Epstein Secrets

ilege Log, which is attached hereto. The documents referenced in the Privilege Log are being delivered today to the Chambers of U.S. District Judge Kenneth A. Marra for ex parte in camera review, pursuant to the Court's Omnibus Order. Respectfully submitted, UNITED STATES ATTORNEY By: Assistant United States

18, 2008, attorney Katherine Ezell representing some of Epstein's victims emailed the line prosecutor, asking whether the NPA was "blessed" by Judge Marra. The line prosecutor emailed back: "As far as I know, Judge Man has not ever seen the agreement or these notification letters.... 1 don't know if t

osecutor, asking whether the NPA was "blessed" by Judge Marra. The line prosecutor emailed back: "As far as I

with handwritten Suppl. Box 3 P-013937 Thru P-013939 Draft Letter, to Professor Paul Deliberative Process Privilege Attorney Work Product G. Cassell, with handwritten corrections Suppl. Box 3 P413940 Thru P-013942 Draft Letter, marked "Confidential: To O ned b Addressee Only," , with handw

ng the information that you have in that regard voluntarily, as opposed to us having to conduct formal discovery to get it. As you also know, Judge Marra has recently ordered discovery to proceed in this case. We obviously would like for that process to go as smoothly as possible and want to avoid be

E DOE, et al., 6 Plaintiffs, JUNE 12, 2009 7 VS. 8 JEFFREY EPSTEIN, 9 Defendant. 10 11 TRANSCRIPT OF MOTION HEARING BEFORE THE HONORABLE KENNETH A. MARRA, 12 UNITED STATES DISTRICT JUDGE APPEARANCES: 13 14 FOR THE PLAINTIFFS: ADAM D. HOROWITZ, ESQ. Mermelstein & Horowitz 15 18205 Biscayne Bou

ct formal discovery to get it. As you also know, Judge Marra has recently ordered discovery to proceed in this

mptly unsealed other pleadings in this matter when the Government tried to object. Sincerely, Cassell Co-Counsel for Jane Doe #1 and Jane Doe #2 G. Cassell Ronald N. Boyce Presidential Professor of Criminal Law S.J. Quinney College of Law at the University of Utah 332 South 1400 East, Room 101 Salt L

ble up or inundate you, as I know other ITN News colleagues have also been in touch with you. I just wanted to make sure I was on your radar if Judge Marra rules next week. Best, Donna Paine Sent from my iPad On Jan 23, 2015, at 1:10 PM, Paul Cassell <cassellp @law.utah.edu> wrote: Hi Donna, | am p

I just wanted to make sure I was on your radar if Judge Marra rules next week. Best, Donna Paine Sent from m

ng this information along to Joan, who will add this information into our contacts list. Thanks for your interest in this important case. Paul Paul G. Cassell Ronald N. Boyce Presidential Professor of Criminal Law S.J. Quinney College of Law at the University of Utah 332 South 1400 East, Room 101 = Salt

ttlement Conference, or in the Alternative, Motion to Direct Parties back to Mediation, Doe v. Epstein, No. 9:08-CV-80893 (S.D. Fla. June 28, 2010) (Marra, J.) (doc. #168) attached hereto as Exhibit "A". Notably, Epstein sought this settlement conference — and ultimately made his payments as a result

there was some improper coercion involved in, for example, Jane Doe's case, his remedy was to raise the matter before Federal District Court Judge Kenneth A. Marra who was presiding over the matter. Far from raising any such claim, Epstein simply chose to settle that case. He is therefore now barred by the doct

ECF on this 28th day of June, 2010: Brad Edwards, Esq. Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman PL Fort uder ale FL 3301 Phone: Fax: G. Cassell, Esq. Pro Hac V t Lake Ci , UT 84112 Fax o-counse or Plaintiff Jack Alan Goldberger, Esq. s, P.A. ach, FL 33401-5012 Co-Counsel for Defendant

f Jane Doe's Opposition to Defendant Epstein's Motion for Summary Judgment and Certification of Having C. Replies due by 5/21/2010. Signed by Judge Kenneth A. Marra on 5/17/2010. (ir) 9:08-cv-80893-KAM Notice has been electronically mailed to: Ann Marie C. Villafana ann.marie.c.villafana@usdolgov,fran.prager@u

ies due by 5/21/2010. Signed by Judge Kenneth A. Marra on 5/17/2010. (ir) 9:08-cv-80893-KAM Notice has

herine Warthen Ezell [email protected], mestrada®podhurst.com Michael James Pike [email protected], bobbie@bcklawcom, [email protected] Paid G. Cassell [email protected] Robert Deweese Critton , Jr rcrit®bc1claw.com, [email protected] EFTA00207443 9:08-cv-80893-KAM Notice has not been deli

ral court, eimed at ya(.aai ingthe federal plea agreareeee:. cn the arounds that it violated sictims' rithie.12371 On April 7, 2015, Judge 7arsiothi Marra riner:i. that the allegationsmade by alleged_ kitual against Prince. Andreahad no hearing on the lawsuit by alleged victims seeking to reopen Epst

, On February 21, 2019, in the case of Two Jane Does v. United States, Senior Judge of the U.S. District Court for the Southern District of Florida Kenneth Marra said federal prosecutors violated the law by failing to notify victims before they allowed him to plead guilty to only the two Florida offenses. Th

. The judge left open what the possible remedy could bef1321 v. Epstein (2015) In a December 2014 Florida court filing by Bradley Edwards and Pa.ul G. Cassell meant for India the Crime Victims Rihis uit,[14°) (then known as , alleged in a sworn affidavit that at age 17, elae had. beep:" sexually tra

pending in federal court, aimed at vacating the federal plea agreement on the grounds that it violated victims' lights.D$71 On April 7, 2015, Judge Kenneth Marra ruled that the allegations made by alleged victim I against Prince Andrew had no liearing on the lawsuit by alleged victims seeking to reopen

open Epstein's non-prosecution plea agreement with the federal government; the judge ordered that allegation to be struck from the record.11 Judge Marra made no ruling as to whether claims by are true or false. Though he did not allow Jane Does 3 and 4 to join the suit, Marra specifically said that

he judge left open what the possible remedy could be. a' `9) v. Epstein (2015) In a December 2014 Florida court filing by Bradley Edwards and Paid G. Cassell meant for inclusion in the Crime Victims 15 Where are they now? The 'Asrhliwiuit,[14°1 alleged in a sworn affidavit that at age 17, (then known

pending in federal court, aimed at vacata the federal plea agreement on the grounds that it violated victims' rights.11-371 On April 7, 2015, Judge Kenneth Marra ruled that the allegations made by alleged victim Virginia Roberts against Prince Andrew had no bearing on the lawsuit by alleged victims seeking t

eopen Epstein's non-prosecution plea agreement with the federal government: the judge ordered that allegation to be struck from the record.Mi Judge Marra made no ruling as to whether claims by Roberts are true or false. Though he did not allow Jane Does 3 and 4 to join the suit, Marra specifically sai

ossible remedy could be.&391 Virginia Giuffre v. Epstein (2015) In a December 2014 Florida court filing by Bradley Edwards External video and ?44 G. Cassell meant for inclusion in the Crime Victims ' g Where are they now? The Rights- Act lawsuit,149-1 Virginia Giuffre (then known as. , Alggest_Syers in t

s pending in federal court, aimed at vacating the federal plea agreement on the grounds that it violated victims' rightsilil On April 7, 2015, Judge Kenneth Marra ruled that the allegations made by alleged victim Virginia Roberts against Prince Andrew had no bearing on the lawsuit by alleged victims seeking t

open Epstein's non-prosecution plea agreement with the federal government the judge ordered • t allegation to_k_stnick from_the recordtilisi Judge Marra made no ruling as to whether claims by Roberts are true or false. Though he did not allow Jane Does 3 and 4 to join the suit, Marra specifically sai

ssible remedy could beig9i Virginia Giuffre v. Epstein (2015) In a December 2014 Florida court filing by Bradley Edwards External video and Panl. G. Cassell meant for inclusion in the Crime Victims g where are they now? The Rights' Act LawsnitP4.91 ykrzipia. Giuffre (then known as biggest players In th

frey Epstein is hereby ordered to be unsealed. DONE AND ORDERED in Chambers, in West Palm Beach, Palm Beach County, Florida, this day of , 2008. KENNETH A. MARRA UNITED STATES DISTRICT COURT Copies furnished to: all counsel of record EFTA00232319 v I fale c.., g la a 0 g o i- 'it' g td s ) EFT

Jane Doe I and Jane Doe 2 Case No.: 08-80736-CV-MARRA/JOHNSON United States District Court, Southern D

Case 9:08-cv-80736-KAM Document 28 Entered on FLSD Docket 09/25/2008 Page 7 of 8 G. Cassell Attorney for Petitioners Pro Hac Vice 332 S. 1400 E. Salt Lake City, UT 84112 Telephone: Facsimile: E-Mail: Jay C. Howell, Esquire Attorney