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

ct to the good faith approval of Epstein's counsel, selecting the attorney representative for the individuals identified under the Agreanent If the United Suites elects to assign this responsibility to an independent third-parry, both the United States and Epstein retain the right to take good faith objection

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

t to the good faith approval of Epstein's counsel, selecting the attorney representative for the individuals identified under the Agreement. If the United Suites tin to assign this responsibility to an independent third-party, both the United States and Epstein retain the right to take good faith objections t

te. The travel must be for the purpose of engaging in the unlawful sexual act. See so Hansen v. Huff, 291 U.S. 559, 562-63 (1934) and Mortensen v. UnitekStates, 322 U.S. 369, 374 (1944) ("An intention that the women or girls shall engage in the conduct outlawed by Section 2 must be found to exist before the

of his parents. Mr. Epstein surely did not go Some Courts have held that the illicit sexual conduct must be: an "efficient and compelling purpose," United Stake v. Meacham 115 F.3d 1458, 1495 (10° Cir. 1997); a "motivating purpose " United Suites v. clugfc1.1, 49 F.3d 1079, 1083 (5° Cir. 1995). Of "at least

d to offer my views regarding the case of Jeffrey Epstein ("Mr. Epstein"), who entered into a Deferred Prosecution Agreement ("the Agreement") with the United State's Attorney's Office for the Southern District of Florida ("USAO") to resolve state and federal criminal investigations relating to his actions involvi

5). Of "at least one of the defendant's motivations for taking the trip in the first place," united States v. Sail 935 F.2d 385, 389 (I° Cir. 1991). SLAWUnited States v. ffotchouez, 224 Fed. Appx. 923 (11° Cir. 2007) (unpublished). EFTA00214726 12/07/07 FRI 15:40 FAX 1 213 680 8500 K RK LANDLELL LIP fril 022

sexual conduct must be: an "efficient and compelling purpose," United Stake v. Meacham 115 F.3d 1458, 1495 (10° Cir. 1997); a "motivating purpose " United Suites v. clugfc1.1, 49 F.3d 1079, 1083 (5° Cir. 1995). Of "at least one of the defendant's motivations for taking the trip in the first place," united St

of the exact location of the Collateral upon Lender's request. Grantor shall not base, or permit the Collateral to be based, outside the continental United States of America. 30.4 Travel Restrictions. Grantor shall not operate or locate the Collateral, or permit the Collateral to be operated, located, or flown (i) outs

rictions. Grantor shall not operate or locate the Collateral, or permit the Collateral to be operated, located, or flown (i) outside the continental United States without war risk coverage, (ii) in or over any country for which the U.S. State Department has issued travel restrictions (excluding any such travel

S0GP LW 2151 E CONVENTION CENTER WAY STE 222 ONTARIO CA 91764-54% Ildmiilll uhILulnLl,LdnlLLiJlnldnhl III This la your authority to change the United Suites registration numb= oa the Wove described aircraft to the special regiatration camber ton Cany duplicate of this form in de aircraft together ait

IN RE: JANE DOE, Petitioner. / FILED by D.C. JUL 0 9 2008 STEVEN M. LAMONT CLERK U.S. DIST CT S.D. Of Ft*. - DECLARATION OF IN SUPPORT OF UNITED STATES' RESPONSE TO VICTIM'S EMERGENCY PETITION FOR ENFORCEMENT OF CRIME VICTIM RIGHTS ACT, 18 U.S.C. $ 3771 1. I, ado hereby declare that I am a member

t 31-2 Entered cm FtSI 989kgM9/2g08 6%9521 of 22 Case 9:08-cv-80736-KAM Document 14 Entered on L D oc e l / age 2 U.S. Department ofilustice United Suites Attorney Southern District of Florida GOVERNMENT EXHIBIT CASE µO.08-8073CCV-MARRA 901IBIT NO. 7 July 9, 2008 VIA FACSIMILE Brad Edwards, E

2255 as she would have bad, if Mr. Epstein been tried federally and convicted of an enumerated offense. For purposes of implementing this paragraph. the United State shall provide Mr. Epstein's attorneys with a list of individuals whom it was prepared to name in an Indictment as victims of an enumerated offense

im el a violation of [enumerated sections. of Tiik IRV and who suffers personal injury as a I eSull of such violation . may sue in asp• appropriate United Suites District Coon and shall recover the actual damages such'persini sustains and the• cost of the suit. sealudury a reasonable anorney's fee.- EFTA0017