Epstein Secrets

n filed an emergency petition for enforcement of the CVRA, "seeking an order compelling the Department of Justice and United States Attorney General Eric Holder, Jr. to comply with the CVRA and to accord them various rights conferred upon crime victims under 21 Respondent's Exhibit A Case No. 08-80736-CIV

f Justice and United States Attorney General Eric Holder, Jr. to comply with the CVRA and to accord them

tion for mandamus that would have to be heard within 72 hours." At least one prisoner has filed exactly this type of suit, not once, but twice. See Searcy v. NFN Palen, 2007 WL 1875802 (D.S.C. June 27, 2007) (prisoner who alleged he was victim of assault filed suit under CVRA attempting to force U.S. A

alleged he was victim of assault filed suit under CVRA attempting to force U.S. Attorney's Office, FBI, and BOP to prosecute alleged perpetrator); Searcy v. NFN Skinner, 2006 WL 1677177 (D.S.C. June 16, 2006) (same). These fears are not imagined — several individuals have tried to use the CVRA to for

Mall) Special Asst. U.S. Attorney IRS District Counsel 1000 S. Pine Island Rd., Ste 340 Plantation, FL 33324-3906 (Via U.S. Mail) The Honorable Eric H. Holder, Jr. Attorney General of the U.S. 950 Pennsylvania Avenue, NW Room 4400 Washington, DC 20530-0001 (Via U.S. Mail) Honorable Jeffrey H. Sloman A

3324-3906 (Via U.S. Mail) The Honorable Eric H. Holder, Jr. Attorney General of the U.S. 950 Pennsylva

ews Avenue, Suite 2 Fort Lauderdale, Florida 33301 (954)524-2820 (954)524-2822 Fax sethaorithtojustice.com JACK SCAROLA Florida Bar No.: 1694.40 Searcy, Denney, Scarola, Barnhart & Shipley 2139 Palm Beach Lakes Blvd West Palm Beach, FL 33409 (561) 686-6300 (561) 684-5816 (fax) 4 EFTA00724499

. U.S. Attorney (Via U.S. Mail) United Healthcare (Via US Mail) Special Asst. U.S. Attorney IRS District Counsel (Via U.S. Mail) The Honorable Eric H. Holder, Jr. Attorney General of the U.S. 950 Pennsylvania Avenue, NW Room 4400 Washington, DC 20530-0001 (Via U.S. Mail) Mark Bloom, Esq. John B. Hutt

t Counsel (Via U.S. Mail) The Honorable Eric H. Holder, Jr. Attorney General of the U.S. 950 Pennsylva

SING, EDWARD FIT LEHRMAN P.L. 16 EFTA00708308 Case 09-34791-RBR Doc 1603 Filed 0410811 Page 17 of 23 Jack Scarola Florida Bar No.: 169440 Searcy, Denney, Scarola, Barnhart & Shipley Attorney for Bradley J. Edwards in the matter of Epstein v. Edwards, et at Case No.: 502009C40408000CCaMBAG 1

Anthony Gruppo 200 West Cypress Creek Road Suite 500 Fort Lauderdale, FL 33309 [email protected] (VIA EMAIL) EFTA00595521 The Honorable Eric H. Holder, Jr. Attorney General of the U.S. 950 Pennsylvania Avenue, NW Room 4400 Washington, DC 20530-0001 (Via U.S. Mail) Mark Bloom, Esq. John B. Hutt

(VIA EMAIL) EFTA00595521 The Honorable Eric H. Holder, Jr. Attorney General of the U.S. 950 Pennsylva

th his current firm, Edwards filed and pursued civil lawsuits Mr. Edwards, an attorney with the FJW firm, is represented by Jack Scarola of the firm Searcy, Denny, Scarola, Barnhart, and Shipley.. EFTA00595514 against Epstein to recover damages for Epstein's extensive pattern of molestations. Mr refe

n filed an emergency petition for enforcement of the CVRA, "seeking an order compelling the Department of Justice and United States Attorney General Eric Holder, Jr. to comply with the CVRA and to accord them various rights conferred upon crime victims under 21 EFTA00078855 Case 9:08-cv-80736-KAM Documen

f Justice and United States Attorney General Eric Holder, Jr. to comply with the CVRA and to accord them

tion for mandamus that would have to be heard within 72 hours." At least one prisoner has filed exactly this type of suit, not once, but twice. See Searcy v. NFN Paletz, 2007 WL 1875802 (D.S.C. June 27, 2007) (prisoner who alleged he was victim of assault filed suit under CVRA attempting to force U.S.

n filed an emergency petition for enforcement of the CVRA, "seeking an order compelling the Department of Justice and United States Attorney General Eric Holder, Jr. to comply with the CVRA and to accord them various rights conferred upon crime victims under 21 EFTA00177071 Case 9:08-cv-80736-KAM Documen

f Justice and United States Attorney General Eric Holder, Jr. to comply with the CVRA and to accord them

tion for mandamus that would have to be heard within 72 hours." At least one prisoner has filed exactly this type of suit, not once, but twice. See Searcy' NFN Pale!; 2007 WL 1875802 (D.S.C. June 27, 2007) (prisoner who alleged he was victim of assault filed suit under CVRA attempting to force U.S. Att

n filed an emergency petition for enforcement of the CVRA, "seeking an order compelling the Department of Justice and United States Attorney General Eric Holder, Jr. to comply with the CVRA and to accord them various rights conferred upon crime victims under 21 EFTA00230086 Case 9:08-cv-80736-KAM Documen

f Justice and United States Attorney General Eric Holder, Jr. to comply with the CVRA and to accord them

alleged he was victim of assault filed suit under CVRA attempting to force U.S. Attorney's Office, FBI, and BOP to prosecute alleged perpetrator); Searcy v. NFN Skinner, 2006 WL 1677177 (D.S.C. June 16, 2006) (same). These fears are not imagined — several individuals have tried to use the CVRA to for

Shortly after the Department released its opinion, one of the CVRA’s congressional sponsors, then-Senator Jon Kyl, sent a letter to Attorney General Enc Holder strenuously objecting to the Department’s conclusions. Senator Kyl directly stated his view that “[w]hen Congress enacted the ' Scott Campbell, Step

to a criminal defendant in similar circumstances. If prosecutors have sufficient information to provide notice 3 Letter from Jon Kyl, U.S. Sen., to Eric H. Holder, Jr., Att’y Gen. (June 6, 2011), reprinted in 157 Conc. REc. $3608 (daily ed. June 8, 2011) (statement of Sen. Jon Kyl). 4 18 USC. § 3771(c\(1). 5

rts concluded that a victim of uncharged conduct should not be afforded statutory protections.'°! Yet none of these cases—United States v. Turner,'°? Searcy v. Paletz,'® or Searcy v. Skinner'°*—provide strong support for OLC’s position. Turner is a particularly poor fit. Although OLC’s memorandum characte

Shortly after the Department released its opinion, one of the CVRA's congressional sponsors, then-Senator Jon Kyl, sent a letter to Attorney General Eric Holder strenuously objecting to the Department's conclusions. Senator Kyl directly stated his view that "when Congress enacted the [*62] CVRA, it intended t

that a victim of uncharged conduct should not be afforded statutory protections. !°! Yet none of these cases - United States v. 10 104 Turner, !9? Searcy v. Paletz, !°3 or Searcy v. Skinner - provide strong support for OLC's position. Turner is a particularly 9 See 42 U.S.C. § 10607(c). % Td. § 10607(

? It was against that backdrop that Senator Kyl gave the example of conferring about proceedings "after charging." In his letter to Attorney General Holder, Senator Kyl also noted that he had: made clear that crime victims had rights under the CVRA even before an indictment is filed. For example, ... I

t proceedings "after charging." In his letter to Attorney General Holder, Senator Kyl also noted that he had: made clear