EFTA00205419Set 9
2012-01-231p215w
Case
Date: Mon, 23 Jan 2012 14:17:50 +0000
Importance: Normal
Attachments: DE48-3_201 ictim_notification_Ittpdf; DE48-
4 20110321 icti n_ltr.pdf; DE48-
6 20110321 f• DE48 ... forSpdf; DE48-
8 20110321 302 of from Jan 2008.pdf;
DE48 20110321_Motn_for_finding_a_violation_of_CVRA.pdf; DE48-
2 20110321=M302.pdf
Hi Ed - FINALLY, I found it. Now I know why the court wants ... should be
back by 11:15. Let me know how I can help, okay?
«DE48-3_21=1 im notification Itr.pdf>> <<D 01 ti ' Lion Ittpdf>> «DE48
https://www.justice.gov/epstein/files/DataSet%209/EFTA00205419.pdf
EFTA00208553Set 9
1992-05-136p2,669w
Response to
Petitioners' Motion for Finding of Violations of the Crime Victims Rights Act (DE48), and Petitioners' Motion to
Have Their Facts Accepted (DE49), it is the position ... Unseal. Instead, the United States has filed herewith, under seal, a redacted version of
DE48 and the relevant portions of Exhibit A, and asks the Court to unseal only redacted ... trial brief).
Petitioners' "Statement of Undisputed Material Facts," and Exhibit A to DE48 contain allegations related
to uncharged crimes against not only Epstein but several other individuals. F4 In keeping
https://www.justice.gov/epstein/files/DataSet%209/EFTA00208553.pdf
EFTA00208546Set 9
1992-05-136p2,643w
Response to
Petitioners' Motion for Finding of Violations of the Crime Victims Rights Act (DE48), and Petitioners' Motion to
Have Their Facts Accepted (DE49), it is the position ... Unseal. Instead, the United States has filed herewith, under seal, a redacted version of
DE48 and the relevant portions of Exhibit A, and asks the Court to unseal only redacted ... trial brief).
Petitioners' "Statement of Undisputed Material Facts," and Exhibit A to DE48 contain allegations related
to uncharged crimes against not only Epstein but several other individuals. F4 In keeping
https://www.justice.gov/epstein/files/DataSet%209/EFTA00208546.pdf
EFTA00208115Set 9
2011-04-0710p2,886w
Response to Petitioners' Motion for Finding of Violations of the Crime Victims
Rights Act (DE48), and Petitioners' Motion to Have Their Facts Accepted (DE49), it is the position ... filed the Non-Prosecution
Agreement ("NPA") in the public portion of the Court file. (DE48, Ex. E.) That document is the
subject of a Protective Order in the instant suit ... Unseal. Instead, the United States has filed herewith, under seal, a redacted version of DE48 and
the relevant portions of Exhibit A, and asks the Court to unseal only redacted
https://www.justice.gov/epstein/files/DataSet%209/EFTA00208115.pdf
EFTA00208230Set 9
2008-08-149p4,242w
Court to accept as true their proposed "Statement of Undisputed Material
Facts" contained in DE48 because they claim that the United States has failed "to advise the victims of what ... Motion for Finding of Violation of the CVRA [DE1 and
DE48]. Nonetheless, to correct misstatements in the record, the United States points out the following examples
of areas where Petitioners ... with FBI Agents and AUSA's from the U.S.
Attorney's Office." (DE48 at 17.) And another individual represented by Petitioners' counsel was interviewed
on May 28, 2008. These
https://www.justice.gov/epstein/files/DataSet%209/EFTA00208230.pdf
EFTA00212572Set 9
2008-08-1415p4,582w
Court to accept as true their proposed "Statement of Undisputed
Material Facts" contained in DE48 because they claim that the United States has failed "to advise
the victims of what ... victims), he committed violations of federal law,
including repeated violations of 18 U.S.C. § 2422.
(DE48 at 3-4 1 1.) Jane Does No. 1 and No. 2 had the opportunity ... Palm Beach, not West
Palm Beach. Even this simple correction was ignored. (See DE48 at 3-4.)
3
EFTA00212574
Case 9:08-cv-80736-KAM Document 58 Entered on FLSD
https://www.justice.gov/epstein/files/DataSet%209/EFTA00212572.pdf
EFTA00208091Set 9
2008-08-1415p4,583w
Court to accept as true their proposed "Statement of Undisputed
Material Facts" contained in DE48 because they claim that the United States has failed "to advise
the victims of what ... victims), he committed violations of federal law,
including repeated violations of 18 U.S.C. § 2422.
(DE48 at 3-4 1 1.) Jane Does No. 1 and No. 2 had the opportunity ... Palm Beach, not West
Palm Beach. Even this simple correction was ignored. (See DE48 at 3-4.)
3
EFTA00208093
Case 9:08-cv-80736-KAM Document 58 Entered on FLSD
https://www.justice.gov/epstein/files/DataSet%209/EFTA00208091.pdf
EFTA00212561Set 9
1992-05-135p2,532w
Response to
Petitioners' Motion for Finding of Violations of the Crime Victims Rights Act (DE48), and Petitioners' Motion to
Have Their Facts Accepted (DE49), it is the position ... Unseal. Instead, the United States has filed herewith, under seal, a redacted version of
DE48 and Exhibit A, and asks the Court to unseal the redacted versions.
CERTAIN PORTIONS ... trial brief).
Petitioners' "Statement of Undisputed Material Facts," and Exhibit A to DE48 contain allegations related
to uncharged crimes against not only Epstein but several other individuals. In keeping with
https://www.justice.gov/epstein/files/DataSet%209/EFTA00212561.pdf
EFTA00212552Set 9
2008-08-148p3,776w
Court to accept as true their proposed "Statement of Undisputed Material
Facts" contained in DE48 because they claim that the United States has failed "to advise the victims of what ... Motion for Finding of Violation of the CVRA [DE1 and
DE48]. Nonetheless, to correct misstatements in the record, the United States points out the following examples
of areas where Petitioners ... with FBI Agents and AUSA's from the U.S.
Attorney's Office." (DE48 at 17.) And in May 2008, another of Mr. M' clients received a victim
notification letter after
https://www.justice.gov/epstein/files/DataSet%209/EFTA00212552.pdf
EFTA00208502Set 9
2008-08-148p3,781w
Court to accept as true their proposed "Statement of Undisputed Material
Facts" contained in DE48 because they claim that the United States has failed "to advise the victims of what ... Motion for Finding of Violation of the CVRA [DE1 and
DE48]. Nonetheless, to correct misstatements in the record, the United States points out the following examples
of areas where Petitioners ... with FBI Agents and AUSA's from the U.S.
Attorney's Office." (DE48 at 17.) And in May 2008, another of Mr. Edwards' clients received a victim
notification letter after
https://www.justice.gov/epstein/files/DataSet%209/EFTA00208502.pdf
EFTA00208513Set 9
2008-07-0733p17,063w
Motions, including a
"Motion for Finding of Violations of Crime Victim's Rights Act." (DE48, 49, 50, 51.) This response follows.
ARGUMENT
Petitioners are not entitled to any relief ... that would
effectively keep the victims from learning what was happening through the press." (DE48 at 7.) Yet Petitioners
admit that they were notified regarding the change of plea ... Attorney's Office. She provided additional details of Epstein's sexual abuse of her." (DE48 at 17.) And, one of
Petitioners' counsel's other clients,E, was originally interviewed
https://www.justice.gov/epstein/files/DataSet%209/EFTA00208513.pdf
EFTA00212731Set 9
2011-04-078p1,129w
these proceedings, then the United States respectfully requests that the Court
unseal Petitioners' filings, DE48 and Exhibit A to DE48, only in redacted form. Attached hereto are
the relevant portions ... DE48 and Exhibit A to DE48 with the United States' proposed redactions.
As explained in the United States' Response, the Petitioners do not oppose the redactions
marked in blue ... casselp@law.utah.cdu
Attorneys for Jane Doe # 1 and Jane Doe # 2
EFTA00212734
RELEVANT PORTIONS OF DE48
EFTA00212735
the case. See generally U.S. Attorney's Correspondence, Exhibit "A" to this filing (hereinafter
https://www.justice.gov/epstein/files/DataSet%209/EFTA00212731.pdf
EFTA00078835Set 9
2011-04-0854p17,640w
Document 62 Entered on FLSD Docket 04/08/20U. Page 7 of 54
Rights Act." (DE48, 49, 50, 51.) This response follows.
ARGUMENT
Petitioners are not entitled to any relief in this ... that would effectively keep the victims from learning what was
happening through the press." (DE48 at 7.) Yet Petitioners admit that they were notified
regarding the change of plea ... Attorney's Office. She provided additional details of Epstein's sexual abuse of her."
(DE48 at 17.) And, one of Petitioners' counsel's other clients, S.R., was originally interviewed
https://www.justice.gov/epstein/files/DataSet%209/EFTA00078835.pdf
EFTA00208037Set 9
2011-04-0754p17,943w
Entered on FLSD Docket 04'07)2011 Page 7 of 54
Rights Act." (DE48, 49, 50, 51.) This response follows.
ARGUMENT
Petitioners are not entitled to any relief in this ... that would effectively keep the victims from learning what was
happening through the press." (DE48 at 7.) Yet Petitioners admit that they were notified
regarding the change of plea ... Attorney's Office. She provided additional details of Epstein's sexual abuse of her."
(DE48 at 17.) And, one of Petitioners' counsel's other clients, E, was originally interviewed
https://www.justice.gov/epstein/files/DataSet%209/EFTA00208037.pdf