Epstein Secrets

m yours (USAO) or one of the many plaintiffs' attorneys as it relates to what I can do or assert in defense of Mr. Epstein. As I expressed to Judge Marra, my charge from Mr. Epstein is to take no action that could reasonably be considered to be a violation of the NPA. With that in mind, I am sending

E DOE, et al., 6 Plaintiffs, vs. JUNE 12, 2009 7 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

ert in defense of Mr. Epstein. As I expressed to Judge Marra, my charge from Mr. Epstein is to take no action

case with the prosecution agreement or without the 7 prosecution agreement. We are ready to go forward. 8 THE COURT: You're not going to assert to the United 9 States Government that what he's doing in defending the case is 10 a violation for which he should be further prosecuted? 11 MR. GARCIA: Absolute

m yours (USAO) or one of the many plaintiffs' attorneys as it relates to what I can do or assert in defense of Mr. Epstein. As I expressed to Judge Marra, my charge from Mr. Epstein is to take no action that could reasonably be considered to be a violation of the NPA. With that in mind, I am sending

laintiffs, vs. JEFFREY EPSTEIN, Defendant. WEST PALM BEACH, FLORIDA JUNE 12, 2009 9 10 TRANSCRIPT OF MOTION HEARING 11 BEFORE THE HONORABLE KENNETH A. MARRA, UNITED STATES DISTRICT JUDGE 12 13 14 15 16 APPEARANCES: FOR THE PLAINTIFFS: ADAM D. HOROWITZ, ESQ. Mermelstein & Horowitz 18205 Biscayne

ert in defense of Mr. Epstein. As I expressed to Judge Marra, my charge from Mr. Epstein is to take no action

case with the prosecution agreement or without the 7 prosecution agreement. We are ready to go forward. 8 THE COURT: You're not going to assert to the United 9 States Government that what he's doing in defending the case is 10 a violation for which he should be further prosecuted? 11 MR. GARCIA: Absolute

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

case with the prosecution agreement or without the 7 prosecution agreement. We are ready to go forward. 8 THE COURT: You're not going to assert to the United 9 States Government that what he's doing in defending the case is 10 a violation for which he should be further prosecuted? 11 MR. GARCIA: Absolute

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

ing 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, vs. JUNE 12, 2009 7 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

case with the prosecution agreement or without the 7 prosecution agreement. We are ready to go forward. 8 THE COURT: You're not going to assert to the United 9 States Government that what he's doing in defending the case is 10 a violation for which he should be further prosecuted? 11 MR. GARCIA: Absolute

rcement of Crime Victim's Rights Acts (A-I)." The victim also asked the federal court to allow her to share the NPA with third parties (A-3). Judge Marra denied the motion, finding — as the U.S. Government had argued (A-4) — that the NPA was not a record of the federal court. (A-6) ("First, as respon

ORIDA JANE DOE, et al., Plaintiffs, I JUNE 12, 2009 vs. JEFFREY EPSTEIN, I Defendant. 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 16 For Jane Doe

w her to share the NPA with third parties (A-3). Judge Marra denied the motion, finding — as the U.S. Governm

case with the prosecution agreement or without the 7 prosecution agreement. We are ready to go forward. 8 THE COURT: You're not going to assert to the United 9 States Government that what he's doing in defending the case is 10 a violation for which he should be further prosecuted? 11 MR. GARCIA: Absolute

E DOE, et al., 6 Plaintiffs, vs. JUNE 12, 2009 7 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

4 29:1,16 34:5 38:12,13 39:11 41:14 making 42:7 43:9,24 44:5 man 12:24 mandate 7:24 820 8:21 10:3 many 2023 31:3 35:17 42:1 Marie 2:14 4:9 MARRA 1:11 Martin 2:174:16 Master 21:2 32:16 matter 20:15 37:13 44:19 matters 21:11 may 3:3 5:172,10 99,1210:4,17 11:19 13:17,18 14:18 15:12 16:18

case with the prosecution agreement or without the 7 prosecution agreement. We are ready to go forward. 8 THE COURT: You're not going to assert to the United 9 States Government that what he's doing in defending the case is 10 a violation for which he should be further prosecuted? 11 MR. GARCIA: Absolute

aintiffs, vs. JEFFREY EPSTEIN, Defendant. WEST PALM BEACH, FLORIDA JUNE 12, 2009 9 10 TRANSCRIPT OF MOTION HEARING 11 BEFORE THE HONORABLE KENNETH A. MARRA, UNITED STATES DISTRICT JUDGE 12 APPEARANCES: 13 FOR THE PLAINTIFFS: ADAM D. HOROWITZ, ESQ. 14 Mermelstein & Horowitz 18205 Biscayne Bouleva

uite 500 - West Palm Beach, FL 33401 08-80736-CV-MARRA 001276 EFTA00799705 Case 9:08-cv-80736-KAM Do

case with the prosecution agreement or without the 7 prosecution agreement. We are ready to go forward. 8 THE COURT: You're not going to assert to the United 9 States Government that what he's doing in defending the case is 10 a violation for which he should be further prosecuted? 11 MR. GARCIA: Absolute

ermelstein 6 Horowitz 18205 Biscayne Boulevard 151 Miami, FL 33160 For Jane Doe APPEARANCES: TRANSCRIPT OF MOTION HEARING BEFORE THE HONORABLE KENNETH A. MARRA, UNITED STATES DISTRICT JUDGE 16 BRADLEY J. EDWARDS, ESQ. 17 Rothstein Rosenfeldt Adler 401 East Las Olas Boulevard 18 Fort Lauderdale, FL 33

3 4:18 35:17 42:1 213 303 3521 17:7,9,14,21,24 31:6 32:17 334 ggs 102 Mark 2:1441 38:18 32:1 35:15,20 35:14 393 41:13 legal 10:1324:10,13 MARRA 1:11 move 722 8:18 19:1 ammerom 23:21 41:1642:10,16,17 352138:12403 Mar* 2:17 4:16 192021:17,21 0 43:17 41:5439 Master 212 32:16 37:12 obj

case with the prosecution agreement or without the 7 prosecution agreement. We are ready to go forward. 8 THE COURT: You're not going to assert to the United 9 States Government that what he's doing in defending the case is 10 a violation for which he should be further prosecuted? 11 MR. GARCIA: Absolute

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 parse in camera review, pursuant to the Court's Omnibus Order. Respectfully submitted, UNITED STATES ATTORNEY By: slA. Villa aft Assist

g. ! GOVERNMENT EXHIBIT A Case No. 08-80736-CV-MARRA P-000146 EFTA00185325 U.S. Department of Just

case with the prosecution agreement or without the 7 prosecution agreement. We are ready to go forward. 8 THE COURT: You're not going to assert to the United 9 States Government that what he's doing in defending the case is 10 a violation for which he should be further prosecuted? 11 MR. : Absolutely no

f the NPA through the federal proceedings before Judge Marra (see 's response to the petition filed herewith

2,18 27:24 29:1,16 34:5 38:12,13 39:11 41:14 making 42:7 43:9,24 44:5 man 12:24 mandate 7:24 8:20 8:21 10:3 many 20:23 31:3 42:1 2:14 4:9 MARRA 1:11 Martin 2:17 4:16 Master 21:2 32:16 matter 20:15 37:13 44:19 matters 21:11 may 3:3 5:1 7:2,10 9:9,12 10:4,17 11:19 13:17,18 14:18 15:12

case with the prosecution agreement or without the 7 prosecution agreement. We are ready to go forward. 8 THE COURT: You're not going to assert to the United 9 States Government that what he's doing in defending the case is 10 a violation for which he should be further prosecuted? 11 MR. GARCIA: Absolute