircraft going to the United States. I boarded the plane along with and the other two CBP personnel. We walked the length of the plane and ascertained there was no one on board. We t

program is voluntary. In order to continue to receive notifications, it is your responsibility to keep your contact information current. Sincerely, Twiler Smith Victim Specialist U.S. Department of Justice Federal Bureau of Investigation FBI - West Palm Beach S uth FlAnlAr nriVA W st Palm Beach, FL 3340

the FBI. It is the property of the FBI and is loaned to your agency; it and its contents are not to be distributed outside your agency. Embassy of the United States of America Office of the Legal Attache US Consulate Level 59 MLC Centre 19-29 Martin Place Sydney NSW 2000 File No. 31E-MM-108062\174 03 December 2008 Mr. Vic Sulko

S Consulate Level 59 MLC Centre 19-29 Martin Place Sydney NSW 2000 File No. 31E-MM-108062\174 03 December 2008 Mr. Vic Sulkowski Acting Coordinator Americas, Europe, Middle East & Africa Desk Australian Federal Police Canberra, ACT Australia Re: Jeffrey Epstein Dear Mr. The United States Attorney's Off

enclosed letter to DOB berra, Australia; telephone numbers and The letter references the outcome of a Non-Prosecution Agreement entered into by the U.S. Government and Mr. Jeffrey Epstein. The letter provides with the terms of the Agreement and contact information should she have any questions. On 24/07/06, th