EFTA00087853Set 9
2009-02-0991p22,192w
admit liability to the Plaintiff, C.M.A.
COUNT I
Cause of Action Pursuant to 18 USC §2255
May/June 2002
20. The Plaintiff, C.M.A., adopts and realleges paragraphs 1 through 19
above ... right by a jury.
COUNT II
Cause of Action Pursuant to 18 USC §2255
June 2002- Incident 2
26. The Plaintiff, C.M.A., adopts and realleges paragraphs 1 through 19
above ... right by a jury.
COUNT V
Cause of Action Pursuant to 18 USC §2255
August of 2002 - Incident 1
44. The Plaintiff, C.M.A., adopts and realleges paragraphs 1 through
https://www.justice.gov/epstein/files/DataSet%209/EFTA00087853.pdf
EFTA00609400Set 9
2009-10-1917p3,935w
Second Parties further stipulate and agree that this settlement is pursuant,
exclusively, to 18 USC §2255 and that the First Parties agree to waive and relinquish all other
federal, state ... violated any federal statute that
constitutes a predicate for a damage claim under 18 USC §2255 or an admission that he
violated any other federal or state statute or that ... right to fully
defend other cases where damages exceeding the statutory minimum for 18 USC §2255 claims
of $50,000 are sought.
2
EFTA00609403
3. Enforcement. This Settlement Agreement shall
https://www.justice.gov/epstein/files/DataSet%209/EFTA00609400.pdf
EFTA00194687Set 9
2008-09-02135p42,589w
Epstein to an "identified individual" who "elects to proceed exclusively under 18 USC 2255,
and aRrees to waive any other claim for damages. whether pursuant to state. federal or common ... Jane Doc
101, that she "exclusively seeks civil remedies pursuant to 18 USC 2255." Exhibit 27, Amended
Complaint 1 24. Such an averment satisfies only the exclusivity portion
https://www.justice.gov/epstein/files/DataSet%209/EFTA00194687.pdf
EFTA00731162Set 9
2008-06-304p1,667w
details, with women identified by the
Government as "victims" as defined by 18 USC 2255, each for the
statutory damage amount of $50,000 even though at least ... based
on statutory minimum lump sum payments such as those prescribed by 18
USC 2255. JE had repeatedly, through counsel, advocated for a restitution
trust fund to compensate any injured ... list of
individuals who the USAO claims are "victims" as defined in 18 USC
2255 and then not to disclose the identities of the "victims" named in the
list "after
https://www.justice.gov/epstein/files/DataSet%209/EFTA00731162.pdf
EFTA00609438Set 9
6p1,597w
Second Parties further stipulate and agree that this settlement is pursuant,
exclusively, to 18 USC §2255 and that the First Parties agree to waive and relinquish all other
federal, state ... violated any federal statute
that constitutes a predicate for a damage claim under 18 USC §2255 or an admission that he
violated any other federal or state statute or that ... right to fully
defend other cases where damages exceeding the statutory minimum for 18 USC §2255 claims
are sought, and where a Plaintiff waives her right to bring suit under
https://www.justice.gov/epstein/files/DataSet%209/EFTA00609438.pdf
unique issues relating to the integration of a civil damage statute, 18
USC 2255, into an agreement that, at its essence, deferred federal criminal
prosecution but required that Epstein comply ... Agreement;
7. Further, Epstein has settled each case brought exclusively pursuant to
18 USC 2255 (or threatened to be brought pursuant to that statute) even
though as to one such ... contact with her, and as to another the civil six year statute, see 18 USC
2255(c), had expired before the lawsuit was instituted. He settled these
EFTA00730219
cases only
https://www.justice.gov/epstein/files/DataSet%209/EFTA00730219.pdf
EFTA00189961Set 9
2010-04-022p510w
legal deficiencies and seeks only to raise
substantial and unresolved legal issues regarding 18 USC §2255 (which, if
allowed, would lead only to the plaintiff amending her filing rather than ... without prejudice to its being re-
filed under the version of the statute, 18 USC §2255, that was in existence at the
201 S. Biscayne Boulevard. Suite 1300 • Miami. Florida ... should be required to plead her action under the applicable version of 18 USC
2255") and p.24 ("the statute in effect during the time of the alleged conduct
applies
https://www.justice.gov/epstein/files/DataSet%209/EFTA00189961.pdf
EFTA00725777Set 9
2010-04-022p427w
civil pleading which
seeks only to raise substantial and unresolved legal issues regarding 18 USC
2255 (which, if allowed, would lead only to the plaintiff amending her filing
rather than ... without
prejudice to its being re-filed under the version of the statute, 18 USC 2255,
that was in existence at the time of the conduct rather than the later ... should be required to plead her action
under the applicable version of 18 USC 2255") and pg 24 ("the statute in
effect during the time of the alleged conduct applies
https://www.justice.gov/epstein/files/DataSet%209/EFTA00725777.pdf
unique issues relating to the integration of a civil damage statute, 18
USC 2255, into an agreement that, at its essence, deferred federal criminal
prosecution but required that Epstein comply ... Agreement;
7. Further, Epstein has settled each case brought exclusively pursuant to
18 USC 2255 (or threatened to be brought pursuant to that statute) even
though as to one such ... unbelievable" and as to another, though the civil six year statute, see
18 USC 2255(c), had expired before the lawsuit was instituted the
attorney representative demanded , and received 500k
https://www.justice.gov/epstein/files/DataSet%209/EFTA00587073.pdf
EFTA00730624Set 9
2010-04-052p513w
legal deficiencies and seeks only to raise
substantial and unresolved legal issues regarding 18 USC §2255 (which, if
allowed, would lead only to the plaintiff amending her filing rather than ... without prejudice to its being re-
filed under the version of the statute, 18 USC §2255, that was in existence at the
2O1 S. Biscayne Boulevard. Suite 1300 • Miami, Florida ... should be required to plead her action under the applicable version of 18 USC
2255") and p.24 ("the statute in effect during the time of the alleged conduct
applies
https://www.justice.gov/epstein/files/DataSet%209/EFTA00730624.pdf
EFTA00213235Set 9
2010-04-022p514w
legal deficiencies and seeks only to raise
substantial and unresolved legal issues regarding 18 USC §2255 (which, if
allowed, would lead only to the plaintiff amending her filing rather than ... without prejudice to its being re-
filed under the version of the statute, 18 USC §2255, that was in existence at the
201 S. Biscayne Boulevard. Suite 1300 • Miami. Florida ... should be required to plead her action under the applicable version of 18 USC
2255") and p.24 ("the statute in effect during the time of the alleged conduct
applies
https://www.justice.gov/epstein/files/DataSet%209/EFTA00213235.pdf
EFTA00208970Set 9
2007-09-2776p17,680w
idea of the charges that we hadanned to
bring as related to 18 USC 2255. With respect to question 2, do I have your permission to send Mijust that
section ... idea of the charges that we had planned to
.ing as related to 18 USC 2255. With respect to question 2, do I have your permission to send =just that ... idea of the charges that we had planned to
bring as related to 18 USC 2255. With respect to question 2, do I have your permission to send Bert just
https://www.justice.gov/epstein/files/DataSet%209/EFTA00208970.pdf
EFTA00183732Set 9
2008-09-02136p42,094w
Epstein to an "identified individual" who "elects to proceed exclusively under 18 USC 2255,
and aerees to waive any other claim for damages. whether pursuant to state, federal, or moron ... allege, as did Doe
101, that she "exclusively seeks civil remedies pursuant to 18 USC 2255." Exhibit 27, Amended
Complaint ¶ 24. Such an averment satisfies only the exclusivity portion
https://www.justice.gov/epstein/files/DataSet%209/EFTA00183732.pdf
EFTA00725775Set 9
2010-04-022p373w
Complaint without prejudice to its being refilled
under the version of the statute, 18 USC 2255, that was in existence at the
time of the conduct rather than the later ... should be required to plead her action under the applicable version
of 18 USC 2255") and pg 24 ("the statute in effect during the time of the
alleged conduct applies ... civil counsel to
permanently preclude Jane Doe 103 from bringing a lawsuit under 18 USC
2255.
EFTA00725775
Again, we appreciate your providing us with the Office's position so that
https://www.justice.gov/epstein/files/DataSet%209/EFTA00725775.pdf
EFTA00213453Set 9
2007-09-2379p13,346w
idea of the charges that we had
planned to bring as related to 18 USC 2255. With respect to
question 2, do I have your permission to send Bert just ... idea of the charges that we had
planned to bring as related to 18 USC 2255. With respect to
question 2, do I have your permission to send Bert just ... idea of the charges that we had
planned to bring as related to 18 USC 2255. With respect to
question 2, do I have your permission to send Bert just
https://www.justice.gov/epstein/files/DataSet%209/EFTA00213453.pdf
EFTA00296592Set 9
2007-09-2379p13,410w
idea of the charges that we had
planned to bring as related to 18 USC 2255. With respect to
question 2, do I have your permission to send Bert just ... idea of the charges
ct to
planned to bring as related to 18 USC 2255. With respe
that section
question 2, do I have your permission to send Bert just ... idea of the charges that we had
planned to bring as related to 18 USC 2255. With respect to
question 2, do I have your permission to send Bert just
https://www.justice.gov/epstein/files/DataSet%209/EFTA00296592.pdf