Epstein Secrets

n FLSD Docket 09/25/2008 Page 2 of 8 Epstein's entry of guilty pleas to various state charges and an 18-month jail sentence, in exchange for which the U.S. Government apparently agreed to defer all federal prosecution — including any federal prosecution for the federal crimes committed against the victims. At a h

of the protective order barring them from publicly disclosing or discussing the terms of the non-prosecution agreement between Jeffrey Epstein and the United States Government. Jeffrey Epstein has made no response to this motion. The Government, however, contends that the victims' motion should be denied because the victim

cuments will be disclosed and there will be no adequate remedy. Petitioner, Jeffrey Epstein is referred to by proper name. Non-party interveners, E.W., B.B. and The Post are referred to as E.W., B.B. and The Post. All emphasis is supplied unless indicated otherwise. The following symbol is used: A

ith notice to the United States, the other party to the Agreement. (A-6). Rather than seeking relief from Judge Marra in federal court, non- party E.W., a victim of Mr. Epstein, filed a motion in the state criminal action on May 12, 2009, seeking to intervene and unseal the non-prosecution agreemen

1.333.772-'1662) 4115158d-6c22-4c50-b036-e423618c2fb5 EFTA00723108 Page 143 1 criminal experiences that it's either the State of 2 Florida or the United States Government that prosecutes 3 people, not individuals; true? 4 MR. EDWARDS: Object to the form. 5 THE WITNESS: I don't understand. 6 BY MR. CRITTON: 7

have to be the Jane Doe; Jane Doe? 5 A. Yes. 6 Q. Are you aware of any individuals that Miss - 7 Mr. Edwards represents, other than you, a and E.W.? 8 A. No. 9 Q. All right. Then it goes down — again, 1 10 take you back where it says: "Jane Doe was identified 11. via the FBI's investigati

25 Federal, local, that you had been to Mr. Er:stain's home; Page 136 Q. Okay. would be -- 2 A. Yes. 3 Q. — you would assume. C.W. would be E.W., and 4 you would have to be the Jane Doe; Jane Doe? 5 A. Yes. 6 Q. Are you aware of any individuals that Miss - 7 Mr. Edwards represents, oth

ilege. Id. at page 98; line 24-25. Q: All right. At the time you began representing E.W. or at any time prior to the filing of the lawsuit against the United States Government in July of '08, did you learn whether she was listed as a, or deemed to be a victim by the United States Attorney's Office? Transcript of Depositio

AROLA: I am going to object. That calls for attorney-client privilege. Id. at page 98; line 24-25. Q: All right. At the time you began representing E.W. or at any time prior to the filing of the lawsuit against the United States Government in July of '08, did you learn whether she was listed as a, o

reet, Fort Lauderdale, FL 3330I• 954.467.1223 EFTA00799405 lines 20-21. Q: During that time that you have been involved in this case on behalf of E.W., has Mr. Howell participated in the case; that is, has he done work on the case? Id. at page 90; lines 20-23. A: Yes. Id. at page 90; line 24. Q:

June 11, 2009 motion (A-13). Epstein's counsel consented to that procedure. (A-18 at p. 9, Il. 16 -18.) The Judge held that neither the State, nor the U.S. Government, nor Epstein had shown why the NPA ought to remain confidential and ordered the records unsealed.9 (A-16.) 9 It is important to note that the Stat

fact, the U.S. Attorney's Office has taken no position on this matter throughout the lower court proceedings and specifically informed counsel for E.W. that it had no position (A-18 at p. 7,11. 10-14.) At that hearing, the Court found that the proper procedures to initially seal the records were not

Inc. d/b/a The Palm Beach Post ("the Post") its attorneys' fees and costs in responding to this petition. JURISDICTION The Post adopts Respondent E.W.'s statement concerning jurisdiction. Insofar as this Court finds jurisdiction, the Post requests that this Court expedite its consideration of this

ilege. Id. at page 98; line 24-25. Q: All right. At the time you began representing E.W. or at any time prior to the filing of the lawsuit against the United States Government in July of '08, did you learn whether she was listed as a, or deemed to be a victim by the United States Attorney's Office? Transcript of Depositio

AROLA: I am going to object. That calls for attorney-client privilege. Id. at page 98; line 24-25. Q: All right. At the time you began representing E.W. or at any time prior to the filing of the lawsuit against the United States Government in July of '08, did you learn whether she was listed as a, o

Attorney-Client and work-product privileges. Id. at page 89; lines 20-21. Q: During that time that you have been involved in this case on behalf of E.W., 3 It is significant to note that other jurisdictions have sanctioned counsel for just this behavior during deposition. See e.g. Van Pilsum v. Iow

s June 11, 2009 motion (A-13). Epstein's counsel consented to that procedure. (A-18 at p. 9,11. 16 -18.) The Judge held that neither the State, nor the U.S. Government, nor Epstein had shown why the NPA ought to remain confidential and ordered the records unsealed.9 (A-16.) 9 It is important to note that the Stat

for respondent, State of Florida) B.B. (non-party intervener) William J. Berger of Rothstein Rosenfeldt Adler (counsel for non-party intervener, E.W.) Honorable Jeffrey J. Colbath (circuit court judge) Barbara J. Compiani of Kreusler-Walsh, Compiani & Vargas, P.A. (appellate counsel for petiti

fact, the U.S. Attorney's Office has taken no position on this matter throughout the lower court proceedings and specifically informed counsel for E.W. that it had no position (A-18 at p. 7,11. 10-14.) At that hearing, the Court found that the proper procedures to initially seal the records were not

gain prior to the - let me start again. EXHIBIT "A" 2 EFTA00606648 Prior to the filing of the lawsuit against Jane Doc 1 and Jane Doe 2 against the United States Government, did you learn from any source, maybe a document, maybe a telephone call or a conversation that you had with a third party separate from your clien

answer the threshold "yes" or "no" question: Did [Mr. Howell] ever relate that to you." Id. 9. Edwards in one instance when asked what his client E.W. told him on the phone, himself claimed privilege. Id. at 90. Later, when asked "for what purpose did Ms. L.M. originally hire you?," his attorney o

ing to L.M. and E.W. were not produced because of some tangential privilege based on the pending Crimes Victims' Rights Act ("CVRA") action against the United States Government, this lacks merit. None of the subject e-mails are communications between the government and Edwards' clients or their counsel or implicate any iss

ls are attorney-client privileged communications between Edwards (or any other co-counsel) and Edwards' and Mr. Cassell's three tort clients (L.M., E.W. or Jane Doe). Rather, the majority of the documents are e- mails among attorneys and staff within RRA, with Mr. Cassell, and with media sources and d

sealing such documents. After hearing argument of counsel, the Court makes the following findings and rulings: 1) Neither the State of Florida nor the U.S. Government nor Mr. Epstein have presented sufficient evidence to warrant the sealing of documents currently held by the Court. 2) The Motions to seal the Co

Jeffrey Epstein. Ms. Shullman, Esq. was present on behalf of the Palm Beach Post, Mr. Berger, Esq. and Mr. Edwards, Esq. were present on behalf of E.W., Mr. Kuvin, Esq. was present on behalf of B.B., Assistant State Attorney Barbara Bums was present on behalf of the State of Florida. No appearance

ealing such documents. After hearing argument of counsel, the Court makes the following findings and rulings: 1) Neither the State of Florida nor the U.S. Government nor Mr. Epstein have presented sufficient evidence to warrant the sealing of documents currently held by the Court. 2) The Motions to seal the Co

Jeffrey Epstein. Ms. Shullman, Esq. was present on behalf of the Palm Beach Post, Mr. Berger, Esq. and Mr. Edwards, Esq. were present on behalf of E.W., Mr. Kuvin, Esq. was present on behalf of B.B., Assistant State Attorney Barbara Burns was present on behalf of the State of Florida. No appearance