Epstein Secrets

., Suite 400 West Palm Beach, FL 33401 (561) 820-8711 Fax: (561) 820-8777 E-mail: ann.marie.c.lillafanaralusdoi.gov Attorney for the Government Joseph L. Ackerman, Jr. Fowler White Burnett PA 777 S. Flagler Drive, West Tower, Suite 901 West Palm Beach, FL 33401 Criminal Defense Counsel for Jeffrey Epstei (

mergency Petition and Petitioners' Motion seeking a finding that the CVRA was violated. The only material fact is that the United States Attorney's Office for the Southern District of Florida never filed federal 'Whether or not the CV RA applies is the central question in dispute in this matter because no federal criminal case

0736-KAM Document 59 Entered on FLSD Docket 04/07/2011 Page 3 of 9 plea proceedings. Id., citing United States,. Ingrassia, 2005 WL 2875220 at •17 (E.D.N.Y. Sep. 7, 2005). The district court concluded, "[t]he CVRA, therefore, dots not authorize an unbridled gallop to any and all information in the gover

CLUSION Based on the foregoing, Edwards' Renewed Motion for Summary Judgment should be denied. Dated: February 16, 2012. Respectfully submitted, Joseph L. Ackerman, Jr. Florida Bar No. FOWLER WHITE BURNETT, P.A. 901 Phillips Point West 777 South Easier Drive West Palm B Telephone: Facsimile: and Christo

all reasonable inferences must be drawn in favor of the nonmovant. See also Parsons & Whittemore Enter. Corp. v. Schwartz 387 F. Supp. 2d 368, 372 (S.D. N.Y. 2005) (assuming that a jury could draw an adverse inference from the invocation of the Fifth Amendment, "the court is still required at summary jud

radley J. Edwards SERVICE UST Jane Doe v. Jeffrey Epstein United States District Court, Southern District of Florida Christopher E. Knight, Esq. Joseph L. Ackerman, Esq. Lily Ann Sanchez, Esq. FOWLER WHITE BURNETT P.A. 901 Phillips Point West 777 South Flagler Drive West Palm Beach, FL 33401 Jack Alan Gold

ng girls. Edwards's attorney in the case has received copies of correspondence between Epstein's criminal defense attorneys and the U.S. Attorney's Office for the Southern District of Florida demonstrating that Epstein was prepared to plead guilty to such offenses. The correspondence is all in the same vein and consists of the

radley J. Edwards SERVICE UST Jane Doe v. Jeffrey Epstein United States District Court, Southern District of Florida Christopher E. Knight, Esq. Joseph L. Ackerman, Esq. Lily Ann Sanchez, Esq. FOWLER WHITE BURNETTIO. 901 Phillips Point West 777 South Flagler Drive West Palm Beach, FL 33401 Jack Alan Goldbe

ng girls. Edwards's attorney in the case has received copies of correspondence between Epstein's criminal defense attorneys and the U.S. Attorney's Office for the Southern District of Florida demonstrating that Epstein was prepared to plead guilty to such offenses. The correspondence is all in the same vein and consists of the

21, 2011, on the following using the Court's CM/ECF system: Assistant U.S. Attorney 500 S. Australian Ave., Suite 400 West Palm Beach, FL 33401 Joseph L. Ackerman, Jr. Fowler White Burnett PA (courtesy copy of pleading via U.S. mail) 10 EFTA00230129 1"Afferr— Case 9:08-cv-80736-KAM Document 58 Entered on

mergency Petition and Petitioners' Motion seeking a finding that the CVRA was violated. The only material fact is that the United States Attorney's Office for the Southern District of Florida never filed federal °Whether or not the CVRA applies is the central question in dispute in this maser because no federal criminal case w

., Suite 400 West Palm Beach, FL 33401 (561) 820-8711 Fax: (561) 820-8777 E mail: ann.marie.c.villafana(ieusdoj.gov Attorney for the Government Joseph L. Ackerman, Jr. Fowler White Burnett PA 777 S. Flagler Drive, West Tower, Suite 901 West Palm Beach, FL 33401 Criminal Defense Counsel for Jeffrey Epstei (

mergency Petition and Petitioners' Motion seeking a finding that the CVRA was violated. The only material fact is that the United States Attorney's Office for the Southern District of Florida never filed federal °Whether or not the CVRA applies is the central question in dispute in this maser because no federal criminal case w