U.S, Department of Justice Office of Professional Responsibility 950 Pennsylvania Avenue N.W., Room 3266 Washington, D.C. 20530 CONFIDENTIAL The Honorable Wifredo A. Ferrer United States Attorney United States Attorney's Office for the Southern District of Florida 99 N.E, 4" Street Miami, Florida 33132 Dear Mr. Ferrer: af Assistant United States Attorney m7 forwardéd to the Office of Professional Responsibility (OPR) a letter dated December 10, 2010 you received from Professor Paul of the at faenne~ CasselligS.1. Quinney College of Law @ the University of Utah. In his letter, lay Cassell alleged misconduct by the United States Attorney’s Office (USAO) in the criminal investigation of Jeffrey Epstein. OPR has completed its inquiry into wheyfEr"ihproper influences” resulted in the USAO’s decision to enter into a non-prosecution agreement with Mr. Epstein. ce Most, ifnotall, othfe Exxirs allegations are currently being litigated on behalf of victims under the Crime Victim’s Rights Act in Jane Doe #] and Jane Doe #2 v. United States, Case No, 08-80736-Civ-Marra/Johnson (S.D. Fla.). OPR has jurisdiction to investigate allegations of misconduct involving Department of Justice (DOJ) attorneys or law enforcement personnel that relate to the exercise of an attorney’s authority to investigate, litigate or provide legal advice. Itis, however, the policy of this Office to refrain from investigating issues or allegations that were, are being, or could have been addressed in the course of litigation, unless a court has made a specific finding of misconduct by a DOJ attorney or law enforcement personnel or there are present other extraordinary circumstances. Based on our review of Professor Cassell’s correspondence, and the pleadings filed in the Doe case, we have determined that his allegations fall into this category. No 08-80736-CV-MARRA P-013919 EFTA00230437

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court has made a finding of misconduct and there are no extraordinary circumstances. We have, therefore, determined that these allegations do not warrant further inquiry and we consider this matter to be closed. We hawe nott 4d PW~W-rf teow foe) ” ~. Coasct% of wt Sincerely, SoM bee Counsel 08-80736-CV-MARRA P-013920 EFTA00230438

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::OODMA/PCDOCS/OPR/309807/1 201100372 Howard 08-80736-CV-MARRA P-013921 EFTA00230439

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U.S. Department of Justice Office of Professional Responsibility 950 Pennsylvania Avenue N.W, Room 3266 Washington, D.C. 20530 CONFIDENTIAL The Honorable Wifredo A. Ferrer United States Attorney United States Attorney’s Office for the Southern District of Florida 99 N_E. 4" Street Miami, Florida 33132 Dear Mr. Ferrer: Assistant United States Attorney P| forwarded to the Office of Professional Responsibility (OPR) a letter dated December 10, 2010 that you received from Professor Paul Cassel], of the S.J. Quinney College of Law at the University of Utah. In his letter, Professor Cassell alleged misconduct by the United States Attomey’s Office (USAO) in the criminal investigation of Jeffrey Epstein. OPR has completed its inquiry into whether “improper influences” resulted in the USAO’s decision to enter into a non-prosecution agreement with Mr. Epstein. Most, if not all, of Professor Cassell’s allegations are currently being litigated on behalf of victims under the Crime Victim's Rights Act inJane Doe i#l and Jane Doe #2 v. United States, Case No. 08-80736-Civ-Marra/Johnson (S.D. Fla.). OPR has jurisdiction to investigate allegations of misconduct involving Department of Justice (DOJ) attorneys or law enforcement personnel that relate to the exercise of an attorney’s authority to investigate, litigate or provide legal advice. It is, however, the policy of this Office to refrain from investigating issues or allegations that were, are being, or could have been addressed in the course of litigation, unless a court has made a specific finding of misconduct by a DOJ attorney or law enforcement personnel or there are present other extraordinary circumstances, Based on our review of Professor Cassell’s correspondence, and the pleadings filed in the Doe case, we have determined that his allegations fall into this category. No 08-80736-CV-MARRA P-013922 EFTA00230440

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court has made a finding of misconduct and there are no extraordinary circumstances. We have, therefore, determined that these allegations do not warrant further inquiry and we consider this matter to be closed. We have notified Professor Cassell of our decision. Sincerely, Counsel -2- 08-80736-CV-MARRA P-013923 EFTA00230441

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:,ODMA/PCDOCS/OPR/309807/1 201100372 Howard 08-80736-CV-MARRA P-013924 EFTA00230442

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U.S. Department of Justice Office of Professional Responsibility 950 Pennsylvania Avenue N.W., Room 3266 Washington, D.C. 20530 Professor Paul G, Cassell S.J. Quinney College of Law The University of Utah 332 South 1400 East, Room 101 Salt Lake City, Utah 84112-0730 Dear Professor Cassell: Your letter dated December 10, 2010 to United States Attorney Wifredo A. Ferrer was forwarded to the Office of Professional Responsibility (OPR). OPR has completed an inquiry into your allegation of professional misconduct by the United States Attomey’s Office for the Southem District of Florida (USAO) in the criminal investigation of Jefirey Epstein. Specifically, you question whether “improper influences” resulted in the USAO’s decision to omer non-prosecution agreement with Mr. Epstein. Most, if not all, of the allegations set forth in your letter are currently being litigated on behalf of victims under the Crime Victim’s Rights Act in Jane Doe #/ and Jane Doe #2 y. United States, Case No. 08-80736-Civ-Marra/Johnson (S.D. Fla.). OPR has jurisdiction to investigate allegations of misconduct involving Department of Justice (DOJ) attorneys or law enforcement personnel that relate to the exercise of an attorney’s authority to investigate, litigate or provide legal advice. It is, however, the policy of this Office to refrain from investigating issues or allegations that were, are being, or could have been addressed in the course of litigation, unless a court has made a specific finding of misconduct by a DOJ attorney or law enforcement personnel or there are present other extraordinary circumstances. Based on our review of your correspondence, and the pleadings filed in the Doe case, we have determined that your allegations fall into this category. No 08-80736-CV-MARRA P-013925 EFTA00230443

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court has made a finding of misconduct and there are no extraordinary circumstances. We regret that we can be of no further assistance to you. Thank you for bringing this matter to our attention. Sincerely, Counsel _2- 08-80736-CV-MARRA P-013926 EFTA00230444

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2 ODMA/PCDOCS/OPR/309806/1 Howard 201100372 08-80736-CV-MARRA P-013927 EFTA00230445

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U.S. Department of Justice Office of Professional Responsibility 950 Pennsylvania Avenue N.W., Room 3266 Washington, D.C. 20530 Professor Paul G. Cassell S.J. Quinney College of Law The University of Utah 332 South 1400 East, Room 101 Salt Lake City, Utah 84112-0730 Dear Professor Cassell: Your letter dated December 10, 2010 to United States Attorney Wifredo A. Ferrer was forwarded to the Office of Professional Responsibility (OPR). OPR has completed an inquiry into your allegation of professional misconduct by the United States Attorney's Office for the Southem District of Florida (USAO) in the criminal investigation of Jeffrey Epstein. Specifically, you question whether “improper influences” resulted in the USAO’s decision to enter a non-prosecution agreement with Mr. Epstein. Most, if not all, of the allegations set forth in your letter are currently being litigated on behalf of victims under the Crime Victim’s Rights Act in Jane Doe #4] and Jane Doe #2 v, United States, Case No. 08-80736-Civ-Marra/Johnson (S.D. Fla.), OPR has jurisdiction to investigate allegations of misconduct involving Department of Justice (DOJ) attorneys or law enforcement personnel that relate to the exercise of an attorney’s authority to investigate, litigate or provide legal advice. It is, however, the policy of this Office to refrain from investigating issues or allegations that were, are being, or could have been addressed in the course of litigation, unless a court has made a specific finding of misconduct by a DOJ attorney or law enforcement personnel or there are present other extraordinary circumstances. Based on our review of your correspondence, and the pleadings filed in the Doe case, we have determined that your allegations fall into this category. No 08-80736-CV-MARRA P-013928 EFTA00230446

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court has made a finding of misconduct and there are no extraordinary circumstances. We regret that we can be of no further assistance to you. Thank you for bringing this matter to our attention. Sincerely, MS ine Counsel 08-80736-CV-MARRA P-013929 EFTA00230447

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ODMA/PCDOCS/OPR/309806/1 Howard 201100372 08-80736-CV-MARRA P-013930 EFTA00230448

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U.S, Department of Justice Office of Professional Responsibility 950 Pennsylvania Avenue N.W., Room 3266 Washington, D.C. 20530 oO np. Professor Paul G. Cassell 4°} . S.J. Quinney College of Law . A Tre University of Utah aX ok ‘ N 332 South 1400 East, Room 101 “y a Salt Lake City, Utah 84112-0730 Dear Professor Cassell: 4 yr — OrrPBeeember te 2Hg Your letteg to United States Attorney Wifredo Ferrer was forwarded to the Office of Professional Responsibility (OPR). OPR has completed an inquiry into your allegation of professional misconduct by the United States Attomey’s Office for the Southern . & ” District of Florida (USAO) in the criminal investigation of Jeffrey epsifn Spi ically, you Pi sale s ko ‘s i ——that “improper influences” Osethe-USAO resulted in the decision to : a non-prosecution agreement with Mr. Epstein faregetnetfederatproseestion-ofsexoftertsts. iw Mest, fF net 222, of Set be heey ebdhe- statements porrmttir-sieaport of alee lergbgoncae sis one gly ‘tigate on behalf of victims under the Crime Victim's Rights Act in Jane Doe #1 and Jane Dod¥2 ery ~~ yv. United States, Case No. 08-80736-Civ-Marra/Johnson (S.D. Fla.). rose ee esnchadetbat, 4 “connected billionaire; it the Federa - agreement, it vicims were dé —whenherepresentedanasseciateofMr Epstein after retirino from the US AQ, OPR has jurisdiction to investigate allegations of misconduct involving Department of Justice (DOJ) attorneys or law enforcement personnel that relate to the exercise of an attorney’s authority to investigate, litigate or provide legal a Vice. ,It is, Rawever, the policy of this Office to refrain from investigating issues 08-80736-CV-MARRA P-013931 EFTA00230449

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er)? or allegations that were p prcidressed or t¥at could have been addressed in the course of litigation, unless a court has made a specific finding of misconduct by a DOJ attorney or law enforcement personnel or there are present other extraordinary circumstances. Based on our review of your correspondence, and the pleadings filed in Ne case, we have determined that your allegations fall into this category. No court has made a finding of misconduct and there are no extraordinary ‘ circumstances, a oe) F é to our attention. Se. Sincerely, ~. Qo ’ i ¢ + af, , Counsel if Z- -2- 08-80736-CV-MARRA P-013932 EFTA00230450

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2:ODMA/PCDOCS/OPR/309806/1 Howard 201100372 08-80736-CV-MARRA P-013933 EFTA00230451

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U.S. Department of Justice Office of Professional Responsibility 950 Pennsylvania Avenue N.W., Room 3266 Washington, D.C. 20530 CONFIDENTIAL€ TO BE OPENED BY ADDRESSEE ONLY The Honorable Wifredo A. Ferrer United States Attorney United States Attogney’s Office for the Souther District of Florida 99 N.E. 4° Street Miami, Florida 33132 Dear Mr. Ferrer: On December 16, 2010, Assistant United States Attorney [EEE forwarded to the Office of Professional Responsibility (OPR) a letter you received from Professor Paul Cassell, S.J. Quinney College of Law of the University of Utah. In his letter, Mr. Cassell alleged misconduct by the United States Attorney’s Office (USAO) in the investigation of Jeffrey Epstein for federal sex offenses. OPR has completed its inquiry into Mr. Cassell’s allegation that “improper influences” on the USAO resulted in the decision to enter into a non-prosecution agreement with Mr. Epstein foregoing federal charges. Many of the statements made by Professor Cassell in support of his allegation have been raised in litigation on behalf of victims under the Crime Victim’s Rights Act in Jane Doe #] and Jane Doe#2 v. United States, Case No. 08-80736-Civ-Marra/Johnson (S.D. Fla.). Those statements include that: Jeffrey Epstein is a politically-connected billionaire; that the Federal Bureau of Investigation was not informed of the non-prosecution agreement; that victims were deceived about the non-prosecution agreement; and that a former Assistant United States Attorney had a conflict of interest when he represented an associate of Mr. Epstein after retiring from the USAO. OPR has jurisdiction to investigate allegations of misconduct involving Department of Justice (DOJ) attorneys or law enforcement personnel that relate to the exercise of an attorney’s authority to 08-80736-CV-MARRA P-013934 EFTA00230452

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investigate, litigate or provide legal advice. It is, however, the policy of this Office to refrain from investigating issues or allegations that were addressed or that could have been addressed in the course of litigation, unless a court has made a specific finding of misconduct by a DOJ attomey or law enforcement personnel or there are present other extraordinary circumstances. Based on our review of Professor Cassell’s correspondence, and the pleadings filed in the Doe case, we have determined that his allegation falls into this category. No court has made a finding of misconduct and there are no extraordinary circumstances. With respect to Professor Cassell’s statements that Mr. Epstein may have had advance knowledge of an impending search warrant during the investigation, and that he has been denied discovery in civil litigation by victims against Mr. Epstein, we have determined that these statements do not warrant further inquiry and we consider this matter to be closed. Sincerely, Counsel 08-80736-CV-MARRA P-013935 EFTA00230453

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:ODMA/PCDOCS/OPR/309807/1 201100372 Howard 08-80736-CV-MARRA P-013936 EFTA00230454

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U.S. Department of Justice Office of Professional Responsibility 9350 Pennsylvania Avenue N.W., Room 3266 Washington, D.C. 20530 Professor Paul G. Cassell S.J. Quinney College of Law University of Utah 332 South 1400 East, Room 101 Salt Lake City, Utah 84112-0730 Dear Professor Cassell: On December 16, 2010, your letter to United States Attorney Wifredo Ferrer was forwarded to the Office of Professional Responsibility (OPR). OPR has completed an inquiry into your allegation of professional misconduct by the United States Attorney’s Office for the Southern District of Florida (USAO) in the criminal investigation of Jeffrey Epstein. Specifically, you alleged that “improper influences” on the USAO resulted in the decision to enter into a non-prosecution agreement with Mr. Epstein foregoing federal prosecution of sex offenses. Many of the statements you made in support of your allegation have been raised by you in litigation on behalf of victims under the Crime Victim's Rights Act inJane Doe #1 and Jane Doe#2 v. United States, Case No. 08-80736-Civ-Marra/Johnson (S.D. Fla.). Those statements include that: Jeffrey Epstein is a politically-connected billionaire; that the Federal Bureau of Investigation was not informed of the non-prosecution agreement; that victims were deceived about the non- prosecution agreement; and that a former Assistant United States Attorney had a conflict of interest Bhi cemnein 9 Fromtreus AO when he represented an associate of Mr. Epstein, OPR has jurisdiction to investigate allegations of misconduct involving Department of Justice (DOJ) attorneys or law enforcement personnel that relate to the exercise of an attornehd authority to investigate, litigate or provide legal advice. It is, however, the policy of this Office to refrain from investigating issues or allegations that were 08-80736-CV-MARRA P-013937 EFTA00230455

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addressed or that could have been addressed in the course of litigation, unless a court has made a specific finding of misconduct by a DOJ attorney or law enforcement personnel or there are present other extraordinary circumstances. Based on our review of your correspondence, and the pleadings filed in Doe case, we have determined that your allegations fall into this category. No court has made a finding of misconduct and there are no extraordinary circumstances. With respect to your statements that Mr. Epstein may have had advancef knowledge of an impending search warrant during the investigation, and that you have been denied discovery te- Oy inet whieh-you-feel-entitted in civil litigation by victims for-demeges-from Mr. Epstein, we have determined that these statements do not warrant further inquiry and we consider this matter to be closed. We regret that we can be of no further assistance to you. Thank you for bringing this matter to our attention. Sincerely, Counsel -2- 08-80736-CV-MARRA P-013938 EFTA00230456

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Document Number C:\Documents and Settings\rplagenhoef\Local Settings\Temporary Internet Files\Content.Outlook\6MC6F8 Y M\OPR-#309806-v l-epsteinclsltrcassell. WPD Howard 201100372 08-80736-CV-MARRA P-013939 EFTA00230457

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U.S. Department of Justice Office of Professional Responsibility 950 Pennsylvania Avenue N.W., Room 3266 Washington, D.C. 20530 CONFIDENTIAL: TO BE OPENED BY ADDRESSEE ONLY The Honorable Wifredo A. Ferrer United States Attorney Southern District of Florida 99 N.E. 4" Street Miami, Florida 33132 Dear Mr. Ferrer; On December 16, 2010, Assistant United States Attorney [EEE forwarded to the Office of Professional Responsibility (OPR) a letter you received from Professor Paul Cassell, S.J. Quinney College of Law of the University of Utah. In his letter, Mr. Cassell alleged misconduct by -your offfec in the investigation of Jeffrey Epstein for federal sex offenses. OPR has completed its inquiry into Mr. Cassell’s allegation that “improper influences” on the USAO resulted in the decision to enter into a non-prosecution agreement with Mr. Epstein foregoing federal charges. Many of the statements made by Professor Cassell in support of his allegation have been raised in litigation on behalf of victims under the Crime Victim’s Rights Act in Jane Doe #] and Jane Doe#2 v. United States, Case No. 08-80736-Civ-Marra/Johnson (S.D. Fla.). Those statements include that: Jeffrey Epstein is a politically-connected billionaire; that the Federal Bureau of Investigation was not informed of the non-prosecution agreement; that victims were deceived about the non-prosecution agreement; and that a former Assistant United States Attomey had a conflict abter retiring rm Te usag of interest when he represented an associate of Mr. Epstein. OPR has jurisdiction to investigate allegations of misconduct involving Department of Justice (DOJ) attomeys or law enforcement 08-80736-CV-MARRA P-013940 EFTA00230458

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personnel that relate to the exercise of an attorne(S/authority to investigate, litigate or provide legal advice. It is, however, the policy of this Office to refrain from investigating issues or allegations that were addressed or that could have been addressed in the course of litigation, unless a court has made a specific finding of misconduct by a DOJ attorney or law enforcement personnel or there are present other extraordinary circumstances. Based on our review of Professor Cassell’s correspondence, and the pleadings filed in the Doe case, we have determined that his allegation falls into this category. No court has made a finding of misconduct and there are no extraordinary circumstances. With respect to Professor Cassell’s statements that Mr. Epstein may have had advanced knowledge of an impending search warrant during the investigation, and that he has been denied O06 dams discovery tesvhtelthe-teels-entitted in civil litigation by victims fonddnages om Mr. Epstein, we have determined that these statements do not warrant further inquiry and we consider this matter to be closed. Sincerely, Counsel 08-80736-CV-MARRA P-013941 EFTA00230459

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Document Number C:\Documents and Settings\rplagenhoef\Local Settings\Temporary Internet Files\Content.Outlook\6MC6F8 Y M\OPR-#309807-v 1 -epsteinclosingltrusa. WPD 201100372 Howard 08-80736-CV-MARRA P-013942 EFTA00230460

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Griffin, Lisa (OPR) From: a Orr) Sent: sday May 05, 2011 11:19 AM To: (OPR) Subject: RE: Re-write of Epstein letters for your review Also, was the civil litigation where he didn’t get full discovery in state court? From: SEE (OPR) Sent: Thursday, May 05, 2011 11:08 AM To: (OPR) Subject: RE: Re-write of Epstein letters for your review Thanks for your guidance and help. From: EE (OPR) Sent; Thursday, May 05, 2011 11:01 AM To: SE CoP) Subject: RE: Re-write of Epstein letters for your review Cool. Let me read more closely for typos but this is great From: FY (OPR) Sent: Thursday, May 05, 2011 10:41 AM To: (OPR) Subject: Re-write of Epstein letters for your review Let me know what you think. 08-80736-CV-MARRA P-013943 EFTA00230461

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Griffin, Lisa (OPR) From: ES Ore) Sent: y 05, 2011 11:17 AM To: {OPR) Subject: RE: Re-write of Epstein letters for your review Was the search warrant a federal or state warrant? From: (I (ore) Sent: Thursd. May 05, 2011 11:08 AM To: SME (CP) Subject: RE: Re-write of Epstein letters for your review Thanks for your guidance and .ielp From: SN (OPR) Sent: Thursday, May 05, 2011 11:01 AM To: (OPR) Subject: RE: Re-write of Epstein letters for your review Cool. Let me read more closely for typos but this is great From: SE (opr) Sent: Thursday, May 05, 2011 10:41 AM To: (OPR) Subject: Re-write of Epstein letters for your review Let me know what you think. 08-80736-CV-MARRA P-013944 EFTA00230462

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Griffin, Lisa (OPR) From: CEE 0F®) Sent: May 04, 2011 5:01 PM To: ann (OPR) Subject: : draft letters in Epstein matter Let me think on it. He mentioned Reinhard in his first letter, right? As one of the “proofs” of improper influence? From: SE (0°) Sent: Wednesday, May 04, 2011 4:57 PM To: (OPR) Subject: draft letters in Epstein matter Ruth — How do these look? Lisa 08-80736-CV-MARRA P-013945 EFTA00230463

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OPR From: EE (ork) Sent: ay 04, 2011 4:08 PM To: (OPR) Subject: FYI on the Florida matter We talked t — he understand that OPR does not get involved in litigation and will handle Cassell’s requests. He told us that AUS and the case agent say that Reinhard was present for a meeting in which the culpability of ff was discussed. iz is the person he later represented after retiring. However, even if true, he isa former who may have had a conflict after he left us and OPR would not look into such a thing. (And | doubt PIN would prosecute him for a standards or conflict violation..) This does not seem to change our position on closing the matter, Lisa is drafting a closing letter. (oTw, i seemed fine when | told him we were going to close.) 1 08-80736-CV-MARRA P-013946 EFTA00230464

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EFTA00230465

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From: (OPR) Sent: ? To: . (OPR) Subject: FW: OPR inquiry - request for information Attachments: motion-intervene. pdf; sanctions-motion-attached pdf = Robin and Lisa, here is the latest on the Florida matter. | have a late lunch today but could meet at 3 or after. Pe be From: Paul Cassell [mailto [A Py Sent: Tuesday, May 03, 2011_12:23 PM ro: al (32): RIN cusar 5) ie te Cc: Brad Edwards ss pl Subject: RE: OPR inquiry - request for information ry Dear HB ans Ruth, As you will have seen, Bruce Reinhard has filed a motion to intervene in our Crime Victims’ Rights Act case. (Since Ruth has not been served, | attach a copy of the pleading to this e-mail). As you will see, Reinhard claims that we have no factual basis for making an assertion that (for example) Reinhard improperly represented | in violation of Justice Department regulations. 1n view of this motion, we are writing to inquire into the current status of the Justice Department's inquiry into Reinhard’s conduct. We also believe that the Justice Department has access to information that will support the allegations in our a summary judgment motion. We further believe that the Justice Department has access to information that will help us respond to Reinhard’s claim that he was not privy to any non-public information about the Epstein case. We are therefore respectfully requesting that the Justice Department provide this information to us by Tuesday, May 10, 2011, b-3 so that we can use this information in responding to Reinhard’s motion to intervene. Alternatively, if releasing the information at this time will be harmful to the Justice Department's on-going inquiry into Reinhard’s conduct, we request that the Justice Department inform Judge Marra that the Reinhard situation is currently the subject of a Justice Department inquiry and that further release of information would be harmful at this time. We request an opportunity to discuss this matter with you at your earliest convenience. Thank you in advance for your assistance. Sincerely, Brad Edwards and Paul Cassell Co-Counse! for Jane Doe #1 and Jane Doe #2 Paul G. Cassell Ronald N. Boyce Presidential Professor of Criminal Law $.J. Quinney College of Law at the University of Utah 332 South 1400 East, Room 101 Salt Lake City, UT 84112-0730 Fax: 801-581-6897 Email http://www. law.utah.edu/profiles/default.asp?PersoniD=57&name=Cassell, Paul CONFIDENTIAL: This electronic message - along with any/all attachments - is confidential. This message is intended only for the use of the addressee. If you are not the intended recipient, the person responsible to deliver it to the intended recipient, you may not use, disseminate, distribute or copy this communication. if you have received this message in error please immediately notify the sender by reply electronic mail and delete the original message. Thank you 1 08-80736-CV-MARRA P-013948 EFTA00230466

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From: (OPR) [mailto:Ruth.Plagenhoef@usdoj.gov]} Sent: Friday, April 15, 2011 3:02 PM To: Paul Cassell Subject: RE: OPR complaint Thanks, Paul. | will pass this on to the Assistant conducting the review. From: Paul Cassell [mailto! Sent: Frid i115, 2011 4:57 PM To: (OPR) Cc: Brad Edwards Subject: RE; OPR complaint Hi Ruth, Thanks for getting back to me. | was confused about one point — my letter to U.S. Attorney Ferrer requesting further investigation of the Epstein matter didn’t appear to me to raise any issues that even arguably could have been raised in litigation. So | was a bit confused by the reference to that complication in your e-mail —1 wasn’t sure what you were suggesting might have been the subject of earlier litigation. Perhaps you were referring to Crime Victims Rights Act issues. As you know, we have raised claims in on-going litigation that the government attorneys violated the Crime Victims Rights Act -- the government attorneys have now responded by arguing that these issues are not properly subject to litigation and the issue is under review by Judge Marra. But we were asking OPR for a general review of the issue of whether improper influences were brought to bear or improper actions taken that led to Epstein receiving a generous “non-prosecution” offer from the U.S. Attorney’s Office — a separate subject. Thanks for keeping us posted. Paul Cassell Paul G. Cassell Ronald N. Boyce Presidential Professor of Criminal Law S.J. Quinney College of Law at the University of Utah 332 South 1400 East, Room 101 Salt Lake City, UT 84112-0730 Voice: Fax: 801-581-6897 Email: http://www.law.utah.edu/profiles/default.asp?Person|D=57&name=Cassell, Paul CONFIDENTIAL, This electronic message - along with any/all attachments - is confidential. This message is intended only for the use of the addressee. If you are not the intended recipient, the person responsible to deliver it to the intended recipient, you may not use, disseminate, distribute or copy this communication. If you have received this message in error please immediately notify the sender by reply electronic mail and delete the original message. Thank you From: EE (OPR) (ait o Sent: Friday, April 15, 2011 2:24 PM To: Pau! Cassell Cc: Brad Edwards Subject: RE: OPR complaint 2 08-80736-CV-MARRA P-013949 EFTA00230467

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Paul, your complaint is under review. Please note that it is unusual for OPR to initiate an investigation of matters that have been or could be raised in litigation. If we determine based on the record in the pending matter that this is the case, we most likely will decline to go forward. Of course, if a court makes a finding criticizing the government or finding misconduct, the complaint can be renewed, We will let you know the results of our review. Ruth From: Paul Cassell [mailto Sent: Friday, April 15, 2011 3:10 PM To: (OPR) Cc: Brad Edwards Subject: RE: OPR complaint Hi Ruth, I'm just writing to see what the status is regarding the OPR inquiry that has been initiated into the Epstein matter. Brad Edwards and | would like to update our clients. Also, | am wondering if we can be helpful in providing any information to you in the inquiry. We know a lot about the Epstein matters, and would be happy to pass that along to you. Thanks in advance for any further information you can provide. Paul Cassell , Co-Counse! for Jane Doe Paul G. Cassell Ronald N, Boyce Presidential Professor of Criminal Law S.J. Quinney College of Law at the University of Utah 332 South 1400 East, Room 101 Salt Lake City, UT 84112-0730 Voice: Fax: 801-581-6897 CONFIDENTIAL: This electronic message - along with any/ail attachments - is confidential. This message is intended only for the use of the addressee. If you are not the intended recipient. the person responsible to deliver it to the intended pient, you may nat use, disseminate, distribute or copy this communication. If you hav ceived this message in error please immediately notify the sender by reply electronic mail and delete the original message. Thank you From: EE (oh) (ait Sent: Thursday, March 17, 2011 10:50 AM To: Paul Cassell Subject: RE: OPR complaint Thanks, Paul, OPR takes no position regarding any party's representations in litigation. Ruth From: Paul Cassell [mailto:casselip@ Sent: Thursday, March 17, 2011 12:11 PM To: A (0P*) 3 08-80736-CV-MARRA P-013950 EFTA00230468

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Cc: Brad Edwards Subject: RE; OPR complaint Hi Ruth, Thanks for the information. Tomorrow (3/18) we will be filing 2 pleading in which we mention AUSA Bruce Reinhart’s apparently improper representation of Epstein-related witnesses. | assume that doing so publicly will not compromise your inquiry We look forward to hearing from you as a soon as possible about the results of your inquiry. Thanks for your help, Paul Cassell Paul G. Cassell Ronald N. Boyce Presidential Professor of Criminal Law SJ. Quinney College of Law at the University of Utah 332 South 1400 East, Roorn 101 Salt Lake City, UT 84112-0730 Fax: 801-581-6897 Email: http://www _law.utah.edu/profiles/default.asp?Person|D=57 &name=Cassell, Paul CONFIDENTIAL. This electronic message - along with any/all attachments ~ is confidential. This message is intended only for the use of the addressee. If you are not the intended recipient, the person responsible to detiver it to the intended recipient, you may not use, disseminate, distribute or copy this communication. If you have received this message in error please immediately notify the sender by reply electronic mail and delete the original message Thank you From: EE (Pe) (roito ii Sent: Thursday, March 17, 2011 9:44 AM To: Paul Cassell Subject: OPR complaint Mr. Cassell, | received your voice mail and thought that | should respond by email to be sure you get a timely answer — with the time difference it can be hard to get in touch. | understand from AUSA | | that he confirmed to you that he sent your complaint and request for an investigation to OPR. We will therefore consider you a complainant in the matter, Your complaint is being handled within the normal process here at OPR. It has been opened as an inquiry and assigned for review. It is not an investigation. We will contact you if we need further information and/or to inform you of the results of our review. Acting Associate Counsel Office of Professional Responsibility US. — of Justice 4 08-80736-CV-MARRA P-013951 EFTA00230469

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OPR From: BS (Or) Sent: March 16, 2011 11:05 AM To: (OPR) Subject: FW: Referral of Cassell Request for Investigation From: | | | (USAFLS) Sent; Wednesday, March 16, 2011 10:52 AM To: (OPR) Subject: Referral of Cassell Request for Investigation Ruth, Attached please find an e-mail from Paul Cassell, regarding his anticipated filing of a motion for summary judgment in this Crime Victims Rights Act case. In December, he sent the U.S. Attorney's Office a letter requesting an investigation into alleged improprieties in the negotiation of a non-prosecution agreement with Jeffrey Epstein. That request was forwarded to OPR on December 16, 2010. Cassell has been pressing me for the name of the person conducting any investigation. | declined to provide him your name, until | cleared it with you first. Does OPR have a policy about providing complainants the names of the investigating attorneys? if not, shall | just refer Cassell to the OPR general phone number? Thanks. From: Paul Cassell i Sent: Tuesday, March 15, 2011 7:21 PM To: (USAFLS) Ce: Ann [BM C. (USAFLS); Brad Edwards Subject: RE: Government's Position on Several Pending Issues? Still Waiting for Answer Dear i “ Brad and | have received Mr. Ferrer’sletter of today. We are deeply disappointed. We will file our court pleadings on Friday. ~~. Mr. Ferrer’s letter still leaves unanswered a number of questions, which | am writing to raise with you -- again. 1. You still have not provided, as you promised you would, the name of the person coordinating the OPR investigation. As a result we have not been able to obtain any information about the status of the investigation, Just to be clear, we intend to include in our filing information that-OPR has begun an investigation and to include the information that we currently have about Bruce Reinhart — we assume that making that information public will not compromise OPR’s work. _ ~ 2. We will be making initial disclosures to you under the Federal Rules of Civil Procedure shortly. We have not heard back from you on whether you will be making parallel disclosures. Accordingly, we understand your position to be that you are not obligated to provide to us any documents under Rule 26. We understand your position to be that, despite the “best efforts” clause in the CVRA and your obligation to treat victims with faimess, you can withhold evidence from the victims that will help them prove CVRA violations. For example, we understand you to take the position that you can withhold the other half of the U.S. Attorney’s correspondence, correspondence between the Department and Ken 08-80736-CV-MARRA P-013952 2 EFTA00230470

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Starr and Lillian Sanchez on behalf of Epstein, and information about Bruce Reinhart’s role in the Epstein case. In short, we understand you to be asserting a blanket position that you can withhold information that will help prove the victims’ CVRA case. If this is incorrect, please advise us promptly. If we have misunderstood you and you are willing to provide us relevant information, we will promptly provide you with a list of such information. If we have understood you correctly, we will be filing a motion with the Court shortly to block the Justice Department from suppressing such highly relevant information. 4. You still have not given us your position on the victims’ motion to file an unsealed, unredacted pleading reciting the U.S. Attorney’s correspondence. What is your position on that motion: We have been asking for your position on this motion for some time now, If we have not heard back from you by c.0.b. Wednesday, March 16, 2011, we will include in our pleadings the following statement: “The Justice Department attomeys handling this case have been contacted several times for their position on this issue but have refused to respond to give their position.” Thanks you in advance for your assistance. Sincerely, Paul Cassell, Co-Counsel for Jane Doe Paul G. Cassell Ronald N. Boyce Presidential Professor of Criminal Law S.J. Quinney College of Law at the University of Utah 332 South 1400 East, Room 101 Salt Lake City, UT 84112-0730 Fax: 801-531-6897 Email: http://www.law.utah.edu/profiles/default.asp?Person|D=57&name=Cassell, Paul is treended only 2 intended this message in error, 08-80736-CV-MARRA P-013953 EFTA00230471

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;7? ior OPR From: (OPR) Sent: ember 16, 2010 10:59 AM To: (OPR) Subject: : ‘eferral - Allegation of Misconduct - U.S. Attorney's Office, S.D.Fla. Attachments: cassell_OPR.pdf As | said, | | probably sent me this because he knows me from my PRAO days. Let me know if | need to do anything. BTW, the Epstein matter rings a bell with me ~ | believe there was a self-referral when his attorneys accused AUSAs of misconduct, something to do with choosing an attorney for a victim who was a friend of the AUSA| think. it was an inquiry that got closed. Sent: ber 16, 2010 10:22 AM To: (OPR) Subject: OPR Referral - Allegation of Misconduct - U.S. Attorney's Office, $.D.Fla. Ruth, In 2006, the Palm Beach Police Department began investigating allegations that Jeffrey Epstein, a multi- millionaire investor living in Palm Beach, was enticing underage girls into prostitution. Epstein was alleged to have paid underage girls to provide him with massages, while the young girls were unclothed. The case was referred to the FBI and U.S. Attorney's Office, and the FBI began its own investigation. Epstein hired a number of highly-paid attorneys, including Alan Dershowitz and Kenneth Starr, to attempt to stave off criminal charges. Ultimately, in 2007, Epstein was charged in state court with soliciting minors for prostitution. In September 2007, the U.S. Attorney's Office entered into a Non-Prosecution Agreement with Epstein, in which he agreed to plead guilty to the state criminal charge, and serve a sentence of 18 months. Epstein also agreed that, in any civil action under 18 U.S.C. 2255 by the underage victims, he would not raise the lack of a federal sex offense as a defense. In July 2008, Epstein plead guilty, and was sentenced to serve six months at the Palm Beach County Detention Facility, followed by 12 months in home detention. In July 2008, after the Non-Prosecution Agreement had been executed, two victims, TM and CW, filed an action under the Crime Victims Rights Act (CVRA), 18 U.S.C. 3771. They claimed that the government was obligated, under 18 U.S.C. 3771(a)(5), to speak with the victims prior to the execution of the Non-Prosecution Agreement. An emergency hearing was held on July 11, 2008, before U.S. District Judge Kenneth Marra. Since Epstein had entered his state court plea and been sentenced already, the court found there was no emergency. He directed the parties to meet and determine if there were any factual disputes and whether an evidentiary hearing would be necessary. Attorney Brad Edwards initially represented the victims. Soon, he was joined by Paul Cassell, a University of Utah law professor, and former federal judge who served in the District of Utah from 2002-2007. Cassell is a victims’ rights advocate who has appeared in many cases throughout the United States. The victims’ rights suit was inactive for the next two years, with Edwards and Cassell using the civil suit as a means to attempt to gain access to information helpful in their civil actions for damages against Epstein. They were able to obtain a copy of the Non-Prosecution Agreement through the civil litigation. 1 08-80736-CV-MARRA P-013954 EFTA00230472

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In August 2010, the district court, noting that the last civil suit had been settled, entered an order closing the case. Edwards and Cassell immediately filed documents with the court, advising that the case should not be closed or dismissed, and they wanted to pursue final action by the court. Since September 2010, AUSA and | have been dealing with Cassell and Edwards on how to resolve the case. They claim the victims had a right to be consulted prior to the execution of the Non-Prosecution Agreement, and that we violated the CVRA by not consulting them. The remedy they seek is a set aside by the court of the Non- Prosecution Agreement, and a prosecution of Epstein. On December 10, 2010, United States Attorney Wifredo A. Ferrer, First Assistant and I, met with Cassell, Edwards, and CW, one of the victims. | We discussed the posture of the case, and CW told us her views of what occurred and her desire to see Epstein receive justice for what he did. Cassell presented U.S. Attorney Ferrer a four-page letter, requesting an investigation of the Jeffrey Epstein nh) 4 prosecution. A copy of Cassell’s letter is attached. He claims there may have been improper influence (L/ exercising by Epstein, noting that Epstein is a ‘politically-connected billionaire — Cassell cites to an alleged~ Renker ane that asearch warrant on his resid@ s to be executed; that a former AUSA, Bruce(> (2) (Reinhart, Jeft the West Palm Beach sere and soon began appearing on behalf of individuals aligned wit s) Epstein; and an unprecedented level of secrecy between the’ FB and the U.S. Attomey’s Office, where the F was purportedly kept in the dark about the impending Non-Prosecution Agreement. He also claims that the victims were deceived regarding the existence of the Non-Prosecution Agreement. (@) WA Cassell has made a non-frivolous allegation of serious misconduct by the U.S. Attorney's Office. _ | believe this matter needs to be referred to OPR, so it can determine the appropriate action to be taken. Accordingly, | am providing a copy of Cassell’s December 10, 2010 letter to you for any further action you deem appropriate. }am at the NAC today. | will be going on my Christmas vacation starting tomorrow, December 17. | can be reached by e-mail at all times, and also can be reached at all times at JE | will be back at my office on December 29. Thanks for your assistance, and have a great holiday. <<cassel|_OPR.pdf>> ro ™ ‘ ( 4) Can ¢ get tet ttn ow bee 2 08-80736-CV-MARRA P-013955 EFTA00230473

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