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

(7), supra, elects to file suit pursuant to 18 U.S.C. § 2255, Epstein will not conteat the jurisdiction of the United States District Court for the SouthernDistrict of Florida over his person and/or the subject matter, and Epstein waives his right to contest liability and also waives his right to contest damage

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

(7), supra, elects to file suit pursuant to 18 U.S.C. § 2255, Epstein will not conteat the jurisdiction of the United States District Court for the SouthernDistrict of Florida over his person and/or the subject matter, and Epstein waives his right to contest liability and also waives his right to contest damage

2:44 PM NOT A CERTIFIED COPY Case 9:08-cv,80736-KA.ocurnen\ 48-5 Emered on FLSD Do.03/21/2011 I I :sentenced not later y,an October 26, 2007-. the UnitedjStates bas 110 objection to J;:pstein seJfsreporting to begin ~rving hls sentence ·not later than January 4, 2008. • 12. Epstein agrees that.he will no

lty and to ·provide compensation in the tQanner aescribed ab()ye, ifEpsteirt successfully fulfills allt>fthe tenns ~ _conditi9M of this agreement, the United Stat~s 1,1~0 agrees that it will niH institute: BilY criminal charges against any potential ~~onspirators ofEpstein, inclµding but not limited toi Sarah Ke

offense includcs; ;but is net limitadto; a conviction liy a foderabor miUtary'tribunal,-including courts-martial conducted by the Armed Forcos of tho United Status,, >and includes a conviction-orentry of a ploa of',guilty or nolo contendere resulting in a-sanctiun in anyistato of dio United-States or other juris

he gain time he earned during his period of incarceration. 13. The parties anticipate that this agreement will not be made part of any public record. Ifthe United States receives a Freedom ofInformation Act request or any compulsory process commanding the disclosure of the agreement, it will provide notice to Epstein

ll.· .. attempt to obstruct justice, or ... to threaten, injure, or intimidate, a prospective witness or juror." 18 U.S.C. § 3142(t)(2)(B); see also United States v. Friedman, 837 F.2d 48 (2d Cir. 1988). The Bail Reform Act lists four factors to be considered in the detention analysis: (1) the nature and circ

text of the agreement purports to bind “the Government.” See Annabi, Tl\ F.2d at 672. This analysis similarly extends to a non-prosecution agreement. See United States v. Laskow, 688 F. Supp. 851, 854 (E.D.N.Y. 1988) (“Defendant’s argument, in effect, is that unless there is an explicit statement to the contrary, it

a charge to the Grand Jury, filing an information, or in bringing a defendant to trial. Epstein hereby requests thatthe United States Attorney forthe SouthernDistrict ofFloridadefer such prosecution. Epstein agrees and consents that any delay from the date ofthis Agreementto the date ofinitiation ofprosecution, as