Epstein Secrets

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 08-80736-Civ-Marra/Johnson JANE DOES #1 and #2 I. UNITED STATES JOINT STATEMENT OF UNDISPUTED FACTS The parties hereby stipulate and agree that the following facts are not in dispute and may be accepted as true

ensued between the United States and Epstein. Despite the investigation revealing that Epstein had molested more than 40 minor girls, in Late 2007, the United Stales entered into a non- prosecution agreement (NPA) with Epstein - esseNiatly egree:ng to immunize Epstein for al of the Federal Sex crimes he committed

copy of the terms was not provided. A notification was not provided to Jane Doe #2 because the agreement limited Epstein's liability to victims whom the United States was prepared to name in an indictment. As a result, Jane Doe #2 never received a notification a letter about the agreement. The-rietifieation4id-net

on the [NPA] when seeking civil relief against Epstein . . . and affirmatively advanced the terms of the [NPA] as a basis for relief from Epstein." United States' Reply in Support of its Motion to Dismiss for Lack of Subject Matter Jurisdiction, Doc. 205-6 at 12-13. After reaping the benefits of the NPA, the

ledged the private nature of discovery" Looney I Moore, No. 2:13-CV-00733-KOB (N.D. Ala. April 7, 2014), 2014 U.S. Dist. LEXIS 48349, at *3, citing Chicago Tribune Co. Bridgestone/Firestone, Inc., 263 F.3d 1304, 1316 (11'1' Cir. 2001) ("Discovery, whether civil or criminal, is essentially a private process becaus

Case 9:08-cv-80736-KAM Document 188 Entered on FLSD Docket 06/18/2013 Page 5 of 11 proceedings against the defendant making them under Rule 410. See e.g United States v. Paden, 908 F.2d 1229, 1235 (.5th Cir. 1990)(statements made during negotiations that resulted in a final plea of guilty not protected under Rule

ided only against "adversaries." Thus, disclosure of the material to an adversary, real or potential, works a forfeiture of work product protection. United States v. Massachusetts Institute of Technology, 129 F.3d 681 (1" Cir. 1997). In this case, Epstein's attorneys' disclosure to the United States Attorney's

8/2013 Page 2 of 4 the asserted right of access against the other party's interest in keeping the information confidential." Romero at 1246, citing Chicago Tribune Co. v. Bridgestone/Firestone, Inc., 263 F.3d 1304, 1309 (11' Cir. 2001). In balancing the competing interests, the court appropriately considers "wheth

ator Feinstein)(explaining that the right to confer was "intended to be expansive," applying to "any critical state or disposition of the case") and United States v. Heaton, 458 F. Supp. 2d 1272 (D. Utah 2006)(government motion to dismiss charge of using facility of interstate commerce to entice minors to enga

ted States of America. (Lee, Dexter) (Entered: 01/26/2012) 01/26/2012 .1.44 RESPONSE in Opposition re_12$ Motion for Miscellaneous Relief filed by United States of America. (Sanchez, Eduardo) (Entered: 01/26/2012) 01/27/2012 145 ENDOR ingitl Motion for Leave to File Excess Pages. Signed by Judge on 1/27/2012. (ir)

6/18/2013 Page 2 of 4 the asserted right of access against the other party's interest in keeping the information confidentiarRomero at 1246, citing Chicago Tribune Co. v. Bridgestone/Firestone, Inc., 263 F.3d 1304, 1309 (11* Cir. 2001). In balancing the competing interests, the court appropriately considers "wheth

on the [NPA] when seeking civil relief against Epstein . . . and affirmatively advanced the terms of the [NPA] as a basis for relief from Epstein." United States' Reply in Support of its Motion to Dismiss for Lack of Subject Matter Jurisdiction, Doc. 205-6 at 12-13. After reaping the benefits of the NPA, the

edged the private nature of discovery" Looney v. Moore, No. 2:13-CV-00733-KOB (N.D. Ala. April 7, 2014), 2014 U.S. Dist. LEXIS 48349, at *3, citing Chicago Tribune Co. v. Bridgestone/Firestone, Inc., 263 F.3d 1304, 1316 (11t' Cir. 2001) ("Discovery, whether civil or criminal, is essentially a private process becau