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From: To: ' Cc: r> " , '1 Subject: RE: Briefing in Florida regarding whether the Florida NPA extends to New York - concession by Epstein's attorney that NPA only applies in Florida Date: Wed, 07 Aug 2019 19:07:23 +0000 Attachments: Exh_067_EPSTEIN_PLEA_CONFERENCE_CRIMINAL_06-30-08.pdf HIM, You and the team there may have already seen this, but in view of the importance of the issue, I wanted to pass it along. Attached is the transcript of the hearing from Florida state court in 2008, in which Epstein pled guilty to Florida state charges. During the course of questioning by the judge, Epstein's Florida attorney (Jack Goldberger) stated (on Epstein's behalf) that the NPA contained an obligation by the U.S. Attorney's Office for the Southern District of Florida "not [to] prosecute Mr. Epstein in the Southern District of Florida ...." See page 38 (emphasis added). I wanted you to be sure to have this information, as the subject is likely to be important. for Jane Doe 1 (phone
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UNITED STATES DISTRICT COURT
UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 08-80736-Civ-Marra/Johnson JANE DOES #1 and #2 I UNITED STATES JANE DOE #1 AND JANE DOE #2'S MOTION FOR FINDING OF VIOLATIONS OF THE CRIME VICTIMS' RIGHTS ACT, REQUEST FOR AN EVIDENTIARY HEARING IF FACTS ARE CONTESTED, AND REQUEST FOR HEARING ON APPROPRIATE REMEDIES COMES NOW Jane Doe #1 and Jane Doe #2 (also referred to as "the victims"), by and through undersigned counsel, to move for a finding from this Court that their rights as crime victims under the Crime Victims Rights Act (CVRA) have been repeatedly violated by the U.S. Attorney's Office, to request an evidentiary hearing to establish those violations if the U.S. Attorney's Office contests the underlying facts, and to request a brief schedule and a hearing on the appropriate remedies for these violations. As recounted in more detail below, the victims have recently-obtained correspondence between the U.S. Attorney's Office and defendant Jeffrey
UNITED STATES DISTRICT COURT
UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 08-80736-Mise-Marra/MatthrA mari JANE DOE #1 and JANE DOE #2, Petitioners, I UNITED STATES OF AMERICA, Respondent. RESPONDENT'S ANSWERS TO PETITIONERS' FIRST REQUESTS FOR ADMISSIONS I. Admit. 2. (a) Cannot admit or deny. Jeffrey Epstein's ("Epstein") attorneys learned of the notifications that were planned to be provided to persons designated as victims when contact was made with the attorney who was then representing Jane Doe #21 to determine how she wanted to be notified. At that time, Epstein's attorneys contacted the U.S. Attorney's Office ("USAO") and stated their objections to the procedure for notification and the legal bases therefore. Epstein's attorneys also objected to the designation of Jane Doe #2 as a victim because she had self-reported that she was not a victim. Members of the USAO considered those objections. (b) Admit. This attorney was being compensated by Epstein to represent Jane
UNITED STATES DISTRICT COURT
UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 08-80736-CIV-MARRA JANE DOE #1 and JANE DOE #2, Petitioners, vs. UNITED STATES OF AMERICA, Respondent. RESPONDENT'S INITIAL DISCLOSURES Respondent United States of America, by and through its undersigned counsel, makes its Initial Disclosures, pursuant to Fed.R.Civ.P. 26(a)(1)(A), and state: Fed.R.Civ.P. 26(a)(1)(A)fil: 1. R. Alexander Acosta Dean, School of Law Florida International University Rafael Diaz-Balart Hall 11200 S.W. 8'h Street Miami, Florida 33199 (305) 348-1118 Dean Acosta was the United States Attorney, Southern District of Florida, during the time when the criminal investigation of Jeffrey Epstein was opened in the U.S. Attorney's Office, and the non-prosecution agreement was negotiated. 2. was the First Assistant U.S. Attorney in the U.S. Attorney's Office, during the time when the criminal investigation of Jeffrey Epstein was opened, and the non-prosecution agreement was negot
UNITED STATES DISTRICT COURT
UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 08-80736-Civ-Marra/Johnson JANE DOES #1 and #2 v. UNITED STATES JANE DOE #1 AND JANE DOE #2'S MOTION FOR FINDING OF VIOLATIONS OF THE CRIME VICTIMS' RIGHTS ACT, REQUEST FOR AN EVIDENTIARY HEARING IF FACTS ARE CONTESTED, AND REQUEST FOR HEARING ON APPROPRIATE REMEDIES COMES NOW Jane Doe #1 and Jane Doe #2 (also referred to as "the victims"), by and through undersigned counsel, to move for a finding from this Court that their rights as crime victims under the Crime Victims Rights Act (CVRA) have been repeatedly violated by the U.S. Attorney's Office, to request an evidentiary hearing to establish those violations if the U.S. Attorney's Office contests the underlying facts, and to request a brief schedule and a hearing on the appropriate remedies for these violations. As recounted in more detail below, the victims have recently-obtained correspondence between the U.S. Attorney's Office and defendant Jeffre
Case 9:08-cv-80893-KAM
Case 9:08-cv-80893-KAM Document 31 Entered on FLSD Docket 04/09/2009 Page 1 of 14 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No.: 08-CIV-80893 - MARRA/JOHNSON JANE DOE, 1. Plaintiff, JEFFREY EPSTEIN, Defendant. / PLAINTIFF'S RESPONSE IN OPPOSITION TO DEFENDANT'S MOTION TO STAY COMPLAINT Plaintiff, Jane Doe, hereby responds to the motion by defendant Jeffrey Epstein ("Epstein") to stay this action until late 2010. The motion for a stay should be denied. Defendant has not carried his heavy burden of justifying a stay in the action. A stay pending resolution of a related criminal prosecution is proper only when "special circumstances so require in the interests of justice." United States 1. Lot 5, Fox Grove, Alachua County, Fla., 23 F.3d 359, 364 (11th Cir. 1994) (internal quotations omitted). Of course, "The proponent of a stay bears the burden of establishing its need." Clinton I. Jones, 520 U.S. 681, 708 (1997). To stay a civil action in light
Case 9:08-cv 80119-KAM
Case 9:08-cv 80119-KAM Document 180 Entered on FLSD Docket 06/24/2009 Page 1 of 51 1 2 3 4 5 6 7 8 9 10 11 12 13 16 2Y) UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA WEST PALM BEACH DIVISION CASE NO. 08-80119-CIV-MARRA JANE DOE, et al., Plaintiffs, vs. JEFFREY EPSTEIN, Defendant. x APPEARANCES: WEST PALM BEACH, FLORIDA JUNE 12, 2009 TRANSCRIPT OF MOTION HEARING BEFORE THE HONORABLE KENNETH A. MARRA, UNITED STATES DISTRICT JUDGE FOR THE PLAINTIFFS: For Jane Doe TOTAL ACCESS COURTROOM NETWORK REALTIME TRANSCRIPTION EFTA00212053 Case 9:08-cv 80119-KAM Document 180 Entered on FLSD Docket 06/24/2009 Page 2 of 51 2 I I I I I 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 FOR THE DEFENDANT: REPORTED BY: ROBERT D. CRITTON, JR., ESQ. MICHAEL BURMAN, ESQ. Burman Critton, etc. 515 North Flagler Street West Palm Beach, FL 33401 JACK A. GOLDBERGER, ESQ. Atterbury Goldberger Weiss 250 Australian Avenue Sou
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