(USAFLS)" </DI
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From: (USAFLS)" </DI To: "Brad Edwards Subject: Confidential Settlement Negotiations Date: Sat, 25 Jun 2016 20:17:08 +0000 Importance: High Attachments: Proposed_Order_Approving_Stip_for_Dismissal.pdf; Proposed_Stipulation_for_Dismissal.pdf; USAO_Letter_to Jane_Doe_l_-_06-22- 2016_with_watermark.pdf; 20160625_Jane_Doe_Settlement_Agreement.pdf Ili Brad —I am sending you our complete packet, that is: (1) Proposed Settlement Agreement, including title of DOJ official for meeting (2) Proposed Stipulation of Dismissal and Order accepting it (this would be Appendix "B") (3) Proposed letter (this would be Appendix "C") Sealed Appendix A is the victim list from you with my one addition. I need from you: Appendix D (proposed amendments to the "Attorney General Guidelines for Victim and Witness Assistance" and to the procedures for filing complaints with the Justice Department's Crime Victims' Rights Ombudsman) Appendix E (proposed amendments to the U.S. Attorney's Manual) I am
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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 Petitioners, v. UNITED STATES OF AMERICA, Respondent. RESPONDENT'S OPPOSITION TO VICTIMS' MOTION TO UNSEAL NON-PROSECUTION AGREEMENT Respondent, by and through its undersigned counsel, files its Opposition to Victims' Motion to Unseal Non-Prosecution Agreement, and states: I. THE MOTION TO UNSEAL SHOULD BE DENIED BECAUSE THE NON-PROSECUTION AGREEMENT HAS NEVER BEEN FILED UNDER SEAL IN THIS COURT. Petitioners have filed their motion to unseal the non-prosecution agreement, claiming that no good cause exists for sealing it. As an initial matter, the motion should be denied because the non-prosecution agreement entered into between the United States Attorney's Office and Jeffrey Epstein was never filed in the instant case by the United States, either under seal or otherwise. On August 14, 2008, this Court held a telephonic hearing to discuss petitioners' r
6/19122, 3:62 PM
6/19122, 3:62 PM teSTEIN4 M;i„ ei.A15,DNIER - C,CA,SZNi frietv7 AoS-‘ ,..ci 11,N CC)•:E4 rjetrIW - tELNEPS ‘ -NidPedia tMA\etraE Epstein a massage'. She claims she was taken to his mansion, • Perversion of Justice, Miami Herald, where he exposed himself and had sexual intercourse with November 30, 2018. her, and paid her Sao° immediately afterward.1120 A similar $50-million suit was filed in March 2008, by a different woman, who was represented by the same lawyer.11n1 These and several similar lawsuits were dismissed.r1391 All other lawsuits have been settled by Epstein out of court.D311 Epstein made many out-of-cogr settlements with alleged vigil-m[1301 Victims' rights: Jane Does v. United States (2014)*56C, ni3C6 E St P i‘JEt<ri PCS rrl • It-•S A December 3o, 2O14, federal civil suit was filed in Florida by Jane Doe 1. (Courtney Wild) and Jane Doe 2 against the United States for violations of the Crime Victims' Rights Act by the U.S. Department of Justice's
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 DECLARATION OF BRADLEY J. EDWARDS, ESQ. I. I, Bradley J. Edwards, Esq., do hereby declare that I am a member in good standing of the Bar of the State of Florida. Along with co-counsel, I have represented Jane Doe #1 and Jane Doe #2 in civil suits against Jeffrey Epstein for sexually abusing them. I have also represented other girls who were sexually abused by Epstein. As a result of that representation, I have become familiar with many aspects of the criminal investigation against Epstein and have reviewed discovery and correspondence connected with the criminal investigation. I have also spoken to Jane Doe #1 and Jane Doe #2 at length about the criminal investigation and their involvement in it, as well enforcement (or lack their of) of their rights as crime victims in the investigation. I also represent Jane Doe #1 and Jane Doe #2 in the pen
Case 9:08-cv-80736-KAM
Case 9:08-cv-80736-KAM Document 28 Entered on FLSD Docket 09/25/2008 Page 1 of 8 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-80736-CIV-MARRA/JOHNSON JANE DOE #1 AND JANE DOE #2, Petitioners, v. UNITED STATES OF AMERICA, Respondent. VICTIM'S MOTION TO UNSEAL NON-PROSECUTION AGREEMENT COMES NOW the Petitioners, Jane Doe #1 and Jane Doe #2, by and through their undersigned attorneys, pursuant to the Crime Victim's Rights Act, 18 U.S.C. Section 3771 ("CVRA"), and file this motion to unseal the non-prosecution agreement that has been provided to their attorneys under seal in this case. The agreement should be unsealed because no good cause exists for sealing it. Moreover, the Government has inaccurately described the agreement in its publicly-filed pleadings, creating a false impression that the agreement protects the victims. Finally, the agreement should be unsealed to facilitate consultation by victims' counsel with others involved who have
UNITED STATES DISTRICT COURT
UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 08-80736-CI V-Marra/Matthewman JANE DOE # I and JANE DOE #2, Petitioners, I UNITED STATES OF AMERICA, Respondent. UNITED STATES' RESPONSE TO PETITIONERS' FIRST REOUEST FOR ADMISSIONS TO THE GOVERNMENT The United States (hereinafter the "government") hereby responds to Jane Doe #1 and Jane Doe #2's First Request for Admissions to the Government Regarding Questions Relevant to Their Pending Action Concerning the Crime Victims Rights Act (hereinafter the "Request for Admissions"), and states as follows:' I. The government admits that the FBI and the U.S. Attorney's Office for the Southern District of Florida ("USAO") conducted an investigation into Jeffrey Epstein ("Epstein") and developed evidence and information in contemplation of a potential federal prosecution against Epstein for many federal sex offenses. Except as otherwise admitted above, the government denies Request No. I. The government's res
CM/ECF - Live Database
CM/ECF - Live Database r Page 1 of 3 U.S. District Court Southern District of Florida (West Palm Beach) CIVIL DOCKET FOR CASE #: 9:08-cv-80736-KA M Doe'. United States of America Assigned to: Judge Kenneth A. Marra Cause: no cause specified Date Filed: 07/07/2008 Jury Demand: None Nature of Suit: 440 Civil Rights: Other Jurisdiction: U.S. Government Defendant LRJ Date Filed # Docket Text 07/07/2008 1 EMERGENCY PETITION for Victim's Enforcement of Crime Victim's Rights Act 18 USC 3771 against United States of America Filing fee $ 350. Receipt#: 724403, filed by Jane Doe. (rb) (Entered: 07/07/2008) 07/07/2008 2 CERTIFICATE OF EMERGENCY by Jane Doe re 1 Complaint (rb) (Entered: 07/07/2008) 07/07/2008 3 ORDER requiring U.S. Attorney to respond to 1 Complaint filed by Jane Doe by 5:00 p.m. on 7/9/08. Signed by Judge Kenneth A. Marra on 7/7/08. (ir) (Entered: 07/07/2008) 07/09/2008 4 NOTICE of Attorney Appearance by Dexter Lee on behalf of United States of America (
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