UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No, 08-80736-Civ-Marra/Johnson JANE DOES 41 and #2 UNITED STATES / JOINT STATEMENT OF UNDISPUTED FACTS The parties hereby stipulate and agree that the following facts are not in dispute and may be accepted as true: 1. Between about 2001 and 2006, defendant Jeffrey Epstein (a—bitlionaire—with-signifieant 49 enticed into prostitution minor girls at his mansion in West Palm Beach, Florida, and elsewhere. Among the girls he sexually-abused so enticed were Jane Doe #1 and Jane Doe #2. Because Epstein, through others, used a means of interstate commerce and knowingly traveled in interstate commerce to engage in this conduct, s), he committed violations of federal law, specifically repeated violations of 18 U.S.C. § 2422. 2. In 2006, at the request of the Palm Beach Police Department, the Federal Bureau of Investigation (“FBI”) opened an investigation into allegations that Jeffrey Epstein (“Epstein”) and his personal assistants had used facilities of interstate commerce to induce young girls between the ages of thirteen and seventeen to engage in prostitution, among other offenses. The case was presented to the United States Attorney’s Office for the Southern District of Florida, which accepted the case for investigation. The Palm Beach County State Attorney’s Office was EFTA00191264

--=PAGE_BREAK=--

also investigating the-ease Epstein. See Declaration of Bradley J. Edwards, Esq. at J 1-2 (hereinafter “Edwards Declaration”). 4, On about June 7, 2007, FBI agents hand-delivered to Jane Doe #1 a standard-CVRA-victim notification letter. See Edwards Declaration, Exhibit “A.” The notification promises that the Justice Department would makes its “best efforts” to protect Jane Doe #1’s rights, including “[t]he reasonable right to confer with the attorney for the United States in the case” and “to be reasonably heard at any public proceeding in the district court involving... plea... .” The notification further explained that “{a]t this time, your case is under investigation.” That notification meant that the FBI had identified Jane Doe #1 as a potential victim of a federal offense, and-assemeonre protected by the CVRA- 5. On about August 11, 2007, Jane Doe #2 received a standard CVRA victim notification letter. See Edwards Declaration, Exhibit “B.” The notification promised that the Justice Department would makes its “best efforts” to protect Jane Doe #2’s rights, including “[t]he reasonable right to confer with the attorney for the United States in the case” and “to be reasonably heard at any public proceeding in the district court involving ... plea... .” The notification further explained that “[a]t this time, your case is under investigation.” That notification meant that the FBI had identified Jane Doe #2 as a potential victim of a federal offense. and-as-someone-protected-by the CW RA, 6. Barlyin During the investigation, the FB] agents and the Assistant U.S. Attorney had-several meetings met with Jane Doe #1. Jane Doe #2 was represented by counsel that was paid for by EFTA00191265

--=PAGE_BREAK=--

the criminal target Epstein and, accordingly, all contact was made through that attorney. Jane Doe #2 was openly hostile to the investigation, and told investigators that she was not a victim of any offense, that Epstein was an “awesome man,” and that she would consider marrying Epstein. Jane Doe #2 actively avoided law enforcement’s attempts to secure her cooperation with the investigation and contacted other potential witnesses and victims to advise them against cooperating with the authorities. Edwards Declaration at 5. 7. In and around September 2007, plea discussions took place between Jeffrey Epstein, represented by numerous attorneys (including lead criminal defense counsel Jay Lefkowitz), and the U.S. Attorney’s office for the Southern District of Florida.[,] represented—primarityby ead These plea negotiations eventually resulted in Epstein pleading guilty to enty two state court felony offenses with a recommendation of 18 months’ imprisonment. and-weuld-serve-only-eounty Copies Parts of the correspondence are attached as Exhibit J to the Edwards Declaration accompanying this filing (hereinafter cited as “U.S. Attorney’s Correspondence” and referenced by Bates number stamp).' Because Epstein has moved to keep these documents from the public, they are at this time filed under seal with the Court. ;-e- Counsel for Jane Doe #1 and Jane Doe #2 received copies of half of the e- mail correspondence (the half reflecting Villafafia’s communications to defense counsel) via discovery requests served upon counsel for Epstein in connection with Jane Doe #1 and Jane Doe #2’s civil suits against Epstein on about June 30, 2010. See Edwards Declaration at 120-22. EFTA00191266

--=PAGE_BREAK=--

8. At the time of plea discussions, AUSA Villafana had drafted the-U.S-Attorney’s-Office-had an 82-page prosecution memorandum outlining numereus federal sexual offenses committed by Epstein, and had prepared drafted a 53-page indictment. fer-numerousfederat-offenses. U.S. Attorney’s Correspondence at 4. H, On about September 24, 2007, Assistant U.S. Attorney A. Marie Villafafia sent an e-mail to Jay Lefkowitz, criminal defense counsel for Epstein, regarding the agreement, a copy of which is attached hereto as Exhibit _. Due-te-the-eonfidentiality-elause inthe Agreement, EFTA00191267

--=PAGE_BREAK=--

42; On about September 25, 2007, AUSA Villafafia sent an e-mail to Lefkowitz, a copy of which is attached hereto as Exhibit _. aidan. 13. On about September 26, 2007, AUSA. Villafafia sent an e-mail to Lefkowitz, a copy of which is attached hereto as Exhibit __. in-whieh-she-stated:—“HiJay—Can-you give me-a-eall EFTA00191268

--=PAGE_BREAK=--

44. On about September 27, 2007, Assistant U.S. Attorney A. Marie Villafafia sent an e-mail to Lefkowitz regarding an attorney who was under discussion to be a representative of victims of Epstein civil litigation, a copy of which is attached hereto as Exhibit. revealed EFTA00191269

--=PAGE_BREAK=--

17. On about September 24, 2007, Epstein and the U.S. Attorney’s Office reached an agreement whereby the United States would defer federal prosecution in favor of prosecution by the State of Florida, Epstein and the U.S. Attorney’s Office accordingly entered into a “Non- Prosecution Agreement” (NPA) reflecting their agreement. Mest-signifieantly4 The NPA gave Epstein a promise that he would not be prosecuted for a series of federal felony offenses involving the enticement into prostitution of a large number of minor girls. invelving-his sexuat-abuse-of morethan30-minergirls; The NPA instead allowed Epstein to plead guilty to two state felony offenses for solicitation of prostitution and procurement of minors for EFTA00191270

--=PAGE_BREAK=--

prostitution. The NPA also set up a procedure whereby a victim of Epstein’s sexual abuse could obtain an attorney representative to proceed with a civil claim against Epstein, provided that the victim agreed to proceed exclusively under 18 U.S.C. § 2255 (+5 which provided that the-each victim would recover agreed-to-seek no mere less than $150,000 in damages against Epstein — an amount that Epstein argued later was limited to no more than $50,000). See Edwards Declaration, Exhibit “C” (copy of the non-prosecution agreement). The agreement was signed by Epstein and his legal counsel, as well as the U.S. Attorney’s Office, on about September 24, 2007, 18. A provision in the non-prosecution agreement made the agreement confidential seeret. In particular, the agreement stated: “The parties anticipate that this agreement will not be made part of any public record. If the United States receives a Freedom of Information Act request or any compulsory process commanding the disclosure of the agreement, it will provide notice to Epstein before making the disclosure.” By-entering-into-such-e-cenfidentiality-agreement the EFTA00191271

--=PAGE_BREAK=--

20. The Non-Prosecution Agreement that had been entered into between the U.S. Attorney’s Office and Epstein was subsequently modified by an October 2007 Addendum and a December 19, 2007, letter from the U.S, Attorney to Attorney Lilly Ann Sanchez. See Supplemental Declaration of A. Marie Villafafia, doc. #35, at 1; U.S. Attorney’s Correspondence at 234-37. On about August 14, 2008, Epstein’s defense counsel told the U.S. Attorney’s Office that they did not consider the December 19, 2007, letter to be operative. /d. 21. In October 2007, shortly after the initial plea agreement was signed, Jane Doe #1 was contacted to be advised regarding the resolution of the investigation. On October 26, 2007, Special Agents E. Nesbitt Kuyrkendall and Jason Richards met in person with Jane Doe #1. The Special Agents explained that Epstein would plead guilty to state charges, he would be required to register as a sex offender for life, and he had made certain concessions related to the payment of damages to the victims, including Jane Doe #1. During this meeting, the agents explained that this would end the federal investigation of the case and no federal charges would be filed. EFTA00191272

--=PAGE_BREAK=--

22. Jane Doe #1's perception of the explanation provided by the Special Agents was that only the State part of the Epstein investigation had been resolved, and that the federal investigation would continue, possibly leading to a federal prosecution. Edwards Declaration at | 8. 23. On about November 27, 2007, Assistant U.S. Attorney Jeff Sloman sent an e-mail to Jay Lefkowitz, defense counsel for Epstein, a copy of which is attached hereto as Exhibit. Fhe 24. On about November 29, 2007, Assistant U.S. Attorney A. Marie Villafafia sent a draft of a crime victim notification letter to Jay Lefkowitz, defense counsel for Jeffrey Epstein. The notification letter explained: “I am writing to inform you that the federal investigation of Jeffrey Epstein has been completed, and Mr. Epstein and the U.S. Attorney’s Office have reached an agreement containing the following terms... .” The letter then went on to explain that Epstein would plead guilty to two state offenses and receive an 18 month sentence. Fheetterdid-net EFTA00191273

--=PAGE_BREAK=--

Because Epstein’s attorneys sought higher review of the enforceability of the Non-Prosecution Agreement, the U.S. Attorney’s Office never sent the proposed victim notification letter discussed in the previous paragraph to the victims. Instead, a misleading letter stating that the case was “currently under investigation” (described below) was sent in January 2008 and May 2008. Atwe-+ime-befere 26. On about December 6, 2007, Jeffrey H. Sloman, First Assistant U.S. Attorney sent a letter to Jay Lefkowitz, , a copy of which is attached hereto as Exhibit. noting the-U.S—Attorneys EFTA00191274

--=PAGE_BREAK=--

28. On December 13, 2007, A. Marie Villafafia sent a-letter to Jay Lefkowitz, defense counsel for Epstein, , a copy of which is attached hereto as Exhibit __.rebutting-charges-that 30. Following the signing of the Agreement and the modifications thereto, Epstein’s performance was delayed while he sought higher level review within the Department of Justice. See U.S. Attorney’s Correspondence passim. EFTA00191275

--=PAGE_BREAK=--

31. On January 10, 2008, Jane Doe #1 and Jane Doe #2 received letters from the FBI advising them that “/t/his case is currently under investigation. This can be a lengthy process and we request you[r] continued patience while we conduct a thorough investigation.” See Doc. #14 (attachments 3 and 4 to declaration of A. Marie Villafafia) (emphasis added). Fhe-statement-in 33. On about February 25, 2008, Assistant U.S. Attorney Sloman sent an e-mail to Jay Lefkowitz, , a copy of which is attached hereto as Exhibit __.Bpstein*s-criminal defense EFTA00191276

--=PAGE_BREAK=--

34. — In about April 2008, Jane Doe #1 contacted the FBI because Epstein’s counsel was attempting to take her deposition and private investigators were harassing her. Assistant U.S. Attorney A. Marie Villafafia secured pro bono counsel to represent Jane Doe #1. Pro bono counsel was able to assist Jane Doe #1 in avoiding the improper deposition. AUSA Villafafia secured pro bono counsel by contacting Meg Garvin, Esq. of the the National Crime Victims’ Law Center in Portland, Oregon, which is based in the Lewis & Clark College of Law. During the call, Ms. Garvin was not advised that a non-prosecution agreement had been reached. 35. On May 30, 2008, another of Mr. Edwards’s clients who was recognized as an a potential victim of Epstein ¥ietim by the U.S, Attorney’s Office, received a letter from the FBI advising her that “/t/his case is currently under investigation. This can be a lengthy process and we request your continued patience while we conduct a thorough investigation.” ‘Fhe-statement 36. In mid-June 2008, Mr. Edwards contacted AUSA Villafafia to inform her that he represented Jane Doe #1 and, later, Jane Doe #2, Mr. Edwards asked to meet to provide information about the federal crimes committed by Epstein, hoping to secure a significant federal indictment against Epstein. AUSA Villafafia and Mr. Edwards discussed the possibility of federal charges being filed. At the end of the call, AUSA Villafafia asked Mr. Edwards to send any information that he wanted considered by the U.S. Attorney’s Office in determining whether to file federal charges. EFTA00191277

--=PAGE_BREAK=--

37. On Friday, June 27, 2008, at approximately 4:15 p.m., AUSA Villafaiia received a copy of Epstein’s proposed state plea agreement and learned that the plea was scheduled for 8:30 a.m., Monday, June 30, 2008. AUSA Villafafia and the Palm Beach Police Department attempted to provide notification to victims in the short time that Epstein’s counsel had provided. Attorney Edwards was called to provide notice to his clients regarding the hearing. AUSA-ViHafaiie-did 4. AUSA Villafaiia strongly encouraged Attorney Edwards and his client to attend and address the Court at sentencing if they so desired. 38. On June 30, 2008, AUSA Villafafia sent an e-mail to Jack Goldberger, criminal defense counsel for Epstein, a copy of which is attached hereto as Exhibit _.that-stated-Jack—The 39. On July 3, 2008, Mr. Edwards sent to AUSA Villafafia a letter. See Affidavit of Bradley J. Edwards, Esq., at 15 (attachment 2). In the letter, Mr. Edwards indicated his client’s desire that federal charges be filed against defendant Epstein. In particular, he wrote on behalf of his clients: “We urge the Attorney General and our United States Attorney to consider the fundamental import of the vigorous enforcement of our Federal laws. We urge you to move forward with the traditional indictments and criminal prosecution commensurate with the crimes EFTA00191278

--=PAGE_BREAK=--

Mr. Epstein has committed, and we further urge you to take the steps necessary to protect our children from this very dangerous sexual predator.” When Mr, Edwards wrote this letter, he was still unaware that a non-prosecution agreement had been reached with Epstein[.] — afaetthat Edwards first saw a reference to the NPA on or after July 9, 2008, when the Government filed its responsive pleading to Jane Doe’s emergency petition. hat-pleading—was—thefirst_publie Edwards Declaration at J 15. 40. On July 9, 2008, AUSA Villafafia sent a victim notification to Jane Doe #1 via her attorney, Bradley Edwards. Edwards Declaration, Exhibit “H.” That notification contains a written explanation of some of the terms of the agreement between Epstein and the U.S. Attorney’s Office. A full copy of the terms was not provided. A notification was not provided to Jane Doe #2 because the agreement limited Epstein’s liability to victims whom the United States was prepared to name in an indictment. As a result, Jane Doe #2 never received a notification a letter about the agreement. agreementwiththe-L_S.Attorney’s Offiee— Edwards Declaration at J 16. 41. On July 9, 2008, AUSA Villafafia filed a sworn declaration with the Court in connection with the case (doc, #14). The declaration purported to recount limit parts of the non-prosecution agreement and stated that “these provisions were discussed” with several victims, including Jane Doe #1. /d. at 4. 42. On July 11, 2008, the Court held a hearing on Jane Doe #1 and Jane Doe #2’s Emergency Petition for Enforcement of Rights. During the hearing, the Government conceded that Jane Doe EFTA00191279

--=PAGE_BREAK=--

#1 and Jane Doe #2 were “victims” within the meaning of the Crime Victim’s Rights Act. Tr. at 14-15. EFTA00191280

--=PAGE_BREAK=--

EFTA00191281

--=PAGE_BREAK=--

49. On April 9, 2009, counsel for Jane Doe #1 and Jane Doe #2 sent to the Court in this case (via the PACER system) a notice of a change of law firm affiliation. Doc. #37. 50. EFTA00191282

--=PAGE_BREAK=--

EFTA00191283

--=PAGE_BREAK=--

SO AGREED AND STIPULATED TO, THIS DAY OF DECEMBER, 2010. By: BRADLEY J. EDWARDS COUNSEL FOR PLAINTIFFS WIFREDO A, FERRER UNITED STATES ATTORNEY DEXTER LEE ASSISTANT U.S. ATTORNEY EFTA00191284

--=PAGE_BREAK=--

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 08-80736-Civ-Marra/Johnson JANE DOES #1 and #2 UNITED STATES STIPULATION The parties to this action, that is, Jane Doe #1, Jane Doe #2, and the United States of America, by and through their undersigned counsel, do hereby stipulate and agree that the following facts are true and correct and that no further evidentiary hearing is required with respect to the pending “Victim's Emergency Petition for Enforcement of Crime Victim Right Act, 18 U.S.C. § 3771. 1. In 2006, at the request of the Palm Beach Police Department, the Federal Bureau of Investigation (“FBI”) opened an investigation into allegations that Jeffrey Epstein (“Epstein”) and his personal assistants had used facilities of interstate commerce to induce young girls between the ages of thirteen and seventeen to engage in prostitution, amongst other offenses. The case was presented to the United States Attorney’s Office for the Southern District of Florida, which accepted the case for investigation. 2. At the time that the investigation was opened, the Palm Beach County State Attorney's Office had presented evidence to a state grand jury, which had returned an EFTA00191285

--=PAGE_BREAK=--

indictment charging solicitation of prostitution. That charge made no reference to the ages of the minor victims and, upon conviction, did not require sex offender registration. 3. Jane Doe #1 is a woman with initials C.W., and Jane Doe #2 is a woman with initials T.M. Both were victims of Epstein’s while they were minors beginning when they were fifteen years old. Both Jane Does were identified through the Palm Beach Police Department's investigation of Epstein. 4. Attached as Exhibits 1, 2, 3, and 4 to the Declaration of A. Marie Villafaiia are true and correct copies of victim notification letters sent to Jane Does | and 2 from the United States Attorney's Office and the FBI. 5. Throughout the investigation, the FBI agents and the Assistant U.S. Attorney had several meetings with Jane Doe #1. During those meetings, Jane Doe #1 never expressed a desire to be consulted prior to the resolution of the investigation. Jane Doe #2 was represented by counsel and, accordingly, all contact was made through that attorney. That attorney never expressed that Jane Doe #2 wanted to be consulted prior to the resolution of the investigation. 6. In September 2007, Epstein and the U.S. Attorney’s Office reached an agreement whereby the United States would defer federal prosecution in favor of prosecution by the State of Florida, so long as certain basic preconditions were met, those included a conviction on a state sex offense that reflected that the victims were minors at the time the crimes occurred and that would require sex offender registration. Another key objective for the United States Attorney's Office was to preserve a federal remedy for 7 EFTA00191286

--=PAGE_BREAK=--

the young girls whom Epstein had sexually exploited. The Agreement contained an express confidentiality provision. The Agreement was subsequently modified in October and December 2007. 7. Although individual victims were not consulted regarding the agreement, several had expressed concerns regarding the exposure of their identities at trial and they desired a prompt resolution of the matter. At the time the agreement and the modifications were signed in September, October, and December 2007, Jane Doe #2 was openly hostile to the prosecution of Epstein. 8. In October 2007, shortly after the initial agreement was signed, Jane Doe #1 was contacted to be advised regarding the resolution of the investigation. On October _, 2007, Special Agents E. Nesbitt Kuyrkendall and Jason Richards met in person with Jane Doe #1. The Special Agents explained that the investigation had been resolved, that Epstein would plead guilty to two state offenses, he would be required to register as a sex offender for life, and he had made certain concessions related to the payment of damages to the victims, including Jane Doe #1. Jane Doe #1 also was advised that Epstein would be entering a guilty plea in state court on October __, 2007, although the October change of plea did not take place. During this meeting, Jane Doe #1 did not raise any objections to the resolution of the matter. 9. Jane Doe #1 misunderstood the explanation provided by the Special Agents, believing that only the State part of the Epstein investigation had been resolved, and that the federal investigation would continue, possibly leading to a federal prosecution. ~3~ EFTA00191287

--=PAGE_BREAK=--

10. When Epstein's attorneys learned that some of the victims had been notified, they complained that the victims were receiving an incentive to overstate their involvement with Epstein in order to increase their damages claims. Following the signing of the Agreement and the modifications thereto, Epstein’s performance was delayed while he sought to rescind the Agreement. Throughout that period, the FBI and the U.S. Attorney’s Office maintained contact with the victims, to be prepared if Epstein were to renege on the agreement. 11. After Jane Doe #1 had been notified of the terms of the agreement, but before Epstein performed his obligations, Jane Doe #1 contacted the FBI because Epstein's counsel was attempting to take her deposition and private investigators were harassing her. Assistant U.S. Attorney A. Marie Villafafia secured pro bono counsel to represent Jane Doe #1 and several other identified victims in connection with the criminal investigation. Pro bono counsel was able to assist Jane Doe #1 in avoiding the improper deposition. 12. In mid-June 2008, Attorney Edwards contacted AUSA Villafafia to inform her that he represented Jane Doe #1 and, later, Jane Doe #2. Attorney Edwards asked to meet to provide information regarding Epstein. Attorney Edwards was asked to send any information that he wanted considered, but did not send anything. 13. On Friday, June 27, 2008, at approximately 4:15 p.m., AUSA Villafafia received a copy of Epstein's proposed state plea agreement and learned that the plea was scheduled for 8:30 a.m., Monday, June 30, 2008. AUSA Villafafia and the Palm Beach Police Department attempted to provide notification to victims in the short time that ~4e EFTA00191288

--=PAGE_BREAK=--

Epstein’s counsel had provided. Attorney Edwards was called to provide notice to his clients regarding the hearing. 14. On July 9, 2008, AUSA Villafafia sent a victim notification to Jane Doe #1 via her attorney, Bradley Edwards, which is attached as Exhibit 6 to the Villafafia Declaration. That notification contains a written explanation of the full terms of the agreement between Epstein and the U.S. Attorney’s Office. A notification was not provided to Jane Doe #2 because the agreement limited Epstein’s liability to victims whom the United States was prepared to name in an indictment. SO STIPULATED AND AGREED. Dated: BRADLEY EDWARDS, ESQ. Attorney for Plaintiffs Jane Does #1 & 2 R. ALEXANDER ACOSTA UNITED STATES ATTORNEY Dated: By: ASSISTANT US. ATTORNEY DEXTER LEE Attorney for Defendant United States EFTA00191289

--=PAGE_BREAK=--

Case 9:08-cv-80736-KAM Document 247 Entered on FLSD Docket 05/02/2014 Page 1 of 13 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 08-80736-CIV-MARRA/JOHNSON JANE DOE #1 and JANE DOE #2, Plaintiffs, UNITED STATES OF AMERICA, Defendant, ROY BLACK, et al., Intervenors. / INTERVENORS’ MOTION FOR A PROTECTIVE CONFIDENTIALITY ORDER AND INCORPORATED MEMORANDUM OF LAW Intervenors Roy Black, Martin Weinberg, and Jeffrey Epstein, pursuant to Rule 26(c) of the Federal Rules of Civil Procedure and Local Rule 26.1, respectfully move this Court for the entry a Protective Confidentially Order which (1) limits the dissemination of certain Confidential Discovery Material (“CDM”) described below, to a designated list of the Plaintiffs’ counsel and support staff, and (2) prohibits any party from filing pleadings, briefs, memorandums or exhibits purporting to reproduce, quote, paraphrase or summarize any CDM or portions thereof, absent leave of the Court to file the document or portion thereof under seal in accordance with Local Rules of the United States District Court for the Southern District of Florida, See Exhibit 1, Proposed Protective Confidentiality Order. EFTA00191290

--=PAGE_BREAK=--

Case 9:08-cv-80736-KAM Document 247 Entered on FLSD Docket 05/02/2014 Page 2 of 13 In support of this motion, the Intervenors submit the following Memorandum. Part I sets forth the background of this matter, Part I] demonstrates why the Court can and should issue the requested protective order. MEMORANDUM I. BACKGROUND Intervenor Jeffrey Epstein entered into a Non-Prosecution Agreement (“NPA”) with the government in September, 2007. Under that agreement, Mr. Epstein pled guilty to two state felony offenses and served a prison sentence and a term of community control probation. The agreement, with which he has fully complied, also required that he pay the legal fees of the attorney-representative of identified victims and that he not contest liability in any cases brought against him solely under 18 U.S.C. § 2255. Plaintiffs sued under § 2255 and received settlements as the direct result of Mr. Epstein’s agreement not to contest liability in those cases. Plaintiffs, such as the Jane Does in this case, “relied on the [NPA] when seeking civil relief against Epstein . . . and affirmatively advanced the terms of the [NPA] as a basis for relief from Epstein.” United States’ Reply in Support of its Motion to Dismiss for Lack of Subject Matter Jurisdiction, Doc. 205-6 at 12-13. After reaping the benefits of the NPA, the plaintiffs seek herein, among other remedies, the rescission of that agreement. During the course of civil litigation against Mr. Epstein, Mr. Epstein was ordered, over his strenuous objection, to produce documents given to him by the government during the course of his settlement/plea negotiations with it. See “2 EFTA00191291

--=PAGE_BREAK=--

Case 9:08-cv-80736-KAM Document 247 Entered on FLSD Docket 05/02/2014 Page 3 of 13 Jane Doe #2 I Epstein, No. 08-80119-MARRA, Doc, 462. Once the CVRA action was reactivated — after plaintiffs had successfully pursued their civil monetary remedies against Mr. Epstein to completion — plaintiffs sought to use that correspondence in the CVRA case and thereafter also sought disclosure from the government of correspondence authored and sent to the government by Mr. Epstein’s attorneys in the course of their efforts on behalf of their client to resolve the ongoing criminal investigation of him. Both Mr. Epstein and his criminal defense attorneys — Intervenors Roy Black and Martin Weinberg — filed motions to intervene for the limited purpose of challenging the use and disclosure of the settlement/plea negotiation correspondence (Doc. 56, 93), followed by supplemental briefing and motions contending, among other things, that the correspondence fell within the bounds of privilege under Fed. R. Evid. 501. Doc. 94, 160,161, 162. This Court granted the motions to intervene (Doc. 158, 159), but ultimately ruled that the correspondence — the CDM at issue in the instant motion — was subject to disclosure. Doc. 188. Among other things, the Court rejected Intervenors’ argument based on Rule 501 on the ground that Congress has already addressed the issue in Fed. R. Crim. P. 11(f) and Fed. R. Evid. 410 and likewise rejected the Intervenors’ request that the Court recognize a privilege for plea negotiation communications. Id. at 8-9. The Intervenors appealed the Court’s ruling to the Eleventh Circuit. However, on April 14, 2014, the Eleventh Circuit affirmed the Court’s rulings using the same rationales. 3. EFTA00191292

--=PAGE_BREAK=--

Case 9:08-cv-80736-KAM Document 247 Entered on FLSD Docket 05/02/2014 Page 4 of 13 Il. ARGUMENT Although the Court ruled that the Plaintiffs could discover the CDM, the Court reserved ruling on how the Plaintiffs could use the material thereafter, expressly cautioning that “this order is not intended to operate as a ruling on the relevance or admissibility of any particular piece of correspondence, a matter expressly reserved for determination at the time of final disposition.” Doc 188, p. 10. Unless and until the Court determines those reserved issues, the Court should bar the Plaintiffs from disseminating and/or publicly disclosing the substance of the CDM absent further order of the Court. A. Discovery Should Not Be Routinely Made Available to the Public “The Eleventh Circuit has repeatedly acknowledged the private nature of discovery” Looney I Moore, No. 2:13-CV-00733-KOB (N.D. Ala. April 7, 2014), 20/4 U.S. Dist. LEXIS 48349, at *3, citing Chicago Tribune Co, l Bridgestone/Firestone, Inc., 263 F.3d 1304, 1316 (11" Cir. 2001) (“Discovery, whether civil or criminal, is essentially a private process because the litigants and the courts assume that the sole purpose of discovery is to assist trial preparation.”) (quoting United States I Anderson, 799 F.2d 1438, 1441 (11" Cir. 1986; emphasis in original). See also Anderson, 799 F.2d at 1441 (“Historically, discovery materials were not available to the public or press.”) (citation omitted); Jn re: Denture Cream Products Liability Litigation, No, 09-2051-MD-Altonaga/Simonton (S.D. Fla. Jan. 18, 2013), 2013 U.S. Dist. LEXIS 8114, at *37 (“the common law right of access to judicial proceedings does not apply to discovery materials, ‘as these materials are neither public -4- EFTA00191293

--=PAGE_BREAK=--

Case 9:08-cv-80736-KAM Document 247 Entered on FLSD Docket 05/02/2014 Page 5 of 13 documents nor judicial records’”) (quoting Chicago Tribune, 263 F.3d at 1311; citation omitted), Thus, “[a] court may restrict distribution of discovery material even if there ‘certainly is a public interest in knowing more’ about its contents.” Tillman I C.R. Bard, Inc,, Case No. 3:13-cv-222-J-34JBT (M.D. Fla. March 13, 2014), 20/4 U.S. Dist. LEXIS 41406, at *6, quoting Seattle Times Co. l Rhinehart, 467 U.S. 20, 31 (1984) Placing limitations on the dissemination and use of pretrial discovery is particularly important since “[t]he overwhelming majority of documents disclosed during discovery are likely irrelevant to the underlying issues...” Federal Trade Commission l Abbvie Products LLC, 713 F.3d 54, 63 (11" Cir, 2013). Therefore, “[s]uch documents, prior to admission into the record in support of a motion or as evidence at trial, ‘play no role in the performance of Article III functions’ of a federal judge.” Travelers Indemnity Co. I Excalibur Reinsurance Corp., No. 3:11-CV-1209 (CSH) (D. Conn. Aug. 5, 2013), 20/3 U.S. Dist. LEXIS 110400, at *37, quoting United States | Amodeo, 71 F.3d 1044, 1050 (2d Cir. 1995). These principles are vitally important here where counsels’ private communications with prosecutors “if publicly released could be damaging to reputation and privacy” and would likely constitute an “abuse of [a court’s] processes.” Seattle Times, 467 U.S. at 35 While courts have recognized that settlement agreement materials may sometimes be discoverable, see, e.g., In re MSTG, Inc., 675 F.3d 1337, 1348 (Fed. Cir. 2012), they are ' But see Wagner | Wastiffs, Case No. 2:08-cv-431 (S.D. Ohio May 14, 2013), 20/3 U.S. Dist. LEXIS 68349 (denying motion to compel discovery of settlement agreement on relevancy grounds); Duncan] Phoenix Supported Living, Inc., No. 2:05ev1 (W.D. N.C. Sept. 12, 2006), 2006 U.S. Dist. (continued...) -5- EFTA00191294

--=PAGE_BREAK=--

Case 9:08-cv-80736-KAM Document 247 Entered on FLSD Docket 05/02/2014 Page 6 of 13 rarely admissible as evidence at trial, see, e.g, LaserDynamics, Inc. I Quanta Computer, Inc,, 694 F.3d 51, 78 (Fed. Cir. 2012) (reversing district court for admitting settlement agreement at trial); Apple, Inc. l Samsung Electronics Co., Ltd., Case No. 11-CV-01846- LHK (N.D. Cal. Nov. 7, 2013), 20/3 U.S. Dist. LEXIS 160337, at **51-54 (barring parties from relying on settlement agreement at trial under Fed. R. Evid. 403). For this reasons alone, it is appropriate to limit the dissemination and use of discovery concerning settlement discussions, even if not privileged. See Charles E. Hill & Associates, Inc. l ABT Electronics, Inc., 854 F. Supp. 2d 427, 430 (E.D. Tex. 2012) (designating discovery material including settlement communications as “Outside Counsel Eyes Only Confidential Information” and cautioning parties that while it is allowing the discovery it intends to later weigh relevance carefully and noting that settlement negotiations are “always suspect to some degree and are often littered with unreal assertions and unfounded expectations ... And are not always grounded in facts or reason.”). Indeed, unless and until the Plaintiffs demonstrate a bona fide need to use the discovery at trial or in pleadings, the Intervenors need not even demonstrate “good cause” in order to obtain relief. As the Hon. Karon Owen Bowdre, Chief Judge of the U.S. District Court for the Northern District of Alabama recently held: ‘(...continued) LEXIS 66742, at **9-11 (finding settlement communications non-discoverable as “not .. Likely to lead to the disclosure of admissible evidence” and would tend to chill settlement efforts) (citations omitted), -6- EFTA00191295

--=PAGE_BREAK=--

Case 9:08-cv-80736-KAM Document 247 Entered on FLSD Docket 05/02/2014 Page 7 of 13 Based on this standard of practice, the court finds that restricting the use of discovery materials to case-related purposes only, even over Plaintiffs’ objection, is within this court’s discretion and authority even without the application of the Rule 26(c) good cause standard. By its text, Rule 26(c) applies to situations where the court is either limiting what a party has to produce at all in the discovery process, or limiting public access to documents that are actually filed in the case. Fed. R. Civ. Pro. 26(c). The disputed limitation in this case does not fall into either of these categories.... Looney I Moore, No, 2:13-CV-00733-KOB (N.D. Ala. April 7, 2014), 20/4 U.S. Dist. LEXIS 48349, at ** 4-5 (emphasis in original). B. Good Cause Exists For the Protective Order In Any Event Even if the Intervenors would be required to demonstrate “good cause” for the requested protective order at this point, that standard is met where restrictions are appropriate under Rule 26(c) to protect the Intervenors from “annoyance, embarrassment, oppression, or undue burden or expense.” See Looney, 2014 U.S. Dist, LEXIS 48349, at *5; Irizarry- Santiago I Essilor Industries, 293 F.R.D. 100, 104 (D. P.R. 2013). The Intervenors include not only the third-party client whose non-prosecution agreement is the one Plaintiffs are trying to undo but also the client’s attorneys, who are even further removed from the actual litigants. Counsels’ lengthy arguments may or may not have had any influence on the government's decision-making and, therefore, their relevance is particularly remote. Cf United States | Byrd, Crim. No. 13-0266-WS (S.D. Ala. April 7, 2014), 20/4 U.S. Dist. LEXIS 48035, at **14-18 (denying newspaper’s motion to obtain copies of unsolicited sentencing letters mailed to the judge prior to sentencing, despite “no formal promises of -7- EFTA00191296

--=PAGE_BREAK=--

Case 9:08-cv-80736-KAM Document 247 Entered on FLSD Docket 05/02/2014 Page 8 of 13 secrecy or confidentiality,” because “the privacy interests of the letter writers and the interests of the judicial system in obtaining hones, uncensored input” outweighed public's interest in disclosure, especially where the sentencing letters “neither drove no significantly impacted the sentencing decision” which was based on a plea agreement). Like the situation at issue in Looney, the instant case is a “high profile” one and should not be “tried in the media, rather [than] in the courtroom.” Looney, 20/4 U.S. Dist. LEXIS 48349, at *5. Moreover, there is a well documented history in this case of the media reporting inflammatory statements made by Plaintiffs’ counsel, either directly to the press or in pleadings, and these statements have frequently been based on discovery materials. See, e.g., Attorneys Say Miami Prosecutors Violated Crime Victims’ Rights Act, Main Justice, March 22, 2011 (quoting Plaintiffs’ motion asserting that the U.S. Attorney’s Office “deliberately misled’ them and claiming that the “only reason” the U.S. Attorney’s Office “concealed the existence of the non-prosecution agreement from them was “to avoid a firestorm of public controversy that would have erupted if the sweetheart plea dal with a politically connected billionaire had been revealed”); Attorneys want Jeffrey Epstein agreement thrown out, PalmBeachDailyNews.com, March 21, 2011 (repeating aforementioned accusations from Plaintiffs’ motion attacking the U.S. Attorney’s Office, adding that the Office had allegedly engaged in a “pattern of deception” and noting that Plaintiffs’ motion had made references to “e-mails and letters from the federal office to Epstein’s lawyers”); News Reports about Billionaire Pedophile Jeffrey Epstein Highlight the EFTA00191297

--=PAGE_BREAK=--

Case 9:08-cv-80736-KAM Document 247 Entered on FLSD Docket 05/02/2014 Page 9 of 13 Importance of Victims Rights, Briefing Wire.com, March 8, 2011 (quoting Plaintiffs’ counsel saying “we took on powerful people and sought to level the playing field to protect victims” and that he “hopes that the media attention” will “inspire victims” to “hold predators accountable”); Judge Receives Epstein Tape Ruling Pending, Palm Beach Daily News, May 5, 2010 (quoting plaintiffs’ counsel as arguing that a 22-minute tape recording of Mr. Epstein was “‘critical’” in showing his alleged “lack of remorse” and that he was a “pitiless” sexual abuser); Lawyer: Epstein Made Admissions On Tape, Palm Beach Daily News (FL), April 29, 2010 (quoting Plaintiffs’ motion concerning the same tape recording); Attorney For Epstein Victims: ‘I have Never Seen A Stranger Case’, Palm Beach Daily News, September 20, 2009, p. A.1 (quoting Plaintiffs’ counsel as opining that Mr. Epstein “could have gone to prison for life,” that he had “never seen a stranger case” and that the U.S. Attorney’s Office was effectively “saying we'll do everything in our power to see he doesn’t get punished”); Palm Beach sex offender's secret plea deal: Possible co-conspirators not charged, presses victims to settle civil suits, The Palm Beach Post, September 18, 2009 (quoting Plaintiffs’ counsel as saying that non-prosecution agreement “taught [the victims] that someone with money can buy his way out of anything. It’s outrageous and embarrassing....”); Judge to Rule on Sealed Plea-Deal Papers Today, Palm Beach Daily News, June 25, 2009, p. A.1 (reporting Plaintiffs’ counsel saying that he wanted to use the settlement documents in depositions); Hearing Set to Consider Secrecy of Plea Bargain, Sun-Sentinel (Ft. Lauderdale, Florida), Palm Beach Edition, June 15, 2009, p. 3B (in -9. EFTA00191298

--=PAGE_BREAK=--

Case 9:08-cv-80736-KAM Document 247 Entered on FLSD Docket 05/02/2014 Page 10 of 13 response to reporter’s question about whether he thought Mr. Epstein had received special treatment, Plaintiffs’ counsel quoted as saying: “Are you kidding? It’s transparent. Certainly, no one else gets treated like that”). See Composite Exhibit 2. The publicity-generating comments by Plaintiffs’ counsel have continued since the Eleventh Circuit’s ruling. The wave began on April 21, 2014. That day, the Washington Post published a lengthy letter written by one of Plaintiffs’ lead counsel containing his editorialized history of the case criticizing the Intervenors’ arguments and concluding with his opinion that “the federal prosecutors deliberately concealed the sweetheart plea deal.” See Composite Exhibit 3, The same attorney was also quoted by the Sun-Sentinel as making the unsupported accusation that somehow Mr. Epstein “used his political connections and great wealth” to secure a plea bargain that, in counsel’s opinion “was unheard of, frankly, if you look at these charges.” /d. Also that same day, the Plaintiffs’ other lead counsel was quoted by the Palm Beach Daily News as referring to Mr. Epstein as “[a] well-connected billionaire” who “got away with molesting many girls.” Appeals court rules against sex offender; Attorneys for underage victims seek to overturn ‘sweetheart plea’, PalmBeachDailyNews.com, April 21, 2014. Jd. On April 22, 2014, the same attorney issued a “press release” likewise trumpeting the appellate victory, identifying Mr. Epstein’s counsel by name and containing a personal statement from counsel. See Composite Exhibit 4. In a parallel article published in the Daily Business Review, Plaintiffs’ counsel was quoted as follows: “Edwards said the -10- EFTA00191299

--=PAGE_BREAK=--

Case 9:08-cv-80736-KAM Document 247 Entered on FLSD Docket 05/02/2014 Page 11 of 13 documents at this point will be disclosed only to the plaintiffs and will not become part of the public record.” /d. (emphasis added). The implication of the “at his point” qualifier suggests that Plaintiffs’ counsel plan to inject the private discovery into “the public record” at a later date. The next day, April 23, 2014, the Facebook page for the Farmer Jaffe Weissing law firm began posting multiple photographs of Mr. Epstein with links to numerous newspaper articles about the case, along with snippets of prejudicial quotations from Plaintiffs’ counsel. See Composite Exhibit 5. The same comments were then posted on the law firm’s blog “www. pathtojustice.com with yet another large photograph of Mr. Epstein, resembling a mug shot, /d. The blog includes such personalized opinions, such as: “We have a very strong case that, prodded by Epstein, the federal prosecutors deliberately concealed the sweetheart plea deal.” Jd. In light of the prominence of this case in the media, the repeated use of the media by Plaintiffs counsel to drum up support for their case (and to prejudice the community against Mr. Epstein and his counsel), and the Plaintiffs’ suggestion that they could make the CDM available to the public in the future (just not “at this point”), the requested protective order is more than justified. As Chief Judge Bowdre likewise concluded in a similar, but less egregious, situation: The court has already expressed to the parties its concern that this potentially high profile case will be tried in the media, rather in the courtroom. Significant media coverage of the case has already occurred. In the interest of justice, this court is EFTA00191300

--=PAGE_BREAK=--

Case 9:08-cv-80736-KAM Document 247 Entered on FLSD Docket 05/02/2014 Page 12 of 13 committed to giving both parties a fair trial, which includes protecting the Defendants from the “annoyance, embarrassment, {and] oppression” that could occur from allowing their names to be dragged through the metaphorical mud before a jury has even made any determination of wrongdoing. At least one other court has cited the risk of excessive publicity preventing the selection of an impartial jury as legitimate support for a finding of good cause under Rule 26(c). See Anderson I Cryovac, Inc., 805 F.2d 1, 4 (Ist Cir. 1986) (overturning the district court’s decision on other grounds), As such, the court finds that good cause exists to support the Protective Order as written.... Looney I Moore, 2014 U.S. Dist. LEXIS 48349, at **5-6. LOCAL RULE 7.1(a)(3) CERTIFICATION Counsel hereby certify that they have conferred with all parties who may be affected by the relief sought in this motion in a good faith effort to resolve the issues raised in the motion and have been unable to do so, Plaintiffs oppose this motion. CONCLUSION For all of the foregoing reasons, the Court should GRANT this motion and enter the requested Protective Order. Respectfully submitted, /s/Roy Black Roy Black Jackie Perezek BLACK, SREBNICK, KORNSPAN & STUMPF, P.A. 201 So. Biscayne Blvd., Suite 1300 Miami, Florida 33131 Tele: (305) 371-6421 -12- EFTA00191301

--=PAGE_BREAK=--

Case 9:08-cv-80736-KAM Document 247 Entered on FLSD Docket 05/02/2014 Page 13 of 13 Fax: (305) 358-2006 rblack@royblack.com jperczek@royblack.com Attorneys for Intervenors /s/Martin G. Weinberg Martin G. Weinberg 20 Park Plaza, Suite 1000 Boston, Massachusetts 02116 Tele: (617) 227-3700 Fax: (617) 338-9538 owlmgw@att.net Attorney for Intervenors CERTIFICATE OF SERVICE IHERE CERTIFY thata true copy of the foregoing was filed via CM/ECF, this 2"? day of May, 2014. /s/Roy Black Roy Black -13- EFTA00191302

--=PAGE_BREAK=--

Case 9:08-cv-80736-KAM Document 247-4 Entered on FLSD Docket 05/02/2014 Page 1 of 6 COMPOSITE EXHIBIT 4 EFTA00191303

--=PAGE_BREAK=--

s2m@ase 9:08-cV-807 BGs Ad Mu DcUtae Nec? Hh Bubnalferste Meehan rb BD Geld POGAOMROAeHewPage 2 of 6 a NOT FOR REPRINT © DAILY BUSINESS REVIEW ©) Click to Print or Select 'Print' in your browser menu to print this document. Page printed from: Dai/y Business Review Prosecutors Must Turn Over Docs In Billionaire Sex Offender Jeffrey Epstein Case John Pacenti, Daily Business Review April 22, 2014 Roy Black Partner Black, Srebnick, Kornspan & Stumpf Attomeys for two alleged sexual assault victims trying to negate a federal nonprosecution agreement with billionaire pedophile Jeffrey Epstein applauded a decision by a federal appellate court as a triumph for victims' rights. But Epstein's celebrity defense attorney Roy Black said the decision by the U.S. Courts of Appeals for the Eleventh Circuit in Atlanta undercuts the plea negotiation process and attorney-client privilege. The U.S. Court of Appeals for the Eleventh Circuit affirmed an order requiring prosecutors to turn over documents about plea discussions with Epstein. The decision also lifted an appellate stay on the ruling by U.S. District Judge Kenneth Marra in West Palm Beach to allow the release of documents to the women, identified in court papers only as Jane Doe No. 1 and Jane Doe No. 2. The women say they were sexually molested as minors by Epstein and claim federal prosecutors violated the Crime Victims' Rights Act when they negotiated the nonprosecution agreement in 2007. Both sides agreed the opinion sets a precedent unrivaled in other federal circuits. "So much of the legal area of victims’ rights is breaking new ground and new territory," said Jay Howell, a Jacksonville appellate lawyer who represented the women. "The court decision here expands the rights of the victims and the victims' ability to discover information about the criminal case." hitp ‘Awaw. dail yousinessrevew.com/cs/Satellite?c=Article_C&childpag erame=DBR %2F Article_C%2F Article 2F Layouts %2F Printer F riendly8pag ename=ALM w3 EFTA00191304

--=PAGE_BREAK=--

s2ma€ase 9:08-CV-80 7B BKM UDDOLATEP RED Fullpals Hee Pines Hetty SPD BER EP OPEL YEO IM™ Page 3 of 6 He said the women have stuck with the case out of "a fundamental sense of injustice" for the underage victims of Epstein. Black, a partner at Black, Srebnick, Kornspan & Stumpf in Miami, said the 23-page opinion issued Friday has wider implications in plea bargains. No longer can defense attorneys be candid with prosecutors when trying to negotiate a plea, he said. "This is now the leading precedent holding that plea bargain discussions are not confidential, and now criminal defense lawyers must censor their communications with prosecutors," Black said. "The Eleventh Circuit has ruled there is no privilege, there is no confidentiality.” Miami attorney Joseph DeMaria, a partner at Fox Rothschild and former federal prosecutor, said while the opinion is legally correct, it could have a significant impact on the 90 percent of federal cases resolved by pleas. He said it now is up to Congress to amend the Crime Victims' Rights Act to carve out a safeguard for defendants. He foresees “a chilling effect on plea negotiations where victims are aggressively seeking information." "if these type of plea discussions are now discoverable by victims, then it's going to cause significant problems for the government and defendants in trying to resolve criminal cases," DeMaria said. Epstein was accused of luring underage women to his Palm Beach mansion for sex. The television show "Law & Order SVU" had a "ripped from the headlines” episode based on Epstein, who is also known for his celebrity connections Flight logs show former President Bill Clinton flew on Epstein's private plane 10 times from 2002 to 2005. Plea bargain The appellate case stems from a decision by federal prosecutors not to charge Epstein if he pleaded guilty to state charges in Palm Beach Circuit Court for soliciting an underage girl for prostitution. He was sentenced to 18 months in jail and house arrest. Epstein moved back to New York City from Palm Beach after he finished his sentence. The women contend they could have argued against the nonprosecution agreement if they were informed before the agreement was reached. "Our clients want to see Mr. Epstein held accountable for the numerous sex offenses he committed against many children," said Bradley Edwards, the women's trial counsel and a partner at Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman in Fort Lauderdale. Edwards said the documents at this point will be disclosed only to the plaintiffs and will not become part of the public record. Andrew Levi, a partner at Lehr Levi & Mendez in Miami and former federal prosecutor, said once documents are in the hands of civil attorneys they can easily be passed on to news media or put in other court records. hitp:/Mww.dallybusinessrevew.convcs/Salellite?c= Article_C: &childpag ename=DBR %2F Article_C%2F Article%2F Layouts %2F Printer riendlySpag ename=ALM 23 EFTA00191305

--=PAGE_BREAK=--

S220'Case 9:08-CV-BO7 ISK MD Bourne Ae? M Pulbrae Fre PAE SOD Gated POSPEXEOte"Page 4 of 6 "It's not as if they are given to the attorney with any type of limitation attached,” he said. "We are going to have to see how this plays out in the future to determine if this decision has a chilling effect on the candor and possibly the effectiveness of communications by defense counsel when negotiating a plea." Unanimous opinion Epstein's criminal defense attorneys, Black and Martin G. Weinberg of Boston, intervened in the appeal as third parties. The appellate ruling was written by one of the more conservative members of the Eleventh Circuit. Judge William H. Pryor said the federal rule of evidence cited by Epstein in the interlocutory appeal did not protect him against discoverability of plea negotiations. “And even if they did, Epstein clearly falls outside its protection because he entered a guilty plea and the victims intend to use the correspondence against the United States, not against Epstein," Pryor wrote. He was joined in the unanimous decision by Judge Beverly Martin and U.S. District Judge Charlene Edwards Honeywell of Oriando, sitting by designation, The U.S. attorney's office in Miami argued before Marra that the victims did not need to be notified of the agreement because the women's liberty was not at stake. It also took the position that the Crime Victims Right Act did not apply unless federal charges were filed against Epstein. Victims’ Rights Howell said the decision indicates how courts have come around to the victim's point of view. He said as a state prosecutor in 1978, victims’ rights were nearly non-existent. "There has been a fundamental change in the courts," he said, "It's only been in the last 30 years that courts examines things from the view point of the victim." He said plaintiffs attorneys have asked the Justice Department in Washington why Epstein was offered the nonprosecution agreement but were told all decisions on the billionaire were made in Florida. "Why was such a lenient deal offered?” Howell asked. "Washington is supposed to be tough on crimes against children, but the decision in this case certainly disputes that policy." Copyright 2014. ALM Media Properties, LLC. All rights reserved. http JAwww.dailyousinessrewew.corvcs/Satellite7c=Article_C &childpag ename=DBR%2F Article_C %2F Artic e%2F Layouts %2F PrinterF riendlySpag ename= ALM v3 EFTA00191306

--=PAGE_BREAK=--

sezeiCase 9:08-cv-80788KAM RUBbOC ErnEne Pa Piatirs inter ed cont BErde dter OS/OZBORRLoP age 5 of 6 [Search ] PRLOG Pross Rotuase Distribution PR Home Country News Joltod Stvios, Auntiahy too Hong Kong Uniteres Kioetctonns Ayes Comotrrys beds ry News Al Nows Exctusive News May 2014 1 Th We Tu Mo Su So 24 April 2094 wm 28 2 a Appeals Court Rules in Favor of Crime Victims’ Rights in Registered Pedophile Jeffrey Epstein Case tn a landmark decision, the US Court of Appeals for the Eleventh Circult Court on April 18, 2014, ruled In favor of two crimo victims represented by Farmer Jaffe Welssing Partner Brad Edwards and his co-counsel, Paul Cassell FOR IMMEDIATE RELEASE PRLog (Press Releaso) - Apr, 22, 2014 - FORT LAUDERDALE, Fla. - Comact Brad Edwards, Fi Jafle Welssing, Edwards. Few bieeran PL Custom Tote Bag (800) 400-1098 Kim Sailor, BARD Markating/PR Vistaprint kseller@berdmarketing.com Like what you see? Get up to 25% off $2.49 Appeals Court Rutes in Favor of Came Victims* Rigs in Registored Podophilo Jofrey Epstein Case In @ landmark decision, the US Court of Appeals for the Eleventh Circut Court on April 16, 2014 tuled In favor of two crime victims represented by Farmor, Jafo Weorssing. Edwards Fistos & Lehrman Partner Brad Edwards and his co-counsel Paul Cassell, Ronaki N, Boyce Prasidential Protessor of Caminal Law - S.J. Quinny Col ege of Law al the University of Utah, The ruling upheld the District Court which ordered the United States Attomey’s Office to provide the victims and their advocates the large volume of correspondence exchanged between Jofirey Epstein and iho Government that resulted In the government electing not to Federally prosecute Epstein for his many sexual chimes against children. Atlomeys Edwards and Cassell argued the case belore (ho Eleventh Circuit in February, against attomeys Roy Black and Marlin Weinberg The case imolves a federal criminal investigation that resulted in the Federal Government leaming that Jotirey Epste.n and certain co-conspirators sexually abused dozens and dozens of minor girls in West Palm Beach. Florida, Epstein ultimately reached a plea deal under which he plead gu Ity only to a slate charge of procuring a minor for prostitution in axchange for the Federal Govomment agree ng not (to pursue federal sex crimes on behalf of more than 40 victims, Represented by Allomey Brad Edwards and Paul Cassell. two of the g:is sought fo have the plea deal thrown oul because prosecutors had nol informed them of what was happen ng and had taken steps to conceal (he peculiar plea arrangements, ‘The vict.ms moved lo have access to the comespondence between prosecutors and delonse attomeys fo prow ther case The Eleventh Circuil rulod that thal the vcloms were entitled lo have access lo the matenals Agreeing wth Attorneys Edwards and Cassell, the Eleventh Circuit ruled that the communications were not pnuleged of otherwise barred from distribution The Elevonih C.rcutt expla.ned that the victims should “eroy an evidentiary benefit from the disclosure of plea negotiations to prove where the United States Wolated their rights Under the [Crime Victims’ Rights} Act.” Upon leaming of the ruling Attorney Brad Edwards stated: “The wclims have fougit hard for almost 6 years now lo leam why the person who molested them and many other children was ultimately allowed 10 live above the law and avold being held accountable for his crimes. I'm pleased that the Eleventh Circuit has made this ruling which will bring the vc ms one step closer to knowing the truth, Wealth and power should nol immunize anyone from punishment for harmful sexual acts against childran, in the circumstances when it does the wctims should al leas! have access to the explanation why. These documents should begin to explain.” Farmer, tate Weissing, Edwards, Fistos & Lehrman, P L., a Fort Lauderdale Litigation firm, focuses on Consumer Class Actors. Personal Injury, Wronghit Death. and Whistleblower Suils (qui tam), The finn is headquartered at 425 N Andrews Avenue, Suite 2 and may be reached al (800) 400-1098 or (954) 524-2820. Additional information about Brad Edwards, of Farmer. Jafle. Werssing, Edwards & Lehrman. PL. may be obtained from the firm's website at bilo Jw. carhlojuslice com/attomeys brag-edwards!. illo! Swew.ebysesodassaull.com or bitp./wwey,pathtojustice.cgrn. hitp:vaww pelog .org/12313086-appeals-court-rules-in-favor- of-crime-victims-rights-in-registered-pedophile-jefirey- epstein-case. him’ Daily News GT Hos netality LLC ss LG Assets, Inc, Announce Accuis bon offre Wydnar Balen Rouge Hote! Vas. Mind Ineoduces, 8. Squat ik Coll " Popular Journalesubys ¢ Public st Launches Pew Mises E-Cowse OY Senps.o9 Gtotit Actuaiad! Dout Apal ae Aesrusunen Name ged Bonion Manrepng Purtnes Yinners Announces foi Caren a a Fisnt Sounat Weekly News Equvesiogn Toams wn ge Stor 2 at Soper Rode ito Fyrtyer Cancer Suppor and Awaro- ass 6964 viows shy Enea Shown Chicco. Lana Burlesque wews frcheiac Iylans Cezteowal to Ful 1256 wews SEEKERS, A Seracnset Movel tor Young Aduits - 826 vows Bronner Bros. & Lisa Nicol Collection Runway Model Mowe Avena on lo Wil focal models - 734 wews M22 2014 News, EFTA00191307 v2

--=PAGE_BREAK=--

Contact BARD Markoling Toacdmarkeling. — End — Follow Email Embed POF / Print gi « 1) ContactEmait : Contact Author ***@bardmarketing com Source BAAD Marketing City’Town Fon La. derdate + Florida - Uv tate industry Lugot Tags Brad Edwards, Jofirey Coste, Crime nis, farmer alle we Shortcut priog.org/12313086 Disclabner: Issuers of the pross wlaaces are se osponsible bor tt ntent af crew RL 1 be held hialilo + CONtaAE postud ‘ any Latest Press Releases By “HARDMarketing” le Me S! #) FORCE 6 Uno! Sovih Flondaresearchers . soem atiy fe Ste for Award Wins: intropucinec FREE SHIPPING EVERY DAY, EVERY ORDER SHOP & SEE CODE» Like PRLog? 9K 2K 1K Rie ssing v7] htip Awww. prlog .org/12313086- appeal s-court-rules-in-favor-ol-crime-viclims-righis-in-regisiered-pedophile-jeffrey epsicin-case him S220 ase 9:08-cv-80 7B AM RoodmrerE Ae Marsa es ek ot FAS EoD hey SSL 2S 1LERUP age 6 of 6 EFTA00191308

--=PAGE_BREAK=--

Case 9:08-cv-80736-KAM Document 247-5 Entered on FLSD Docket 05/02/2014 Page 1 of 12 COMPOSITE EXHIBIT 5 EFTA00191309

--=PAGE_BREAK=--

Case 9:08-cv-80736-KAM Document 247-5 Entered on FLSD Docket 05/02/2014 Page 2 of 12 22014 Farmer Jafle Weissing Farmer Jaffe Weissing | Uke | Follow Message 295 thes * 44 talking about thes * 9 were here ~ ~ —_ Law Pactce 425 N. Andeews Ave., Ste. 2, Fort Lauderdale, Floride | 2 (800) 400-1098 295 2) About - Suggest an Ecit Photos Contact Us weeos kes r 1 [ rgagnts —} Pest Prete / Video Inve Your Friends to Uke This Page See AP Type a friend's name... ee] Farmer Jaffe Welssing a, HER otanchette 8 Yesterday _- randy Sennen [ina] Farmer Jatfe Weissing Gabe Zambrano has been selected as a 2014 Top Rated Lawyer in Mass Torts by ALM & Martindale ie Marco Ragozzina Hubbell, J . https: //plus.google.com/ 10380942 1573266262708/posts/DuVXCV =“ ~ ~ r2P4t — with Gabriel F Zambrano, Reviews, aKekht Recent Posts by Others on Farmer Jatfe Welssing wea ites /wew. facebook convF armerJaffeWWelssing w29 EFTA00191310

--=PAGE_BREAK=--

Case 9:08-cv-80736-KAM Document 247-5 Entered on FLSD Docket 05/02/2014 Page 3 of 12 272014 LEGAL LEADERS’ SLOT CI &AlmM ATED LAWYERS lke * Comment * Share 15 poopie the this, =, Marianne Carlisle Salem Way to 90, Gabe. 19 hours ago * Uke ial Farmer Jaffe Weissing dared a kik. 2 hows ago Filing a Lawsuit for Sexually Assault by a Massage Therap st http: //hub,am/ LkqlFap Filing @ Lawsult for Sexualby Axsnult by » Massage Therapist ttp: [/weww pathnofustice.combiog/ tid 3 TS 11253 rg 0 rut for servaty Uke * Comment * Snare Stacey Farwnr Woes this. ial i Farmer Jaffe Weissing H Apet 29 Join us in wishing Farmer Jaffe Weissing - Gary Farmer a Happy Birthday! hips :/www.facebook comF armerJaffeWeissing Farmer Jaffe Welssing [UT Rac Sterner Moore & Hey Jatt, looks Shue a good group!! Very professional photo... March 26 at 6:26pm Premier Process Serving % Call Jacksonville's most reliable process servers. Premier Pro February 26 ot 12:02pm Bonnie Manis “Gabe Zanbrano, of Farmer Jaffe Welssing, & 8 Co-Chair February 25 at }0:46am Tomious B hours antl game thret Let's go Canes! 1° November 2, 2013 at 12 0pm Roce Point Legal Race Polnt Legal has delvered technology, muthredia and c. Serenter 12, 2013 at 10.15am Mom Posts Ukes See All sl Mirena Lavesuits | Injuries | Lawyers | Attorneys C) Local Business _ American Association for Justice > 1 frien: wlbo fens Uns. Ue Broward County Courts Browerd County) Courthouses; Un Governerent Organization * Professional Services * Courthouse Gin Brockovich Publ Figue ie Stetson Unversity CoBege of Law 1M Cotege & Unversity aad Acuity Recent | CARE Mar ee Farmer Jaffe Weissing created 7th Annual 4KIDS Bg Cardic 5K Faness.Sports Farmer Jaffe Welssing shared a ink. Yesterday Sexual Assault by Massage Therapists hetp://hub.am/ Lkscg4D Sexual Assault by Massage Therapists http: // wren. pallojustice. cony blog/bid/344165/seruohassaut-by- mussage-therapists Sexual assaults of chents Dy mossage therapists at the spa are occurring at high rates ard wuts can be Mec. Lie * Conmemnit © Share EFTA00191311

--=PAGE_BREAK=--

Case 9:08-cv-80736-KAM Document 247-5 Entered on FLSD Docket 05/02/2014 Page 4 of 12 5/2/2014 Use * Comment Share 27 people the this, View 3 more comments Tammy Stockdale Happy Birthday Gary!!!!! Apri 29 at 6:04pm* Uke Anastasia Bithos Zambrana Happy Birthday oy Apri 29 at B4ipm: Uke inl fj Farmer Jaffe Weissing shared 2 ink, Apri 29 “#Colleges and #unversities need to face the facts about #sexualassault,” #VicePresidentBiden said in a statement as a 20- page report was released. "No more turning a blind eye or pretending it doesn't exist. White House releases report on sex assaults at colleges weer ereshingtongost.com Uke * Comment + Share Golom Mustafa ihes (Ns. FG] Former Jaffe Welssing Federal offciats have bunch a Web ste Pg) called NotAlone..gov to support survivors of sexual assautt on (rpuses and aiso plan to chabenpe colleges to survey ther students next year about sexual mtsconduct and other safety bsue. Apel 29 at 9:49" Uke isl Farmer Jaffe Weissing Apel 28 Jain us in wishing Krsten Wagner a Happy Birthday! hips :/Awav.lacebook comF armer JatleWetssing Farmer Jafle Welssing Farmer Jaffe Welssing created an event. Aget 29 ‘5K. FITNESS. SPOATS. nr near mee 7th Annual 4KIDS Big Cardio SK, Fitness.Sports Tomorrow Central Broward Regonal Park, Fort Lauderdale, Ca Florida mh Lauderhi, Florkta Be the fest person to jon Uke * Comment « Share ly Farmer Jaffe Welssing shared 2 int. L Apel 29° Fated Join attorney #MattWelssing on May 3 and run the 7th Annual #4Kics Big Cardio SK Help make a differance in the lives of Florida's foster children, Click Ink be'ow to sign-up or make a donation. peghirnion: AD Actnities inckading SK, Penest, Spoets. S/M2OMM ESO mms Staruing Ceremony At Bell Tower ssyioue €en-7 ‘WWatk Barts At Ball Tower s/afzone ? ads At Mala Suge simone re | (Classes And Sports Tourney syurore 6:30 am-33 Journey Awards Al Main Stage SURO AS ame? (0, Food, Acthiithet, And Events suo 700 we 12 4KIDS BIG Cardio! Move, Sweat. Give, - Home wenn kintera.ong 5G Card Sk. Fitness. Sports. Genefiting 41005 of South Florida - Join us May 3, 2014 for an arrazing day of ftness, sports, activities, food and fun in the park, while supporting lads in cms, Ube * Comment * Shave Anastasia Bahos Zambvand Burs this, ial farmer Jaffe Welssing shared a kik, Apri 28 Farmer Jaffe We-ss ng continues to evaluate legal claims against £9 EFTA00191312

--=PAGE_BREAK=--

Case 9:08-cv-80736-KAM Document 247-5 Entered on FLSD Docket 05/02/2014 Page 5 of 12 §272014 Farmer Jaffe Weissing Suryker Corporation over thelr ‘recalled’ #Rejuvenate & #ABGI tip implants. Any questions welcome. hitp://wwew, pathlojustice.com/stryker-lawsults STRYKER HIP RECALL LAWSUITS eww pathtojusticg cps fationwtle Case Evaluations nvoiving vests against STRYKER HIP REPLACEMENTS following & recall of the REJUVENATE 6 ASG Ul. STRYKER REJUVENATE and AG Il mocuar-neck femoral hap system recalled th July 2013, Uke + Commannt + Share Use * Comment * Share 10 people Bee this, Christina Fitch Happy Gathdayt | Apel 78 at 3°SOpm* Uke Anastasia Bithos Zambrano Hapoy Britktay Apri 2 8.50pm > Like ih f q Parmer Joffe Welssing shared a ink. WD Ape as Newsweek examines Mirena [UD lawsuits and growing number of allegations and claims involving use the contraceptive. Do the benefits outwelgh the risks? Are they as safe and effective es claimed? Those questions remain at the heart of ongoing lawsuits and litigation, Farmer Jafie Welssing Gabe Zambrano remains an original thought leader on the controversy and we are lwestigating claims, as well as accepting new cases, Contact us with questions, http://www.newsweek.com/2014/05/02/courtroom-contoversy-bel nd-popular-contraceptive-mirens 248443.homI The Courtroom Controversy Behind Popular Contraceptive Mirena Uke * Comment * Share Bonnie Manis Bes this. sik 7) Farmer Jaffe Welssing Aget 23 Daily Mail reviews 11th Circult decision and Sun Seritinel article reagarding Jeffrey Epste n. Related links appear below. htips /wwcfacebook conyF armerJafleVVeis sing 4223 EFTA00191313

--=PAGE_BREAK=--

Case 9:08-cv-80736-KAM Document 247-5 Entered on FLSD Docket 05/02/2014 £72/2014 Farmer Jafle Weissing 50x olfonder: Jefiroy Epatetn served 13 months in prison in 2007 for relations with tean girts de * Comment * Share Mace Une Bhes this. r q Farmer Jafie Weissing http //www.dabynnd co.uk). ./Borawes-see-ve i oy, BiBionaire's victins Lo see negotiations that led to lenient sentence ween Gadyrmat.co. uk . ‘The Florida financier had counted numerous celebrities, polkicians ard socalt .. See More Apt 23 a1 6:49pm" eer 1 Former Jafle Weissing tp //wwew. se semmel.cony.../Mjettrey-eover. I Victims win right to see negotiations that led to ‘lenient’ plea agreement for billionaire sex | weve, Sun-Sentinel.com | DW 2 Palm Beach batonare being Hrvastigaied for having sex wah young grt... See Move 4 Agrt 23 at 6:49pm* Uke 1 iat Farmer Jaffe Welssing shared a nk, CD pote Appeals Court Rules in Favor of Crime Victims’ Rights In Registered Pedophile Jeffrey Epstein Case hitp://hub.am/1i99)03 Appeals Court Rules In Favor of Crime Victims’ Rights in Registered Pedophile Jefirey Epsteln Case http //wwr.paumopustice, com biog bid 3 Farmer Jaffe Welssing shared a luk, ‘ Apri 23 ittps JAwaw. facebook comvF armer JafieWeilssing Page 6 of 12 wea EFTA00191314

--=PAGE_BREAK=--

‘Case 9:08-cv-80736-KAM Document 247-5 Entered on FLSD Docket 05/02/2014 Page 7 of 12 2014 Farmer Jatie Weissing Join us in welcoming attorney #AdamHorowitz to the Farmer Jaffe Weissing Team. Adam joins attorney Brad Edwards to further expand the firm's nationwide #CrimeVictinsR ghts and #SexualAbuse Practice Group. hetp: //www. pathtojusnc c.com/adam -hor owitz/ Adam Horowitz Use - Comment» Share 7 people tae Us. Sandra H, Simpson Johnson Wekore sboard Mr, Horowtz, Apel 23 at 10 36am" Uke Rebeca Misdroji Fleischer Mazal tov’ Aprd 24 at 7:57am: Ube inti rc Farmer Jaffe Welssing shared a ink. AW ots “Our cients want t see Mr. #Epstein held accountable for the numerous #sexoffenses he committed against many children,” said *BradleyEdwards, the women's t-al counset and a partner at Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman in Fort Lauderdale. Prosecutors Must Turn Over Docs In Billionaire Sex Offender Jefrey Epstein Case tke * Comment * Sure 2 people Ber tes, iat Uy Farmer Jaffe Weissing shared a ink. Apr The front page of today's Sun-Sentinel - Victims wn right to see Negowations that led to ‘lenient’ plea agreement for bill onaire sex offender JeffreyEpste n, Victims win right to see negotiations that fed to ‘lenlent’ plea agreement for Hilps:/Maw, facebook comF armer JatfeVVels sing Farmer Jaffe Wetssing shared @ ink, Apt 22 Additional news coverage on attorney #BradEdwards case against #JeffreyEpstein, Ths is 2 big victory for his clients and for #crimevictims, Beventh Circult rules that discovery can move forward on my Crime Victims’ Rights Act case Ww washungtonpast.com: Uke» Comment * Share 1 6 poopie lhe thes, ik { . Former Jaffe Welssing shared a ink. Apet 21 In recent years, the number of #cyclists and #pedestrians #hulled and # njured In #crashes in # Broward and #PalmBeach counties has spiked, EFTA00191315

--=PAGE_BREAK=--

“Case 9:08-cv-80736-KAM Document 247-5 Entered on FLSD Docket 05/02/2014 Page 8 of 12 Ver2014 Farmer Jaffe Weissing Farmer Jaffe Welssing Prive: Home = { 7 farmer Jaffe Welssing Timeline Recent Uke Sunrise pushes pedestrian, bike safety wre. Sune gentinel.com 2014 Recent Police are targeting two Oshiand Park Boulevard inmersections with a high 2013 nuerber of bicycle and pedestrian crashes, airing to educate everyone about the rules of the road. 2012 2011 Use Comment * Share 2010 Founded iy Farmer Jaffe Weissing shared a ink. ‘ Apri 21 Sponsored This Is one more step in the fight by vetims’ attorneys Grad Edwards and Paul Cassell to overturn the secret deal, which saved Epstein from facing serious federal charges and serving s grvfcant prison me. LogoSportswear -! fogosoftwear.com Si st » Al Up to 30% off Appeals court rules against sex offender vetaprint.com Uke * Comment » Shave a u a 6 people tee this, vi Made Line It's 8 very good day. Lith chaut got Mt right, Congratutations! Apri 2) ob 1d Jams tes 1 ' bak Her Carry On Wipe! lafreshgroup.com st a Farmer Jaffe Welssing shared a ink, Farmer Jaffe Welssing shared a ink, G pet 18 Apet 17» Edited E . & LT A #TampaDaySchoc’ principal has been arrested after #malesting Local #teacher rearrested and accused of #sexuallyassaultng & a student he befriended after the death of his father, The K-8 #studert after being warned by schoo! officials not to spend any Citizen ECO-DRIVE school specializes assisting students who have m id to moderate Ume alone with the #vctim, amazon.com #learningd&sabilives, dysiexia, arndety, and ADHD. Broward teacher accused of sex with teen had been warned to Tampa Oay School principal arrested after authorities say he stay away molested a student artides suresentinel.com wwer. tampabay, — Areigious school biology teacher accused of naving sex wih one of tits A Tempe Day School orincipal was arrested Thuriday after suthorties 14-year-old students a car parked behind a strip mulls now facing said he mapproprately touched a 14-year-clf mole student he had federal charges, Erk Richard Beasley, 24, of... befrended, according to 8n arrest report, Une Comment * Share Uke * Comment * Sta Bonnie Mans thes this hitps sw. lacebook.conyF armerJafieVVeissing e3 EFTA00191316

--=PAGE_BREAK=--

' S220Rase 9:08-cv-807 SERA ME OUR ins infer 4796 Vicki adel IORPR ABE Oeics OLAGPBOIae Page 9 of 12 Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, P.L. * 1-B55-700-PATH Current Aricies |G} RSS Feed Appeals Court Rules In Favor of Crime Victims’ Rights In Registered Pedophile Jeffrey E Epstein Case Posted on Wed, Apr 23, 2014 Come Lbs2024 bote Hid BAPLW2014 Mayo. 1 of 23 (PUBLISH) IN THE UNITED STATES COURT OF APPEALS POR THE ELEVENTH CIRCUIT No 13-12023 D.C Docket No, 9.08-¢v-80736-KAM JANE DOE NO. |. JANE DOE NO. 2, Pliavotttts-Appeitees. vena UNITED STATES OF AMERICA Defendant. ROY BLACK. MARTIN G WEINBERG, lntervenons-Appellas Appenis Gor the United States District Coun for the Souther Dustrict of Florida (Ap 162018) Before PRYOR sud MARTIN: Cucuit Judges. and HONEYWELL.” Diswict Jwilge * Honpeable Chawlene Eclwauds Homeywell. United States Drsinct Judge fos the Middle Dysinct of Flanda, stung by devigention http /wew pathiojustice, comvblog /bid/343584/Appeals-Court-Rules-in-F avor-ol-Crime-Victims-Rights-in-Registered-Pedophile-JeffreyE-Epslein-Case#.U20n... 1/4 EFTA00191317

--=PAGE_BREAK=--

- sreoCase 9:08-cv-807 3fipdtaA WbunROBUIROR bOtive Sichke Reseach Ah FkaRDeaket OS Bad20i4 Page 10 of 12 On Friday, April 18, 2014, the Eleventh Circuit ned that discovery can move forward in an important Crime Victims’ Rights Act case thal my co-counsel Paul Cassell and | (Brad Edwards) have been litigating for nearly six years, The narrow issue before the Circuil was whether proseculors and defense attorneys share an absolule privilege, lo the exclusion of even the victims of the crime, so as to Prevent anyone (including the victims) from knowing anything about the plea discussions. The District Court ruled that no such privilege exists and the 11th Circuit has now agreed. In this case, the ruling means that the victims will have @ chance fo review the corresponderce exchanged between Epstein and prosecutors to learn how exactly the secretive deal was reached while the victims were lead to believe a prosecution was underway. The ruling will also get the victims one step closer to retuming to the district court and seeking to invalidate the plea agreement thal was consummated in violation of their rights. We hope that the case will ultimately set an important precedent establishing the timing for when victim's rights are triggered and ultimately prevent prosecutors from keeping Victims in the dark about the plea deals reached with perpetrators. JETFREY C CPSITR Here are the important facts, taken from the Eleventh Circuit's opinion: In 2006 the FB! began Investigating allegations that Jeffrey E, Epstein had sexually abused dozens and dozens of minor girts. The United States Attorney's Office for the Southem District of Flonda accepled Epstein's case for prosecution, and the FBIissued victim notification letters to my two clients, minors Jane Doe No. 1 and Jane Doe No, 2, in June and August 2007. Extensive plea negotlations ensued between the United States and Epstein. Despite the investigation revealing that Epstein had molested more than 40 minor girls, in late 2007, the United States entered into a non- prosecution agreement (NPA) with Epstein - essentially agree'ng to immunize Epstein for all of the Federal Sex crimes he committed in exchange for his offer to plead guilty to minor Florida stale offenses (¢,g., solicitation of prostitulion), for which he served the majority of his “Ume" in a lush private office, as opposed {o a cell, During the Federal Plea negoliations, not only did the Uniled States neglect to “meaningfully confer” with the victims before it entered into the agreement with Epstein, it also concealed its existence of the agreement for at least 9 months. For example, the Uniled States sent post-agreement letters to the victims reporting that the “case Is currently under Investigation” and explaining that “{t)his can be a lengthy process and we request your continued patience while we conduct a thorough investigation,” Some of those letiers were delivered to victims as late as May, 2008 - many months after the NPA was signed and just before Epstein’s stale court plea that served to permanently extinguish the righis of victims. itp, pathloj ustlce.comblog /bid/343584/Appeals-Court-Rules-in-F avor-of-Crime-Victins-Righis-in-Reg!stered-Pedophile-Jetfrey E-Epstein-Case#U20n.. 2/4 EFTA00191318

--=PAGE_BREAK=--

* 9220 ase 9:08-cv-807 36ekKetourbocumentiotiheyiciinn knedhitty sb SPeDonkerGrearchs Page 11 of 12 On June 27, 2008, the United States informed me that Epstein planned to plead guilty to the Florida state charges three days later. But the United States failed to disclose that Epsiein's pleas to those state charges arose from his federal non-prosecution agreement and that the pleas would bar a federal prosecution. As a result, the victims did not attend the stale court proceedings. in fact, Federal prosecutors asked that | express my concerns about Mr. Epstein in a letter addressed to them. | sent that letter on July 3, 2008 detailing the reasons why federal prosecution of Mr. Epstein were extremely important for the safety of children, This exercise was obviously futile, especially in light of the fact that the plea to which Epstein had already entered brought an end to any chance of federal prosecution. On July 7, 2008, while under the mistaken belief (along with my cfents) thal a federal plea deal was imminent and should be stopped - at least to give my clients a chance to first confer with the prosecutor as to the terms of the plea deal - | filed a petition alleging that Jane Doe No. 1 was a viclim of federal sex crimes committed by Epstein and that the United Stales was wrongfully excluding her from plea negotiations, We also alleged that the prosecutors had violated her rights under the Crime Victims’ Rights Act (CVRA) - specifically her rights to confer with federal prosecutors, to be treated with faimess, lo receive timely notice of relevant court proceedings, and to receive information about restitution. The United States response was the first ime we realized that there was no imminent federal plea to slop - the deal had already been done. By telling my clients to be patient, and by having me spend lime writing letters about the need to prosecute Mr, Epstein, the United States had effectively run out the clock on my clients’ rights. Remarkably, the United States, in its pleadings, defended the allegations that it had violated the victims’ rights by claiming the Act did not apply to pre-indictment negoliations with potential federal defendants; therefore, the victims’ "rights” had never been triggered and thus could not have been violated. The defense was that the victims had no rights...despite the CVRA. After Jane Doe No. 2 joined the initia! petition, the district courl (Mara.J.) found that both women qualified as “crime victims” under the Act. The district court later rejected the Govermment's argument that the CVRA only apples after a federal criminal indictment has been filed. Among other relief, we sought rescission of the non-prosecution agreement as a remedy for the violation of the victims’ righis. To make the case for such a remedy, we moved for discovery of the correspondence between the United States and Epstein's atlomeys during the plea negotiations. Epstein’s attomeys intervened, arguing thal Federal Rule of Evidence 410 and Federal Rule of Criminal Procedure 11 create a privilege for plea negotiations blocking release of the correspondence. They also argued thal the court should find that the materials were protected under the work product doctrine or, alternatively, should be protected under a new "commonmiaw privilege for plea negotiations.” Yes, Epsiein's defense attorneys argued al the District level and appellate level that absolule confidentiality should exist between defendanis and prosecutors to the exclusion of everyone - including the victims of the crime. The district court first ned thal rescission of the plea agreement was a possible remedy under tha Aci. The court then ruled thal we were entitled io review the correspondence, rejecting all of Epstein's arguments. On Friday, the Eleventh Circuil affirmed the district court's decision. Al pp. 18-22, the Circuit concluded thal there was no basis for restricting access lo the correspondence when the victims had a legitimate need to review. The Circuil rejected, for example, the work product argument: Disclosure of work-product materials to an adversary waives the work-product privilege. See, e.g., Inre Chrysler Motors Corp. Overnight Evaluation Program Litig., 860 F.2d 844, 846 (8th Cir, 1988); Inre Doe, 662 F.2d 1073, 1081-82 (4th Cir, 1981). Evenil it shared the common goal of reaching a quick settlement, the United States was undoubtedly adverse to Epstein during its investigation of him for federal offenses, and the Inlervenors’ disclosure of thelr work product walved any claim of privilege. . . The Circuit also declined to recognize a new privilege for “plea bargaining”: As a last-ditch effort, the intervanors contend that “[i}f more is needed in addition to the plain language of Rule 410 to preclude disclosure of the correspondence to plaintiffs, it can be found in the conjunction of Rule 410, the work-product privilege, and the Sixth Amendment right to the effective assistance of counsel in the plea bargaining process,” but this novel argument fails loo. As explained above, Rule 410 does not create a privilege and the Intervenors waived any work-product privilege. The intervenors concede too that the right to counsel under the Sixth Amendment had not yet attached when the correspondence was exchanged. Lumley ff City of Dade City, Fla., 327 F.3d 1186, 1195 (11th Cir, 2003) (*[T]he Sith Amendment right to counsel ordinarily does not arise until there is a formal commitment by the government lo prosecute,” such as a “formal charge, preliminary hearing, indictment, information, or arraignment.”). The “conjunctive” power of three false claims of privilege does not rescue the correspondence from disclosure, .. . The Supreme Court has identified several considerations relevant to whether a court should recognize an evidentiary privilege—the needs of the public, whether the privilege is rooted In the imperative for confidence and trust, the evidentiary benefit of the denial of the privilege, and any consensus among the slates, Jaffee | Redmond, 518 U.S. 1, 10-15, 116 S. Cl. 1923, 1928-31 (1996)}—but none of these considerations weighs In favor of recognizing a new privilege to prevent discovery of the plea negotiations, Although plea negotiations are vital to the functioning of the criminal justice system, a prosecutor and target of a criminal investigation do not enjoy a relationship of confidence and trust when they negotlate, Their adversarial relationship, unlike the confidential relationship of a doctor and patient or atlomey and client, warrants no privilege beyond the terms of Rule 410. See Jaffee, 518 U.S. at 10, 116 S.Ct. at 1928. But the viclims would enjoy an evideniiary benefit from the disclosure of plea negotiations to prove whether the United States Violated their rights under the Act. The bigger issue Is whether the Crime Victims’ Rights Act is going to be taken seriousty by prosecutors and the courts. We have a very strong case thal, prodded by Epstein, the federal prosecutors deliberately concealed the sweetheart plea deal they had cooked up with him to avoid public criticism of the deal. Bul the CVRA was the law of the land and required the prosecutors to confer with the victims about the deal - before It was made. | am hopeful that this Case substanilales and advances the rights of crime victims In the criminal hitpvww pathiojustice.corvblog /bid/343584/Appeals-Court-Rules-in-F avor-of-Crime-Victims-Rights-in-Registered-Pedophile- Jeffrey E-EpsteinmCase#.U20n... 44 EFTA00191319

--=PAGE_BREAK=--

» s2eo@ase 9:08-Cv-807 3 bpd dou ROGLIIMAH AA hei cole tA eAInOey rh SDPeRpckanOw 2A Page 12 of Process al an early stage, and that ullimately the violation of our clieres fights in this case can be resurrected through the invalidation of this agreement that was reached In violation of their rights. Tags: Crime Victims Rights Act, CVRA, Jeffrey E Epstein, Florida Registered Sexual Offender Post Comment Name Email Website (optional) Comment Allowed lags: <a> link, <b> bold, <i> italics O Receive email whan someone replies. © Subscribe to this blog by email. © 2014 Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, P.L. All rights reserved.Sitemap Lega! Disclaimer Your Path to Justice Begins and Ends With Us! © 2013 - Path To Justice FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L., 425 North Andrews Avenue, Suite 2, Fort Lauderdale, FL 33301 http. /Awew. palhlojustice.corr/blog /bid/343584/Appeals-Court-Rules-in-F avor-ol-Crime-Victims-Rights-in-Registered-Pedophile- JeffreyE-EpstelnCasel#.U20n.. 4/4 EFTA00191320

--=PAGE_BREAK=--

Case 9:08-cv-80736-KAM Document 247-1 Entered on FLSD Docket 05/02/2014 Page 1 of 9 EXHIBIT 1 EFTA00191321

--=PAGE_BREAK=--

Case 9:08-cv-80736-KAM Document 247-1 Entered on FLSD Docket 05/02/2014 Page 2 of 9 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO, 08-80736-CIV-MARRA/JOHNSON JANE DOE #1 and JANE DOE #2, Plantiffs, UNITED STATES OF AMERICA, Defendant, ROY BLACK, et al., Intervenors / PROPOSED ORDER OF CONFIDENTIALITY (“PROTECTIVE ORDER”) THIS CAUSE came before the Court upon the /ntervenors’ Motion For a Protective Confidentiality Order and Incorporated Memorandum of Law, For the reasons that the Court will set forth in a separate forthcoming Order, the motion is hereby GRANTED. Now, therefore, it is ORDERED that: 1. This Protective Order applies to all correspondence between the United States Attorney’s Office and the Intervenors, including any attachments thereto, that was the subject of the Court’s Order of June 18, 2013 (Doc, 188), hereinafter referred to as the “Confidential Discovery Material” or “CDM.” 2. The parties shall designate the CDM by marking them on the face of the writing: EFTA00191322

--=PAGE_BREAK=--

Case 9:08-cv-80736-KAM Document 247-1 Entered on FLSD Docket 05/02/2014 Page 3 of 9 CONFIDENTIAL - SUBJECT TO STIPULATION AND ORDER OF CONFIDENTIALITY. The marking shall be affixed in such a manner as not to obliterate or obscure any written matter. With respect to discovery materials produced electronically, the designation of Confidential may be made on the outside of the disk or cd. 3. In the event that the Producing Party inadvertently fails to designate any CDM as confidential in this Action, it may make such designation subsequently by notifying all parties to whom such discovery material was produced, in writing as soon as practicable. After receipt of such notification, the parties to whom production has been made will treat the discovery material and all copies as having been designated as CDM. 4. The parties agree that the CDM, or any summary thereof, shall be used solely for the purpose of this Action and for no other purpose without prior written approval from the Court or the prior written consent of the Producing Party and the Intervenors. All persons receiving or given access to CDM in accordance with the terms of this Protective Order consent to the continuing jurisdiction of this Court for the purposes of enforcing this Protective Order and remedying any violations thereof. 5. a. CDM shall not be disclosed to anyone other than the following categories of persons: (i) The Court (and any appellate court), including court personnel. EFTA00191323

--=PAGE_BREAK=--

Case 9:08-cv-80736-KAM Document 247-1 Entered on FLSD Docket 05/02/2014 Page 4 of 9 (ii) Court reporters (including persons operating video recording equipment at depositions) and person preparing transcripts of testimony to the extent necessary to prepare such transcripts, with the consent of counsel. (iii) Plaintiffs’ attorneys who appear as counsel of record in this case, including the attached list of paralegals, clerical, secretarial and other staff employed or retained by such counsel, provided that such staff and employees also comply with the provisions of Paragraph 6 hereof. (iv) Retained consulting or testifying experts, advisors and consultants, including persons directly employed by such experts, advisors and consultants (collectively “experts”) but only to the extent necessary to perform their work in connection with this Action. ® Any additional persons as counsel for the parties and Intervenors shall consent to in writing before the proposed disclosures, b. All parties and their respective counsel, paralegals and employees and assistants of all counsel receiving the CDM shall take all steps reasonably necessary to prevent disclosure of the CDM other than in accordance with the terms of this Protective Order. c. Disclosure of the CDM other than in accordance with the terms of this Protective Order may subject the disclosing person to such sanctions and remedies as this Court may deem appropriate, including without limitation, contempt, injunctive relief and damages. EFTA00191324

--=PAGE_BREAK=--

Case 9:08-cv-80736-KAM Document 247-1 Entered on FLSD Docket 05/02/2014 Page 5 of 9 6. No copies of any CDM shall be made or delivered to any person other than those categories of persons referred to in paragraph 5 above, and even then only in accordance with paragraphs 7 and 8 herein. 7. CDM may only be disclosed to persons who are not included in those categories referred to in paragraph 5.a. above, upon prior written consent of the Producing Party’s and Intervenors’ counsel. If either the Producing Party’s counsel or the Intervenors’ counsel refuses to give consent, the CDM shall not be disclosed. The Receiving Parties may apply to the Court for an order of relief, on notice to the Producing Party and Intervenors. 8. Any person referred to in paragraphs 5.a.iii through 5 above who is furnished a copy of any CDM shall first be given a copy of this Protective Order and required to read it and be bound by its terms. 9. At any time during this Action, the Receiving Parties may challenge the designation of CDM as confidential by written notice to the Producing Party’s counsel and counsel for the Intervenors specifying by exact bates number the materials in dispute and the precise nature of the dispute with regard to each document or portion thereof. The parties and Intervenors shall have twenty (20) days from receipt of the written notice to determine if the dispute can be resolved without judicial intervention and, if not, the Receiving Parties amy move for an Order removing the confidential designation. The Receiving Parties shall have the burden of proof on such a motion to establish good cause for removing the confidential designation and treatment. EFTA00191325

--=PAGE_BREAK=--

Case 9:08-cv-80736-KAM Document 247-1 Entered on FLSD Docket 05/02/2014 Page 6 of 9 10. No party shall be obligated to challenge the propriety of any designation, and a failure to do so shall not preclude a subsequent challenge on the propriety of such designation and shall not constitute an admission that any information is, in fact, confidential, ll. Inthe event a party seeks to file any pleading, brief or memorandum or other document purporting to reproduce, paraphrase or summarize any CDM or portions thereof, that party shall take appropriate action to insure that the documents receive proper protection from public disclosure and shall seek leave of Court to file the document under seal in accordance with Local Rules of the United States District Court for the Southern District of Florida. 12. a, In the event that a party intends to file CDM with the Court in support of, or in opposition to, a non-discovery motion (e.g. motion for summary judgment or any other dispositive or substantive motion), the filing party shall take appropriate action to insure that the documents receive proper protection from public disclosure and shall seek leave of Court to file the document under seal in accordance with the local rules. b. The non-discovery motion filing and briefing schedule shall be adjusted and tolled to provide sufficient time for the Court to consider and rule on the motion seeking permission to file the document(s) under seal. c. Once the matter has been resolved, the filing party may file the document(s) in accordance with the parties’ and Intervenors’ agreement and/or the Court’s instructions, as applicable. EFTA00191326

--=PAGE_BREAK=--

Case 9:08-cv-80736-KAM Document 247-1 Entered on FLSD Docket 05/02/2014 Page 7 of 9 13. The CDM and/or other papers which are filed under seal shall be kept under seal until further order of the Court; however, said CDM and other papers filed under seal shall be available to the Court and counsel of record, and to all other persons entitled to receive the confidential information contained therein under the terms of this Protective Order. 14. This Protective Order is intended to provide a mechanism for the handling of the CDM and is not intended to imply that any CDM is relevant or admissible in this Action or any other litigation. Any party may move for relief from, or general or particular modification of, the mechanism for maintaining confidentiality herein set forth, or the application of this Protective Order in any particular circumstance, and each party specifically reserves all rights to object to the relevance or admissibility of any information produced in accordance with this Protective Order on any grounds it may deem appropriate. 15. Ifaparty receiving CDM in accordance with the terms of this Protective Order is served with a subpoena or other process by any court, administrative or legislative body, or any other person or organization which calls for the production of any CDM, the party to whom the subpoena or other process is directed shall, within two business days of its service, notify the opposing party or parties and the Intervenors of the pendency of such subpoena or order and provide them with a copy of the subpoena or process and the date by which compliance is requested. Any party or the Intervenors opposing the production of the -6- EFTA00191327

--=PAGE_BREAK=--

Case 9:08-cv-80736-KAM Document 247-1 Entered on FLSD Docket 05/02/2014 Page 8 of 9 information demanded in the subpoena or process shall notify the party served of its objections as early as possible prior to the requested compliance date. 16. This Protective Order may be amended with leave of Court, by the agreement of counsel for the parties and Intervenors in the form of a stipulation submitted to the Court for approval, or by the Court sua sponte after affording the parties and Intervenors the opportunity to be heard. If the parties and Intervenors cannot agree to an amendment, then a formal motion to amend must be filed with the Court. This Protective Order is intended to regulate the handling of CDM and documents during this litigation, but shall remain in full force and effect until modified, superseded or terminated on the record by agreement of the parties thereto or by order of the Court. 17. All counsel of record in this Action shall make a good faith effort to comply with the provisions of this Protective Order and to ensure that their agents, employees and clients do so as well. In the event of a change of counsel, retiring counsel shall notify new counsel of their responsibilities under this Order. 18. This Protective Order does not restrict or limit the use of CDM at any hearing or trial, which may be the subject of a further protective order and/or appropriate court orders. Prior to any hearing or trial at which the use of CDM is anticipated, the parties and Intervenors shall meet and confer regarding the use of the CDM. If the parties and Intervenors cannot agree, the parties and Intervenors shall request the Court to rule on such procedures. Notwithstanding, this Protective Order shall remain in full force and effect until EFTA00191328

--=PAGE_BREAK=--

Case 9:08-cv-80736-KAM Document 247-1 Entered on FLSD Docket 05/02/2014 Page 9 of 9 modified, superseded, terminated on the record by agreement of the parties and Intervenors or by order of the Court. 19. Within sixty (60) days after the conclusion of this Action, whether by judgment, settlement or otherwise, including conclusion of any appeal, all CDM including but not limited to materials furnished to consultants and/or experts shall be returned to the Producing Party unless the parties stipulate to destruction in lieu of return; provided, however, that counsel of record in this case may retain for their files, copies of any of their work product, pleadings, court filings, brief, and exhibits, which incorporate or contain documents, information or material designated as “CONFIDENTIAL”. 20. Upon final termination of this Action, whether by judgment, settlement or otherwise, including all appeals, the Clerk of the Court shall return to counsel for the parties, or destroy, any materials filed under seal. Before destroying any document filed under seal, the Clerk of Court shall advise all parties of their option to accept return or destruction and shall allow no less than thirty (30) days from issuance of the notice for counsel to respond. In the absence of a response, the Clerk of Court may destroy documents filed under seal. DONE AND ORDERED in Chambers at West Palm Beach, Florida, this _ day of May, 2014. Kenneth Marra United States District Judge ce: All counsel EFTA00191329

--=PAGE_BREAK=--

Case 9:08-cv-80736-KAM Document 247-2 Entered on FLSD Docket 05/02/2014 Page 1 of 22 COMPOSITE EXHIBIT 2 EFTA00191330

--=PAGE_BREAK=--

‘Case 9:08-cv-80736-KAM Document 247-2 Entered on FLSD Docket 05/02/2014 Page 2 of 22 Attorneys Say Miami Prosecutors Violated Crime Victims" Rights Act | Main justice IEGOTIATING WITH THE DOU: BR) wae susnce STRATEGIES FOR OPTIMAL RESULTS BRACEWELL Lawyers with _ FREE Webinar - Wed., April 13 &CIULIAN) Mace Aueul Got Tipe? loys or Heylter CT 0 | mvt WAIN JUSTICE = TICS, POLICY AND THE LAW — ~ JusTJOBS } | ANTI-CORRUPTION orneys Say Miami Prosecutors Violated Crime Victims’ Rights Act US. ATTORNEYS GHART (interactive) | tephanie Woodrow | March 22, 2011 11:52 am <5 Printable Vi | 180 attomeys for two girls who contend thay were agsaultod by Dilfonaire and Rights/Reprinis Cad sox offender Jeffrey Epstein fied court papers on Monday Calming the vek Wend 1U.S Atlorney’s office violated the Crime Victims’ Rights Act by signing a nonprosecution agreement with Epstein ‘ ut nottying them, the Palm Beech Osily News reported | Epsicin served 13 months In jail trom June 2008 to July 2009 for one alate count of acticiting 4 ‘on underage girl for prostitution As @ rosult, ho is required to register 04 a sex offender While bs 9. he wasn't proseculed for odditians! charges. more than 40 gis undor the age of 18 sey they 4 , came to his home and gave him massages Ouring tho massages, they say, ha masturbated “| and soxualy assaulted them = Providing clients with proven experience and innovative solution: sto complex compliance and enforcement issues inside th , Beltway and around the glob Brad Edwards and Paul Cassell, atiomeys representing two of his alleged victims, say In the filing that the U.S. Attorney's office for the Southern District of Florida of deliverataly misled the victins by telling them there was en caging Investigation Into thelr clalms. However, they say, the office was concesiing the fact that thay already had signed a osccition ded with Epstein Weliny © Cheeatinr Chantored thers en beet om ‘ding to the mation, the U S. Atiorney’s office In January 2008 and May 2000 sent “false notification’ latter in to an’s alleged victims saying “(his case is curenty under investigation However, the office had signod the agreemant iano Septmber 2007 COVINGTON dtormeys want a court hearing during which they will ask that the agreement be invalidated because It viclaled the COVINGTON & BURLING LLA w rights In the moticn the attornays claim the ugroement Is egal because the goverment did nol protect to }reasionally mandated rights of victims before ft entered this agreement.” Recognized for its Leading dge grants the request, Epsinin could be charged by the U.S Atlomey’s office. If he were charged and convicted on White Collar Crime and al charges, he could be sentenced to 10 years to fife for each charge. Anti-Corruption Practices by Chambers and Lega/ 500 ‘Ging to the mation, “The onty reason that the (US. Atiorney’s office) concealed the oxistence of the non-prosecution iment from the victims was not to comply with some logal resticton. but rather to avold @ firestorm of public aversy Hat would have erupted if the sweetheart ples deal with # politically connoctod billionaire had been revealed ~ 1 Vatie, special counsel for he US Atomay’s Office Southem District of Florida, in en email to the newspaper that iho 4/7/11 138 PM Attorney's office will respond in court filings ever, 88 wo stated more than two years ago In July 2008 In our response to the plointitis’ then-omergoncy poston for cement of the Crime Victim Rights Act, the CVRA was not violated because no federal charges wore ever fled in tha vor District of Florida,” Vole end. “Because the matter remains ponding in court, It would be Inappropriate at ite time aida additional comment on the meriis of the current mation * aTen pnere Decisions about whe, where and hua fo prosecute hove alway. been -and nest ceomiinmthe respon ibdity of the weoeutive brunch,” - Attorney General Eric Holder discussing pressure from members of Congress to prosecute Khalid Stu ith Mohammed befare a military commission rather than in http / /www.mainjustice.com/201 1/03 /22/attorneys-say-miam!- prosecutors -violated~crime-victims' -rights-act/ Page 1 of 2 EFTA00191331

--=PAGE_BREAK=--

‘Case 9:08-cv-80736-KAM Document 247-2 Entered on FLSD Docket 05/02/2014 Page 3 of 22 Attorneys Say Miami Prosecutors Violated Crime Victims’ Rights Act | Main Justice 4/7/11 138 PM weer Bue Sevlerul court. ‘ema To Tap Non-Proft Hoad For DOJ Crime Victims Post wmakers Bemoan Lack of Funding For Victims’ Rights asoculot Who Viclatod Rights of istamic Groups by Acckfont Is Now US Attornay mocratic Donor Viotatod Spirit of Election Laws, LA Prosecutors Say JUSTICE DEPARTMENT NEWS a dorat Prosecutors Viciated Laws, Elhics Rulas in 201 Casos Since 1998, Study Fins UELEASES wee Soviets Atermay Gomme Tom Penal Sranhe ot Educationt Os Oe DER POST NEWER POST oe seu Asks Slalgs lo Help Enforce ADA Proipctions for Encing Hiring Freeze, Kansas U.S. Aliomey Warss More Sere reat aeroay I, heen wo Pay $1.2 toot Lancet Foreign Corrupl Prectiees Act Altorney General Eric Holder Speaks el Nalional Action Networht@ Ge 13th Annual Convention nents are cloned. Shenandoah, Pennsytvenie, Men Senteced tor Involvement in he Fatal Reatlog of Luss Ramirea New Jerecy Wastewator Trealment and Chemical Supely Comary and Ouner Serteneed for Thelr in Freud Conspiracy Sibemme Sector and Hushend Charged with Tax Tet neat cn hg Fae Liens for Bithoms of Dollars Againat Federal Enforcement Parner Gonaral arte Motaer Spoete ot Nettonel Forum on Youth Violence Department of Justice House Judiciary Committes Office of Government Bthica Oftics of Legal Counsel Office of Professions! Responsibility Senate Judiciary Committee oe | About | Advertine | Jobe | Privacy Policy | Tonms of Use Copyright © 2011 WOC Media LLC ‘bitp:/ (www. mainjustice.com/201 1/03/22 /attorneys-say-mlami-prosecutors -violated -crime-victims’ -rights-act/ Page 2 of 2 EFTA00191332

--=PAGE_BREAK=--

Case 9:08-cv-80736-KAM Document 247-2 Entered on FLSD Docket 05/02/2014 Page 4 of 22 Home > Palm Beach News Attorneys want jeffrey Epstein agreement thrown out JUST A CLICK AWAY! Diniug? Director, PalmBeachDailyNev f/ Attomeys want Jeffrey Epstein agreement thrown out LATEST NEWS Today Thursday Apni 7. 208 Tam at Soa Gul Comiago lo focus on genomics Pain Beach Women's intemationat Fitm Festival sabuits Thursday in support of women fimmokers Day Academy pupits revisit Notable characters in Palm Bench hetory Gow Scott at Midtown Grach ‘Give mo the tet,’ bo Jolla oticals about Peach cOnceNS By MICHELE DARGAN OALY NEWS STAFF WRITER Updated: 9.41 a.m Wednesday March 23, 2011 Posted 7.21 pm. Monday. March 21, 2011 Emat | Print | Share | Lange Type Court papers filed Monday say the U.S. Attorney's Office violated the Crime Victims’ Rights Act by signing a nonprosacution agreement with sex offender Jelfrey Epstain without notifying his victins Attorneys Grad Edwards and Paul Cassell, representing Jane Doe #1 and Jane Doe #2, want a court hearing, where they will ask that the agreement be invalidated because, they say, ihe victims’ rights were viotated If that happens, It could open up the 56-year-o'd Paim Beach billionaire to a slew of federal charges involving sex crimes with minors thal were set aside by the agreement. The motion, fled Monday in federal court in West Palm Beach, accuses the U.S Atlomey's Office of deliberately misleading tho victims by teting them (he investigation was ongoing, while concealing they had already signed a doal wilh Epstein According to the mation, the US Altomey’s Office sent ‘laise notification” letiers in January 2008 and May 2008 to the victims saying “(t)his case is currently under investigation” after the government had signed the agroement wth Epsiein in September 200: “The only reason that the (US Altomey's Office) concesied ihe existence of the non-prosecution agreement from the victims was Not to comply w.th some legal restriction, bul rather to avoid a firestorm of public controversy that would have erupted If the sweetheart plea deal with a politically connected bitlonaire had been revealed,” the motion says if Epstein were found guilty on federal chargos, statutory penaiiles ranged from 10 years to life instead, the sealed pact was part and parcel of Epsiein's acceptance of a stale plea deal. where he received an 16-month sentence lor so iciling a minor for prostitution and soliciling prostitution He served 13 months segregated In a vacant wing of (he counly stockade and was let out on work re'ease six days a week for up to 16 hours a day Edwards and other allorneys fougm in court for a year before successfully getting the agreemoni unsealed in Seplember 2009 More than 30 minor giris were Wentified as Epstein’s victims in the pact 4/7/10.1.37 PM rta Way, Palen Beach ah can Paim B \/ . | VPs net Id Click bere for the latest events! Find us on Facebook = Palm Beach Dally News Uke Web Search by YAHOG! Hieebouk vocsal playin NOST RECENT Al. aums hitp / /weew.palmbeachdallynews.com/news/attorneys -want -jeffrey-epstein-agreement-thrown-out-1338111.htmi wat The Berety ofthe Pam Four Arts benat EFTA00191333

--=PAGE_BREAK=--

Case 9:08-cv-80736-KAM Document 247-2 Entered on FLSD Docket 05/02/2014 Page 5 of 22 Atvorneys want Jeffrey Epstein agreement thrown out 4/7/11. 1370M ee ' Doe 1 and 2, who were 14 and 13, respectively, al the time of the Incidents, received monetary setitements in civil cases. They aro among more than two-dozen underage girls who filed lawsulls or settiod claims agains! Epstein, alleging they wore lured to bis Palm Beach mansion to give him seaually charged massages and/or sex in exchange for money. The motion fled Monday says the agreement Is illegal because the government did not protect the “Congressionally mandated rights of victims before ft emared this agreement.” Alicia Vallo, special counsel for the U.S. Attorney's Office Southern District of Florida, sald in an e-mail that the U.S. Attomey's Office will respond In court Mings. “However, as we stated more than two years ago In July 2008 in our response to the plaintifis’ then-emergency petition for enforcement of the Crime Viclim Rights Act, the CVRA was nol violaled because no federal charges were ever filed In the Souther District of Florida,” Valle sold, “Because the matier remains pending in court, It would be inappropriate al this time lo provide additional comment on the merits of tha current mation.” The attorneys reference e-malls and letiers (rom the federal olfice to Epstein's lawyers acknowledging the government's legal obligation to inform victims about the pact. The e-mails are redacted In the motion because they are under seal. The attorneys filed a separale motion Monday to unseal the correspondence. “The reasonable inference from the evidence is that the U S. Altomey’s Office wanted to keep the agreement a secral to avoid intense criticism that would surely ensued had the victims and tho public learned that 2 billionaire sex offender with political connections had arranged to avoid federal prosecution for numerous felony sex affanses against minor girls,” the mation says “As part of this pattern of deception, the U.S. Atlorney’s Office discussed victim nolification wilh the defendant sex offender and. afier he raised objections, stopped making notifications,” Epstein sought “a higher level of review" within the Department of Justice, the mation says. “A reasonable inference from the evidence is that Epstein usad his sign ficant politica! and social connections to lobby the Justice Depariment to avoid significant federa! prosecution.” the motion states __ Mote sf Share this wrticte: COMMENTS Comments are closed news sockry weamien ante ADVERTISE ‘wei, SECTION — sronts Arte Colender ‘erAvicts in oe tie Rechoree al Calancine i Leggs ar rasion var eretnes ray teeaal Awnmenve & Yoh Spractot Reporte Tevtien Cotgentor ousess a ——_ Visitors’ Guide Toan Cowes common moce Food wn Seeren te Renew Feral Cate <= Pitsey Werricane Guiste 1010 Pie teeat elewe COLUMNISTS, bes prise Ag Chrombas af Comumeree eens Suber a Lemer } a eae CAL EBTATE http://www. palmbeachdallynews.com/news /attorneys -want-jeffrey-epsteln- agreement -thrown-out-1336211.htmi Page 2 of 3 EFTA00191334

--=PAGE_BREAK=--

. Case 9:08-cv-80736-KAM Document 247-2 Entered on FLSD Docket 05/02/2014 Page 6 of 22 Attorneys want Jeffrey Epstein agreement thrown out 4/7/11 137M Copyright © Thu Apr 07 $9.39 S4 EDT 2011 At rights resorved By using PalmBoachDatyNews com, you accept the terms of our visiior agreement Plonso road It Natt PrknBonctiDaltyNows cam | Pilvacy Policy | Abou! our ody ZO AME CORES hutp //veww.palmbeachdallynews.com /news /attorneys-want -jeffrey-epstein -agreement-thrown -out-1338111.htmi Page 3 of 3 EFTA00191335

--=PAGE_BREAK=--

Case 9:08-cv-80736-KAM Document 247-2 Entered on FLSD Docket 05/02/2014 Page 7 of 22 News Reports about Billionaire Pedophile Jeffrey Epstein Highlight the Importance of Vi... Page | of 3 BRIEFINGWIRE A Fiee Press Release Websito Briefing Search Keyword: Categury [[Ciear | | Search | Author Details Hubs O src en News Reports about Billionaire Pedophile Jeffrey Epstein Highlight the Importance of Victims Rights Hundreds of news articles have reporled billionaire pedophile Jeffrey Epstein's close relationship with Britain's Prince Andrew Attorney Brad Edwards has pursued victim nights cases on behalf of ten women who were sexually molested by Epstein Agh a Lawyer Online Now 12 Lawyers Are Online, Current Wait Time; 14 Minutes Law Jusinswer.cain ‘Asa ty Google BasfingWire com, 3/08/2011 - Contact Farmer, Jalfe, Weissing. Edwards, Fistos & Lehrman, P.L. (954) 524-2820 Kim Sa le’, BARO Marketing/PR (561) 637-2575 Fort Lauderdale, FL -- In the last week, hundreds of news artic es have reported bilhonaire pedophile Jefirey Epsiein's close relationship with Gritain’s Prince Andrew. Attorney Brad Edwards has pursued vicl'm rights cases on behall of len wornen who, between 12 end 15 years of age, were sexually molested and abused by Epstein. The stories of their abuse have a'l the trappings of a Hollywood movie, including posh settings http://www. briefingwire.com/viewBricfing.aspx?id=24907 agin | Lain ‘Adv by Google Free, Confidential Lawyer Locator, Save Time - Describe Your Case Now! woe LoyolMatch cove Ask a Lawver Online | Now 27 Lawyers Online Now Answer Your Quest ons In Minutes eAnswe* conyLiw Sexual Abuse Allegations ; We wrote the book on defending false molestation allegations www PolkeAbuse com Local 1-Day Coupons Up to 90% Off the Best Stuff To Dol Restaurants, Spas, Events and More, www. LivengSocial.cam The Diana Screen Employment screening tool. Help prevent child molestation. dlanascreen.com EFTA00191336

--=PAGE_BREAK=--

Case 9:08-cv-80736-KAM Document 247-2 Entered on FLSD Docket 05/02/2014 Page 8 of 22 News Reports about Billionaire Pedophile Joffrey Epstein Highlight the Importance of Vi... Page 2 of 3 at Epstein’s Palm Beach Mansion, private Caribbean Island and his jel. But Epstein’s heinous sexual abuse of these victims Is no fiction. Edwards successfully represented these women, obtaining justice for each of them, by proving that Epstain and his International sex trafficking criminal enterprise exploited |hem and hundreds of other underage girls. This recent wave of news coverage highlight the importance of the victims rights work that Altorney Edwards does on behalf of victims of sexual molestation and other sexual abuse. Edwards conducts extensive Investigations and pursues clvil lawsults against sexual predators to protect the rights of his victim cllents and to hold sexual predators, like Epstein, accountable. Many sexual predators, like Epstein, are wealthy and powerful and able to focus vast resources snd high profile lege! teams In an atlernpt to deflect attention, avold criminal liability, and deny justice to thelr victims. Speaking of his work on the Epstein cases, Edwards says ‘we took on powerful people and pret to ojevel the playing field to protect victi Representing these women has made Edwards aware that child sexual abuse is extremely prevalent. According to U.S. Health and Human Services study, more than 83,000 substantiated reports of sexually abused children were made In 2006 alone. The actual number of Incidents of sexual abuse Is likely much higher because it |s believed that sexual abuse, especially amongst children, Is significantly underreported. Edwards hopes that the media altention focused on Epstein's sexual abuse will “inspire victims to report these crimes” and will convey his belief “that victims rights cases can effectively protect thelr rights, maintain thelr snonymity, and hold predators accountable.” Farmer, Jatle, Weissing, Edwards, Fistos & Lehrman, P.L , a Fort Lauderdale Litigation firm, focuses on Consumer Class Actions, Sexual Abuse Cases as well as other significant Personal Injury, Wrongful Death, and Whistlebiower Suits (qul tam). The firm is headquartered at 425 N, Androws Avenue, Suite 2, Fort http://www. briclingwire.convviewBriefing aspx?id=24907 5/2/2011 EFTA00191337

--=PAGE_BREAK=--

_ ‘Case 9:08-cv-80736-KAM Document 247-2 Entered on FLSD Docket 05/02/2014 Page 9 of 22 News Reports about Billionaire Pedophile Jeffrey Epstein Highlight the Importance of Vi... Page 3 of 3 Lauderdale, Florida 33301 and may be . reached at (goo 400-1098 of (954) 524- 2820 Additional Information about Bred Edwards or Farmer, Jaffe, Welssing, Edwerds, Fistos & Lehrman, P.L. may be Obtained from the firm's website at www palhtojustice.com, EAQs | Contact Us | Terma & Conditions | Privacy Policy © 2000 BriefingWare LLC http://www. bricfingwire.com/viewBricfing.aspx?id=24907 5/2/2011 EFTA00191338

--=PAGE_BREAK=--

Case 9:08-cv-80736-KAM Document 247-2 Entered on FLSD Docket 05/02/2014 Page 10 of 22 Palm Beach Dally News: Archives 4/7/11135 PM pesireeacha) Search for Paim Beach Dally News Follow @ShinySheot ‘on Twitter! NEWS leigpan | Archives © Emil this page EY Prin tis poye TX Most popular New Search Return to results ~— Printer Friendly About your archives purchase: Your purchase of 20 eriicles expires on 04/07/2011 4:22 PM. You have Wewed 3 artices end have 17 ericles remaining INSIDER Palm Beach Dally News (FL) JUDGE RECEIVES EPSTEIN TAPE ‘ y RULING PENDING f- MICHELE OARGAN, Daily News Staff Writer a :, Published: May 5, 2010 b tw aN YORE —~ A Nechation ederal Pee ed ener ayn ipa recorded conmerseticn = But US. District Judge M. reserved ruling on whether the recording wil be released to | Shannon Donnelly atiomeys representing who were sexually abused by Epstein as minors. McKenna dkin't listen to the recording during the hearing. Fort Lauderdale attomey Bred Edwards and Utah atiorney and law professor Paul Cassell are fighting !o obtain the 22-minute tape on behalf of Epstein victim Jane Doe. She has filed one of ® dozen pending civil cases In federal court in West Palm Beech egulnst Epstein, A status check is sel tor Thursday in those cases before U.S, District Judge Kenneth Marra. Doe could have seliled the lawsuit for $50,000 but Is asking for $50 milion In damages, Cassel sald Tuesday. "Jane Doe was repeatedly sexually assaulted over a lengthy period of time by this wealthy and powerful man,” Caneel seid, Epstein, 57, Is currently under house arrest in his Palm Bach home after serving 13 months of an 18- monty stete sentence for soliciting a minor for prostitution and soliciting prostitution, Nearly two dozen young women have filed lawsuits against the b llionalre money manager -- some already sattiod — all alleging Epstein sexually abused them as minors at his El Brillo Way home. protected priviege Rush, of the New York Dally News, was present in the courtroom, but did nol have to testity Tuesday. Nelther did Fort Lauderdale private investigator Michael Fisten, #tso in the courtroom. Working on behai! of Epstein victims, Fisien discovered the existence of the tape and had @ conversation with Rush about ts Representing Rush and the newspaper, Washingion stlormey Laura Handman and New York Dally News sttomey Anne Carroll erqued the tape should not be releosed under any circumstances, ciling reporter's protected privilege, Rush toki Epatein the conversation was “off the record’ end has never published any Pponion of inat conversation, But even if portions had been printed, the unpublished portions would all be projected, Handman said, Hangman cled cases where inlerviews were conducted In the presence of other people and priviage was In addition, “ Handman argued that Rush should not have to testify In court. The ability for reporter's privilege to be protected is crucial In culling sources and gathering information for news siorias, Handman sald Reporting ts all about give and take between the reporter and the source, that's what roporters have to do, Handman said. “This is so critical to news gathering,” Handman sald. "Mr, Rush could find himself testifying in |many] cases just because he hed the temerity to do some reporting on a very important siory. Fee naming helpht to Dos's case on the tape and Jana Doe ts nt referred t2 orca in tht tape,” Handman said. Cassel argued thal the tape Is “critical in showing Epstein’s lack of remorse.” Cassel described Epstein as a pitiless sexual abuser to Jane Doe and at least 30 other minor girs. Even though Jane Doe Is not referred to by namo on the tape, Epstein raters to his viclims ws “the girs" and makes disparaging remarks about them on the tape, Cassell sald. Tape played for others Cassell said privilege does not apply because It was walved when Rush played the tape for three people and verbally divulged lis contents to two others, including Fisien and Edwards, who also represenis two other victims, Bul even if there is “qualified priv'ege,” Cassell says, Ii ls outwolghed by Doe's Inability to obtain the Informailon anywhere alse and the jury's need to hear Epstein's own words about his lock of remorse, Since Epstein has exercised his Fifth Amendment right during questioning by victims’ atiorneys, the jury http //nl.newsbank.com/nt-search/we/Archives?p_actlondoc&p_doc! .ername~dkiesqAs_accountid ~ACO1110406202210122618s_upgradeableano Page lof 2 EFTA00191339

--=PAGE_BREAK=--

Case 9:08-cv-80736-KAM Document 247-2 Entered on FLSD Docket 05/02/2014 Page 11 of 22 Palm Beach Dally News: Archives 4/7/11 1.359M will have no other way to hoor Epsiein’s words In his own voice, Cassell sald. Deadline for discovery in the Doe case ls May 31, with the tial set for July 14, com Copyright (c) 2010 Palrn Beach Dally News Se os Po NOT Buy Car Ineurance We found out how drivers can get wore. News TOreakingtiews (orn fianaoes 126 Points To His Credit Score www CredificaairFromitcene.com 422/Hr Job — 262 Openings Make §79/hr Working From Home. As seen on vers workfromhamegude met/jobs CORED http://nl.newsbank.com/nl-search/we/Archives?p_actlon=doc&p_docl.,.ername=dkiesq&s_accountid=AC01110406202210122614s_upgradeableeno Page 2 of 2 EFTA00191340

--=PAGE_BREAK=--

Case 9:08-cv-80736-KAM Document 247-2 Entered on FLSD Docket 05/02/2014 Page 12 of 22 Palm Beach Daily News Archives 4/7/12. 132 PM Soarch for Palm JUST A CLICK AWAY Beach Daly News s =. : . . Follow CeShiwiheet Ponca Y Yering? DAivectore ary el y J on Tete ¥ PalmBeachDailyNews‘com NEWS Religion | Archives © E-mol tis poge Print this pago TY Most popular New Search Return foresulls Printer Filendly About your archives purchase: Your purchase of 20 articles expires on 04/07/2011 4:22 PM. You have viewed 2 ericies and have 18 articies remaining, Palm Beach Dally News (FL) i sa io feed Ks LAWYER: EPSTEIN MADE ADMISSIONS ON TAPE news MICHELE DARGAN, Dolly News Statf Witter Published: Aprii 29, 2010 A tape recorded Interview between @ reporter and convicied sex offender Jeffrey Epstein contains “damming admissions by Epstein,” which includes Epaten saying he had come “close to crossing @ line” conceming sex with underage girts. Those and other revelations abou the 22-minute interview by New York Daly News reporter III Rush Palm Beach Daily News with Epstein are contained in @ 24-poge court fing by attomeys Brad Edwards and Poul Co: NEWSLETTERS of Jane Doe. Edwards represents Doe and two other Epstein victims, Edwards and Cassell are fighting to obtain the tape to further thelr case of sexual abuse by Epstein when Doe wan a minor. Epstein, 57, was released from jell in July after serving 13 months of an 18-month state sentence for soliciting a minor for prostitution and soliciting prostitution. Nearly two dozen young women have fied tawsults against Epstein — some already settied -- a8 alleging Epstein sexually abused them as minors at his El Brillo Way home, where he Is now serving house ernest The New York Dally News Is seeking to keep the tape confidential, citing reporter's protected privilege. In response, Cassell says the newspaper walved its protected privéege when Rush played the recording for three people and descrided lis contents to two others, Including Edwards. In addition, Cassell writes that privilege can? be appiied in this siiualion because ft doasn't Involve an issue related to a confidential source. The person on the tape is Epstein. Even if there Is “qualified privilege,” Cassell maintains It is outweighed by Doe's Inablity lo obtain the information anywhere else and her “compeling need lo obte’n Jefirey Epstein’s own words about his sexusl abuse and lack of remorse.” When reached by phone Wednesday, Anne Carroll, atlarney for the New York Dally News, sald she will answer Cassell in a court filing. Both the New York Daily News and Doe have asked # federal court judge in Manhattan to listen to the tape in chambers to help determine whether privilege applies Epstein and others who helped him procure minor girls for massages and sex acts have taken the Fith Amendment in ther depositions, stymising Doe and the other victins suing Epstein, the documents say. Michael Fisten, an investigator working for Doe, discovered the existence of the tape in fall 2009. An suihor who had listened to the tape told Fisten that Rush had a lape recording of Epstein “discussing the sexusl abuse of minor girls.” According to 8 sworm affidavit by Fisten, ha called Rush, who confirmed he interviewed Epsiein and mado @ tape. According to Fisten, Rush told him that he complied negative information from Epstain about his exploits with underage girls and how he eluded the justice system. But Fisten sald that Rush told him that his publisher, who knows Epstein, killed it afer recelving @ call from Epstein. Fisten seid Rush tok hm, among other things. that the following information was contained on the tape That Epsie’n said he went to jal! in Florida for no reason end # the sexuel sbuse of minors had happened In New York, ha would have only received @ $200 fine, That L.M., one of Edwards’ cilents who sued Epstein for sexual abuse a3 @ minor, came to him as @ prostitute and @ drug user (meaning she come to him for sex, ralher then him pursuing her) ‘That all the gis suing him are only trying to get a meal ticket. ‘That the only thing he m ght have done wrong was to maybe cross the [ne a tittle too closaly. in 8 sworn deposition, Edwards stales that Rush disclosed much of the Information contained on the tape to him in @ conversation. Edwards seid in his statement that the Rush Interview is “unique and not otherwise obtainable from other witnesses because Ml can be used to prove perjury -- a federal crime, Edwards seid Epstein testified In @ deposition that he did not recognize the name Rush from the New York Dally News “despite the fact that he gave @ personal inierview that we al now fo have bean tape recorded.” = mdargan@)pbdallynews com hup //nlnewsbank.com/ni-search/we/Archives?p_action=docép doci ername«dkiesqés_accountid»ACO1110406202210122614s_upgradeableeno Page 1 of 2 EFTA00191341

--=PAGE_BREAK=--

Case 9:08-cv-80736-KAM Document 247-2 Entered on FLSD Docket 05/02/2014 Page 13 of 22 "pale Beach Dally News Archives 4/7/11132 PM Epstein ‘Has ‘come close to crossing a line.’ Copyright (c) 2010 Palm Beach Dally News Refinance Rates at 2.65%" $160,000 Mortgage for $659/mo, No SSN req LengGo com/Mongage Le 2 News 7OreakingNems.com Man_“Cheats” Credit Score He Added 126 Points To His Credit Score wrew.CreditflepalrFromHome com Make $79/nr Working From Home, AS seen on neljobs wenn. work frommomneguide. Cauca? bttp://nl.newsbank.com/ni-search/we/Archives?p_action=doc&p_doct...ernameedklesqés_accountideACO?110406202210122614s_upgradeable=no Page 2 of 2 EFTA00191342

--=PAGE_BREAK=--

*Case 9:08-cv-80736-KAM Document 247-2 Entered on FLSD Docket 05/02/2014 Page 14 of 22 Page | = . a) @ LexisNexis 6 of 1! DOCUMENTS Copyright 2009 ProQuest Information and Learning All Rights Reserved ProQuest SuperText Copyright 2009 Patm Beach Post Paim Beach Daily News September 20, 2009 Sunday Dnl Edition SECTION: A SECTION; Pg. A.1 LENGTH: 1126 words HEADLINE: ATTORNEY FOR EPSTEIN VICTIMS: ‘| HAVE NEVER SEEN A STRANGER CASE’ BYLINE; MICHELE DARGAN, MICHELE DARGAN, Daily News Staff Writer BODY: Sex offender Jeffrey Epstein could have been charged with multiple counts of five federal offenses involving sex acts with minors and faced a life sentence, but, instead, the government agreed not to prosecute him or his procurers if he spent 18 months in the county jail on two state charges, Those were the details unsealed Friday in a nine-page federal non- prosecution agreement that lets Epstein and co-conspirators Sarah Kellen, —: Groff and Nadia Marcinkova off the hook for any of those past crimes. “He could have gone to prison for life and somehow he's getting immunity in exchange for nothing?" said Fort Lauderdale attorney Brad Edwards, who represents three Epstein victims. "] have never seen a stranger case. To me, it's more spectacular what's not in it, It's the U.S, Attorney's Office saying we'll do everything in our power to see he doesn't get punished.” Edwards has been fighting for a year in federal and state court to unseal the agreement. "The non-prosecution agreement raises more questions than it answers," said Miami attorney Adam Horowitz, who represents seven victims, "Why did all the co-conspirators receive immunity? Why were the victims not consulted re- garding the sentence? Why did he receive such a minimal sentence? The federal deal has remained sealed in Epstein's state court file since he pleaded guilty in June 2008 to state charges of procuring a minor for prostitution and soliciting prostitution. U.S. Attorney's Office does not comment ‘The federal charges he could have faced were: conspiracy to persuade minor femates to engage in prostitution, conspiracy to travel to engage in illicit sexual conduct with minor females, persuading minor females to engage in pros- titution, traveling to engage in illicit sexual conduct with minor females and causing a person under 18 years to engage in sex for money while knowing they are underage. The charges carry various statutory penalities ranging from 10 years to life, with a minimum mandatory of at least 10 years. Alicia Valle, spokeswoman for the U.S, Attomey’s Office in Miami, declined comment. Expert: Feds take few sex-assault cases EFTA00191343

--=PAGE_BREAK=--

Case 9:08-cv-80736-KAM Document 247-2 Entered on FLSD Docket 05/02/2014 Page 15 of 22 Page 2 ATTORNEY FOR EPSTEIN VICTIMS: 'l HAVE NEVER SEEN A STRANGER CASE’ Palm Beach Daily News September 20, 2009 Sunday North Palm Beach criminal defense attormey Barry Maxwell said he is not surprised that federal charges weren't filed. “My experience has been that the federal government does not intervene in sex-assault cases, except if we're deal- ing with a serial rapist or it crosses jurisdictional lines," Maxwell said, "It's either not a big enough case or not atrocious enough for them.” Epstein, 56, served 13 months of his 18-month sentence at the Palm Beach County Stockade and received liberal work-release privileges while in jail. He was able to go to his West Palm Beach office six days a week for up to 16 hours a day. . He is now serving one year of probation at his Palm Beach mansion and is registered as a lifelong sex offender. Epstein ‘fully abided' by deal, says defense Epstein's attorney Jack Goldberger released the following statement: "This document relates to allegations that were made many years ago. It was by its provisions and agreement of the parties to remain confidential in part to protect the identities of collateral third parties. "Mr. Epstein has fully abided by all of its terms and conditions. He is looking forward to putting this difficult peri- od of his life behind him. He is continuing his longstanding history of science philanthropy both here in South Florida and nationwide," Goldberger had blocked the unseating by filing court papers asking that the documents stay sealed “to prevent a se- rious imminent threat to the fair, impartial and orderly administration of justice; to protect a compelling government interest; to avoid substantial injury to innocent third parties; and to avoid substantial injury to a party by disclosure of matters protected by a common law and privacy right, not generally inherent in these specific type of proceedings, sought to be closed,” Circuit Judge Jeffrey Colbath ordered the agreement to be unsealed in June, but Epstein's attorneys appealed the ruling to the Fourth District Court of Appeals, which affirmed Colbath's ruling. Colbath had ruled that the federal agreement ~ sealed in state court -- was improperly sealed, 'L felt it was my fault’ More than a dozen lawsuits against the billionaire money manager have been filed in federal and state court, all with similar allegations: that a minor girl was taken to Epstein's mansion on El Brillo Way and led upstairs to a spa room by one of Epstein's assistants, where he would ask the girl to perform massages and/or various sex acts, for which he would pay her. One victim, who is known as Jane Doe #5 in a federal court lawsuit against Epstein, said she didn't find out about the deal until afer it was finalized, She was 15 at the time one of her schoolmates told her she could make $200 by giv- ing a massage to a man in Palm Beach. She says she was "nervous and scared and wanted to leave" once she got to Epstein’s spa room. "I thought, I can't call my dad or my mom because I'm stuck in this situation and didn't know what to do," she said. “IL really didn't know what this man was capable of. For a long time, | felt like it was my fault and that's exactly what he wanted me to feel.” Epstein has curfew While he is serving the 12 months of house arrest at his Palm Beach home, Epstein must observe a 10 p.m. to 6 a.m. curfew, have no unsupervised contact with anyone younger than 18 and not view, own or possess pornographic or sexual materials. The indictment followed an | 1-month investigation by Palm Beach police, who said Epstein paid five underage girls for massages and sometimes sex at his El Brillo Way home. Then-State Attomey Barry Krischer declined to pros- ecute Epstein on multiple charges involving unlawful sex acts with minors, Instead, he brought the case to a grand jury, which charged Epstein on the lesser charge of soliciting prostitution. Then-Palm Beach Police Chief Michael Reiter wrote Krischer a letter asking him to recuse himself from the case. When that didn't happen, Reiter requested an FBI investigation to determine if any federal laws were broken. EFTA00191344

--=PAGE_BREAK=--

Case 9:08-cv-80736-KAM Document 247-2 Entered on FLSD Docket 05/02/2014 Page 16 of 22 Page 3 ATTORNEY FOR EPSTEIN VICTIMS: ‘Il HAVE NEVER SEEN A STRANGER CASE' Palm Beach Daily News September 20, 2009 Sunday ‘Out of the ordinary’ West Palm Beach criminal defense attorney Gregg Lerman said several aspects of the Epstein case are unusual. "I don't understand why it would be a federal case in this circumstance, and why was there anything in writing at all and why did they seal the agreement?" Lerman said. "Why did it go to the grand jury instead of through the state filing lewd assault charges? That's unusual, And it's very unusual that they structure a plea to get county time rather than prison time, That's definitely out of the ordinary, Nobody goes to county jail as a state criminal punishment." ~~ mdargan @pbdailynews.com GRAPHIC: Caption: Epstein Deal does not allow prosecution of co- conspirators. LOAD-DATE: September 1, 2010 EFTA00191345

--=PAGE_BREAK=--

+ Case 9:08-cv-80736-KAM Document 247-2 Entered on FLSD Docket 05/02/2014 Page 17 of 22 v Local News West Palm Beach, Palm Beach County, Martin & St. Lucie Counties | The Palm Beach Post 4/6/11 138 PM @ Palen Beachy Post | cpceeemy tn , CLEANS OUT UP TO 40% OF NEWS | Reemecery | SLUDGE IN THE IST OIL CHANGE* ake Sutscrie Hee "Vee a9 weve sags ro Pom wy LF ot Jost ot, Penaeih® : Gov, SconO ‘ ite out ioe cou ring tee Local News ©) Greater Palm Beaches and Treasure Coast Palm Beach sex offender's secret plea deal: Possible co-conspirators not charged, presses victims to settle civil suits By SUSAN SPENCER WENDEL Palm Seach Post Stat Writer Friday, September 18, 2009 WEST PALM BEACH — Bittonaire financer sex oftender Jeffrey Epstein's socrel non-prosecution agrsement he struck with faceral prosecyiors wes unsealed Friday, offering the first public look at the deal Epsteln’s high-powered logal counsel brokerod on his behalf According the agreement, the Federal Bureau of investigation and the US Atomay’s Office investigated Epstein for various federal crimas, including prosiiiution, some pun'shable by @ minimum of 10 yoars up to Ife in priaon fut federal prosecutors backed down and agreed to rucall grand jury subpooanas, if Epsiain pleaded guilty to Grseinhem cence Pecos site td, welch ro irate aie He received an 18-month jall sentoncs, of which ha served A former federal prosecutor of 15 yoors, Mark Johnson of Stuart, sald the disparity In the potential sonionces was unusual, The Uniled States Attorney's Office also agreed not to charpe any of Epsiain’s possitie co-conspirators - Sarah Kellen, Adriana Ross, Lesley Groft and Nadie Marcinkove. The agreement was negotiated In pert by Naw York heavyweight ciminal defense amtornay Gerald Letcourt On its fret deaf in September 2007, required that Epstein pay an stlomey - tapped by tho U.S Aamvaye tien and approved by Epstein - to represent some of the victims in civil culls they had fied against Epstein. That attomey is prominent Miem! lawyer Bob Josatsberg Former prosocutcr Johnson said he has never seen 6 provislon tke that before. But an adderduen to the agreement signed the following month struck Epsiein's duty lo pay Josefeborg he and the victirns did not sccepl 6 settlement and Insised pursued litigation. ‘The agreement, signed by Assistant US Atomey Maria Villafena, does nct expressly siaie whether any victims wore contacted of consulted before the des! was made. Attomey Brad Edwards of Fort Laudordate, who reprosents three of the young women, bollaves that none of the batwoen 30 and 40 woman identified 86 victims in the federal wore Iold of the deal. Edwards sald hie cllonis were atl! receving letters in the mall months efterwards saying the U.S. Attorney's Office assuring them Epatoin would be prosecuted ean ane may cht lnenltn tind by the wernan. who are repranecied by w verily altornays In many, the facta alleged are the same that Epstein had » prediection for teenage girls, Kdentifed poor, vutnerable ones and lured the to his home vie other young women. The teens describe escanding a staircase Ened with nude photographs of young girls and to the spe rocen where Epstein would appear in a small towel Formar Circuit Judge Bill Bergor, who represents one of the victims, and The Pein Beach Post sought the unseoling of the agroement. Berger refers to it as & “eweothear deal “Why was It #0 Important for the govormment to make this deal?* Borger asked rhetorically "Wo heve not yet hed ‘hanast explanation by any public official as to why It was made .. and why the victim's ware sold down the river * Former federal prosecutor Ryon McCabe descrited the agroement es “very unorthodax,” Such agreements, ho sald, Bre usually reserved for corporations, no! individuals itp //www.palmbeachpost.com/pbewest/ content /local_news /epaper/2009/09/ 18/091 8epsteln.html © Site O Wed Web Search by YAHOO! Obama Launches Mortgage Relief Plan Il you owe less than $729,000 on your morgage, you probably qualify tor the President's Making Home Affordable Program With rales lower than they've ever been there has never been a better time to rafinance if you are a homeowner and you haven't looked into refinancing recently you may be surprised at how much you can save Select Your Age: Calculste New House Payment COLUMNISTS AND BLOGGERS FRANK CERABINO Road Frank's Intest coumns ‘ond follow him on Twitter Reed moro HOT CELEBRITY NEWS MOST POPULAR Fatal shooting in Delray Beach draws crowd of 100 onlookers: Lake Worth mayor says The Cottege complaints use ‘Oay cart against city manager : Wost Paim Beach mayor: Fimfghierlayotte tly Narey Noveck charged in 2006 Fort Lauderdale killing of her mothar-intaw Boynicn Police war ef naw twist on ATM identity fraud FOLLOW THE POST ON TWITTER SIGN UP FOR MOBILE TEXT ALERTS The Palm Beach Post onficeno: Uke | 16,985 people like The Patm Beach Post Page lof} EFTA00191346

--=PAGE_BREAK=--

V Case 9:08-cv-80736-KAM Document 247-2 Entered on FLSD Docket 05/02/2014 Page 18 of 22 Local News West Palm Beach, Palen Beach County, Martin & St. Lucie Counties | The Palm Beach Post “U's very, very rare. I've never seen or hosed of the procedure thal was set up hore” sald McCabe who has no Invotvement in any Epsiein litigation and Is now 8 securities litgation atiornay "He's essentially avoiding foderal prosecution because he can ettord to pay that many lawyers to help those vicims rewew their cases. If 8 person has no money he couldn't be able to strike a deal like this and avoid federal prosecution.” ‘The beck-room doa! with federal prosecutors all the more interesting in ight of the lagal hoavywelghts who have worked for Epstein. including Harvard professor Alan Dershowitz end Kenneth Siar of Clinton impeachment fame Letcourt in past president of the National Assocation of Criminal Defense Lawyers Epstote’s local defense nfompy. Jack Goldbergor, Issued a statement Friday saying he had fought te release of the sealed agreement to protect the third partes numod there “Mr. Epstein hes fully ablded by oll of its terms and conditens. He is looking forward to putting this cificult porod in his iife behind him He is continuing his long standing history of science philanthropy .* Epstein ended up avoiding federal charges, and ploaded guilty in stata court lo felony solicitation of prostituiion and procuring # parson under the ege of 16 for prostitution in July 2006, he was sentenced to 18 months in jail, and later eflowed out up to six days = week on work releaso Epstein tof the jail in tuto Juty 2009 after serving not quite 13 months of the sentence, having eamed gain time for good behavior Palm Bench Police bogan investigating the “Intemational manayman of mystery,” as tho New York magazine dubbed him, aftr they recelved a complaint from a relative of a 14-year-old git who hed given Epstein a nakod Massage at his home on the Intracoastal Waterway Police sought and found In poor neighborhoods 6 verlaty of tall, thin, modeldike young women, who told stories of begin recruiting. then going to Epatein's home and massaging and stimulating him. They walked away with between $200 and $1,000. ‘The Investigation triggered tensions between polce and prosecutors. with Hhen-Chial Michnel Reller saying ina May 2006 letter to hon-State Attomey Barry Kriecher that the chief prosecutor should disqualify himeelf “tl continue to find your office's treatment of thase cases highly unusual," Reiter wrote He en asked for and got (he federal investigation that ended in he sosied dos! “The Joffrey Epstein matter was an experience of whet a many~nilion-dotlar defense can eccomplsh.* Reiter told the Palm Beach Dally Nows upon Ns rotiroment. http //www.palmbeachpost.com/pbewest/content/local_news/epaper/2009/09/18/0918epstein.htm! 4/6/1112 38 PM RIN Woady vere Beka Recent Activity ea | You need to be lagged nto f ebook te Ser yinat fr ends! actevity Cerabing; Florida House GOP's ‘wierus® ban: A free-speech battle is horn 1,518 people shared this. ' Foreclosure crisis. Fed -up Judges crack f£ down disorder in the courts 207 people shared this. | EE] Facedeot sous plogin POSTPIX » Lalost nows phatos SELBY SHOES 561-969-9369 IN THE SHADE INC 772-223-4212 BELTONE 561-948-3049 MARIO’S MEATS 561-469-7019 SELBY SHOES 561-969-9360 Historic Archive (1897 - 1988) Search Wstaric edillons of The Pain Booch Post, Pals Baach Dally Nows. Mami Nows and more i's roe! Page 2 of 3 EFTA00191347

--=PAGE_BREAK=--

Case 9:08-cv-80736-KAM Document 247-2 Entered on FLSD Docket 05/02/2014 Page 19 of 22 Page | @ LexisNexis® 7 of 1) DOCUMENTS Copyright 2009 ProQuest Information and Learning All Rights Reserved ProQuest SuperText Copyright 2009 Palm Beach Post Palm Beach Daily News June 25, 2009 Thursday Final Edition SECTION: A SECTION; Pg. A.1 LENGTH: 557 words HEADLINE: JUDGE TO RULE ON SEALED PLEA-DEAL PAPERS TODAY BYLINE: MICHELE DARGAN, MICHELE DARGAN, Daily News Staff Writer BODY: A circuit judge will decide today whether the public will be privy to the federal government's non-prosecution deal with Jeffrey Epstein, which was sealed when the convicted sex offender pleaded guilty in June 2008 to two felony counts. Epstein, of Palm Beach, will be released from the Palm Beach County Stockade July 22, after serving less than 13 months of his 18- month sentence for procuring a minor for prostitution and solicitation of prostitution. Teri Barbera, spokeswoman for the Palm Beach County Sheriff's Office, confirmed his release date Tuesday. Epstein's projected release date had been Sept, 24, but gain time ~ which includes his participation in a work-release program -- moves the date up to July 22, Barbera said. Epstein, 56, has been in the work-release program since Oct. 10, in which he is allowed out of the stockade six days a week, from 10 a.m. to 10 p.m., to go to his West Palm Beach office, the Florida Science Foundation, monitored by an ankle bracelet and accompanied by a deputy. As part of Epstein's state plea agreement, the U.S. Attorney's Office agreed not to prosecute Epstein on federal charges as long as he fulfills all requirements of his sentence and probation. The federal non-prosecution agreement has been under seal in state court. Epstein's attorney Jack Goldberger filed court papers asking that the documents stay sealed for the following rea- sons; "to prevent a serious imminent threat to the fair, impartial and orderly administration of justice; to protect a com- pelling government interest; to avoid substantial injury to innocent third parties and to avoid substantial injury to a party by disclosure of matters protected by a common law and privacy right, not generally inherent in these specific type of proceedings, sought to be closed.” Fort Lauderdale-based attomey Brad Edwards represents three Epstein victims and has asked Circuit Judge Jeffrey Colbath to unseal the federal agreement to the public, An attorney for The Palm Beach Post also has asked that the rec- ords be unsealed, Edwards and his clients have seen the agreement after a federal judge ruled that they are allowed to see it, But that ruling bars Edwards and anyone else who sees the document from disclosing the terms to anyone else. Edwards said he wants to use that document "in the deposition of various material witnesses” relative to his cases. EFTA00191348

--=PAGE_BREAK=--

Case 9:08-cv-80736-KAM Document 247-2 Entered on FLSD Docket 05/02/2014 Page 20 of 22 Page 2 JUDGE TO RULE ON SEALED PLEA-DEAL PAPERS TODAY Palm Beach Daily News June 25, 2009 Thursday Radarontine.com has reported that Epstein has “secretly been helping the feds unravel a Ponzi scheme" related to the June 2008 indictment of two former managers of Bear Steams Mortgage Investment Fund, Epstein's rep, Howard Rubenstein, confirmed last year that Epstein is "Major Investor No. 1" in the indictment, which says he lost about $57 million. Goldberger could not be reached for comment. The Manhattan money manager has been incarcerated since June 30, when he pleaded guilty to the two felony counts. As part of the plea agreement, Epstein must serve one year of house arrest after his release and register as a life- long sex offender. In addition to the criminal case, there are more than a dozen civil lawsuits ~ both state and federal ~ pending against Epstein. All contain similar allegations: Epstein, through his employees and assistants, brought minor girls to his Palm Beach home on El Brillo Way for erotic massages and sometimes sex. -- mdargan@pbdailynews.com GRAPHIC: Caption: Epstein To be released from jail July 22. LOAD-DATE: September 1, 2010 EFTA00191349

--=PAGE_BREAK=--

Case 9:08-cv-80736-KAM Document 247-2 Entered on FLSD Docket 05/02/2014 Page 21 of 22 Page | @ LexisNexis’ 9 of 13 DOCUMENTS Copyright 2009 Sun-Sentinel Company All Rights Reserved Sun-Sentinel (Fort Lauderdale, Florida) June 15, 2009 Monday Palm Beach Edition SECTION: LOCAL; Pg. 3B LENGTH: 348 words HEADLINE: HEARING SET TO CONSIDER SECRECY OF PLEA BARGAIN BYLINE: Susan Spencer-Wendell The Palm Beach Post BODY: A Palm Beach Circuit Court judge will not immediately unseat a deal that wealthy Palm Beach money manager Jeffrey Epstein made with federal prosecutors to avoid charges, Circuit Judge Jeff Colbath acknowledged, though, at a hearing last week that Epstein's deal was not sealed in ac- cordance with state and local court rules, "I don't see where any of the procedures were ever followed to begin with," Colbath said. Colbath also set a full hearing on the matter for June 25. Attorneys for young women now suing Epstein, together with The Palm Beach Post, are asking Colbath to unseal the deal that Epstein made with federal prosecutors. "It's a secret agreement, a secret sweetheart agreement," said former Circuit Judge Bill Berger, who represents some of the women, “Everybody was in on this deal except the victims and the public. The public should be outraged it has gone as far as it has." Brad Edwards, a second attomey representing the women, has seen the sealed deal after a federal judge allowed him and his clients to view it, but would not discuss its contents. Edwards would say only that the women were “outraged” that it had been negotiated behind their backs. A reporter asked Edwards whether he thought Epstein received special treatment by federal prosecutors. “Are you kidding? It's transparent. Certainly, no one else gets treated like that," Edwards said. Epsicin, 56, a reported money manager of billionaires, is serving an 18-month sentence in the Palm Beach County Stockade after pleading guilty almost a year ago in state court to felony solicitation of prostitution and procuring (een- agers for prostitution. Epstein is allowed out, though, each day from 7 a.m. to I p.m., a Sheriff's Office spokesman said, Displeased with the way the State Attorney's Office handled the case, Palm Beach police forwarded information to the FBI. INFORMATIONAL BOX: Young women have sued EFTA00191350

--=PAGE_BREAK=--

Case 9:08-cv-80736-KAM Document 247-2 Entered on FLSD Docket 05/02/2014 Page 22 of 22 Page 2 HEARING SET TO CONSIDER SECRECY OF PLEA BARGAIN Sun-Sentinel (Fort Lauderdale, Florida) June 15, 2009 Monday Money manager Jeffrey Epstein made a deal and is serving an 18-month sentence in jail. Attomeys for young women suing Epstein are asking a judge to unseal the deal that Epstein made with federal prosecutors. NOTES: < Informational box at end of text. {TOPIC} Prostitution solicitation case LOAD-DATE: June 15, 2009 EFTA00191351

--=PAGE_BREAK=--

Case 9:08-cv-80736-KAM Document 247-3 Entered on FLSD Docket 05/02/2014 Page 1 of 13 COMPOSITE EXHIBIT 3 EFTA00191352

--=PAGE_BREAK=--

cable re -Citerirsder dnt disereunrerananos forarendnyPamertiekans Simms dct... PRaged ef 33 Eleventh Circuit rules that discovery can move forward on my Crime Victims’ Rights Act case By Paul Cassell Updated: April 21 at 9:41 am On Friday,the 11th Circuit ruled that discovery can move forward in an important Crime Victims’ Rights Act case that my co-counsel, Brad Edwards, and I are pursuing. The narrow issue before the court was whether prosecutors and defense attomeys could assert some sort of “privilege” to prevent crime victims from reviewing the correspondence that lead to a plea bargain. More broadly, the ruling means that the victims will have a chance to return to the district court and seek to invalidate a plea agreement that (we alleged) was consummated in violation of their rights, | hope that the case will ultimately set an important precedent that federal prosecutors can’t keep victims in the dark about the plea deals that they reach. Here are the important facts, taken from the 11th Circuit’s opinion: The case arose in 2006, the FBI began investigating allegations that wealthy investor Jeffrey Epstein had sexually abused dozens and dozens of minor girls. The U.S. Attorney's Office for the Southern District of Florida accepted Epstein’s case for prosecution, and the FBI issued victim notification letters to my two clients, minors Jane Doe No. | and Jane Doe No. 2, in June and August 2007. Extensive plea negotiations ensued between the prosecutors and Epstein. On Sept. 24, 2007, the prosecutors entered into a non- prosecution agreement with Epstein in which they agreed not to file any federal charges against Epstein in exchange for his guilty plea to minor Florida offenses (e.g., solicitation of prostitution). Not only did the prosecutors neglect to confer with the victims before they entered into the agreement with Epstein, they also concealed its existence for at least nine months. For example, the prosecutors sent post-agreement letters to the victims reporting that the “case is currently under investigation” and explaining that “[t]his can be a lengthy process and we request your continued patience while we conduct a thorough investigation.” On June 27, 2008, the prosecutors informed my co-counsel, Brad Edwards, that Epstein planned to plead guilty to the Florida charges three days later. But the prosecutors failed to disclose that Epstein’s pleas to those state charges arose from his federal non-prosecution agreement and that the pleas would bar a federal prosecution. As a result, the victims did not attend the state court proceedings. On July 7, 2008, Edwards and I filed a petition alleging that Jane Doe No. | was a victim of federal sex crimes committed by Epstein and that the United States had wrongfully excluded her from plea negotiations. We also alleged that the federal prosecutors had violated her rights under the Crime Victims’ Rights Act (CVRA) — http://www. washingtonpost.com/news/volokh-conspiracy/wp/2014/04/2I/eleventh-circuit-r... 5/2/2014 EFTA00191353

--=PAGE_BREAK=--

cable woth Girewy see shot diseevaneranapys fornperrbergmrcementelan Sieh id... PRege? af 33 specifically her rights to confer with the government, to be treated with fairness, to receive timely notice of relevant court proceedings, and to receive information about restitution. The United States responded by claiming that it used its “best efforts” to comply with the rights afforded to victims under the CVRA, but that the act did not apply to pre-indictment negotiations with potential federal defendants, After Jane Doe No, 2 joined the initial petition, the district court (Marra, J.) found that both women qualified as “crime victims” under the CVRA. The district court later rejected the government’s argument that the act only applies after the filing of a federal criminal indictment. (I’ve written a law review article about the issue of how early crime victims’ rights attach in the criminal process, which can be downloaded here.) Among other relief, we sought rescission of the non-prosecution agreement as a remedy for the violation of the victims’ rights. To make the case for such a remedy, we moved for discovery of the correspondence between the U.S. and Epstein’s attomeys during the plea negotiations, Epstein’s attorneys intervened, arguing that Federal Rule of Evidence 410 and Federal Rule of Criminal Procedure 11 create a privilege for plea negotiations, barring release of the correspondence. They also argued that the court should find that the materials were protected under the work product doctrine or, alternatively, should be protected under a new “common-law privilege for plea negotiations.” The district court first ruled that rescission of the plea agreement was a possible remedy under the act, The court then ruled that we were entitled to review the correspondence, rejecting all of Epstein’s arguments. On Friday, the 11th Circuit affirmed the district court’s ruling that we could review . At pp. 18-22 of its published opinion, the court concluded that there was no basis for restricting access to such correspondence when crime victims have a legitimate need to review it. The court rejected, for example, the work product argument because plea discussions are not confidential: Disclosure of work-product materials to an adversary waives the work-product privilege. See, e.g., Jn re Chrysler Motors Corp. Overnight Evaluation Program Litig., 860 F.2d 844, 846 (8th Cir. 1988); Jn re Doe, 662 F.2d 1073, 1081-82 (4th Cir, 1981). Even if it shared the common goal of reaching a quick settlement, the United States was undoubtedly adverse to Epstein during its investigation of him for federal offenses, and the intervenors’ disclosure of their work product waived any claim of privilege. ... The court also declined to recognize a new privilege for plea bargaining, finding the relationship between prosecutors and defense attorneys did not need special protection: As a last-ditch effort, the intervenors contend that “[i]f more is needed in addition to the plain language of Rule 410 to preclude disclosure of the correspondence to plaintiffs, it can be found in the conjunction of Rule 410, the work-product privilege, and the Sixth Amendment right to the effective assistance of counsel in the plea bargaining process,” but this novel argument fails too. As explained above, Rule 410 http://www.washingtonpost.com/news/volokh-conspiracy/wp/2014/04/21/eleventh-circuit-r.... 5/2/2014 EFTA00191354

--=PAGE_BREAK=--

cablevrod Ginsu sue Anat diseeveneraDarys fennwihanmeCepebickwen sights... Rages of 33 does not create a privilege and the intervenors waived any work-product privilege. The intervenors concede too that the right to counsel under the Sixth Amendment had not yet attached when the correspondence was exchanged. Lumleyfp. City of Dade City, Fla., 327 F.3d 1186, 1195 (11th Cir. 2003) (“[T]he Sixth Amendment right to counsel ordinarily does not arise until there is a formal commitment by the government to prosecute,” such as a “formal charge, preliminary hearing, indictment, information, or arraignment.”). The “conjunctive” power of three false claims of privilege does not rescue the correspondence from disclosure. . . . The Supreme Court has identified several considerations relevant to whether a court should recognize an evidentiary privilege—the needs of the public, whether the privilege is rooted in the imperative for confidence and trust, the evidentiary benefit of the denial of the privilege, and any consensus among the states, Jaffee. Redmond, 518 U.S. 1, 10-15 (1996)—but none of these considerations weighs in favor of recognizing a new privilege to prevent discovery of the plea negotiations. Although plea negotiations are vital to the functioning of the criminal justice system, a prosecutor and target of a criminal investigation do not enjoy a relationship of confidence and trust when they negotiate. Their adversarial relationship, unlike the confidential relationship of a doctor and patient or attorney and client, warrants no privilege beyond the terms of Rule 410. See Jaffee, 518 U.S. at 10. But the victims would enjoy an evidentiary benefit from the disclosure of plea negotiations to prove whether the United States violated their rights under the Act. Moving forward, this case raises the important issue of what kinds of remedies are available for violations of the Crime Victims’ Rights Act. Our complaint alleges that, prodded by Epstein, the federal prosecutors deliberately concealed the sweetheart plea deal they had reached with him to avoid public criticism of the deal. I am hopeful that in future district court proceedings, we will be able to prove that clear violation of the CVRA and then obtain the remedy of invalidating the illegally- negotiated plea deal. © The Washington Post Company http://www. washingtonpost.com/news’volokh-conspiracy/wp/2014/04/21/eleventh-circuit-r... 5/2/2014 EFTA00191355

--=PAGE_BREAK=--

CaSOReas oy cyise seaine! ssKaiirRdars saw -PelaoRaahsaibineysisABKet 05/02/2014 PReRed af 33 Follow us on Friday, May 2, 2014 | 3:56 p.m Subscribe | Today's paper | Customer care Sign In | Register the shiny sheet | Search | Posted: 12:00 a.m. Monday. April 21, 2014 Appeals court rules against sex offender Attorneys for underage victims seek to overturn ‘sweetheart plea.’ Related By Michele Dargan Daily News Staff Writer Underage victims of billionaire sex offender Jeffrey Epstein are entitled to correspondence between federal prosecutors and Epstein’s attorneys related to his sweetheart plea deal, a federal appeals court ruled Friday. This is one more step in the fight by victims’ attorneys Brad Edwards and Paul Cassell to overturn the secret deal. which saved Epstein from facing serious federal charges and serving significant prison time. If Epstein had been found guilty on federal charges, statutory penalties ranged from 10 years to life in prison Instead, the sealed pact was part and parcel of Epstein's acceptance of a state plea deal Epstein pleaded guilty to soliciting a minor for prostitution and soliciting prostitution. He received an 18-month sentence. in a vacant wing of the Palm Beach County Stockade, and was let oul on work release six days a week for up to 16 hours a day, Edwards and Cassell represent Jane Doe No. 1 and Jane Doe No, 2, who say the U.S. Attorney's Office violated the Crime Victims’ Rights Act by signing the federal non-prosecution agreement in 2007 without notifying the victims. Their case is pending in U.S. District Court in West Palm Beach. The 24-page published opinion says U S. District Judge Kenneth Marra did not err in his June 2013 ruling. when he ordered the correspondence turned over to the victims. “Sweetheart plea’ “We're now going to get a complete picture of the negotiations that led to this sweetheart plea arrangement,’ said Cassell. a former federal judge. “We think it will show the part of the discussion to keep the victims in the dark about what was happening, If that's what the correspondence shows, we'll use that as part of our argument for throwing out the plea,” Cassell said he anticipates thal 500 pages of correspondence should be released early this week The opinion by the three-judge panel ruled against Epstein's arguments thal the correspondence was protected by an attorney's work-product privilege. The court says privilege was waived when attorneys voluntarily sent the correspondence to federal prosecutors during negotiations. “Disclosure of work-product materials to an adversary waives the work-product privilege,” the tuling says. http://www.palmbeachdailynews.com/news/news/local/appeals-court-rules-against-sex-offe... 5/2/2014 EFTA00191356

--=PAGE_BREAK=--

Cadermals condoyiss againgt gos alinediy d-y nalnoraahsai brspsoeeket 05/02/2014 Phepeé af 23 The ruling also dismissed Epstein's claims that a federal rule of evidence protects his plea correspondence. That rule applies only to defendants who withdraw a guilty plea, Because he pleaded guilty, that doesn't apply, the ruling says. “While respectful of the panel's decision, given issues of overriding importance to the criminal justice system regarding the need for continued confidentiality for communications between defense lawyers and prosecutors, we will be petitioning the court of appeals for further review,” said Boston based atlorney Martin Weinberg, who represents Epstein. The U.S. Attorney's Office failed to notify victims prior to striking a non-prosecution agreement with Epstein on Sept. 24, 2007, and didn't tell them of the agreement's existence for at least nine months, the ruling says. On June 27, 2008, the U.S. Attorney's Office told the victims that Epstein planned to plead guilty to state charges three days later. But federal prosecutors failed to disclose that his pleas to the state charges arose from his federal non- prosecution agreement and would bar federal charges. Jane Does No. 1 and No. 2, who were, respectively, 12 and 13 at the time they were victimized, received confidential monetary settlements in civil cases. They are among more than two dozen underage girls who filed lawsuits or settled claims against Epstein. All alleged they were lured to his Palm Beach mansion to give him sexually charged massages and/or sex in exchange for money. “A well-connected billionaire got away with molesting many girls,” Edwards said. “These girls should al least know how and why he was able fo get away with these crimes. This ruling will allow us access to the documents that will provide insight into how that happened. | suspect that the answers revealed by these documents will ultimately allow us to invalidate that agreement and permil prosecution of Mr. Epstein.” More News We Recommend From Around the Web * Appeals-court decision in Epstein case rights a * Bad Neighborhoods: How to Read the Warning terrible wrong (Palm Beach Daily News) * Memorial service set for former ‘Daily News’ reporter (Palm Beach Daily News) * Ernest S. Johnston Jr. (Palm Beach Daily News) * Choosing plants? There's always something new (Palm Beach Daily News) + Stale restripes Royal Palm iniersections (Palm Beach Daily News) * Eunice “Penny” Jacobs (Palm Beach Daily News) Signs Before You Move in (realtor.com) The 5 Most Dangerous Cities in the U.S. (AARP) Stunning Photos Of Leonardo DiCaprio's For Sale Home (Lonny Magazine) Rosie O'Donnell Is Buying Olivia Newton-John's Florida Estate For $5.6 Million... See The Pictures (Lonny) Andy Griffith's Widow to Raze His Home (AARP) Supermodel Heidi Klum's Kid Is Growing Up Gorgeous (StyleBistro) Comments MH you would like to post a comment please Sign in or Register | Cancel | Edit comment | 2 Comment(s) Comment(s) 1-2 of 2 * Posted by THEPALMBEACHER1 at 3:02 p.m. Apr 21. 2014 + Report Abuse \ts inconceivable to see articles like this!’ USUALLY, one gets charged with statutory rape, child molestation, etc., and its Guaranteed that they will do prison time.. Now, If your a “BILLIONAIRE”. you can BUY yourself freedom, and throw money fo the victims and say adios!""! Its OBVIOUS, payments, kickbacks. DONATIONS, financial promises are all part of this deal. Where is the JUSTICE SYSTEM? Where is the State Attorney, The JUDGES? People go to jail for petty thefts, illegal drugs, assault, battery, domestic violence, but this case is PROOF that the LEGAL system can be BOUGHT for the right price!!! Its OBVIOUS this individual has a severe mental problem, a sexual predator, who would ship young girls like human trafficking back and forth via his private jets. Its no different than "THE BACKPAGE" girls being exploited by their pimps http://www.palmbeachdailynews.com/news/news/local/appeals-court-rules-against-sex-offe... 5/2/2014 EFTA00191357

--=PAGE_BREAK=--

Cade Rds <a cy ss AeAiE! W558 alfRRFATa amy Rel Ibis wssebket 05/02/2014 Phage? of 33 being housed in cheap motels along federal hwy for GUY LIKE THIS to get their sexual perversions satisfied!! Read the entire case and see that young girls flowed thru Palm Beach South Ocean Blvd and South County Rd to his El Brillo "MANSION OF PERVERSION” with this guy as its Master!! For people to think "Palm Beach" has the "Elite", the “Upper Crust" of society, it also is home to some of the worst thieves, sexual predators, financial criminals the world has ever known!! Mr Epstein has Billions of Dollars, and can afford the Best Criminal Attorneys, yet Can't or WON'T get Professional Mental Help with his sexual desires and fascination with young girls. And the Court systems goes along with him!!! Unbelievabie.. + Posted by Adios at 3:12 p.m. Apr 22, 2014 + Report Abuse | agree with the post by the palm bleacher. This guy is a perv and needs to sit oul of sociely. When listening to his depositions, he pretended to be insulted by the questions being asked of him and his lawyer shut it down quickly What remains to be seen is if the soon lo be released files will bear the fruit we all hope it does. My worry is that the tracks will be covered and he will not get his due His opinion of himself allows him to think he did nothing wrong and these BABIES he molested were not of his place in society and were simply objects to be thrown away. What would he think if someone did that to his BABIES if he has any? | can bet that the full force of his money would work against whomever played with his kids. . ...bloody gross! 2 Comment(s) Comment(s) 1-2 of 2 . Simg height="1" width="1" src="http://segments.adap.tv/data/? p=recruemedialic&type=gif&segment= 848 add=true http://www.palmbeachdaily news.com/news/news/local/appeals-court-rules-against-sex-offe... 5/2/2014 EFTA00191358

--=PAGE_BREAK=--

caXiPh BAP B6PSIP RAIN CePHRiAne Hiss lee ‘enkenbalenaereses ent aebibinnsirecien... Reged af 33 sun-sentinel,com/news/palm-beach/fl-jeffrey-epstein-federal-court-of-appeals- 2014042 1,0,6594687.story Sun Sentinel Victims win right to see negotiations that led to 'lenient' plea agreement for billionaire sex offender Latest in legal saga involving Jeffrey Epstein, 61, financier convicted of procuring minor for prostitution By Brett Clarkson, Sun Sentinel 7:43 PM EDT, April 21, 2014 Did a Palm Beach billionaire being investigated for having sex with young girls use his avvertisement wealth to negotiate a lenient and secret agreement that saw him avoid federal prosecution? Attomeys for two victims, known only as Jane Doe | and 2, may soon get an answer thanks to an appeals court ruling against financier and sex offender Jeffrey Epstein, 61. The ruling, issued Friday, orders federal authorities to disclose the correspondence that took place between Epstein's attorneys and federal prosecutors when they were negotiating a 2007 agreement, which allowed him to escape federal prosecution if he pleaded guilty to state charges that carried a lesser penalty. "We're trying to figure out if Epstein used his political connections and great wealth to secure this kind of arrangement, that was unheard of, frankly, if you look at these charges," said Paul Cassell, an attorney for the women. Epstein is a native New Yorker who according to media reports built a huge fortune as a money manager and owns several properties including a primary residence in Manhattan, a Palm Beach mansion and his own island in the Caribbean. At one point he counted among his friends former President Bill Clinton, Donald Trump and other high-powered figures. The appeal court decision described the background of Epstein's case, stating that in 2006, the Federal Bureau of Investigation "began investigating allegations that Jeffrey Epstein had sexually abused several minor girls.” In September 2007, federal prosecutors struck the non-prosecution deal with Epstein, but didn't tell the victims, court filings say, “Not only did the United States neglect to confer with the victims before it entered into the agreement with Epstein, it also failed to notify them of its existence for at least nine months," Circuit Judge William H. Pryor wrote in the appeals court decision. http://www.sun-sentinel.con/news/palm-beach/fl-jeffrey-epstein-federal-court-of-appeals-2... 5/2/2014 EFTA00191359

--=PAGE_BREAK=--

Ca¥iruop vin. sabsip rcameepiintione Hid len & ‘enientales seresroqns fecbitinnsine sey... PRages af 33 In June 2008, Epstein pleaded guilty to a state charge of procuring a person under the age of 18 for prostitution and was sentenced to 18 months in prison. He spent 13 months behind bars, and is registered as a sex offender in Florida. The situation also resulted in civil suits being filed against Epstein, who according to media reports settled claims from about two dozen young women who alleged he paid them for sexual massages at his Palm Beach mansion, some as young as 14, according to media reports. To the attorneys who represent the Jane Does | and 2, the sentence was much lighter than the years, or possibly decades, that Epstein could've spent behind bars had he been prosecuted in the federal system. They're hoping that the correspondence, ordered released by the Eleventh Circuit Court of Appeals, will shed light on what they say is an unusually lenient deal. "I can say that I've been teaching criminal law for more than two decades and I have never seen a plea agreement as lenient as this one, for hands-on sex offenders," said Cassell, who is based in Salt Lake City. But one of Epstein's attorney's, Martin Weinberg, based in Boston, disputed those characterizations. Weinberg said Monday that the plea agreement was "reached in good faith" and that "it's not a fair conclusion" to describe the agreement as either improper or tainted by Epstein's wealth. "It's Mr. Cassell's hope that this correspondence may support that theory, but the reality is that the U.S. Attorney's Office made a responsible judgment in how to implement the law," Weinberg said. Weinberg said he was concerned about the potential impact the ruling would have on the ability of criminal defense attorneys and prosecutors to communicate confidentially. He also said he and Epstein co-counsel, Miami criminal defense attorney Roy Black, will ask the Atlanta-based appeals court to review the decision. As for the Jane Does, who are now over 18, it's just the latest development in a long legal saga, another one of their attorneys said. "They're pretty numb at this point to favorable news because they've heard this before and nothing's happened," said Fort Lauderdale attorney Brad Edwards. Edwards and Cassel said their goal is to have Epstein's plea agreement deemed to be in violation of federal victims' rights legislation and invalidated. Edwards said Epstein should face a new prosecution. Edwards also said he was first told by the U.S. Attorney's Office that he would receive the correspondence documents on Monday, but was then told that they weren't ready yet. Cassell said the documents number 500 pages. In an email, Annette Castillo, spokeswoman for the U.S. Attorney's Office, Southern District of Florida, said the office couldn't comment. bsclarkson@iribune.com, 561-243-6609 or Twitter @BrettClarkson http://www.sun-sentinel.com/news/palm-beach/fl-jeffrey-epstein-federal-court-of-appeals-2..._ 5/2/2014 EFTA00191360

--=PAGE_BREAK=--

CASHES AYE ER 48 RARRE WBA haldad 1g "eeHietedPBfPreSe Bi SeK Al USE ee ts Page defo Copyright © 2014, South Florida Sun-Sentinel http://www.sun-sentinel.com/news/palm-beach/f1-jeffrey-epstein-federal-court-of-appeals-2,.. 5/2/2014 EFTA00191361

--=PAGE_BREAK=--

szaniCase 9:08-cv-80736-KAMiaDoopment 2 472 6 redantered com BL SOyDeoketeO64022014 Page 11 of 1:87 L:74* @ Friday, May 2, 2014 The Palm Beach Post NEWS STARTS HERE Sign Out Search Site Q HOME / NEWS aheretemenl Resitet A A.A Appellate ruling could force feds to reconsider sex charges against Palm Beacher Epstein Posted. 9.25 ..m Monday. April 21, 2014 BY DAPHNE DURET - PALMBEACH POST STAFF WRITER A federal appellate court has moved two young victims of billionaire sex offender Jeflrey Epstein a step closer to wiping out a plea deal that prosecutors made behind their backs. The lth Circuit Court of Appeals ruled Friday that the underage victims were entitled to see all correspondence between federal prosecutors and Epstein's lawyers regarding a secret 2007 plea deal that kept Epstein from federal charges in exchange for an 18-month work-release sentence in state prison, The plea negotiations took place as Epstein litigated a series of now-settled civil claims surrounding allegations that he had sex in his Palm Beach mansion with dozens of underage girls. The two victims who are seeking the documents are not identified in court documents. They were 12 and 13 at hitp./Nwaw. mypal mbeachpos |. comynews news /appellale-ru!ing could-force-feds-to-reconsider-se/nifLw#?icid= pbp_internallink_mypopinutabionbox_feb2014 99eda 1/6 EFTA00191362

--=PAGE_BREAK=--

s20Case 9:08-cf]-80736-kK AtMiaDoopiment 24% 8 rofamtered POF. SOMDaoloetOGH0 240014 Page 12 of the time of their liaisons with Epstein, who pleaded guilty to two prostitution solicitation charges. The girls reached an out-of-court settlement with him. In ruling that the correspondence should be public, the appellate court authorized the release of more than 500 pages of documents. The victims’ lawyers would use the documents to prove that, by keeping the agreement secret, prosecutors violated a federal act aimed at protecting victims’ rights. A win in that battle could invalidate Epstein's agreement with federal prosecutors, allowing them to reconsider criminal charges, but this time with input from the victims. Epstein’s lawyers argued that the correspondence constituted confidential plea negotiations and therefore should not be shared with the victims’ lawyers. “Although plea negotiations are vital to the functioning of the criminal justice system, a prosecutor and target ofa criminal investigation do not enjoy a relationship of confidence and trust when they negotiate,” the appellate justices wrote, calling the prosecutor-defense attorney relationship adversarial. They upheld a 2013 ruling by US, District Court Judge Kenneth Marra. He ordered the release of all the plea documents, but only federal prosecutors complied. The victims’ attorneys, Brad Edwards and Paul Cassell, have called the ruling a victory for the rights of victims to be heard, even in cases like Epstein's, where federal prosecutors ultimately never filed charges. The victims were unaware of the plea agreement until three days before Epstein pleaded to the state charges in June 2008, A federal deal had been in place for nine months by then. Had prosecutors filed charges and negotiated a plea with Epstein in federal court, they would be barred from seeking any additional punishment against him. But because his plea agreement to a sex solicitation charge came in state court, federal prosecutors theoretically could charge him again. Still, Epstein’s lawyers could argue that the only reason he agreed to the state sentence was because he believed it would free him of the federal charges for good. Edwards said Epstein’s attorneys have made parts of those arguments in pre-trial hearings, and he expects them to appeal Friday's ruling. Epstein's Boston- based attorney, Martin Weinberg, told the Palm Beach Daily News he would appeal. “While respectful of the panel's decision, given issues of overriding importance to the criminal justice system regarding the need for continued confidentiality for communications between defense lawyers and prosecutors, we will be petitioning the court of appeals for further review,” Weinberg told the paper. Invalidating Epstein’s plea would force federal prosecutors to meet with the alleged victims to hear their comments on whether to pursue charges against Epstein. They still could decline. “You can't force the federal government to prosecute anyone,” Edwards said. “But we're hoping that if maybe hitpd/www, mypal mbeachpos |. comYnews/news/appellate-ruting -could-force-feds-to-reconsider-se/nflLw/7icid=pbp_internallink_mypbpinvlationbox_feb2014_99eda 26 EFTA00191363

--=PAGE_BREAK=--

s20Case 9:08-cv-80736-KAMIAwcuTnerit 24% @ ekmtered tan RL SO DyeRetOHOR2014 Page 13 of we get some new eyes on the case and the circumstanck$ are different, things will change.” In this Section Palm Beach County Sheriff's Office offers salute to 16 fallen in the line of duly over the decades Free move al Boynton's Dewey Park on Friday Boynton Beach officers stop to investigate Camaro, witness theft of BMW; pursuit ends in crash Greenacres single-family home development moving forward Our Economy. Gardens complex lands 3 sizeable businesses Morning commute on 195, turnpike clear of crashes from Baca to Vero Find out how to work on the Riviera Beach marina development Royal Palm Beach Publix sells Fantasy 5 ticket now worth more than $111K Sun, rain today and mostly rain Saturday in Paim Beach County, TCoast 3 NYPD officers arrested in separate gun incidents PREVIOUS: NEXT: LOCAL OPINION Tequesta crash sends seven people to Commentary: Has GM pulled a Pinto? hospitals Popular on MyPalmBeachPost.com COMMENTS Post comment hitpJwew. mypal mbeachpos | com/news/news/appellate-ruling-could-force-feds-to-reconsider-se/nifLw/?icid= pbp_internallink_mypbpinvilationbox_feb2014 9Scda V6 EFTA00191364

--=PAGE_BREAK=--

PRIVILEGE LOG File folder entitled “CORR RE GJ SUBPOENAS?” containing correspondence related to various grand jury subpoenas and Privilege(s) Asserted 6(e) Work Product Box #1 P-000040 thru P-000549 6(e) Work Product Contains documents subject to investigative privilege Also contains documents subject to privacy rights of victims who are not parties to this litigation 6(e) Contains information subject to investigative privilege Also contains information subject to privacy rights of victims who are not parties to this litigation 6(e) Contains information subject to investigative privilege Also contains information subject to privacy rights of victims who are not parties to this litigation Work Product Contains information subject to investigative privilege Operation Leap Year Grand Jury Log containing subpoenas OLY-01 through OLY-81, correspondence and research related to enforcement of same, documents produced in response to some subpoenas; and attorney (Villafaiia) handwritten notes Box #1 P-000550 thru P-000621 File folder entitled “Ritz Compact Flash SW” containing copies of a sealed search warrant application, warrant, and supporting documents File folder entitled “PNY Technologies Compact Flash SW” containing copies of a sealed search warrant application, warrant, and supporting documents Box #1 P-000694 thru P-000781 File folder entitled “JE Corporations” containing attorney research on Epstein-owned corporations and prior litigation File folder entitled “Capital One” containing subpoena and correspondence File folder entitled ‘DTG Operations/Dollar Rent-a-Car” containing subpoena and responsive documents 6(e) Contains documents and information subject to investigative privilege Also contains documents and information subject to privacy rights of victims who are not parties to this litigation Page 1 of 23 EFTA00191365

--=PAGE_BREAK=--

Box #1 P-000855 thru P-000937 Box #1 P-000938 thru P-000947 Box #1 P-000948 thru P-000982 6(e) Contains documents and information subject to investigative privilege 6(e) Contains documents and information subject to investigative privilege Work Product Attorney-Client Contains information subject to investigative privilege. Also contains information subject to privacy rights of victims who are not parties to this litigation Work product 6(e) Contains information subject to investigative privilege. Also contains information subject to privacy rights of victims who are not parties to this litigation Work Product 6(e) Contains information subject to investigative privilege. Also contains information subject to privacy rights of victims who are not parties to this litigation 6(e) Contains information subject to investigative privilege File folder entitled “JP Morgan Chase” containing subpoena, correspondence, and responsive documents File folder entitled “Washington Mutual” containing subpoena, correspondence, and responsive documents File folder entitled “Computer Search &” containing legal research on computer search and handwritten notes on indictment preparation File folder entitled “Attorney Notes from Document Review” containing typed and handwritten attorney (Villafaiia) notes, target letters, correspondence re grand jury subpoena File folder entitled “Notes from Fed Ex Records” containing handwritten and typed attorney (Villafaiia) notes and screen shots of FedEx subpoena response electronic file Box #1 P-001057 thru P-001959 Box #1 File folder entitled “Colonial Bank Records” containing records received in response to grand jury subpoena File folder entitled “OLY Grand Jury Log Vol 2: 6(e) P-001960 OLY-51 THROUGH” containing subpoenas Contains information subject Thru numbered OLY-51 through OLY-81 with related to investigative privilege. P-002089 correspondence Also contains information subject to privacy rights of victims who are not parties to this litigation Page 2 of 23 EFTA00191366

--=PAGE_BREAK=--

6(e) Contains information and documents subject to investigative privilege 6(e) Contains information and documents subject to investigative privilege 6(e) Contains information and documents subject to investigative privilege Work product 6(e) Contains information and documents subject to investigative privilege. Also contains information and documents subject to privacy rights of victims who are not parties to this litigation Work product File folder entitled “Epstein Corporate Records: OLY-SI, OLY-52, OLY-53, OLY-54” containing subpoenas, records received in response to subpoenas, and related correspondence File folder entitled “Colonial Bank” containing subpoenas, correspondence related to subpoenas, records received in response to subpoenas File folder entitled “JEGE & Hyperion from Goldberger OLY-46 & OLY-47” containing documents received in response to subpoenas Indictment preparation binder containing: Grand jury subpoena log, evidence/activity summary chart, witness/victim names and contact list, attorney (Villafaiia) handwritten notes, 302s, portions of state investigative file, attorney (Villafafia) typed notes, of individuals listed as “Additional victims” P-002386 Box #! Indictment preparation binder containing: P-002387 Grand jury subpoena log, evidence/activity 6(e) Thru summary chart, witness/victim names and contact Contains information and P-002769 list, attorney (Villafafia) handwritten notes, 302s, documents subject to investigative privilege. Also contains information and documents subject to privacy rights of victims who are not parties to this litigation portions of state investigative file, attorney (Villafaiia) typed notes, relevant pieces of grand jury materials, telephone records/flight records analysis charts, victim/witness photographs, DAVID records, NCICs, and related materials for persons identified as Jane Does #15, 16, 17, 18, 19, Past Employees, Misc. Witnesses Indictment preparation binder containing: Box #1 Work product P-002770 witness/victim list with identifying information, 6(e) Thru sexual activity summary, telephone call summary Contains information and P-003211 chart, attorney (Villafafia) handwritten notes, documents subject to 302s, portions of state investigative file, attorney (Villafaiia) typed notes, relevant pieces of grand Jury materials, telephone records/flight records analysis charts, victim/witness photographs, DAVID records, NCICs, and related materials for persons identified as Jane Does #1, 2, 3, 4, 5, 6, 7, 8 investigative privilege. Also contains information and documents subject to privacy rights of victims who are not parties to this litigation Page 3 of 23 EFTA00191367

--=PAGE_BREAK=--

|_BatesRange | Description SS i|_—Privilege(s) Asserted Box #1 Indictment preparation binder containing meta- Work product P-003212 analysis charts of telephone/flight/grand jury 6(e) Thru information for a number of victim/witnesses Contains information and P-003545 documents subject to investigative privilege. Also contains information and documents subject to privacy rights of victims who are not parties to this litigation Work product 6(e) Contains information and documents subject to investigative privilege. Also contains information and documents subject to privacy rights of victims who are not parties to this litigation Work product 6(e) Nadia Marcinkova, :ttCiOY Box #1 P-003546 Thru P-003552 FBI Reports of March 2008 interviews of additional witness/victim located in New York Box #1 P-003553 Thru P-003555B Box #1 P-003556 Printout of filenames from Federal Express subpoena response with Attorney notations Document entitled “Identified Numbers” with accompanying handwritten attorney list compiled from grand jury materials and attorney analysis of records Folder entitled “Flight Manifests” containing manifests received pursuant to grand jury subpoena Work product 6(e) Contains information subject to investigative privilege 6(e) Contains information and documents subject to investigative privilege Work product 6(e) Investigative privilege Deliberative Work product Attorney-client privilege 6(e) Investigative privilege Also contains information and documents subject to privacy rights of victims who are not parties to this litigation Box #1 P-003563 File folder entitled “Recent Attorney Notes” containing handwritten attorney (Villafaiia) notes regarding document review and case strategy File folder bearing victim name containing FBI interview report from May 2008, telephone activity report with attorney (Villafanaiia) handwritten notes, related grand jury material P-003646 Page 4 of 23 EFTA00191368

--=PAGE_BREAK=--

File folder entitled “Summary of Sexual Activity” containing chart bearing handwritten title “Sexual Activity — Summary” with meta-analysis of information, sorted by name of each victim/witness, including name and identifying information of each victim/witness Work product 6(e) Investigative privilege Deliberative process Also contains information and documents subject to privacy rights of victims who are not parties to this litigation Box #1 File folder entitled “Victim Civil Suits” Not privileged. P. Produced to counsel for Petitioners File folder entitled “Research re JE Websites” containing attorney research Work product File folder entitled “Serene Cano (N.Y. AUSA)” containing attorney (Villafaiia) handwritten notes Work product P-003679 Thru P-003680 File folder entitled “Dr. Anna Salter” containing attorney (Villafaiia) memo to expert witness and handwritten attorney notes Work product Investigative privilege File folder entitled “I[] G{] Interview” containing attorney handwritten notes of interview, and attorney handwritten notes regarding potential charges Work product Investigative privilege Also contains information subject to privacy rights of victims who are not parties to this litigation Work product 6(e) Investigative privilege Also contains information and documents subject to privacy rights of victims who are not parties to this litigation P-003693 File folder entitled “Research re Travel for Prostitution” containing attorney (Villafaiia) handwritten notes regarding grand jury presentation, chart entitled “Brought to Epstein’s House” with handwritten notes, Message Pad meta-analysis chart, summary of evidence related to one victim/witness, and relevant grand jury information Empty file folder bearing name of victim/witness P-003694 Thru P-003711 Box #1 P-003712 Investigative privilege Also contains information subject to privacy rights of victim who is not a party to this litigation Page 5 of 23 EFTA00191369

--=PAGE_BREAK=--

Box #1 P-003713 Thru P-003746 Box #1 P-003747 Thru P-003751 Box #1 P-003752 Thru P-004295 Box #1 P-004296 Thru P-004350 Box #1 P-004351 Thru P-004381 Box #1 P-004382 Thru P-004478 P-004552 Thru P-004555 File folder entitled “T{] M[]}” containing grand jury subpoenas, motion and order to compel testimony, and correspondence regarding same File folder entitled subpoena and correspondence regarding same File folder entitled “PBPD Investigative File” obtained via subpoena File folder bearing name of victim/witness containing meta-analysis chart showing telephone calls, travel, and grand jury materials relevant to possible charges File folder entitled “Daniel Documents 53909-004” containing attorney research related to bias issue File Folder entitled “FEDEX” containing documents obtained via subpoena File Folder entitled “State of Delaware Records” containing documents obtained in preparation for indictment File folder entitled “Jet Blue Records” containing documents obtained via subpoena File folder entitled “FL EMPLOYMENT RECORDS?” containing FDLE records on targets and witnesses obtained at attorney request Page 6 of 23 6(e) Documents under seal pursuant to court order 6(e) Investigative privilege Also contains information and documents subject to privacy rights of victims who are not parties to this litigation Work product 6(e) Investigative privilege Also contains information and documents subject to privacy rights of victims who are not parties to this litigation Work product 6(e) Investigative privilege 6(e) Investigative privilege Work product 6(e) Work product Investigative privilege Also contains information and documents subject to privacy rights of victims who are not parties to this litigation Investigative privilege Work product EFTA00191370

--=PAGE_BREAK=--

Box #1 Filed folder entitled “JANUSZ BANASIAK” Work product P-004561 containing attorney (Villafafia) handwritten notes Investigative privilege Thru of interview P-004565 Box #1 File folder entitled “JANUSZ BANASIAK 6(e) P-004566 RECORDS 23-000! THROUGH 23-” containing Work product Thru documents obtained via subpoena Investigative privilege P-004716 Also contains information and documents subject to privacy rights of victims who are not parties to this litigation Box #1 File folder entitled “IGOR ZINOVIEV” Work product P-004717 containing attorney research regarding witness Investigative privilege Thru P-004722 File folder entitled “BEAR STEARNS Work Product RESEARCH” containing attorney research Investigative privilege regarding potential witness and subpoena recipient File folder entitled “LAWSUITS INVOLVING Work Product EPSTEIN CORP’S” containing attorney research Investigative privilege regarding Epstein’s past personal and business litigative practices Filed folder entitled “SEC RECORDS” Work Product containing attorney research regarding Epstein Investigative privilege financial relationships File folder entitled “Message Pads” containing Work Product selected items from evidence obtained via 6(e) subpoena Investigative privilege Also contains information and documents subject to privacy rights of victims who are not parties to this litigation File folder bearing name of victim/witness Work Product containing correspondence with counsel for 6(e) victim/witness, attorney witness outline with Investigative privilege P-005081 attorney handwritten notes, attorney handwritten | Also contains information and notes regarding witness reports and case documents subject to privacy preparation rights of victims who are not parties to this litigation File folder entitled “New York Trip” containing Work product P-005082 attorney notes re witness interview Investigative privilege Thru P-005083 Page 7 of 23 EFTA00191371

--=PAGE_BREAK=--

| BatesRange | __—___—dDescription | rivilege(s) Asserted Box #1 P-005194 Thru P-005300 P-005442 P-005443 Thru P-005496 Box #1 P-005497 Thru P-005556 P-005084 thru P-005107 are non responsive documents and have been removed File folder entitled “ANNA SALTER” containing attorney research on select expert, use of experts at trials in child exploitation cases, and additional research materials on offenders and victims File folder entitled “Extra Copies” containing meta-analysis chart and 302’s of victim/witnesses used in preparing indictment package File folder entitled “JUAN ALESSI STATEMENT” containing transcript obtained via subpoena File folder entitled “KEN LANNING” containing attorney research on select expert, including attorney handwritten notes File folder entitled “Info re Planes” containing correspondence regarding subpoenas and documents received in response to subpoenas File folder entitled “Police Reports & PC Affidavit” containing portions of police reports with attorney notes, related phone records, a list entitled “Victims” with identifying information and attorney handwritten notes, photographs and DAVID information, and additional attorney research regarding Epstein sexual activit File folder entitled “[Victim name] Transcript of Interview & GJ Transcript” File folder entitled “Bear Stearns Subpoena Resp.” containing material received in response to subpoena Page 8 of 23 Work product Investigative privilege Work product 6(e) Investigative privilege Also contains information and documents subject to privacy rights of victims who are not parties to this litigation 6(e) Investigative privilege Work product Investigative privilege 6(e) Investigative privilege Work product 6(e) Investigative privilege Also contains information and documents subject to privacy rights of victims who are not parties to this litigation 6(e) Investigative privilege Also contains information and documents subject to privacy rights of victims who are not parties to this litigation 6(e) Investigative privilege EFTA00191372

--=PAGE_BREAK=--

| BatesRange | __——Description __——_|__Privilege(s) Asserted Box #1 P-005557 Thru P-005576 Box #1 P-005578 Thru P-005583 Box #1 P-005584 Thru P-005606 Box #2 P-005607 Thru P-005914 Box #2 P-005915 Thru P-005977 Box #2 P-005978 Thru P-006050 Box #2 P-006051 Thru P-006065 U.S. Attorney’s Office Criminal Case File Jacket containing file opening documents, expert witness payment documents U.S. Attorney’s Office Asset Forfeiture Case File Jacket containing file opening and file closing documents File folder entitled “600! Immunity Request” containing internal memoranda seeking witness immunity and correspondence with counsel for witness regarding same File folder entitled “MASTER PHONE RECORDS?” containing meta-analysis of all phone, travel, and grand jury data for all victim/witnesses for indictment preparation File folder bearing name of victim/witness containing meta-analysis of all phone, travel, and grand jury data related to that victim/witness for indictment preparation File folder bearing name of victim/witness containing meta-analysis of all phone, travel, and grand jury data related to that victim/witness for indictment preparation File folder bearing name of victim/witness containing meta-analysis of all phone, travel, and grand jury data related to that victim/witness for indictment preparation Page 9 of 23 Work product Deliberative process Work product Deliberative process 6(e) Work product and deliberative process (as to internal memoranda) Investigative privilege Also contains information and documents subject to privacy rights of victims who are not parties to this litigation Work product 6(e) Investigative privilege Also contains information and documents subject to privacy rights of victims who are not parties to this litigation Work product 6(e) Investigative privilege Also contains information and documents subject to privacy rights of victims who are not parties to this litigation Work product 6(e) Investigative privilege Also contains information and documents subject to privacy rights of victims who are not parties to this litigation Work product 6(e) Investigative privilege Also contains information and documents subject to privacy rights of victims who are not parties to this litigation EFTA00191373

--=PAGE_BREAK=--

| BatesRange | Description | _—~Privillege(s) Asserted _| Box #2 File folder entitled “JANE DOE #4” containing Work product P-006066 meta-analysis of all phone, travel, and grand jury 6(e) Thru data related to that victim/witness for indictment Investigative privilege P-006220 preparation Also contains information and documents subject to privacy rights of victims who are not parties to this litigation Box #2 File folder entitled “JANE DOE #12” containing Work product P-006221 meta-analysis of all phone, travel, and grand jury 6(e) Thru data related to that victim/witness for indictment Investigative privilege P-006222 preparation Also contains information and documents subject to privacy rights of victims who are not parties to this litigation Box #2 File folder entitled “CORRECTED PHONE Work product P-006223 RECORDS 5/31/07” containing meta-analysis of 6(e) all phone, travel, and grand jury data related to all Investigative privilege victims/witnesses for indictment preparation Also contains information and documents subject to privacy rights of victims who are not parties to this litigation File folder entitled “[Victim Name] Phone Work product P-006523 Records” containing telephone records received 6(e) Thru in response to subpoena Investigative privilege P-006802 Also contains information and documents subject to privacy rights of victims who are not parties to this litigation File folder entitled “Lists of Identified Phone Work product Numbers” containing charts of information culled 6(e) from grand jury materials, interviews, and other Investigative privilege investigation, with attorney handwritten notes, | Also contains information and and information to issue follow-up grand jury documents subject to privacy subpoena rights of victims who are not parties to this litigation File folder entitled “EPSTEIN/KELLEN CELL Work product PHONE RECORDS” containing documents 6(e) received via subpoena with attorney handwritten Investigative privilege notes and highlighting Also contains information and documents subject to privacy rights of victims who are not parties to this litigation Page 10 of 23 EFTA00191374

--=PAGE_BREAK=--

Box #2 Folder entitled “OLY GRAND JURY LOG: Work product P-007786 OLY-01 THROUGH OLY-SO” containing 6(e) Thru subpoenas, correspondence regarding same, 6(e) Investigative privilege P-008 120 letters, attorney handwritten notes regarding Also contains information and records received in response to subpoenas documents subject to privacy rights of victims who are not parties to this litigation Box #2 Handwritten flight logs received in response to 6(e) P-008121 subpoena Investigative privilege Thru P-008139 Box #2 Grand jury presentation folder containing Work product P-008140 attorney handwritten notes, typed outline with 6(e) Thru additional handwritten notes, complete indictment Investigative privilege P-008298 package dated 2/19/2008, victim list with Also contains information and identifying information, photographs, and documents subject to privacy summary of activity rights of victims who are not parties to this litigation Box #2 File folder entitled “FINAL AGREEMENTS” P-008299 containing subfolder entitled “Agrmts Filed in Thru State Court” (P-008300-P-008327 [not being P-008363 withheld as privileged — have been produced to opposing counsel]); signed Non-Prosecution Agreement, Addendum, and operative portion of 12/19/2007 Sanchez-Acosta letter (P-008328-P- 008343 [not being withheld as privileged — have been produced to opposing counsel]); subfolder entitled “12/19/07 Acosta-Sanchez Ltr” containing unredacted copies of that letter (P- 008344-P-008363 [pursuant to Court’s Order, not being withheld as privileged — will be produced to opposing counsel upon lift of stay by 11" Circuit Box #2 File folder entitled “Lacerda Immunity Request” 6(e) P-008364 containing internal memoranda, Justice Work Product Thru Department documentation, and subpoena Deliberative Process P-008382 ing i ity re Investigative privilege Box #2 Work product P-008383 presentation materials, including “Operation Leap 6(e) Thru Year Revised Indictment Summary Chart (by Investigative privilege P-008516 victim),” grand jury materials, draft indictments, Deliberative process victim reference list, grand jury subpoena log —_| Also contains information and documents subject to privacy rights of victims who are not parties to this litigation Page 11 of 23 EFTA00191375

--=PAGE_BREAK=--

Box #2 P-008517 Thru P-008535 Box #2 P-008536 Thru P-008542 6/25/2007 Letter from Gerald Lefcourt to Jeffrey Sloman and Andrew Lourie {pursuant to Court’s Order, not being withheld as privileged — will be produced to opposing counsel upon lift of stay by 11" Circuit Handwritten attorney notes to prepare for interview of Jane Doe #2 Handwritten attorney notes regarding May 8, 2007 grand jury presentation P-008550 Thru P-008615 Box #2 P-008616 Thru P-008686 Box #2 P-008687 Thru P-008776 Box #2 P-008777 Thru P-008808 File folder entitled “Most Recent Indictment & Good Cases” containing draft indictment and legal research File folder entitled “FBI Summary Charts” containing chart prepared at direction of AUSA, containing victim names, identifying information, summary of activity, and other information relevant to indictment File folder entitled “[Victim name]/Jane Doe #4” containing phone records and meta-analysis of all phone, travel, and grand jury data related to that victim/witness for indictment preparation File folder entitled “[Victim name]}/Jane Doe #5” containing handwritten notes and meta-analysis of all phone, travel, and grand jury data related to that victim/witness for indictment preparation Page 12 of 23 Privilege(s) Asserted Work product Investigative Privilege Contains information subject to privacy rights of victims who are not parties to this suit Work product 6(e) Investigative privilege Contains information subject to privacy rights of victims who are not parties to this suit Work product 6(e) Investigative privilege Deliberative process Contains information subject to privacy rights of victims who are not parties to this suit Work product Attorney-Client Privilege 6(e) Investigative privilege Contains information subject to privacy rights of victims who are not parties to this suit Work product 6(e) Investigative privilege Contains information and documents subject to privacy rights of victims who are not parties to this suit Work product 6(e) Investigative privilege Contains information subject to privacy rights of victims who are not parties to this suit EFTA00191376

--=PAGE_BREAK=--

File folder entitled “[Victim name]/Jane Doe #6” Work product containing meta-analysis of all phone, travel, and 6(e) grand jury data related to that victim/witness for Investigative privilege indictment preparation Contains information subject to privacy rights of victims who are not parties to this suit Box #2 File folder entitled “[Victim name]/Jane Doe #7” Work product P-008848 containing meta-analysis of all phone, travel, and 6(e) Thru grand jury data related to that victim/witness for Investigative privilege P-008862 indictment preparation Contains information subject to privacy rights of victims who are not parties to this suit Box #2 File folder entitled “[Victim name]/Jane Doe #8” Work product P-008863 containing meta-analysis of all phone, travel, and 6(e) Thru grand jury data related to that victim/witness for Investigative privilege P-008890 indictment preparation Contains information subject to privacy rights of victims who are not parties to this suit Box #2 P-008891 Thru P-009103 File folder entitled “Certified Copy of State Case” containing certified copy of Epstein state criminal cases and change of plea transcript [not being withheld as privileged ~ copy provided to Box #2 P-009104 Thru P-O09111 File folder entitled “Meeting Timeline” Work product containing Villafaiia typed notes summarizing Deliberative process meetings with opposing counsel prepared at request of R. Alexander Acosta, with handwritten correction and typed guideline estimate Box #2 11/26/2008 Email from Roy Black to A. Marie P-009112 Villafafia and Karen Atkinson re Jeffrey Epstein Thru (work release) P-009113 [pursuant to Court’s Order, not being withheld as privileged — will be produced to opposing counsel upon lift of stay by 11" Circuit Box #2 7/3/2008 Email from A, Marie Villafafia to Col. P-009114 M. Gauger at PBSO re Epstein work release with Thru attachment [not being withheld as privileged — P-009115 Box #2 12/6/2007 Letter from Tefffey Sloman to Jay P. P-009116 Lefkowitz re Jeffrey Epstein (victim notification) Thru [pursuant to Court’s Order, not being withheld as P-009125 privileged — will be produced to opposing counsel upon lift of stay by 11" Circuit Page 13 of 23 EFTA00191377

--=PAGE_BREAK=--

Box #2 P-009126 Thru P-009134 Box #2 P-009135 Thru P-009141 Box #2 P-009141A Thru P-009141C Box #2 P-009142 Thru P-009152 Box #2 P-009157 Thru P-009208 Box #2 P-009209 Thru P-009213 File folder entitled “[Victim name}/Jane Doe #9” containing meta-analysis of all phone, travel, and grand jury data related to that victim/witness for indictment preparation File folder entitled “[Victim name]/Jane Doe #13” containing meta-analysis of all phone, travel, and grand jury data related to that victim/witness for indictment preparation File folder entitled “[Victim name]/Jane Doe #12” containing meta-analysis of all phone, travel, and grand jury data related to that victim/witness for indictment preparation File folder entitled containing meta-analysis of all phone, travel, and grand jury data related to that individual for indictment preparation File folder entitled “Nadia Marcinkova” containing meta-analysis of all phone, travel, and grand jury data related to that individual for indictment preparation File folder entitled “[Victim name]/Jane Doe #1” containing meta-analysis of all phone, travel, and grand jury data related to that victim/witness for indictment preparation File folder entitled “[Victim name]/Jane Doe #2” containing meta-analysis of all phone, travel, and grand jury data related to that victim/witness for indictment preparation Page 14 of 23 Work product 6(e) Investigative privilege Contains information subject to privacy rights of victims who are not parties to this suit Work product 6(e) Investigative privilege Contains information subject to privacy rights of victims who are not parties to this suit Work product 6(e) Investigative privilege Contains information subject to privacy rights of victims who are not parties to this suit Work product 6(e) Investigative privilege Contains information subject to privacy rights of victims who are not parties to this suit Work product 6(e) Investigative privilege Contains information subject to privacy rights of victims who are not parties to this suit Work product 6(e) Investigative privilege Contains information subject to privacy rights of victims who are not parties to this suit Work product 6(e) Investigative privilege Contains information subject to privacy rights of victims who are not parties to this suit EFTA00191378

--=PAGE_BREAK=--

Box #2 P-009214 Thru P-009271 Box #2 P-009272 Thru P-009354 Box #2 P-009355 Thru P-009403 Box #2 P-009404 Thru P-009536 Box #2 P-009537 P-009711 P-009712 Thru P-009819 Box #2 P-009820 P-009966 Thru P-010096 File folder entitled “[Victim name]/Jane Doe #3” containing meta-analysis of all phone, travel, and grand jury data related to that victim/witness for indictment preparation File folder entitled “Purpose of Travel Cases” containing attorney research and handwritten notes File folder entitled “Interstate Commerce Cases” containing attorney research and handwritten notes File folder entitled “Attorney Conflict Research” containing attorney research and handwritten notes File folder entitled “Mann Act/Travel to Have Sex w/Minor” containing attorney research and handwritten notes File folder entitled “Travel Act” containing attorney research and handwritten notes File folder entitled “Florida Prostitution/Lewdness Statutes” containing attorney research and handwritten notes Booklet entitled “Attorney General Guidelines for Victim and Witness Assistance” [not being withheld as privileged — produced to opposing File folder entitled “Corporate Liability Rsrch” containing attorney research and handwritten notes File folder entitled “Research re Knowledge of Age Unnecessary” containing attorney research and handwritten notes and copy of grand jury subpoe Page 15 of 23 Work product 6(e) Investigative privilege Contains information subject to privacy rights of victims who are not parties to this suit oe Work Product 6(e) EFTA00191379

--=PAGE_BREAK=--

|_BatesRange | Description | __rivilege(s) Asserted Box #2 File folder entitled “Money Laundering” Work Product containing attorney research and handwritten notes P-010276 File folder entitled “1960 & Aiding/Abetting” Work Product P-010277 containing attorney research and handwritten Thru notes P-010394 Box #2 File folder entitled “18 USC § 2255 Cases” Work Product P-010395 containing attorney research and handwritten notes File folder entitled “Research re Overt Acts & Work Product P-010489 Witness Testimony” containing attorney research Thru and handwritten notes P-010509 File folder entitled “Extradition” containing Work Product P-010510 attorney research and handwritten notes Thru P-010525 Box #2 File folder entitled “Rsrch re Crime Victims Work Product P-010526 Rights” containing attorney research, handwritten Deliberative Process notes, draft victim notification letter, and draft correspondence to Jay Lefkowitz (Also contains a November 28, 2007 letter from Kenneth Starr to Alice S. Fisher; and a November 29, 2007 letter from Jay Lefkowitz to R. Alexander Acosta (P-010528 thru P-010530 and P-010556 thru P-010559). Pursuant to the Court's Order, these will be produced to opposing counsel upon lift of stay by 11"" Circuit Box #2 File folder entitled “Immunity” containing Work Product P-010642 attorney research on granting immunity to Thru witnesses P-01650 Box #2 File folder entitled “Research re G.J. Transcript” Work Product P-010651 containing attorney research and draft pleadings 6(e) re compelling production of grand jury transcript Deliberative process with subpoena File folder entitled “Research re GJ Transcript” Work Product containing grand jury subpoena, 6(e) letters, 6(e) attorney research and correspondence related to P-010757 subpoena Page 16 of 23 EFTA00191380

--=PAGE_BREAK=--

| BatesRange | Description | __—Privilege(s) Asserted | Box #2 File folder entitled “Original Proposed Ind.” Work Product P-010758 containing draft indictment 6(e) Thru Deliberative process P-010793 Box #2 File folder entitled “Epstein” containing sample Work Product P-010794 indictments and attorney research re potential Thru charges with attorney notes P-010829 Box #2 File folder entitled “1591 & Money Laundering” Work Product P-010830 containing attorney research and handwritten Thru notes P-010853 Box #2 File folder entitled “18 USC 2425” containing Work Product P-010854 attorney research and handwritten notes Thru P-010876 Box #2 File folder entitled “Knowledge of Age” Work Product P-010877 containing attorney research and handwritten Thru notes P-010920 Box #2 File folder entitled “2423(b) Constitutionality and Work Product P-010921 Purpose of Travel” containing attorney research Thru and handwritten notes File folder entitled “Mistake not a Work Product P-01 1050 Defense” containing attorney research and Thru handwritten notes P-011212 File folder entitled “Research re ‘Pandering’” Work Product containing attorney research and handwritten notes P-011237 File folder entitled “Research re Grand Jury Work Product P-011238 Instructions” containing attorney research and 6(e) Thru handwritten notes P-O11319 Box #2 File folder entitled “Telephone = Facility of Work Product P-011320 Commerce” containing attorney research and Thru handwritten notes P-011361 Box #2 File folder entitled “Def of Prostitution” Work Product P-011362 containing attorney research and handwritten Thru notes P-011374 Page 17 of 23 EFTA00191381

--=PAGE_BREAK=--

Privilege(s) Asserted Box #2 File folder entitled “Relevant Florida Statutes” Work Product P-011375 containing attorney research and handwritten Thru notes P-011456 Box #2 File folder entitled “Unit of Prosecution Work Product P-011457 Research” containing attorney research and Thru handwritten notes P-011626 Box #3 File folder entitled “Attorney Notes” containing Work Product P-011627 attorney handwritten and typed notes Thru P-01 1662 Box #3 File folder entitled “Drafts” containing draft 6(e) P-011663 indictments with attorney handwritten notes, draft Work Product Thru internal memoranda, relevant witness interview Deliberative Process P-011698 and reports and grand jury material and attorney Investigative Privilege P-012189 thru handwritten notes Contains information subject P-012361 to privacy rights of victims (gap was who are not parties to this File folder entitled “6/9/09 Signed Indictment” 6(e) containing signed indictment package dated Work product 6/9/2009 with corrections Deliberative process P-011777 File folder entitled “6/12/09 Victim Notif. Log” Work product containing chart with victim contact information Thru and attorney notes regarding dates and type of P-011788 contacts Box #3 File folder entitled “Breach Memo” containing P-011789 memorandum analyzing breach of Non- Thru Prosecution Agreement with attachments P-011879 Box #3 File folder entitled “Overt Act Lists” containing Work product P-011880 handwritten notes cross-checking all overt acts Attorney-client privilege Thru alleged in draft indictment by victim and typed Deliberative process P-011922 overt act summary charts for indictment 6(e) preparation P-011778 Work product Deliberative process Page 18 of 23 EFTA00191382

--=PAGE_BREAK=--

|_BatesRange | Description | __—Prrivilege(s) Asserted Box #3 P-011923 Thru P-011966 Box #3 P-011967 Thru P-012016 Box #3 P-012017 Thru P-012055 Box #3 P. P-012088 P-012089 Thru P-012129 Box #3 P-012130 Thru P-012150 Box #3 P-012151 Thru P-012167 Folder entitled “Responses to Arguments from JE Counsel” containing: @ 7/13/2007 letter from Lilly Ann Sanchez to Andrew Lourie with handwritten attorney (Lourie) notes; 6/25/2007 letter from Gerald Lefcourt to Jeffrey Sloman, Matt Menchal, Andrew Lourie, and Marie Villafafia with handwritten attorney (Villafaiia) notes; 6/25/2007 email from Andrew Lourie to Matt Menchel and Marie Villafaiia entitled “Thoughts on Lefcourt’s letter” Handwritten and typed attorney (Villafafia) notes regarding main themes raised by Epstein counsel Composition book entitled “Operation Leap Year” containing attorney handwritten notes regarding investigation and case strategy Motion of Jeffrey Epstein to Intervene and to Quash Grand Jury Subpoenas and Incorporated Memorandum of Law Affidavit of Roy Black, Esq. in Support of Motion of Jeffrey Epstein to Intervene and to Quash Grand Jury Subpoenas United States’ Response to Motion of Jeffrey Epstein to Intervene and to Quash Grand Jury Subpoenas and Cross-Motion to Compel Declaration of Joseph Recarey Ex Parte Declaration Number One in Support of United States’ Response to Motion to Quash Subpoenas Page 19 of 23 Work product Deliberative process 6(e) Attorney-Client Privilege Work product Investigative privilege 6(e) Contains information subject to privacy rights of victims who are not parties to this litigation 6(e) Investigative Privilege Also contains information subject to privacy rights of victims who are not parties to this litigation EFTA00191383

--=PAGE_BREAK=--

|_BatesRange | __——Description __——|__Privilege(s) Asserted Box #3 P-012168 Thru P-012170 Box #3 P-012171 Thru P-012173 Box #3 P-012174 Thru P-012176 Box #3 P-012177 Thru P-012178 Box #3 P-012179 Thru P-012188 Box #3 P-012362 Thru P-012451 Box #3 P-012451 Thru P-012452 Ex Parte Declaration Number Two in Support of United States’ Response to Motion to Quash Subpoenas Supplement to Ex Parte Declaration Number One in Support of United States’ Response to Motion to Quash Subpoenas Draft of September 2009 letter from Marie Villafaiia to Roy Black regarding breach of Non Prosecution Agreement with handwritten attorney Villafafia) notes Undated handwritten attorney (Villafafia) notes regarding negotiations and allegations File Folder entitled “FBI G.J, Log” containing copy of FBI grand jury subpoena log with attorney (Villafafia) handwritten notes File folder entitled “Key Documents” containing correspondence between AUSA and case agent regarding indictment prep questions, victim identification information, corrections to draft indictment, indictment preparation timeline, key grand jury material File folder entitled “Victim List” containing list of victims with dates of birth and age information Page 20 of 23 6(e) Investigative Privilege 6(e) Investigative Privilege Also contains information subject to privacy rights of victims who are not parties to this litigation Work Product Attorney-Client Privilege Deliberative Process Work Product Attorney-Client Privilege Deliberative Process 6(e) Work Product Investigative Privilege Also contains information subject to privacy rights of victims who are not parties to this litigation 6(e) Work Product Attorney-Client privilege Investigative Privilege Also contains information subject to privacy rights of victims who are not parties to this litigation Work Product Investigative Privilege Also contains information subject to privacy rights of victims who are not parties to this litigation EFTA00191384

--=PAGE_BREAK=--

__BatesRange | Description | Privilege(s) Asserted Box #3 Complete indictment package marked “Originals Work-product P-012453 12/12/07” Deliberative process Thru 6(e) Also contains documents subject to investigative privilege Also contains documents subject to privacy rights of victims who are not parties to this litigation Box #3 Folder entitled “( Victims) Additional 302s” Investigative Privilege P-012624 containing reports of interviews conducted in Also contains documents Thru June 2007, October 2007, and March 2008. subject to privacy rights of P-012653 victims who are not parties to this litigation Work-product P-012623 Box #3 3-ring binder entitled “Child Molesters: A P-012654 Behavioral Analysis” with attorney (Villafafia) handwritten notes Indictment preparation binder containing: Work Product P-012865 witness/victim list with identifying information, Deliberative Process Thru sexual activity summary, telephone call summary 6(e) P-013226 chart, attorney (Villafafia) handwritten notes, Also contains documents subject to investigative privilege Also contains documents subject to privacy rights of victims who are not parties to 302s, portions of state investigative file, attorney (Villafafia) typed notes, relevant pieces of grand jury materials, telephone records/flight records analysis charts, victim/witness photographs, DAVID records, NCICs, and related materials for persons identified as Jane Does #9, 10, 11, 12, 13, this litigation 14 April 23, 2008 Memo from Jeffrey Sloman to Office of Professional Responsibility re Self Reporting, Corrected Version of the previously submitted April 21, 2008 Letter to OPR Box #3 April 21, 2008 Letter from Jeffrey Sloman to P-013226 Office of Professional Responsibility re Self Thru Reporting P-013230 Box #3 April 22, 2008 Letter from A. Marie Villafaiia to Box #3 P-013227 P-013231 Office of Professional Responsibility re Self- Thru Report of Allegation of Conflict of Interest P-013239 Page 21 of 23 EFTA00191385

--=PAGE_BREAK=--

Box #3 P-013240 Thru Reporting with attachments P-013247 Box #3 P-013248 Thru P-013251 Privilege(s) Asserted April 21, 2008 Letter from Jeffrey Sloman to Privacy Act Office of Professional Responsibility re Self Emails between Richard Sudder, Assistant General Counsel, Executive Office for United States Attorneys, and Benjamin Greenberg, First Assistant U.S. Attorney, Southern District of Florida, regarding Formal Notice of Office-wide Recusal of Southern District of Florida dated August 24 and August 29, 2011 Emails between Richard Sudder, Assistant Attorney-Client Privilege General Counsel, Executive Office for United States Attorneys, and Benjamin Greenberg, First Assistant U.S. Attorney, Southern District of Florida, regarding Recusal matter, dated July 28, August 3, and August 24, 2011 Box #3 Emails between Richard Sudder, Assistant P-013254 General Counsel, Executive Office for United Thru States Attorneys, and Benjamin Greenberg, First P-013257 Assistant U.S. Attorney, Southern District of Florida, regarding Formal Notice of Office-wide Recusal of Southern District of Florida dated August 24 and August 29, 2011 Emails between Richard Sudder, Attorney-Client Privilege Box #3 P-013252 Thru P-013253 Attorney-Client Privilege Box #3 Assistant Attorney-Client Privilege P-013258 General Counsel, Executive Office for United Thru States Attorneys, and Benjamin Greenberg, First P-013259 Assistant U.S. Attorney, Southern District of Florida, regarding Formal Notice of Office-wide Recusal of Southern District of Florida dated July 28 and August 3, 2011 Box #3 Email from Richard Sudder, Assistant General P-013260 Counsel, Executive Office for United States Thru Attorneys, to Wifredo Ferrer (U.S. Attorney, P-013262 SDFL), Robert O'Neill (U.S. Attorney, MDFL), Benjamin Greenberg, (FAUSA, SDFL), and Lee Bentley (FAUSA, MDFL) regarding Formal Notice of Office-wide Recusal of Southern District of Florida dated August 24, 2011. CC's David Margolis (ODAG), Jay Macklin (USAEO), Thomas Anderson (USAEO), Tapken USAEO), James Read (USAEO Attorney-Client Privilege Page 22 of 23 EFTA00191386

--=PAGE_BREAK=--

| BatesRange | Description | __Privilege(s) Asserted Box #3 Emails between Richard Sudder, Assistant Attorney-Client Privilege P-013263 General Counsel, Executive Office for United Deliberative Process Thru States Attorneys, and Benjamin Greenberg, First Work Product P-013271 Assistant U.S. Attorney, Southern District of Florida, regarding recusal of Southern District of Florida, dated July 29, 2011, with attached memorandum from A. Marie Villafafia to Benjamin Greenberg summarizing Jeffrey Epstein Investigation Emails between Peter Mason, Executive Office for United States Attorneys, and Dexter Lee, Southern District of Florida, seeking advice regarding office-wide recusal, dated December 16 and 17, 2010, with attached letter from Paul Cassell to Wifredo A. Ferrer, dated December 10, 2010 Box #3 P-013272 Thru P-013278 Attorney-Client Privilege Page 23 of 23 EFTA00191387

--=PAGE_BREAK=--

To: BigJimLaw@aol.com|[BigJimLaw@aol.com]; Subject: RE: Sent: Tue 006 5:51:08 PM From: Villafana, Ann Marie C. (USAFLS) Hi Jim -- Thank you for the e-mail, and | will even forgive the football reference. | was just set for trial, so the earliest | will be able to reschedule the testimony will be after Thanksgiving. | will give you a call to discuss the nity issue but | am concerned about other things we have talked about -- if Ms. is given immunity, will she be forthcoming and answer the questions? Or am | going to jump through hoops to get her immunity and then have to worry about filing motions to compel, motions for orders to show cause why she shouldn't be held in contempt, etc., etc.? As always, thank you for your assistance. Regards, Marie A. Marie Villafaha Assistant U.S. Attorney 561 209-1047 Fax 561 820-8777 ann.marie.c. villafana@usdoj.gov From: BigJimLaw@aol.com [mailto:BigJimLaw@aol.com] Sent: Tuesday, October 24, 2006 12:00 PM To: Villafana, _ (USAFLS) Subject: Re: Sorry I get back to you sooner. I have been out of town for several weeks. As to Miss she still does not wish to testify in this case and has a Fifth Amendment basis for her position. She wishes not to accept the "proffer letter " cover of Immunity, which again is her right. I think it is a waste of time to have her appear Friday to just take the Fifth. I suggest that you huddle with your people. (It is football season). If you want to push the issue you will have to get formal im . [will accept service now and in the future for you so you. don't have to chase down. Jim Eisenberg 08-80736-CV-MARRA P-013875 EFTA00191388

--=PAGE_BREAK=--

Memorandum Re: Jeffrey Epstein Investigation July 26, 2011 To From Benjamin Greenberg, First Assistant U.S. Attorney A. Marie Villafafia I. Introduction This memorandum summarizes the conflict of interest related to the investigation by the Federal Bureau of Investigation (“FBI”) of additional crimes committed by Jeffrey Epstein (“Epstein”). The memo begins with a brief overview of the original investigation of Epstein, dubbed “Operation Leap Year"; summarizes the resolution of Operation Leap Year by the Southern District of Florida; and addresses the events following the resolution of Operation Leap Year, including the basis for the conflict. Lastly, the memo briefly addresses the additional crimes that the FBI wants to investigate. Il. “Operation Leap Year” The investigation of Jeffrey Epstein initially was undertaken by the City of Palm Beach Police Department in response to a complaint received from the parents of a 14-year-old girl, from Royal Palm Beach. When || and another girl began fighting at school because the other girl accused of being a prostitute, one of the school principals intervened. The principal searched urse and found $300 cash. The principal asked || where the money came from. initially claimed that she earned the money working at “Chik-Fil-A,” which no one believed. then claimed that she made the money selling drugs; no one believed that either. | | finally admitted that she had been paid $300 to give a massage to a man on Palm Beach island. parents approached the Palm Beach Police Department (“PBPD") about pressing charges. PBPD began investigating the recipient of the massage, Jeffrey Epstein, and two of his assistants, Sarah Kellen and Nadia Marcinkova. PBPD identified 27 girls who went to EFTA00191389

--=PAGE_BREAK=--

Epstein’s house to perform “massage services” (not including one licensed massage therapist). The girls’ ages ranged from 14 years’ old to 23 years’ old. Some girls saw Epstein only once and some saw him dozens of times. The “massage services” performed also varied. Some girls were fully clothed while they massaged Epstein; some wore only their underwear; and some were fully nude. During all of these massages, Epstein masturbated himself and he would touch the girl performing the massage, usually fondling their breasts and touching their vaginas - either over their clothing or on their bare skin. Epstein often used a vibrator to masturbate the girls and digitally penetrated a number of them. For the girls who saw him more often, Epstein graduated to oral sex and vaginal sex. Epstein sometimes brought his assistant/girlfriend, Nadia Marcinkova, into the sexual activity. One of the girls described Marcinkova as Epstein’s “sex slave”. On October 18, 2005, PBPD obtained a search warrant with the assistance of the Palm Beach County State Attorney's Office (“PBSAO"). By this time, PBSAO had already been contacted by Epstein’s cadre of lawyers. When PBPD arrived at Epstein’s home two days later (10/20/05) to execute the search warrant, they found several items conspicuously missing. For example, computer monitors and keyboards were found, but the CPUs were gone.' Similarly, surveillance cameras were found, but they were disconnected and the videotapes were gone. Nonetheless, the search did recover some evidence of value, including message pads showing messages from many girls over a two year span. The messages show girls returning phone calls to confirm appointments to “work.” Messages were taken by three of Epstein’s “personal assistants.” Photographs taken inside the home showed that the girls’ descriptions of the layout of the home and master bedroom/bathroom area were accurate. PBPD also found massage tables and oils, the high school transcript of one of the girls, and sex toys. ‘During a meeting, two of Epstein’s attorneys, Gerald Lefcourt and Lilly Ann Sanchez, admitted that attorney Roy Black instructed Epstein to have the CPUs removed although they insisted that those instruction were given well in advance of the execution of the search warrant - not in response to a “leak.” EFTA00191390

--=PAGE_BREAK=--

In sum, the PBPD investigation showed that girls from Royal Palm Beach High School would be contacted by one of Epstein’s assistants to make an appointment to “work.” Up to three appointments each day would be made. The girls would travel to Epstein’s home in Palm Beach where they would meet Epstein’s chef and Epstein’s assistant-usually Sarah Kellen-in the kitchen. The assistant would escort the girls upstairs to the master bedroom/bathroom area and set up the massage table and massage oils. The girl sometimes was instructed to remove her clothing. The assistant would leave and Epstein would enter the room wearing a robe. He would remove the robe and lie face down and nude on the massage table. Epstein would then instruct the girl on what to do and would ask her to remove her clothing. After some time, Epstein would turn over, so that he was lying face up. Epstein would masturbate himself and fondle the girl performing the massage. When Epstein climaxed, the massage was over, and the girl was instructed to get dressed and to go downstairs to the kitchen while Epstein showered. Epstein’s assistant would be in the kitchen and the girl would be paid-usually $200-and if it was a “new” girl, the assistant would ask for the girl’s phone number to contact her in the future.’ Girls were encouraged to find other girls to bring with them. If a girl brought another girl to perform a “massage,” each girl would receive $200. Each time a girl returned to the house, Epstein would pressure the girl to go further sexually, advancing to oral sex and sexual intercourse. Epstein would pay more for these acts - in the words of one girl, “the more you do, the more you make.” The PBPD investigation consisted primarily of sworn taped statements from the girls. When PBPD began having problems with PBSAO, they approached the FBI. The investigation was formally presented to the FBI and to the U.S. Attorney's Office after PBSAO “presented” the case to a state grand jury and the state grand jury returned an indictment charging Epstein only with one felony count of solicitation of [adult] prostitution. After the matter was presented to the U.S. Attorney’s Office and there was a determination that federal statutes had been violated, FBI, ICE, and the U.S. Attorney’s Office opened files. The federal investigation focused on the interstate nexus required for all of the federal violations, so a number of grand jury subpoenas were issued for telephone records, flight manifests, and credit card records. The federal agents also re-interviewed some of the girls. The agents delved into Epstein’s history and interviewed other girls and obtained records to corroborate the girls’ stories. FBI also interviewed Sometimes Epstein made the payment and asked for the phone number, sometimes it was the assistant. EFTA00191391

--=PAGE_BREAK=--

girls who came forward after the PBSAO indictment was reported in the papers and the additional girls identified through those interviews. The attempt to handle secretly the federal case was doomed from the start when the Chief of the Palm Beach Police Department gave a letter to each of the victims identified through his investigation telling them that, because of his disappointment in the way that the PBSAO had handled the case, the matter had been referred to the FBI. Almost immediately, Epstein’s attorneys began calling to request a meeting with the U.S. Attorney's Office. When one attorney was unable to schedule a meeting, Epstein hired another attorney who called up the chain of command until someone agreed to a meeting. Between January and May 2007, an indictment package was prepared, charging Epstein and three of his personal assistants with a number of child exploitation offenses. The case agent made several appearances before the grand jury. Attorneys for Epstein made several presentations to the U.S. Attorney's Office to convince the Office not to prosecute, and made allegations of prosecutorial misconduct against the line Assistant and the First Assistant U.S. Attorney. Epstein also challenged the legal analysis behind the prosecution, both within the U.S. Attorney’s Office (up to the U.S. Attorney) and to the Child Exploitation and Obscenity Section at the Justice Department. All of Epstein’s challenges were considered and rejected. Ill. The Resolution of “Operation Leap Year” On September 24, 2007, Epstein signed a Non-Prosecution Agreement wherein the U.S. Attorney's Office for the Southern District of Florida promised not to prosecute Epstein for the crimes that were the subject of the grand jury investigation if: (1) he pled guilty to two crimes in state court - the state felony prostitution charge and a state charge of procuring minors into prostitution, which would require Epstein to register as a sex offender; (2) he were sentenced to at least 18 months’ imprisonment, and (3) he agreed to pay damages to the victims of his offenses. After signing this Agreement, Epstein and his counsel decided that they were dissatisfied with its terms, and again complained to the Justice Department, seeking review to the Deputy Assistant Attorney General and the Deputy Attorney General. After those attempts also failed, on June 30, 2008, Epstein entered his guilty plea in state court and began serving his sentence. IV. Post-Resolution Events A few days before the plea and sentencing (in state court those occur on the same EFTA00191392

--=PAGE_BREAK=--

day), the Assistant U.S. Attorney handling the matter contacted counsel for three of Epstein’s identified victims and informed him of the upcoming court date, encouraging his clients to attend and be heard. They did not appear. On July 7, 2008, two of those victims filed suit against the United States in federal court claiming that their rights had been violated under the Crime Victims’ Rights Act because they had not been consulted before the Office entered into the Non-Prosecution Agreement. (This will be referred to as the “CVRA Action.”) After an initial flurry of activity, the Petitioners obtained a copy of the confidential Non-Prosecution Agreement, and the Court ordered that it be shared with all of the identified victims. After it was provided, the Petitioners and most of Epstein’s victims focused on their civil suits against him. In 2009, the U.S. Attorney’s Office in Fort Lauderdale initiated an investigation into a Ponzi scheme operated by Scott Rothstein through his law firm. As part of his Ponzi scheme, Rothstein told investors that his law firm represented several of Epstein’s victims and that Epstein was willing to pay huge sums of money to avoid exposing his criminal activities. The attorney representing the victims in the CVRA Action, Brad Edwards (“Edwards”), worked at the Rothstein firm. Epstein sued Edwards, alleging that Edwards was part of the Ponzi scheme, and alleging that Edwards’ attempts to subpoena some of Epstein’s high-powered friends were done to increase the value of the Ponzi scheme, rather than for legitimate discovery purposes. In the summer of 2010, most of the civil suits against Epstein were settled, including the suits filed by the two victims in the CVRA Action. All of the settlements were confidential, so it is unknown how much each of the victims received. In September 2010, U.S. District Judge Kenneth Marra, who handled most of the civil cases and the CVRA Action, issued an Order closing the CVRA Action. Almost immediately thereafter, the Petitioners filed a Motion to Reopen, stating that they had obtained discovery through their civil suits against Epstein that showed that the U.S. Attorney’s Office had violated their rights as victims. For several months, attempts were made to resolve the matter. In short, the victims have asked that the U.S. Attorney's Office disavow the Non-Prosecution Agreement, on the basis that the CVRA was violated, and bring charges against Epstein. Edwards has said that one of his clients repeatedly calls and asks him when Epstein is going to jail. One of the other attorneys on the case has suggested that emails he EFTA00191393

--=PAGE_BREAK=--

considers to be embarrassing to the Office will not be disclosed if we re-open our investigation of Epstein and prosecute him. Herein lies the conflict. Ifthe U.S. Attorney’s Office for the Southern District of Florida re-initiates a grand jury investigation of Jeffrey Epstein, it will be perceived - correctly or incorrectly - as having been done at the insistence of the victims in the CVRA Action. And Epstein will allege that any prosecution arising therefrom will have been undertaken in an effort to resolve the CVRA Action, not based upon the merits of the investigation itself. i. The FBI's Current Investigation The main focus of the FBI’s current investigation is a victim, i. who refused to speak with agents during the “Operation Leap Year" investigation. Based upon her debriefing, Epstein engaged in several additional crimes, in the Southern District of Florida and, more importantly, in several other Districts, with and other minor females. Epstein transported in his private airplanes to engage in sexual activity with him. Epstein also “pimped” to several of his other important friends, and transported her to those sexual encounters. This activity was not part of the initial investigation. | also reported that, during the “Operation Leap Year” investigation, she was contacted by Epstein’s investigators, lawyers, and Epstein himself, and offered payment to remain silent when contacted by the police. FBI agents are seeking grand jury subpoenas at this time to corroborate | statement. They also are asking for permission to approach one of Epstein’s “personal assistants,” who was served with a target letter during the “Operation Leap Year” investigation, to give her a “de-target” letter and interview her. There are several other Districts that may have jurisdiction over the additional crimes under investigation. Epstein lived and still lives in the Southern District of New York; he engaged in sexual activity with in the S.D.N.Y.; and it is believed that he made the calls from the S.D.N.Y. to wherein he offered to pay her to keep her from speaking to law enforcement. When Epstein would fly into and out of New York, however, he used the airport in Teterboro, New Jersey, so the District of New Jersey also has jurisdiction over charges related to traveling in interstate commerce to engage in illicit sexual conduct and transporting minors in interstate commerce. reported EFTA00191394

--=PAGE_BREAK=--

that Epstein engaged in sexual activity with her on his private island in the U.S. Virgin Islands and also had her engage in sexual activity with one of his friends on that island, so the District of the Virgin Islands also would have jurisdiction. also reported frequent sexual activity with Epstein in the District of New Mexico and the Central District of California. In both of those Districts there is evidence (from or other witnesses) of Epstein engaging in illegal sexual activity with other underage victims, as well. EFTA00191395