UNITED STATES DISTRICT COURT
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UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA IN RE GRAND JURY SUBPOENAS FGJ 07-103(WPB) DUCES TECUM NUMBERS OLY-63 and OLY-64 UNITED STATES' UNOPPOSED MOTION FOR PERMISSION TO FILE OVERSIZED RESPONSE TO MOTION OF JEFFREY EPSTEIN TO INTERVENE AND TO QUASH GRAND JURY SUBPOENAS AND CROSS-MOTION TO COMPEL UNDER SEAL UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA IN RE GRAND JURY SUBPOENAS FGJ 07-103(WPB) DUCES TECUM NUMBERS OLY-63 and OLY-64 UNDER SEAL UNITED STATES' UNOPPOSED MOTION FOR PERMISSION TO FILE OVERSIZED RESPONSE TO MOTION OF JEFFREY EPSTEIN TO INTERVENE AND TO QUASH GRAND JURY SUBPOENAS AND CROSS-MOTION TO COMPEL The United States, by and through the undersigned Assistant United States Attorney, hereby files this Motion for Permission to File an Oversized Response, and, in support thereof, states: 1. Movant Jeffrey Epstein, by and through counsel, filed a Motion to Intervene and to Quash two grand jury subpoenas duces tecum on July
Persons Referenced (6)
“...y , 2007, the foregoing document will be served via hand delivery on Attorney Roy Black, counsel for Jeffrey Epstein. The same document will be served on William Richey, counsel for William Riley a...”
U.S. Attorney“...nt was not filed using CM/ECF because it is being filed under seal. Assistant U.S. Attorney SERVICE LIST In re Federal Grand Jury Subpoenas No. OLY-63 and OLY-64 United States District Court, Sou...”
Alexander Acosta“...e has no objection to the granting of this motion. Respectfully submitted, R. ALEXANDER ACOSTA UNITED STATES ATTORNEY By: Assistant United States Attorney 500 South Australian Avenue, Suite 400 ...”
Jeffrey Epstein“...TATES' UNOPPOSED MOTION FOR PERMISSION TO FILE OVERSIZED RESPONSE TO MOTION OF JEFFREY EPSTEIN TO INTERVENE AND TO QUASH GRAND JURY SUBPOENAS AND CROSS-MOTION TO COMPEL UNDER SEAL UNITED STATES D...”
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EFTA DisclosureRelated Documents (6)
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
IthibiSlornam
IthibiSlornam taco L•fhwitit EFTA00176182 U.S. Department of Justice United States Attorney Southern District of Florida DELIVERY BY FACSIMILE Jay P. Lefkowitz, Esq. Kirkland & Ellis LLP Citigroup Center 153 East 53rd Street New York, New York 10022-4675 Re: Jeffrey Epstein Dear Jay: 99 M.E. 41' Street Miami, FL 33132-211! (305) 961-9299 Facsimile: (305) 530-6444 December 6, 2007 I write in response to your recent e-mails and letters regarding victim notification and other issues. Our Office is trying to perform our contractual obligations under the Agreement, which we feel are being frustrated by defense counsel's objections. The Office also is concerned about Mr. Epstein's nonperformance. More than three weeks ago we spoke about the failure to set a timely plea and sentencing date. At that time, you assured me that the scheduling delay was caused by the unavailability of Judge McSorley. You promised that a date would be set promptly. On November 15th, Roland
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
VIA FACSIMILE AND ELECTRONIC MAIL
VIA FACSIMILE AND ELECTRONIC MAIL Jack A. Goldberger, Esq. Atterbury, Goldberger & Weiss, P.A. Roy Black, Esq. Black Srebnick Kornspan & Stumpf P.A. Re: Jeffrey Epstein U.S. Department of Justice United States Attorney Southern District of Florida June 27, 2008 Dear Messrs. Goldberger and Black: Thank you for providing me with the proposed plea agreement between Mr. Epstein and the State Attorney's Office. The U.S. Attorney's Office hereby provides Notice that the proposed sentencing provision does not comply with the terms of the Non-Prosecution Agreement. The second sentencing paragraph of the proposed plea agreement reads: On 08CF00938 1 AMB, the Defendant is sentenced to 18 months Community Control I (one). As a special condition of this Community Control the Defendant must serve the first 6 months in the Palm Beach County Detention Facility ... The Non-Prosecution Agreement specifically provides: Epstein shall be sentenced to consecutive terms of twelve (12) mo
09/18/2007 02:53
09/18/2007 02:53 PM To 'Jay Lefkowite < cc bec Subject Factual proffer Hi Jay — I didn't want us to get sidetracked during the conference call. I want to make sure that we have a factual basis for "harassment" Forcibly flying omewhere else is a different 1512 offense with a 10 year cap. 1 is is the factual proffer that I drafted up earlier this afternoon, to give you an idea of what it would look like. When I include a factual proffer in a plea agreement, I usually use prefatory language like: The parties agree that, had this case proceeded to trial, the United States would have proven the following facts beyond a reasonable doubt, and that the following facts are true and correct and are sufficient to support a plea of guilty . <Cpstein Plea Proffer.doc>> Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 Phone Fax «< Attachment 'Epstein Plea Proffer.doc' has been archived by user 'CommonStorellT/Klrkland•Ellls' on '11/26/2007
UNITED STATES DISTRICT COURT
UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 9:08-ev-80736-Civ-ICAM JANE DOE 1 and JANE DOE 2 I UNITED STATES JANE DOE 1 AND JANE DOE 2'S RESPONSE IN OPPOSITION TO EPSTEIN'S MOTION FOR A PROTECTIVE CONFIDENTIALITY ORDER COME NOW Jane Doe 1 and Jane Doe 2 (also referred to as "the victims"), by and through undersigned counsel, to file this response in opposition to Epstein's Motion for a Protective Confidentiality Order (DE 247). Epstein's motion is a thinly-disguised attempt to relitigate issues already covered by the court's earlier ruling eleven months ago (DE 188), which allowed the victims to file correspondence relating to Epstein's non-prosecution agreement in the public court file. Rather than reverse its previous ruling, this Court should reaffirm it — and allow the important issues presented by this case to be litigated in the light of day. BACKGROUND Because of Epstein's penchant for relitigating issues that have already been decided, it
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