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

of 6 He said the women have stuck with the case out of "a fundamental sense of injustice" for the underage victims of Epstein. Black, a partner at Black, Srebnick, Komspan & Stumpf in Miami, said the 23-page opinion issued Friday has wider implications in plea bargains. No longer can defense attorneys be candi

at Mr. Epstein could "agree" to the occurrence of a predicate pursuant to his NPA obligations but still contest that the plaintiff was injured, see United Stated, Scheidt, supra (finding each to be a separate element) and the letter from Mr. Acosta to Mr. Starr, supra December 4, 2007 letter at p.2 which agr

, judicial restraint, and the rule of lenity applied in construing a statute, Defendant's position as to the meaning of the statute would prevail. See United States'. Santos 128 S.Ct. 2020, 2025 (2008). As summarized by the United States Supreme Court in Santos, supra, at 2025: 5 See argument in sections (2) a

victim of one or more offenses enumerated in 18 U.S.C. § 2255, and, as such, asserts a cause of action against Defendant pursuant to this Section of the United States Code. 30. As a direct and proximate result of the offenses enumerated in 18 U.S.C. § 2255 being committed against the then minor Plaintiff by Defe

cheidt, 2010 W.L. 144837 (E.D. Cal., 2010) (indicating that the statute in effect at the time of the violation governs the minimum damage remedy)? Black, Srebnick. Komspan & Stumpf, P.A. EFTA00194767 Jeff Sloman, Esq. Bob Senior, Esq. Marie Villafana, Esq. March 5, 2010 Page 3 3. Whether personal injur

istribution. The Elaenth Circuil explaned that the %foams should 'entry an esiCenttary benefit from the osclosure of plea negotiations to prow where the United Slates Waned thee rights under the [Owns Victims Rights) Act' Upon literrang 01 the ruling Allomey Brod Edwards stated: The Worn, hako bight hard for almo

Retw He said the women have stuck with the case out of "a fundamental sense of injustice" for the underage victims of Epstein. Black, a partner at Black, Srebnick, Komspan & Stumpf in Miami, said the 23-page opinion issued Friday has wider implications in plea bargains. No longer can defense attorneys be candi

are generally construed according to the principles of contract law, and the government, as drafter, must be held to an agreement's literal terms," United States 'Anglin, 215 F.3d 1064, 1066 (962 Cir, 2000). We believe Epstein has conformed to the Agreement's requirements and would welcome the opportunitytto m

e the opportunitytto meet with you to make sure each party has a common view of its obligations and rights. RB/wg cc: Esq., Acting U.S. Attorney Black, Srebnick, Komspan & Stumpf, PA EFTA00223111 EFTA00223112 IN THE FOURTH DISTRICT COURT OF APPEAL FOR THE STATE OF FLORIDA JEFFREY EPSTEIN, CASE NO: 4D0