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efta-efta00235157DOJ Data Set 9Other

Case 9:08-cv-80736-KAM

Case 9:08-cv-80736-KAM Document 30-p A µ, Egtnefleop FLSD Docket 10/16/2008 Page 1 of 2 • Szadeverai, • AND ASSOCIATES October 15, 2008 AUSA United States Attorney's Office 99 N.E. 4th Street Miami, Florida 33132 Re: Jane Doe # and Jane Doe #2 v. United States of America Case No.: 08-80736-CIV-MARRA/JOHNSON Dear Mr..: I am writing to inquire about whether Mr. Epstein has violated his Non-Prosecution Agreement with the Government. As you know, the Government has repeatedly described the Non-Prosecution Agreement as guaranteeing to the victims of Epstein's sexual abuse at least $150,000 in civil damages. The Government has made these representations in reliance on a current provision in the U.S. Code — 18 U.S.C. § 2255(a) — which provides for an automatic amount of damages of at least $150,000. At the time that the Non-Prosecution Agreement was drafted and signed, that was the law that was in effect. In Epstein's latest filing in federal court, however, he takes the

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DOJ Data Set 9
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EFTA 00235157
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2
Persons
3
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Case 9:08-cv-80736-KAM Document 30-p A µ, Egtnefleop FLSD Docket 10/16/2008 Page 1 of 2 • Szadeverai, • AND ASSOCIATES October 15, 2008 AUSA United States Attorney's Office 99 N.E. 4th Street Miami, Florida 33132 Re: Jane Doe # and Jane Doe #2 v. United States of America Case No.: 08-80736-CIV-MARRA/JOHNSON Dear Mr..: I am writing to inquire about whether Mr. Epstein has violated his Non-Prosecution Agreement with the Government. As you know, the Government has repeatedly described the Non-Prosecution Agreement as guaranteeing to the victims of Epstein's sexual abuse at least $150,000 in civil damages. The Government has made these representations in reliance on a current provision in the U.S. Code — 18 U.S.C. § 2255(a) — which provides for an automatic amount of damages of at least $150,000. At the time that the Non-Prosecution Agreement was drafted and signed, that was the law that was in effect. In Epstein's latest filing in federal court, however, he takes the

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Case 9:08-cv-80736-KAM Document 30-p A µ, Egtnefleop FLSD Docket 10/16/2008 Page 1 of 2 • Szadeverai, • AND ASSOCIATES October 15, 2008 AUSA United States Attorney's Office 99 N.E. 4th Street Miami, Florida 33132 Re: Jane Doe # and Jane Doe #2 v. United States of America Case No.: 08-80736-CIV-MARRA/JOHNSON Dear Mr..: I am writing to inquire about whether Mr. Epstein has violated his Non-Prosecution Agreement with the Government. As you know, the Government has repeatedly described the Non-Prosecution Agreement as guaranteeing to the victims of Epstein's sexual abuse at least $150,000 in civil damages. The Government has made these representations in reliance on a current provision in the U.S. Code — 18 U.S.C. § 2255(a) — which provides for an automatic amount of damages of at least $150,000. At the time that the Non-Prosecution Agreement was drafted and signed, that was the law that was in effect. In Epstein's latest filing in federal court, however, he takes the position that the pre-2006 Amendments version of the law applies. See Defendant Epstein's Motion to Dismiss, for More Definite Statement and To Strike Directed to Plaintiff Jane Doe's Complaint at 9, Jane Doe v. Jeffrey Epstein, No. 08-CIV-80893-Marra/Johnson (discussing § 2255 and stating that the "applicable version of the statute" is "pre-2006 Amendments"). The 2006 Amendments altered § 2255(a), by increasing the presumed minimum damages from $50,000 to $150,000. See Pub. L. 109-248, Title VII, § 707(b), (c), July 27, 2006, 120 Stat. 650. In light of Epstein's latest filing, I write to ask several questions: (1) Would you stipulate that you told me several times that Epstein had agreed to pay at least $150,000 to the identified victims of his abuse? (2) Did Epstein in fact agree to pay damages to the identified victims of his abuse at least $150,000? (3) Did the Government tell victims, either directly or through counsel, that Epstein had agreed to pay his victims at least $150,000? 2028 HARRISON STREET,SUITE 202, HOLLYWOOD, FLORIDA 33020 OFFICE: 954-414-8033/305-935-2011 FAX: 954-924-1530/305-935-4227 B EC BRADEDWARDSLAW.COM EFTA00235157 Case 9:08-cv-80736-KAM Document 30-3 Entered on FLSD Docket 10/16/2008 Page 2 of 2 MS AUSA United States Attorney's Office October 15, 2008 Page Two (4) Is Epstein in compliance with his Non-Prosecution Agreement with the Government when he is now taking the legal position, through his attorneys, that he only has to pay the victims $50,000 damages under § 2255? Thank you for any clarification you can provide on these questions. Sincerely, BE/sg Brad Edwards cc: AUSA United States Attorney's Office 2028 HARRISON STREET,SUITE 202, HOLLYWOOD, FLORIDA 33020 OFFICE: 954-414-8033/305-935-2011 FAX: 954 - 924-1530/305-935-4227 BROBRADEDWARDSLAW.COM EFTA00235158

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Case #9:08-CV-80736-KAM
Domainbradedwardslaw.com
Domainbrobradedwardslaw.com
FaxFAX: 954-924-1530
Phone305-935-2011
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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

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EFTA02726140

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DOJ Data Set 9OtherUnknown

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

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DOJ Data Set 9OtherUnknown

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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

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Dershowitz Supplement to Motion for Limited Intervention

Case 9:08-cv-80736-KAM Document 285 Entered on FLSD Docket 01/12/2015 Page 1 of 6 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 08-80736-CIV-MARRA/JOHNSON JANE DOE #1 AND JANE DOES #2 Plaintiffs, vs. UNITED STATES OF AMERICA, Defendant. ________________________________/ ALAN DERSHOWITZ’S SUPPLEMENT TO HIS MOTION FOR LIMITED INTERVENTION (DE 282) Alan M. Dershowitz, a nonparty to this litigation, respectfully supplements his previously filed Motion for Limited Intervention (

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