Epstein Secrets

n by notorious pedophile and convicted sex offender Jeffrey E. Epstein. It all started in 1994 when 13-year-old Doe met Epstein at a summer camp in Michigan. Doe was Epstein's first known victim and was To protect her anonymity, our client has elected to file her action as a Jane Doe and will be referre

PANISH SHEA & BOYLE, June 8, 2020 VIA E-MAIL AND FEDEX The Honorable Geoffrey S. Berman United States Attorney for the Southern District of New York c/o Assistant nited tates Attorne E-mail: Re: Request for Tangible and Documentary Evidence (Touhy Request) Jane Doe v. Indyke et al., SDNY Ca

esented the case to the U.S. Attomey’s Office for the Southern District of Florida. In 2007, the Office contacted counsel

rights even before prosecutors filed a superseding indictment covering the specific crimes affecting the victims. Citing Dean, the District Court for the Eastern District of New York agreed that the rights were expansive and could apply before charges were filed but were subject to the outer limit that the Government has at least

n Victims of Crime, 25 NEw ENG. J. oN CRIM. & CIV. CONFINEMENT 21, 64 & n.168 (1999) (citing to victims’ rights statutes in Connecticut, Hlinois, and Michigan, among others). Unfortunately, as some commentators have noted, the notice and conferral provisions in some states are ambiguous, and the absence of

sented the case to the U.S. Attorney's Office for the Southern District of Florida. In 2007, the Office contacted counsel

ights even before prosecutors filed a superseding indictment covering the specific crimes affecting the victims. Citing Dean, the District Court for the Eastern District of New York agreed that the rights ® John W. Gillis & Douglas E. Beloof, The Next Step for a Maturing Victim Rights Movement: Enforcing Crime Victim Rights in t

Victims of Crime, 25 New Eng. J. on Crim. & Civ. Confinement 21, 64 & n.168 (1999) (citing to victims' rights statutes in Connecticut, Illinois, and Michigan, among others). Unfortunately, as some commentators have noted, the notice and conferral provisions in some states are ambiguous, and the absence of

that the crime be Iserved as U. S. Attorney for the Southern District of Florida em an interstate nexus. Secoi e . : |

apers named underage girls and the places where Epstein had taken them. The list included locations in Califor- nia, Paris, New Mexico, New York, and Michigan. The papers also included the names, addresses, and phone numbers of famous individuals —Henry Kissinger, Mick Jagger, Dustin Hoff- : F man, Ralph Fi

y 2005, the FBI and the U.S. Attorney’s Office in the Southern _ District of Florida learned of Epstein’s repeated sexual a

Epstein’s computer that reflected many of the names of underage females Epstein abused across the country and the world, including locations such as Michigan, California, West Palm Beach, New York, New Mexico, and Paris, France. See Journal (hereinafter “The Journal” or “Holy Grail”) (Exhibit “F”) (identif

agreed that he would not contest jurisdiction in the Southern District of Florida for any victim who chose to sue him fo

Epstein’s computer that reflected many of the names of underage females Epstein abused across the country and the world, including locations such as Michigan, California, West Palm Beach, New York, New Mexico, and Paris, France, See Journal (hereinafter “The Journal” or “Holy Grail”) (Exhibit “F”) (identif

enge those decisions. '24 A few [*882] limited exceptions prove the rule. In cases of private criminal complaints filed by alleged victims, Colorado, Michigan, Nebraska, and Pennsylvania authorize judges to review public prosecutors' decisions not to charge. !?> Even when statutes grant courts the power to

onvincing Congress to expand their discretion at the expense of judges' sentencing authority, see United States v. Kupa, 976 F. Supp. 2d 417, 419-27 (E.D.N.Y. 2013) (describing the legislative history and Justice Department lobbying related to federal drug statutes, notably 27 U.S.C. § 841 (2012)). 218 See

y Epstein ("Epstein"). It all started in 1994 when 13-year-old Jane Doe met Epstein and Defendant Ghislaine Maxwell ("Maxwell") at a summer camp in Michigan. Jane Doe was their first known victim and was subsequently abused by Epstein and Maxwell for years as a young girl, suffering unimaginable physical

easurable pain and suffering every day. Epstein's Death and Will 26. In July 2019, Epstein was indicted by the Unites States Attorney's Office for the Southern District of New York. 27. On August 10, 2019, Epstein was found dead in his jail cell at the Metropolitan Correctional Center, where he was being held pending trial. U

sentenced to a term of life imprisonment. 3. The indictment concerning the fifth and sixth applicants 17. In 1999 a Federal Grand Jury sitting in the Southern District of New York returned an indictment against Osama bin Laden and twenty other individuals, including the applicants, inter alia alleging various degrees of

by false pretences (Rummel v. Estelle 445 US 263 (1980)); life imprisonment without parole for possessing a large quantity of cocaine (Hamelin v. Michigan 501 US 957 (1991)); twenty-five years to life for theft under a "three strikes" recidivist sentencing law (Ewing v. California 538 US 11 (2003));