EXHIBIT Case Document Entered on FLSD Docket Page of UNITED DI8.8STRICT COURT S-3.9O-1.9UTHERN Case No JANE DOE No J10.2ANE DOE No UNITED STATES 10DOCUMENTS Edwar-7.8d-.8s 10Esq do 10am a standing of Bar of of represent-8.3 Doe No and Doe No as to as the5.7 victims in the above-listed action to en force their under the Crime Vic5tims Rig11h-1ts Ac5t CVRA a5l-1so re5pre5s0e5n-1te5d-9 the7m a5nd se5ve7ra5l othe7r vic5tims in c)5ivi11l suit9s10 aga5.5inst Epstein them am 10also 12familiar w-7.6ith 10crimina6.4l 10justice se-6.7rved as 10state prosecutor in the State Of-7.9fice c4.9ove4.9rs issue4.9s-.1 reg10.9a4.9rdin Governm-12.3e3.7nt?s asse-6.3rtions of more than 10of documents it has prod9.5uced for in camera inspe-6.7c3.3tion in th9.3is case affidavit provid-10.3e3.7s information demonst-12.3r a4.2ting the4.2 nt?s assertions privileg9.2e-6.8 not 10well fo-10.8unded further demon-10.8s trates that the victims have compe6llin-10g10 10and substa4.2ntia4.2l for the4.2 informa4.2tion re4.2que4.2st and have no other of obtainin-11.1g8.9 the information filed petition to enforce the CVRA rig8.5h2.5ts of No and No with reg9.1a3.1rd to offe nses committed ag9.9ainst the5.9m while they29.9 minors The course of the proce-6.7e3.3ding9.3s sinc-6.7e th en is well-known to the C6.4ourt purposes this affida6vit reg10a-6rding10 10privileg10e4s it is enoug9.6h re-6.4count the eff-7.6o-.6rts of the victim7.4s reach of has bl-4.1ocked Court first held a on victims petition on The Court discussed a need a re-8cord 10and to be issue to to the5.4 Circ4.5uit be4.5tte4.5r to to position is a4.5nd the is as actions-11.7 were Tr at Th8.9e Court concluded the with the4.5 following10.5 instruc4.5tions both of 10c4.5onfer is need for additional e-6.9v-.9idence to be Tr at Case Document Entered on FLSD Docket Page of Case Document Entered on FLSD Docket Page of victims8.6 and the Attorney20.7?3.7s the attempted to reach a tipulated set of facts8.5 the U.S o-11ffer-8e3d 10abbr-8eviated-11 set of p-11r2oposed and the victims respond-10.5ed with a d-10.8e3.2tailed set proposed 10facts Rather than r-6.1e4.9spond to the vic4.1tims the4.1 U.S On filed a Notic13.7e to Court Ab-10.3sen ce of Ne-7.6ed for The U.S Attorney19.7?s took the following9.7 position After consider ation the Government bel-4.7i-4.7eves DE asse-8.7rt-4.7ed Court need judicial noti ce of no had filed against Epstein to resolve the Aug9.5u-.5st victims filed a respons to the Government?-7.5s-1.5 a proposed statement of f-7.9acts surroundin-10.9g9.1 the cas DE at The5.8 victims?-437.2r2.8esponse also requested-11.4 that to conf-7.5er 10with the 10victims the undisputed facts of the and produc-6.9e the non-prosecution 10and other information about-17 t-5h1e case Id at Aug9.3u-.7st the Court held a 10on the case the confidentialit-12.9y19.1 of non-prosecution The Court ulti8.4ma tely19.5 orde-6.5red 10production the8.1 to the8.1 the U.S Of-7.9fice th 10non-prosecution available to vic4.8tims the6.8 vic4.8tims re4.8viewe4.8d.8 it a4.8nd pu-9.2rsue4.8d disc4.8ussions with the4.8 Attorney20.8?s the U.S c5.8line7.8d to stipu-6.2la5.8te5.8d se5.8t with the victims and declined 10to provide further info-11.3rm-13.3ation about the case impa7.8sse5.8 the7.8 vic5.8tims to the7.8 the7.8 in othe7.8r counsel for the victims propounded 10requ-10.5ests in state and cas es obtain cor-8r2espondenc-7e betwe-7e3n-11 Epstein and prosecutors-12 regardin-11g9 his plea a-7g9re the4.7 U.S Attorney20.7?s Offic5.1e5.1 unw7.1illing13.1 to to the7.1 informa5.1tion wa5.1s both to the6.7 victims civil8.7 suit8.7 and the6.7ir CVRA enforcement action Ep stein9 refused to produce that information and the 10Court is awar-7.8e 10ex-10.8tende litig10.4ation to obtain the m-11.6a4.4terials followed Court rejected 10all of Epstein?s obj ections to produ-10.5cing9.5 the m-12.5a3.5terials counsel for Epstein sent to counsel for the victims pages of 10e-mail co-11.5rrespo-15.5ndence criminal-13.5 defens-17.3e couns-15.3el 10and plea that had be-6.7en ne-6.7gotiated betwee-6.7n them See to disc5.1lose5.1 for6.1 the7.1 first time5.1 tha7.1t ha7.1d the4.8 U.S Attorn-9.2ey20.8?s Office4.8 to a4.8void Epste4.8i-1.2n a4.8nd to the4.8 vic4.8tims9.8 in the case learn about non-prosecution ement-8.4 that had been betwe-7.8en Epstein8.2 and the Governm-12.6e3.4nt th Court ordered that all of the corr-8.3espondence be tu-11.3rned ove-7.3r the victims Epstein chose to disobey20 that or 10and instead p-11.2r1.8oduced the corr-8.2esponden-11.2ce authored the and reda-7.1cted all co r-7.4r2.6espondenc-6.4e author-7.4ed him or his attorne-6.4y19.6s Doe No No settled lawsuits Epste4.3i-1.7n The4.3n 10with the4.3 ne4.3w informa4.3tio-9.7n they20.3 to moving forwa4.3r3.3d in the4.3 CVRA September the victims8.3 informed the Court 10that they30.3 were preparing10.3 new filing13.2s in the7.2 October 10the Court entered an orde directin-10.6g9.4 the victims provide a status8.4 report-292.6on case 10October That 10counsel the 10victims again contacted-10.7 Case Document Entered on FLSD Docket Page of Case Document Entered on FLSD Docket Page of the U.S about possibilit-12.6y19.4 10of reachin-9.8g10.2 a stipulated 10set of facts in the case That same the U.S Attorne-6.8y19.2?s Of-7.8fice r-7.8e-6.8sponded don?t have any problem with agreeing that a factual assertion is corr ect if we agree that is what occurred at October victims e-mailed to the U.S O-8.6ffice detailed propos-11.6ed statement of5 facts with of the f-8.1acts now d-11.1o-1.1cumented corr-8.1es-12.1pondence betw-9.1een the U.S Of-7.4fice 10and Epstein?s couns-11.4el Th victims requested the U.S Offic4.6e4.6 facts it would to le tte4.9r to the4.9 U.S Attorne4.9y20.9?s the4.9 vic4.9tims fact-4.4s Doe and7.6 Doe No would reiterate their long-st requ-10.4est that work 10with to arrive5.5 a stat-12.5ement of 10.2facts know in summer Doe No Doe No 9.7working8.9 9.7with on a st-13.1ipulation8.9 of facts course 10and took that 10position that no recitation of the fact-3.8s see doc that 30will at least-12.2 look at 10our facts propose 10modifications that deem-12 appropriate.-11.1 evidenc-7.1e2.9 quickl-23.1y to the5.1 Court c5.1ould he5.1lp move this case to a That-4.4 forward of fact-4.4s the appropriat-12.7e3.3 Assistant U.S Attorne-6.7y19.3 10for at October 10rather than stipulate to undi sputed facts the U.S Attorne-6.6y19.4?s cont-11.7acted the vi-7.7ctims attorne-11.7y18.3s and them to iling11.9 of their motion for a two of time4.9 so neg10.9o.9tia4.9tions c4.9ould be he4.9ld be4.9twee4.9n the4.9 a4.9nd the4.9 vic4.9tims in attempt to narrow of disputes in the case and to hopefull-21.4y20.6 a settlement resolution-9.5 without the need for furt-12.4her litig9.6ation Neg9.6o-.4tiatio-10.4ns between the victims and the U.S Office-6.8 then follow-8.8e3.2d the two at p.m on 10.1October on whic4.5h the4.5 vic4.5tims wa4.5s due4.5 U.S informe4.5d-1.5 the6.5 vic4.5tims tha7.4t it not it ha7.4d to the7.4 vic5.4tims a5.4nd advi-13.1se whi-9.1ch were and were inac curate The Of-9fice furth-12e advi-11.9sed the vi-7.9ctims7.1 tha7.2t it be7.2lieve7.2d tha7.2t the7.2 v11.2i-.8ctims did a ri ght to confer with their Office under the CVRA11.3 in case becaus-6.9e in its vi-7.9ew the case is civil litig10.2ation ra ther litig11.3ation No at a result 10as accommodation to th Attorne-6.9y19.1?s on 10October the7.3 vic5.3tims file5.3d re5.3por8.3t with the7.3 in wh ic16h they22 ag12re6e6d0 to 11.5filing14 the8ir motion a6nd up can or dispute4.9s-.1 with the4.9 U.S 10Attorney20.9?s Office4.9 at Discussions wi)7.7th the U.S Attorne-6.3y19.7?s Office-6.7 dra-6.7gged including9.3 pe-6.7rsonal me-6.7eting5.3 No 10and in Decembe-6.9r contradi-11.8ction to this9.2 posit8.2i on on March the Offi-12.7ce informed the vi ctims that it would not be 10ini tial disclosures 10the victims as for civil cases Fed Civ a The U.S Attorne-6.6y19.4?s Offi-12.6ce did not this rule4.6 of civil proc4.6e4.6dure4.6 is ina4.6pp if think this is as a 10case Case Document Entered on FLSD Docket Page of Case Document Entered on FLSD Docket Page of fu-10.8rther dis-11.8c3.2ussions failed to an other-7.4 visible pro-10.4g9.6ress vic5.5tims the7.5 11Office5.5 that they21.3 would file5.3 motion with9.7 the Court March and reque sted further coop-11.3erati-13.3on from the Office on the facts after-6.6 months of discussion the U.S O-8.3ffice inform-12.3ed couns-11.3el the victims tha6.6t 10to promis es made earlier to stipulate to undisputed facts stipulation would be fo9.7rthcoming9.7.-.3 March the Attorne-6.5y19.5 for the Southern District of F5.6l-2.4orida fre4.7do A sent le4.7tte4.7r to the4.7 vic4.7t8.7ims to agreem-14.6ent-8.6 on ma6.5tte6.5r the8.5 CVRA is to this ma5.3tte5.3r in no feder-8.7a2.3l criminal were 10ever 10fil ed 10requests for the agreem-13ent on a set of proposed stipulated facts 10is unnecessar-18.1y18.9 and That is because 10the in U.S.C a 10attach to filing9.6 of our7.6t is matter-6.4 of st-12.1atutory19.9 inte-6.1r2.9pret-12.1ation resol-12.1u-.1tion of that question is not upon ex-9.9iste of set other than whether-9.8 a was 8.4eve file-7.3d in the Unite5.1d-.9 Distric5.1t-.9 for6.1 the7.1 Southe7.1rn Distric5.1t-.9 And while5.1 this10.1 Office remains 10willing9.7 ooper-7.7a3.3te coop-10.7eration-10.7 does not mean to facts that are not r-7.6e3.4levant to the resolution of the at issue from Ferre-6.9r to Paul Cassell unabl-3.8e work reach a of fact-3.8s on March the filed a Motion Su undisputed-10.1 fa-6.1cts along9.4 10with some suppo-10.6rt for 10each the f-6.8acts DE victims also filed a have accept-3.9e2.1d of fact-3.9s DE victims also-9.7 filed a motion to have Court direct the 10Gove r-6.6n.4ment to not withhold rel-4.9evant-8.9 14DE 10on the motions on Se-6.2ptember 10Court rejecte-6.2d-.2 the Gove4.8rnme4.8nt?s the4.8 CVRA in this beca4.8use4.8 the4.8 ha5d ne5ver file5d-9 ag11a5i-1nst Epste5i-1n 10DE The4.5 Court,-9.5 the vic4.5tims that it should 10acc-6.7ept their facts of the Government?s-12.1 failure to contest the facts DE at the Court directed that discover-7.8y19.2 could pr-7.8oceed in the form of requests for admission and doc ument production-310.2r2.8equests Id at Court reserved ruling on the victims motion th9.7at the Government houl-12.5d be directed not to with-10.5hold evidence the 10order the victims filed 10requ-10.4ests for p-10.4r2.6oduction with the Government 10The requ-10.8ests included specific r-8.1e2.9quests of which linked to the7 tha7t vic5tims we5re5 10a5tte5mpting13 to pr8ov-7e5 in this November the when the Gov-11e3rn ment?s respons-12es wer-8e due rather produc4.8e4.8 of the4.8 Gove4.8rnme4.8nt file4.8d motion dismiss9.8 the4.8 petitions DE 10On t-12h0at same the Govern-10me nt filed a motion to stay21 10discover-16y21 The5.1 vic5.1tims file5.1d the Go-8.9ve7.1rnme5.1nt?s motion wa5.1s sta5.1ll The victims also filed a motion to compel production of all of their discover-17.7y19.3 requ-10.7ests DE The4.6 Gove4.6rnme4.6nt file4.6d it wa4.6s not the Gove4.6rnme4.6nt told the4.6 has agreed pr ovide some information to victim7.8s-7.2 even Case Document Entered on FLSD Docket Page of Case Document Entered on FLSD Docket Page of during8.8 the of discover-18.2y18.8 is undertaking9 a se-7arch-11 for that information DE at to that repr-7.3esentati on 10however 10over seventeen months Gove4.7rnme4.7nt did not produc4.7e4.7 inform-11.3a4.7tion to the4.7 vic4.7tims de6.7spite4.7 the6.7 vic4.7tims re4.7minding12.7 the6.7 Government of that stat to the5.1 c5.1ourt after-357s-1ome additional motions and ruling10.5s-.5 on the Court denied-9.9 the Government?s motion to dis8.6miss and an discover-17.5y19.5 DE That same the4.4 Court the4.4 vic4.4tims motion to a4.4nd the4.4 to produce all corres)-12.2pondence betw-9.2een it and Epstein all commu)9.5nications between the Gove4.4rnme4.4nt outside e4.4n.4titie4.4s a4.4nd othe4.6r vi-9.4c4.6tims DE at respect to the third the Cour t7 10allowed the Government to assert privileg9.6e3.6 producin-10.3g9.7 the items in q-10.3u-.3estion for in cam-12.3era in spection and a 10cont emporaneous p-10.8r2.2ivilege Id each-5.3 author add)-11r2esse-7e 10r-8ecipient and subject matte-6.4r at and the Government ma de its production to item 361c3orresponden-11ce with Epstein the Government withheld the correspon-11dence pendin-11g9 a rulin-11g from the5.5 Circ5.5uit on Epste5.5in?6.5s motion pr6.5oduc5.5tion With to the other items the 10Government produ-10.9ced docume-6.1n-.1ts to the Court for camer-7.7a inspection but over 10page to the victims 10Thus the asserted to than of the doc uments in question Th9.6e documents that the Gove4.5rnme4.5nt 10a4.5lmost worthle4.5ss to the4.5 vic4.5tims the4.5 victims own letters to the Governm-12.6e3.4nt Bates court pleadin)-10g10s filed victims or othe5.3r vic5.3tims Epste5.3i-.7n or 10news org11.3a5.3niza5.3tions e.g public ourt rulin-10gs on Epstei related matters e.g B7a4tes public articles-12.7 Bates and similar materials alread-21y29 10available to the vi ctims also included 10four hundred-10.3 of se4.7nt to va4.7rious in this indisting9.6u-.4ishable from the notices the victims lves in case Almost without ex-10.4ceptio9.6n the documents the rnment produ-10.5ced do to the disputed-10.5 issue5.1s in this case Gove-6.5rnment 10one last produ-10.1ction materials in this on 10This involved 10pages documents-11.5 wer-7.5e in the of the issue5.5s.5 in the public doc5.5ume5.5n1.5ts in the5.5 the7.5 vic5.5tims own of the redact-12.9ed judg9.8ment motion while the 10Govern-10.2me nt has produc-6.3ed these-6.3 documents that would-10.3 fa5.8ll into they21.8 re5.8fuse5.8d production-370.8o-.8f hundreds of other documents that ar responsiv-10.7e to our re-6.7quests on the basis rel-5.4evan-13.4ce vic4.4tims to informa4.4tion on a4.4ll for admission The Government however has refu sed to admit the5.9 victims central-12.1 a4.2lle4.2ga4.2tions in this A of the4.2 vic4.2tims re4.2que4.2sts for a4.2d.2missions a4.2nd the4.2 is to 8.5this a5.5ffida7.5vit so tha7.5t the7.5 tha7.5t the7.5 vic5.5tims pursue avenu-16.2e for case Case Document Entered on FLSD Docket Page of Case Document Entered on FLSD Docket Page of vic5.5tims10.5 trie5.5d to inf or6.4ma5.4tion on to the7.4ir voluntar-7.7y19.3 r-7.7e3.3quests for i-12.7n-.7terview with persons who are no longer the sent-4.2 both Reinha-6.7rt and Acosta who both9.3 have info-10.8rmation about-12.8 the Epstein r-7.8e3.2questing9.2 an disc-5.8uss the with of them letters documents that7.5 victims8.5 requested th at th8.9e Government produce them on October all r-7.7e3.3levant to their CVRA 10en f-7.6o-.6rcement 10action wo-10.6uld not have the6.8m The6.8 no othe4.8r of the4.8 This9.8 th4.8e th4.8e th4.8e convenience of the Court the affid-10.4a3.6vit will proceed on a secti basi concerning the need-351.4for the m-13.4a2.6terials 10Also fo the of the Court a the October re5.1que9.1st for6.1 is to this Affida7.1v-8.9it Also is the7.1 11.1vic5.1tims discover-17y20 r-7e4quest As the6 Co ur4.6t will note from reviewing9.6 the 10requests production most of the requests the alleg9.4a3.4tions that the requested do-10.6cuments would support in effort to eliminate di spute from the Government that the documents8.5 were-8 not rel-14evant-8 to the-12 the-8 re for p-10.3r2.7oduction link to in the5.2 summary21.2 motion the5.2 vic5.2tims have a spe-7.7c2.3ific these docum-13.7en ts to support the alle-6g10a4t-12i-2ons in the summar-7y10 judg9.9ment motion found DE at Need-6.8 Court con-10.6c3.4luded that vi proof of this point th4.8e the4.8 Court ha4.8s rule4.8d the4.8 will the7.9 vic5.9tims10.9 to tha7.9t re5.9lie5.9f se5.9tting13.9 no n-prose4.3c4.3u.3tion is que4.3stion reserv-10.9ed d-10.9e3.1terminati-12.9on upon 10DE 10at The Court has further indicated that will7.6 be consi6.9d-1.1ering8.9 an 7.1e2.9stoppel Government as a in case DE at The Court7.6 has that this8.6 a must be consider-7.4ed in contex-10.9t of the ent-7.8ire interface between 10the relevant prosecutorial authorities and9.8 fe5.2de7.2ral offe5.2nse5.2 a5.7sse5.7ssment a a4.6nd to ke4.6ep the4.6 vic4.6tims in the4.6 on the4.6 10of ne8g12o0tia6tions b-8e6twe6e6n-8 Ep-8ste6in a6nd fe6de8ra6l a6u0thor9it ie4.8s until we4.8ll the fa a5.9nd the non-prose-6.5c3.5ution to them as a fait a-6.6ccompli DE at emphasis added-10.6 The victims have a com7.1p-.9elling9.1 need for informa tion about the Governm7.6e3.6nt?s actions to show what the 10and to respond the Government?s as as ot-8.8her defens-7.8es appe-6.8ar be respons-15.2e from the6.4 Gove8.4rnment to the6.4 victim?s motion raising numerous factuall-22.1y19.9 a4.6nd other the4.6 vic4.6tim?s po-9.4sition Product-12.4i-2.4on sts information the Epstein-10.1 investig9.7ation Th-10.3ese nts needed-9.6 to support the victims?-6.6 alleg10.4a4.4tions tha6.4t Gove4.4rnme4.4nt ha4.4d via4.4b.4le for it c4.4ould pursue4.4d.4 See DE at re5.5que9.5sts vic5.5tim notific5.5a5.5tions th5.5is documents are needed support the victims alle g9.7a3.7tions that their under the Case Document Entered on FLSD Docket Page of Case Document Entered on FLSD Docket Page of to notic4.6e4.6 a4.6nd to with the4.6 in this partic4.6ula4.6r3.6 documents are need-11.1ed to demonstrate-307.1t-3.1hat the victims were not properl n-10.5o-.5tified about the non prose4.9c4.9u.9tion NPA into the4.9 Government and 10Epstein and that Government did not conf-7.5er with the victims about the ag10.1reement See e.g DE at No requests in9.9formation about the NPA including9.8 in particul its confidentialit-11.9y20.1 provision These-6.6 docu-10.6m-2.6ents ne-6.6eded monstrate the precl-3.9uded agreem-13.9ent-3.9 Doe No and Doe No as well as to other vic5.6tims See e.g DE at documents are fu rt-4.6her se 10of causing9.4 CVRA violation in 10case e.g at No requests documents relating9.6 to ti-12.9ations between the Gove-6.9rnment and Epstein c-6.2ourt and/or-7.2 location in 10Epstein enter-7.9 including-400.6in particula-6.6r2.4 concer-7.6ni concludin-10.5g9.5 the ple-6.5a in Miami or another-7.1 location 8out-10.9side of Palm each These do)-17cum-9ent-9s are relev-13ant to the vi-6.8ctims alleg9.2a3.2tions woul-4.9d keep Epstein?-5.3s vic tims most of re sided or about Palm Beach-10.4 learnin-10.5g9.5 what happe-6.5ning9.5 the pr-7.5ess e.g DE at No requests documents pertaining10 to neg9.3o-.7tiations betwe-6.7e3.3n the Government Epstein r-7.3e3.7pres-11.3entation of the victims in civil es Epstein.-7.7 These ne-7.9eded prov-11.9e pl-3.9ea with Epstein involved E10.7p-.3stein?s efforts to make sure that the victims wo9.3uld be represent-12.7e3.3d in cases who an some4.9one8.9 fa4.9milia4.9r to his e.g DE No requests do9.7cuments concernin-10.3g9.7 the Government?s and/or Ep-11.1stein awaren-11.1ess or discussion of possible pu9.7blic cr iticism and/or victim objections to the non-12.8prosecution they21.3 doc5.3ume5.3n1.3ts to prove5.3 the5.3 vic5.3tims10.3 a5.3lle5.3ga5.3tions tha7.3t Government wanted non-prosecution with Epstein concealed from public view because-6.2 of intense-6.2 public criticism that would have 10resulted ha-7d the a-7g9r-8eement disclosed and/or victims wo have obj-21.2ected and 10convinced-11.2 the e.g DE at 9are 9al-14so relevant-8 to bi-8as and motive the authors 10subjects of other in this case No requests documents re-6g10a-6rding10 th Government-12.9?s of its potential CVRA oblig11.1a5.1tions in th-8.9is a5.1nd discussions the Gov-10.4e3.6rnment 10and Epstein concernin-10g10 these-6 CVRA oblig10ations in th case These docum-4ent-14s-3 are need-12ed prove-8 the6 victims alleg10a4tions the Government was that it potentiall-12y30 10had oblig10ations under-7 the CVRA to the 10victims about the non-pr os-8.4ecut-9.4ion an relat-14.3ed 6state pl-10ea DE at No requests documents regardin-10.4g9.6 Epstein?s effo-11.4rts to persuade the a and/-4.3or including9.4 effo-10.6rts on his 10behalf fo-10.6rmer Pr esid-10.2ent B6.8ill Clin9.8ton Prince 10Andrew and Harvard Prof-10e4ssor D-8e4rshowitz The4s-1e4 m-12a4te4ri vic5.5tims a5.5lleg11.5a5.5tion that after-7.7 Epstein the non-pros-11.7ecution eement his was while-6.8 his sig10.9n.9ifica4.9n.9t a4.9nd to the Case Document Entered on FLSD Docket Page of Case Document Entered on FLSD Docket Page of favor-18.7abl-9.7e pl-9.7ea See e.g DE al-4.4so need-12.4ed the course of the in this case which in lig10.4ht of the4.4 Gove4.4rnme4.4nt?s to the victims discussed in the para graph the status-7.1 of case No requests 10documents le tte5.2rs se5.2nt to the5.2 the5.2 J-12a3ne 10Doe No and J-12a3ne Doe No advising12.2 the6.2m tha6.2t this case is currentl-11.8y10.2 under investigation.?-10.1 Th-12.1ese 9.4are to show-6.8 that these lette rs inac-7.5curate-7.5 bec-7.9a2.1use no pl-3.9ea a had and the Governm-12.9e3.1nt e.g DE at documents ar-8e also ne-7eded to respond to the Government?s estoppel?-6.9 10defense as 10not ed in the 10Court?s order DE 10at No re5que5sts d11o1c5u1me5nts reg11a5rdin-9g11 the5 10.2vic5tims a5lle5g11a5tions tha7t the7 w-7a5s le5d to believe their investi-12.6g9.4ation Epstein-10.6 wa to p-9.7r3.3oduce a criminal prosecution and that the was 10also misled the Atto of-8.1fice 10about the 10st atus of the has 10are 10because-7.6 is the4.5 Gove4.5rnme4.5nt misle4.5d the4.5 the4.5 Gove4.5rnme4.5nt to the4.5 victims receiv-10.6e3.4d informa-6.6tion about the thro-10.6ug Thes-12.8e do-11.8cuments de7.8monstra5.8t-.2e tha7.8t the7.8 vic5.8tims the7.8 sta5.8tus of the inform-11.4a4.6tion the U.S 10Office4.6?s n-9.4e-5.4gotia4.6tions with Epste4.6i-1.4n of 9.8cases not have infor-7.9m-2.9ed the victims about th progress of the c-7a3se central point in the vic4.3tims would show or something12.2 made6.2 10.5admissible in a tria of Fed Evi if the Attorne-7y19?-8s-2 Offi-13ce was m-13i-3sleading9 the 10about th NPA it would have been part of the sche7.1me plan to mislead the7.1 vi ctims as well.-260.4The documents also needed to support specific allegations in the6.5 vi judg10.3ment See e.g DE 10at No requ-10.3ests d-10.3o-.3cuments va-6.3ri ous meeting9.5s-1.5 the Go-10.5vernment includin-10.5g-.5 with vic4.8tims doc4.8ume4.8n.8ts to prove4.8 during10.8 those the7.2 Gov-6.8e5.2rnment did not disc5.2lose5.2 to vic5.2tims to the7.2ir and th5.2eir tha7.2t the7.2 in summa5.2ry21.2 motion See e.g DE at r-6.9e4.1quests 10all documents with 10from U.S Office to me Edward to write a lette-7.4r th filing feder-8.9a2.1l char-8.9g2.1es Epste4.7i-1.3n a4.7nd follow-up to le4.7tte4.7r doc4.7ume4.7n.7ts are4.7 neede4.7d.7 to show this9.7 request was made to without disclosing9.1 the ex-10.9istence of the non-prosecution agre-6.9ement Thus just as and 10Doe were-7 10dec-7e3ived about 10the NPA 10de-7ceived-11 e.g at is 10also to contradi-13.1ct the 10Government?s 10appa-7.1rent position tha5t9 it9 disc5lose5d th5e o5f0 th5e a5nd to vic5t9ims See e..g Gov?t6.7 Answe4.3rs to a4.3d.3mits Epste4.3i-1.7n to the state discuss-11.6e3.4d 10in the non-pros-11.6ecution agreem-12.9ent the Epstein?s attorne-16.4y19.6s to keep the do-10.4cument me-6.4morializ-6.4ing9.6 the non-pr-7.4osecution confidential but denies they19.9 soug9.9ht at that time to keep the e13.1x-10.9istence of the non-prosecution agreem-14.1ent-4.1 Case Document Entered on FLSD Docket Page of Case Document Entered on FLSD Docket Page of No requests do-10.1cuments ho 10on or about the Government learned that Epstein be enterin-10.8g9.2 his plea state char-7.8ges on or abou-10.8t The are ne-7.9eded descri-3.9be of case 10and prove bot-3.6h and awar-8.3eness he would be entering9.5 a plea-6.5 blocking10.1 prosecution of othe crimes without the victims full kno9.2wledge of what happenin-10.7g9.3 See e.g DE at No requests documents to the4.4 Gove4.4rnme4.4nt a4.4nd Epst-11.6ein to keep the-7 ex-11istence of-8 the non-pros-12ecution a-7g reement includin-10.7g9.3 d-10.7eclining comment-12.7 about the of such an ag8.4r-8.6eement when as-11.5ked about it when hi7.5s plea in state court became public knowled-11.3g-1.3e 360These doc uments needed to prove the vic-6.6tims alleg9.4a3.4tions that the4.6 Gove4.6rnme4.6nt the4.6 NPA from e.g DE 10at to contradict appears to be Govern-11.2ment?s position namel-12y20 that the victims were aw-9.3are of the NPA it wa4.7s e.g Gov?t to RF6.5A tha6.5t USAO ha6.5d communicated with Doe about the secution prio-10.4r to Epstein?s plea.-12 doc-6um-8ent-8s ar-9e also ne to the Government?s-12.8 the4.6 NPA did not ba4.6r disc14.6ussions with vic4.6t8.6ims See e.g Gov?t Answe4.6r3.6s to RF6.6A Gove4.6rnme4.6nt tha6.6t it attorne-17.1y18.9s had for a confidentialit-13.1y28.9 p-11.1r-8.1ovision the non-pros-6.1ecut-7.1ion barred 10conferrin-10.4g9.6 with victims about the agreement No requests d-10o0cuments pertainin-10g10 to the feasibilit-12.1y19.9 the victims about-12.1 the NPA 12along 10with in-11formati on the vi-17.9ctims came-8.4 a notification letter on about September after Epstein had pled These doc4.6ume4.6n.6ts the 10Gove4.6rnme4.6nt no 10for fa4.6iling10.6 to pr6.7ovide7.7 notic5.7e5.7 to victims is the6.8 first inaccur-7.9a3.1te information 10about the as we ll as involvement in that7.5 DE at No requests 10documents uce Reinhart a s-12e3nior p-11r2osecutor who w-9a3s in the U.S Attorney21.6?-5.4s the time4.9 tha6.9t the6.9 negotia4.9te4.9d the NPA 10.4with Epstein blocking his pro-10.1s-1.1ecution in Southern Distri-12.3cdt of No the victims docum-11.7ents sho-9.7w ing9.5 Reinhart-12.5 non publ5.6ic5.6 inf6.6or6.6ma5.6tion a5.6bout Epste5.6in ma5.6tte5.6r will re5.6ca5.6ll tha7.6t Re5.6inha9.6rt ha7.6s affidavit with this Cour 12in whi-8.2ch that in 8.4con-16.3fident-8.3ial non-10.3-public info rmation about the Epstei-13.1n matter DE 10because-7.6 cl-4.1ose would se-6.5em that would-10.5 have-6.5 discussed the Epste in case 11.5with the7m Add learned-10.2 public tha7.3t while5.3 still the7.3 Office5.3 Mr e5.3s.3ta5.3blishe7.3d his offic5.3e5.3 addr-7.3ess and num-12.3ber as busi-4.3n-2.3ess address.-12.3 Howeve-7r did not h-11a3ve 10direct contr-8a sworn in 10a4.7n.7swering the4.7 vic4.7tims Re4.7que4.7sts for 10Admissions the4.7 Gove4.7rn-9.3me4.7nt ha4.7s a4.7d.7mitte4.7d it possesses inf5.9or5.9mation tha6.2t Reinha8.2rt learned confidential non-public information about the case-7.1 and di-3.1scussed with other-7.3 prose-6.3c3.7utors Gov?t 10Answers-11.3 to RF6.4A?s Of this the4.4 Gove4.4rnme4.4nt ha4.4s doc4.4ume4.4n.4ts tha6.4t Re4.4inha8.4rt Case Document Entered on FLSD Docket Page of Case Document Entered on FLSD Docket Page of file5d5 a5 fa5lse5 affida7vit with this Cour8t Th5is10 ri th4.7e if was willing9.6 to provide info rmation about this subject he 10additional information about-16.9 case as 44.-540.6Materials about Reinhart are also need-10ed to support the victims?-267s-1ummary20 10jud-8g10m-2ent motion See e.g DE at raising9.5 10alle g9.6a3.6tions about-12.4 Reinhart affidavit with the al-3.6so di not have did not share-6.4 non-public confidential-12.5 informati on about the Epstein investig9.7ation with of Epstein?s-11.3 attorne-17.2y18.8s DE at the G-8.9overnment has informat demonstrating9.9 that be second-20.3 as well.-680.6Given that Mr Reinhart established a business address Epst-4ei-4n?s busi-4n-2ess time5.3 while5.3 wa5.3s still the7.3 US a5.3nd tha7.3t Mr ultima5te5l-11y21 sev5e1ra5l Ep5ste5i-1n5?s c5o-9-c5o-9n-1spira5tor6s je5t pilots sta5ff dur8in-9g11 th-9e5 c5ivil litig11.5a5.5tion Mr Re5.5inha9.5rt ha7.5d with Epste5.5in while5.5 the7.5 ha5.1s 10.3furthe5.1r tha7.1t posse5.1sse5.1s between-12.2 Bruce-8.2 Reinhart-14.2 10and 8pe-12.2rsons ent-7.5ities affil-13.5i-3.5ated with Reinh-15.7a2.3rt le-7.7ft his job the4.8 U.S At8.8torney20.8?s stated above Reinhart left Attorney20.1?3.1s 10.7Office to start a private 10firm that was located in the same addr-6.9ess Epstein?s personal busin-10.5ess wher-7.5e was This would appe-6.4ar to 10be a violation of rule5.1s c5.3onne5.3c5.3tions to Ep-8.7ste5.3in is to victims a5.3lle5.3ga7.3tions in this Re4.5inha4.5rt he4.5lping10.5 Epste4.5i-1.5n into the4.5 e4.5fforts would provide3.7 motive3.7 for Re3.7inha3.7rt a3.7nd othe3.7r rs not to vic4.3tims a4.3nd not to confer with them Also if Epstein9.6 wa improperl-12.7y19.3 information about the prosecut-4.1i-4.1on or l-4.1ack at could be to the remedi-12.8es of this in the7.6 vic5.6tims will a mong10.9 other to the4.9 10NPA indica5.4te5.4d tha7.4t he will doubl7.4e5.4 aga5.4i-.6nst that effort 10double consid-11.2er ations do not situations where defendant not jeopard prosecutio-10.2n addition the Court7.8 10wish to consider in c5.2r4.2afting 10for the viola4.9tions of the NPA Epste4.9i-1.1n was improperl-22.4y19.6 10obtaining9.6 info-10.4rmation about 10pr osecution e-6.1fforts him would be to is th5.3e th5.3at Government Epstei we4.1ll inte)4.1nd 10to concer-7.9ning9.1 R-13.9e3.1inhart?s conne-6.9ctions including9.6 improper conn-10.4ec-6.4tions to Eps8.6t-2.4ein al-3.7so bi-3.7as show reason the4.7 one4.7 e4.7n.7title4.7d to No requested-10.1 information not ab-10.9out improper connections between Epstein and Reinhart,-10.8 but more-6.8 such 10conne-6.8c tions with if the Government posses-11.7s-1.7es such information would be to the6.7 victims allegations the 10reason-10.5s just discussed its 10answers to victims R-12.9e4.1quests Admission the4.6 a4.6d.6mits it ha4.6s informa4.6tion or busin-9.4e4.6ss re4.6la4.6tionship Epstein 10and pros-11.9ecutor involved-10.9 in the Epstein Case Document Entered on FLSD Docket Page of Case Document Entered on FLSD Docket Page of to Requests for Admission at 10The should be requir-7.2e3.8d 10to disclose all of those-6 documents so that the vi-12.7ctims can det-12.7e3.3rmine wh ether there 10was improper 10about those relationships it is un usual to on prosecutin-11g9 someone such as Epstein then shortl-13y29 ther-8eafte-7r,-11 leave the emplo-11y19ment-13 of the 10g9.3overnme-6.7nt and enter-7.7 into a bus re4.6la4.6tionship with the 10person who bein-10.5g prosecuted No asks for 10documents conce-6.2r2.8ning9.8 inve4.7stig10.7a4.7tion into the4.7 undertaken the Depa rtment?s Office of Profe ssional Responsibilit-11.5y30.5 OPR Washing10t-2on D.C The i8nvestig10ation was undertaken at the request of the victims who asked the De4.7partme4.7nt to dete4.7rmine4.7 were4.7 to the neg10o0tiations involving the possible prose-6c4ution 8(a3nd ultimatel-13y19 the-7 non-p-11r2os-6ecution Epste4.9i-1.1n is from the4.9 privile4.9ge4.9 lo 10that the Government produced that OPR a of 9correspond-25.3ence-9.3 pages 10request-3.1 Se-14e to 10Of imprope-6.5r inf-7.5l-2.5uences bear-7.5 on the 10Epstein prose4.6c4.6u.6tion would supp-9.4ort the4.6 vic4.6tims a4.6llega4.6tions th were4.4 being10.4 notifie4.4d.-9.6 Moreove-6.3r have i-4.5ssue case or direct-13.1ed others to un-11.1dertake an tigation Her-7e4 a-6g0ain this information would be-6 critical to the 9victims f-7.4act caus-6.5e 10OPR has th5.3e whic5.3h vic5.3tims in th11.3is 10of the documents need the production of OPR case file could9.4 this litig11.1a5.1tion a9.1nd is no othe-6r obtain this information-10 from 10OPR 10half-7 y20ear after the victims request of December for an inve stigation OPR sent a letter to Pa5.6ul Ca5.6sse5.6ll in it tha7.6t it it c5.6ould not assistance in providin-10.9g9.1 ation about the alle-5.9g10.1a4.1tions No 10asks for-7 information about U.S Offi-13.5ce the District of was out issues This information is to show vi ct-12.3ims did not notific-6.3ations about7.7 the7.5 NPA tha7.5t the7.5 Office5.5 with Epste5.5in the7.5 tha7.5t ha7.5s to do with the tre4.8a4.8tme4.8nt the4.8 More4.8over in its production of docum-12.6ents and in nce U.S the Southern District ha indic-6.3a3.7ted no r-7.3e3.7sponsive being the5 U.S Attorney21?s in the5 othe5r distric5t-1 tha5t-1 is ha5ndling11 c5onf8lic5t ma5tte5rs I14t a5ppea5rs tha7t this othe4.2r is 10Middle4.2 Dist rict of 10This appe-6.8ars be i-12.8m-2.8probable conf-7.2lict matters-13.2 woul-12.2d cover-9.3ed the 10vi-8.3ctims requests including10 the OPR invest8ig ative file the onflict matter is hi to de4.3te4.3rmining U.S provided-10.7 compl-12.7e3.3te produ-10.7ction to vic5.3tims A would to motiva7.3tions Government th-10.6roug9.4hout the 10the Epstein case information supportin-9.8g10.2 al-12.9legations made Attorne-17y19 10Alex-11ande-7r Acost-13a3 sent th the7.3 investig9.6atin-10.4g9.6 Epstein,-10.4 Epstein launched on the prosecution and the needed Case Document Entered on FLSD Docket Page of Case Document Entered on FLSD Docket Page of the4.6 U.S Offic4.6e4.6 would from the7.1 vic5.1tims10.1 NPA the were assaulted Acos ha4.3s sa4.3id would-9.7 have to disregar-7.4d their obli-12.4g9.6ations to 10crime victims a dditi-11.6on this would show improper behavior E-9.5p-.5stein whic woul-4.3d be of case scop-15.7e woul-3.7d be-7.7ar on bi-8.8as r-6.8e4.2quests 10documents betwe-5.8e4.2n overnment 10and state-6.8 local pros-11.8ecutors-11.8 and police including9.1 The Palm B6e-7ach Police Depa-7rtment regardin-11g9 the non prosecution this involves in formation outside of th Department it is the victims understanding9.7 that the overnment has turned over all of this inf5.9or5.9mation them as the Court has 10directed See requiring9.7 productio-10.3n of information with9.7 pe4.3rsons or e4.3n.3titie4.3s outside4.3 the4.3 it is worth noting10.6 this in10.6forma4.6tion is to tha6.6t the6.6 vic4.6tims not woul-13.8d pr-8.8ecl-3.8ude c6r5ime6s c6o0mmitte6d ag12a6ins-7t the8m No request-12.5s correspond-10.5ence the NPA the6.3 victims understand that the Gov-10.6e-6.6rnment is prepa-6.6r2.4ed to pr oduce all of this informa-6.4tion to them once stay20.8 Circ4.8uit is lifte4.8d for the4.8 of it is worth noting that this corresponden-10ce is-461ne6ed-10ed to de7.3monstrate the7.3 tims claims tha6.9t the Government was con-11c3e-7a-7ling9 the ex-11istence of th NPA from them and that this was done Epste4.3i-1.7n?s Court ha4.3s the4.3 vic4.3tims9.3 for informa4.3tion tha6.3t will allow to to Court in support their-7.2 allegation of conspirac-17y19 betw-9een Eps-12t-3ein and feder-8a3l prosec-7ut ors to keep the victi7.4m-2.6s in the dark on pe5nde5nc-15y21 10of n-9e-5g11o1tia5tions be5twee5n Epste5i-1n 10a5nd fe5de5ra5l-11 a5u1thoritie5s until 10we5ll a5f4ter the fac5t-1 of as a fait ac5c5o1mpli 10DE at No requests information about iderations that Epstein provided or offe-6.7red to provide to individual within the Governme nt Here the understand that this informa4.5tion is to is 10worth ho-9.5we4.5ver this informa4.5tion is to U.S A would not have notified the victims-402.1about 10was happ-15.1eni in their-8.5 an that 10is at the vic5.1tims motion See e.g DE at noting9.8 10allegation that Epstein9.8 pushe4.7d the4.7 U.S Attorne14.7y20.7?s Offic4.7e4.7 to th NPA secret from public view to avoid-420.7pub9.3lic c5.4r4.4itic5.4ism No for will a4.3ssist Doe4.3 No a4.3nd Doe4.3 No in protecting9.2 their under the CVRA This8.2 10re quest links to the Go9.8vernment?s oblig9.8ations-11.2 under the CVRA to 10use its best 10effo-10.1rts victims U.S.C The di-8.6rect 10conne-10.6ction requ-16.6est and vi-7.9ctims case is No 10request 10cor-7.2r2.8espondenc r-7.5e3.5lated to Epstein prose-6.5c3.5ution that the Gove-6.5rnment-12.5 ha4.7d with e4.7n.7titie4.7s outside14.7 the4.7 it is tha6.7t 10have been 6orde-13.1red See DE at produ-10.5ction of informa4.2tion with pe4.2rsons or e4.2n.2titie4.2s ou10.2tside4.2 10g10.2overnme4.2nt the4.2 of this info-8.9rma5.1tion is to the course5.1 of the5.1 Case Document Entered on FLSD Docket Page of Case Document Entered on FLSD Docket Page of inve4.3stig10.3a4.3tion a4.3nd the4.3 vic4.3tims notifie4.3d inve9.9stig11.9a5.9tion No requests all8.3 initial8.3 pr5.3oduc10.3tions that required under the Rules of Civil7.1 Procedure This is a protective requ-11est to ensure that should it be determin10.1ed that the Civil R7.1u.1les to they21.5 the vi-11.9ctims sent a supplemental production 10asking9.4 to provide info-11.3rm-13.3ation concernin-11.3g8.7 i-11.6nvestig10.4ation that th Department undertook the7.7 the7.7 vic5.7tims inve9.7stig11.7a5.7tion in this OPR or other investig10.1ation in the So10.1ut hern District of a of this inf6.8or6.8ma5.8tio is would pr5.6oving12.6 the6.6 vic4.6tims durin-9.4g the4.6 inve4.6stig10.6a4.6tion of Epstein.-900.3This informati-12.3on would also dire-6.3c to Gov-10.4e3.6rnment?s 6.4e3.6stoppel informati-12.8on would also show motive and bias Government has pr-7.8oduced a that violates the Court?s order in this case have been hamp-10.9ered in respondin-10.9g9.1 to th Government?s 10assertio-10.9ns of privileg9.7e3.7 of in it is impossible-504.7t-.7o5.3 th5.3e 10of becaus-7.8e of has prod-16.5uce a each aut-3.7hor address)-12.7ee and subject matter DE of the6.3 entries in the privileg10.4e4.4 fail this re4.2quire4.2me4.2nt g9.6ood illustration of the inadequacies of the pr comes the first in the throu-10.6g some pa-6.3ges documents the 10d-9.8e4.2scription these ges is F6.4ile 10folder-6.6 ent-11.6itled CORR RE GJ SUB6.1P-4.9OENAS cont-12.9aining9.1 10corr-7.9espondenc-6.9e to various su-10.5bpoenas attorne-16.5y9.5 Villa4.1fa4.1?a ha)4.1ndw-7.9ritte4.1n illustration of the inadequacies the privilege is pro-10.2v-.2ided the6.1 first privileg10.1e4.1 to No throug9.3h The Government asserts he-6.4re ments the d-10.6e3.4scription of th-10.6ese pages is F6ile folder ent-12itle Documents 10containing between 10AUSA and case 10ag9.9ent indictment prep qu-10.1estions victim identification infor-7m-2ation corrections to indic5.4tme5.4nt indic5.4tme5.4nt time5.4line7.4 i-11llu5stra5tio5ns-320o5f0 th5e in5ad5eq-9u5a1c5i-1e5s0 pr6ivileg11e-5 log11 whi-11c5h the5 Court-11 will see when-630.5it have also iled contemporan-10.3eously-620.3a r-7.3e3.7sponse to the g10.9overnme4.9nt?s privileg10.9e4.9 whic4.9h ide4.9n.9tifie4.9s situa4.7tions of privile4.7ge4.7 well as ot-7.7her ar n-11eeded to 9.5respond-11 to the Government?s pri-13v-1ileg9e3 Government has never cont me or co--7.7c3.3ounsel about associated with9.3 a log tha8.1t 9with the8.1 11Cour t?s dire5c5tive7s.-9 At time5s re5le5v-9a5nt to this case would-10.2 have willing9.8 to 10work with G-8.9overnment couns-11.9el to ex-10.9cessive burden adequ-10.6a3.4te p-10.6r2.4ivilege r-7.3e3.7quests produ-10.3ction that 10sent to Government 10invited disc ussion to avoi7.2d 10ex-10.8cessive burden to Case Document Entered on FLSD Docket Page of Case Document Entered on FLSD Docket Page of the 10Govern-10.6ment?s asse-6.6r tions requir-7.5e3.5 pre-6.5mises as re4.9l-11.1a4.9tionship a4.9nd the4.9 re4.9ndition of relationship Yet the G-8.6overnment has not prov-10.7ided the factual und-10.7erpi-12.7nning9.3s for its8.3 a5.1sse5.1rtions illustration of this problem is found on pag10e-6 of the suppl-12emental privileg10e4 DE-9 with to supplemental No The 10here r-7.8eads emails between and A Marie Villafa a Atkinson and proposed response to le5.4tte5.4r re notific5.4a5.4tion.?11.4 log the5.4 work produ-9.3c4.7t a4.5nd proc4.5e4.5ss The Government howev-11.1er does not provide document for of the 10factual underpinnin-10.9g9.1s of of with reg10.1a rd to the5.2 cla5.2im the7.2 Gove9.2rnme5.2nt-8.8 doe4.8s not who the6.8 who c4.8lie4.8nt is With to the4.8 work the4.6 not liti8.6g10.6a4.6tion this doc4.6ume4.6n.6t And with th4.5e what-4.2 pro-12.2cess involved th4.8e th4.8e underpinning9.9s of privileg9.9e3.9 10asser tions which the Court will see when it e14x-10amines-361the6 pr5ivileg10e-6 log9.5 and the vi-12.5ctims responsive log9.5 of assert-4.1ed been a of Waiver i7.9llustration on of th supplemental privileg9.6e3.6 DE with to supplemental The A Marie Acos ta Sloman Ki Atkinson and FBI13 proposed r-7e4sponse le5.8tte5.8r re notific5.8a5.8tion.?11.8 log the7.6n indica5.6te5.6s that the7.6 Gove9.6rnm-8.4e5.6nt is the7.3se the7.3 not to the7.3 U.S Attorney20.6?s 10but th4.6e This is a4.6nothe6.6r illustra4.6tion of who a enforcem-4.2ent-4.2 an privileg9.6e3.6 would be waiv dissemination this outside7.4 the7.4 U.S 10Office5.4 illustration of waiver is found on of the supplemental with re)-6.5gard supple-6.5m-2.5ental No to r-7.7eads folde4.3r3.3 Sta4.3rr RAA ha4.3ndw-7.7ritte4.3n A Ma4.3rie Villafa?a Kenn Sta rr cour-7.6se is a who defendant Epstein Recordin-10.8g9.2 information p-10.8r2.2ovided a de-6.8fense 10attorn is not part of 10g9.3ove-6.7rnmental c5.6lie5.6nt pr6.6ivile5.6ge7.6 illustration of waiver-377.3is found on page of the supplemental 10privileg9.7e3.7 with to supplemental No throug9.4h The Negotia5.1tions?5.1 c5.1onta5.1i-.9ning from-8.9 Marie 10Villafa?a to Richards ll 10re status update;-11.8 undate and h-9.8a4.2ndwritten-9.8 ite5.4ms Case Document Entered on FLSD Docket Page of Case Document Entered on FLSD Docket Page of of The und-20.4erst-4.4and refe-8.3renc-12.3es Attorne-7.1y18.9?s the privilege4.7 10would not to this 9am familiar with caselaw recited 6in pl-8.8eadi-8.8ngs rdi-9n1g f-10iduciar-20y17 ex-13cept-9ion?-17 also known 10as the Ga8r7n8e12r in se5.9tting13.9s to pr)6.9ivilege7.9s this the7.9 Government had-11 a 10fiduciar-18y19 obliga tion to protect 10the CVRA rig9.5h-.5ts Doe No and Doe5.1 No 10we the5.5 CVRA the Government had obligations to provide them under the CVRA including9.6 the confer and be of to of the7.5 interac5.5tions14.5 with the7.4 vic5.4tims The4.9 Duty4.9 Pr4.9ivilege fiduciar-18.1y28.9 of Government to the victims in case is clear the FBI both Doe4.1 No a4.1nd No vic4.1tims of Epste5in while5 w-7e5re5 10minors be5g11i-1nnin-9g11 10whe5n1 we-7.2re fourteen 10of and of Th-12.5ese of of 8a and Does were initiall-11.9y20.1 identifie throug14.1h the Palm B7.1each Police Department?s inve9.1stig11.1ation of Epstein the4.2 the4.2 Gove4.2rnme4.2nt ha4.2d Doe4.7 No vic4.7tim in case on about ered to Doe a standard CVRA vic5.2tim notific5.2a5.2tion The7.2 not ific5.7a5.7tion tha7.7t the5.7 best-3.7 effort-3.7s Doe No including9 8t-8he reasonab-11l-3e rig9h-1t to confer with and be heard proceedin-10.5g in the district-12.5 court involvin-10.5g9.5 plea notific-6.8ation further 10ex-10.8plained this 10is unde11.7r inve9.7stig11.7a5.7tion about Au-9.7gust 10ag10.3ents hand-deliver-8ed to J-16ane D-9o3e No standard-11 CVRA vic5.2tim notific5.2a5.2tio11.2n le5.2tte5.2r The7.1 notific5.1a5.1tio-8.9n pr6.1omise5.1s.1 tha7.1t the5.1 best-4 effort-4s prot-8ect-4 J-13ane Doe i-4n-2cl-4udi-4ng8 9he reason-12abl-4e2 confer-9.1 for and public proce-6.1e3.9ding9.9 in the 10district court involving9.9 plea 10The notifica-7tion further ex-11plained-11 tha7.6t this is unde11.6r inv-6.4e5.6s.6tiga7.6tion in the investi-12.6g9.4at-12.6ion the the Assistant U.S 10had Doe No 8.9was was Epstein and all cont act was made th9.5roug9.5h that atto These meetings be6.5cause oblig10.5ations to pr7.5ot ect the6.5 under the CV-7.5RA 10October the initial non sig7.7n1.7ed Epstein and the Of-8.1fice the S-5.1out hern District of Doe No contacted to advised investig ation On Special person Doe she as Case Document Entered on FLSD Docket Page of Case Document Entered on FLSD Docket Page of of the4.6 a4.6nd the4.6 vic4.6tims we4.6ll othe4.6r simila4.4r na4.4ture4.4 the4.4 Gove4.4rnme4.4nt oblig11.7a5.7tion to the7.7 the7.7 vic5.7tims10.7 under the Crime Victims Rig9.5h-.5ts Act Accordin-10.5g9.5l the Government is precluded raising to the7.8 lea5.8s.8t a4.5sse4.5rtion would outweig10.5he4.5d the4.5 10for the4.5 illustration situation where the fidu-9.8ci 10ex-10.5ception applies is 10found on page the5.8 supplemental with to supplemental-12.5 No here4.4 from A to Ac4.7osta4.7 Sloma4.7n Atkinson and 10re p-10.8r2.2oposed response to Go-10.8ldberg er?s lette-6.7r re notification responding to def-7.5e3.5nse le tter-6.7 about victim notification the7 4U.S Offic4.2e4.2 ha4.2d the4.2 CVRA to the4.2 vic4.2tims inte4.2re4.2sts the4.2 Offic5.2e5.2 ca5.2nnot5.2 a5.2sse5.2rt que9.2stions about5.3 whe7.3the7.3r it fulfille5.3d11.3 its ob13.3lig11.3a5.3tions to vic4.7tims in this or the4.7 privileg10.7e4.7 would the7.1 vic5.1tims illustration a situation where th fiduciar-17.7y19.3 ex-10.7ception applies is-381.7found page the first p-10.7r2.3ivilege with to to re Cr ime Vic5.1tims handwritten notes 11victim notification letter,-362.3and to He5re5 ag5ain5,5 ma5te5ria5l-1s issu5e to5 h5e1a5r4t o5f0 th5is10 c5a5s0e5 kind11 of notific5a5tions we5re to the4.6 vic4.6tims how did the4.6 a4.6nd limit those4.6 notific4.6a4.6tions.10.6 Moreover,-10.4 in ev-10.4aluating issues-11.4 determinin-10.2g9.8 kind-8.2 of lette-5.9r to the Gove9.1rnme5.1nt wa5.1s fulfilling13.1 dutie5.1s tha7.1t it to the5.1 vic5.1tims the5.1 Office cannot now assert pr5.2ivilege6.2 que8.2stions ab out whe6.4the6.4r it fulfilled its oblig10.4ations to the th6.6is fa5.3milia5.3r 10with 12the 12in 10va7.3rious when-510.9the communications concern fraud-10.9 or g9.7ove-6.3rnment misconduc of important documents about the6.2 tr eatment the6.5 10victims to whic 10the Government is asserting 10would within Not reg9.4a3.4rd to and documents in the Gove4.7rnme4.7nt?s fro4.7m th4.7e th4.7e prosecution Governm-12.8e3.2nt nd a of the prosecution on 10about Septembe Epstein his and of the4.3 10Office4.3 of 10bars of to the7.3 vic5.3tims about clients Do No and Doe No received letters-12.8 from-4.3 case is currently under investigation can be pro-11.7cess and reque-5.7st nued patience 10while conduct a The7.1 in the7.1 notific5.1a5.1tio5.1n5.1 wa5.1s it did not tha5.4t the5.4 be-6.6en r-7.6e3.4solved non-pros-11.6ecution enter-7.6e3.4d into Epstein and the U.S discusse Moreov-10.2er did not Doe No Doe No a pl-3.8ea ag reement had be-7en rea-7c3he-7d previousl-13y19 and that-13 part-4.3 of agreem-14.3ent-8.3 was a non-10.3-prosecut-4.3i-4.3on e5n1t with the5 U.S At9torney21?s Office5 for the Case Document Entered on FLSD Docket Page of Case Document Entered on FLSD Docket Page of Southe7.3rn Distric5.3t-.7 of the Non wou-12l-4d resol-4v-2e-8 t-4h2e 10fede-12ral-4 case the itself een inform-13.2ed the non-p-11.2r1.8osecution agreem-15.2ent-9.2 al-5.2so are rat-5.2h.8er was not informed about the case in acting12.5 the direction Of-8.3fice about April Doe No cont acted the Ep couns-14.7el was a5tte5mpting11 to ta5ke5 h-9e5r d-9e5position a5nd priva5t-1e5 in-9ve5stig11a5t-1ors 10we5re5 ha5ra5ssing11 her Assista5n1t U.S Attorne-7.2y18.8 Marie secu-11.2red pro bono 10co unsel to represent 9.4Doe No and other identified victims conn ection with the criminal investig ation Pro bono 10counsel was able to assist No in avoiding the imp 10deposition AUSA 10Villafa?a secu-10.7red Garvin Esq the7.2 Na5.2tiona9.2l Crime5.2 in Portland Oreg9.5on which-10.5 is based in the Clark Colleg9.6e3.6 of During9.6 the call Garvin was not that a non-pros-16.3ecut-7.3ion had in matter one 10clients was r-7eco-10g10n0ized an E-9p0stein victim th-10e U.S eceived-10.9 letters-11.9 from the advisin-10.9g9.1 case under investigation can be a and we request 10co-11.1ntinued patience while we conduct a 10investig9.3a tion The stat-12.7ement in the no tification letter was becaus-7.3e it reveal that the case had been resolved th-11e non-prosecution a-7g9re-7ement-13 entered into Epstein the U.S O-8.5ffice in Septembe-6.5r mid-J-11.6une 10cont-12.6acted 10AUSA Villaf-7.6a3.4?a inform her that Doe No and late-6.6r 10asked to provide inform-12.4ation ab-11.2out the 10crimes c5o-1mmitte5d Epste5in hopi5ng13 to se5c5u-1r6e5 a5 sig11n-1ifi-11c5a5n-1t fe5dera5l indic5tme5nt a5g11a5inst Epste5in AUSA a5.3nd disc5.3ussed the5.3 of fe5.3dera file4.7d 10At the4.7 e4.7nd of the4.7 AUSA se4.9nd informa4.9tion the4.9 Office5.1 in de7.1te5.1rmining13.1 file not informe5.3d1.3 previousl-12.3y19.7 in Septembe-6.3r-7.3 the U.S Attorne-16.3y9.7?s Offic-7e3 had r-8e3a-7c3hed agre-7ement not to file not tha7.4t 10.8re5.4solution the7.4 ma5.4tte5.4r immine7.4nt tha6.9t the4.9 Attorney20.9?s Offic4.9e4.9 withhe4.9ld-9.1 this informa4.9tion from me was becaus-6.1e of the p-11.1r1.9ovision that ex-10.7isted 12in the non-pr12.3osecution agreem-12.7ent At this point it is AUSA Villafa4.4na wa in she6.9 to te6ll me6 sent 10to AUSA Villafa?a a le the letter indicated desi-4.7re be def-9.7end 9wrot-9.4e on of ur-9.1ge an our United States to conside-6.4r2.6 the fundamental import of vig9o-11rous enfo-11rc-7ement-393o our urge to move-6.6 for6.5w3.5ard with the indi c5.6tme5.6nts a5.6nd with Mr Epste4.7i-1.3n ha4.7s c4.7o.7mmitte4.7d a4.7nd furth-9.3e4.7r urge4.7 to the4.7 ste4.7p.7s to our c4.6h.6ildre4.6n from this this le5.1tte5.1r still una5.1ware that a non-pros-12.1ecution with Epstein that continued to from the5.1 vic5.1tims the5.1 of this later on and el-3.9sewhere and case deliberate crime vi-7.7ctims and couns-24.5el of ex-11.5istence of Case Document Entered on FLSD Docket Page of Case Document Entered on FLSD Docket Page of non-prosecution would be a 10fraud-11 and g9.9ove-6.1rnment misconduct.-10.1 Documents to that fraud and miscond-10.4uct woul then fall outside of of the4.5 illustration document to which-9.8 the6.2 ime-fr-7.5aud-misconduct-12.5 ex-10.5ception applies-261.5on found on pa-6.2ge 10of the supplemental ge 10with to Suppl The folder entitled Starr to Acosta?12.5 containing9.6 dr-7.4afts of letters from A 10Ac osta4.3 to Sta4.3rr a4.3nd from to L11.4e-5.6fkowitz a4.4nd vic4.4tim not8.4ific4.4a4.4tion with ha4.4ndwritte4.4n e4.4d.4its A these5.6 to the7.6 in th11.6is invol5.6ve discussions between the and defense attorne-17.3y18.7s bout notifications crime victims And the dates of the communications in all 10likel8.5ihood they30.5 w-7.5ould be to the6.9 tha6.9t the6.9 Governme4.9n-1.1t to the6.9 fe4.9w la4.9ter illustration of document to the crime-fr-6.9aud-misconduct ex-9.5ception applies found on page of the supplemen tal privilege log9.5 DE ith to Suppl.10.8 to re-6.2ads Email from-8.4 A Marie Vi-14.4llafa?a to A Acosta Sloman Atkinson,9.6 and re propos-11.4ed respo-10.4n-.4se to Goldberg9.1er letter re victim notification.?14.2 These communic-6.3a3.7tions would presumabl-22.3y19.7 effo-11.2rts the prosecutors Epstein?s defens-12.1e Goldber-8.1g-1.1er to the ion secr-9.8et illustration where ex ception 10would is to information that the Government possesses th Reinhart private,-510.8non-public-6.8 information about the E-9.5p-.5stein case This woul show at the least misconduct Re5.3inha9.3rt in th4.7e doe-7.1s whi-9.1ch Reinhart it not po10.1ss9.1ible to point8.1 the Court8.1 to the specifi-13.3c documen-11.3ts that demonstrate misconduct These-6.3 doc-6.3uments howeve-6.3r2.7 cove-5.3red ex-11.3ception illustration the5 crime-fr-8aud-m-13isconduct ex-11cep tion could potentiall-12y30 appl-22y20 is with to informa4.6tion the4.6 Gove4.6rn-9.4me4.6nt posse4.6sse4.6s Ma4.6tth4.6ew personal or business relat-12.5i-2.5onshi with defendant Epst ein Gov?t Answers to RF5.8A?s This could potentiall-22.2y19.8 sh-10.2ow-278.2misconduct 10Menc-10.2hel and 10also potentiall-22.2y19.8 motive to violate-6.2 vic4.2tims rig10.2h.2ts The4.2 Go-9.4ve4.6rnme4.6nt?s privileg10.6e4.6 ha4.6s nume4.6r3.6ous pers the Epstein prosecution See e.g the first privile4.4ge4.4 DE with rega)4.4rd to The vi-12.2ctims inf5.8or5.8mation su-9.2gge8.8sting tha6.8t c4.6ontrolle4.6d e4.6n.6titie4.6s or ha4.6d some4.6 busine4.6ss re4.6la4.6tionship with hi8.6m doc4.6ume4.6n.6ts Government possesses 10showing9.6 a pe-6.5rsonal business relati onship 10between one of its prosecutors and man 10he was 10with prosecuting-240.3s-1.3hould be Governme5.2n-.8t its fa5.6irs Offic5.6e5.6 of Profe5.6ssiona5.6l-10.4 Responsibilit-12.2y29.8 collected information a bout possible i7.8m-2.2proper behavior the inve4.4stig10.4a4.4tion of the4.4 ma4.4tte4.4r Gov?t to RF6.4A a4.4d.4mits Department?s Of-7.8fice of Prof-7.8essional Res-10.7ponsibilit-11.7y30.3 and/or ot Government entities have 10collected in-10.6formati-12.6on about othe-6.6r ment Reinhart?s-7.6 possible improper beha-6.4vior in the Epstein matte fa-7.2ct that the Governme-7.2nt?s a-9g7en-13ci-5es h-13ave col-9l-5ect-15ed such i-5n1for-14m at-5i-5on 8dem-5ons-12t-5r0at-5es t-5h1ere a pri-5m-5a1 faci-5e-9 Case Document Entered on FLSD Docket Page of Case Document Entered on FLSD Docket Page of case improper-8.2 behavi-13.2or which is to trigg11.4e5.4r the5.4 to various privileges noted in the le-5.4gal memora-5.4ndum factual materi-13.5als are cove-6.3red i-4.3ssue case Ma of is are5.8 fac5.8tua7.8l F11.9a.9ctual Not has assert-4.5ed pr to most of a4.7sse4.7rtions it is i8.7m-1.3possi to de4.4te4.4rmine4.4 who is who is the4.4 were 10confidential to those involve in the of servi-12.5ces it is difficult for me to respond to of the asser tions of attorne-6.3y29.7 10client privileg9.3e3.3 and in the4.7 Governme4.7nt fa4.7ile4.7d to its of that the 10applies Atto4.6rne4.6y.6-Clie4.6nt Pr4.6ivile4.6ge i7.8llustration of doc13.8uments at which a app-16.7ears have improperl-12.7y19.3 10asse-6.7rted inadequate found at with to Suppl to for these pages docum-12.7ents File folder-8.1 entitled 10?-8.1I11.9nformation dra4.3f3.3ts of a4.3nd is 10impossible4.3 from this de4.9sc4.9ription to how the4.9 privile ge applies to these documents could other illustra4.4tions of the4.4 proble4.4m-1.6 Gove5.6rnme5.6nt?s a5.6ttorney21.6-c5.6lie5.6nt c5overs situa7tions whe7r4e5 it wa5s in re5.8la5.8tionship with the7.8 vi c6tims a6nd the8refor7e6 is limite6d in now8 a6s-9se6rting14 p-8r5ivile6ge8 ex-10.2ample supplemental privile-6.2ge log9.2 DE 10an conce-6.8r2.2ning Suppl B7.1ox throug10.1h which invol ves F5.6ile folder entitled 10Starr to Acosta 10containin-10.5g9.5 dr-7.5afts of lette-6.5rs fr om A Acost to Starr 10and from Sloman L21.1e-5.9fkowitz vic4.1tim notific4.1a4.1tion with ha4.1ndwritte4.1n a4.1nd e4.1d.1its This inf6.4or6.4ma5.4tion to the7.4 issue7.4s.4 invol5.4ve7.4d in this it notific5.1a5.1tion.?11.1 the ha5.1s to the4.5 vic4.5tims from is in The4.5 to the5.5 pr6.5ivile5.5ge7.5 in this s10.5itua7.5tion li9.5mits the7.5 g11.5ove9.5rnme5.5nt?s to invoke also 10appear to be shared 10comm unications between the Government and Epstei-12.9n?s attorn it is how the5.2 privile5.2ge5.2 c5.2ould such one e13x-11ample of wh9y19 th-11e victims have establ ished a compelling4.4 need for the materials de5.3sc5.3ribe5.3d in the a5.3nd othe5.3r like5.3 is the tha7.3t the7.3 Cour8.3t indi-11.2cated that it will be cons-10.2ider an 8e2stoppe-10l ar-9g8u2m-8ent-8 r-9a2is ed 8.7the Governm-8.5ent-8.5 as defense in this case DE at The has noted that this implicates e4.5quita4.5ble4.5 whic4.5h must in the4.5 historic4.5a4.5l-1.5 of th15e entire interface between-10.4 Epstein the relevant prosecutorial aut horitie4.6s and the federal offense vi-4ct-4i-4m0s an assessm-4.8ent-8.8 of a a4.7nd prose4.7c4.7u.7tors the4.7 vic4.7tims in da4.7rk on the4.7 of ne4.7g10.7o.7tia4.7tions Epstein and 13auth orities until well after fa-7.3ct and 8pr-12.3esent-7.3ation the non-9.3-pros-12.3ecution agreem-14.6ent-8.6 as a fait a-6.4ccompli DE at 7.4(e3.6mphasis materials-11.4 to Case Document Entered on FLSD Docket Page of Case Document Entered on FLSD Docket Page of whic4.9h the4.9 is th5.9at the4.5 10Gove4.5rnme4.5nt vic4.5tims compe4.5lling10.5 for informa5tion a5nd the5 e5x-9c5e5p1tion to the5 10.2a5ttorne-15y21-c5lie5nt pr6ivilege a5pplie5s to pe7rmit the7 Court to provide4.7 to the4.7 vic4.7tims Gove-6.7rnment not ex-10.7plained 10ha that would releasin-10.2g vic5.5tims the Governme5.5n-.5t harm an to additional info-10.2rmation on that-432.2alleged-10.2 harm-4.5 the that is be withheld the Gover-7.6n-.6ment 10under inve8.9stig10.9a4.9tion the Professional Responsibilit-11.7y30.3 OPR opened with to the Ep stein This investig9.7ation9.7 was undertak-10.9en at the request of the victims in case On December co-counsel Professor Paul Casse ll of the4.6 of of me4.6t Attorne-6.9y19.1 10for the District of this in the4.9 Attorney20.9?s in Mia4.6mi 10At on Profe4.6ssor le4.6tter to U.S him to investigate happened during9.1 the Ep-10.9stein prosecution and how8 the8 vic6tims w-6e6re trea6te6d dur9in-8g12 th-8a6t0 inve10sti-10g0a8tion Ba6se6d-8 on the pr7iv-8ile6g12e-4 tha8t h-8a6s bee6n0 provided as well as su-10.8bsequent corr-7.8esponden-10.8c-6.8e se nt to Professor ll that request for inve8.8stig10.8ation 10over to OPR in Washing10.8t-1.2on D.C Del-4i-4b-6erati-4v2e Process Pr-8i-4v2i-8l-4ege ultimate outcome the6.3 OPR inve9.5stig11.5ation is unc9.5lear Wh is clear is tha6.1t documents are withheld about that investig10.1ation 309.9documents that 10would to the central issue5.4s in this whole the of the supplemental privileg9.4e3.4 DE to the7 OPR 9inv13estig11ation of6 how7 the7 Eps-7t-4ein case handl-12ed-12 and how-16 the vi-8ctims wer-9e2 treated pr-8o-13cess 10with 10to the4.8 proce4.8ss of a d-12.1ecision the ul-8.1timate decision self The Governm-8.5ent-18.5 here has assert-4.2ed p-12.2r.8ocess ove-6.2r pro-12.2cess decision is not which do-10.6cument em bodies the final OPR decision or of the4.4 Gove4.4rnme4.4nt?s privileg10.4e4.4 whether that final decisi-13.1on has been produced-11.1 Give7.3n the7.3 limite5.3d de7.3sc5.3rip-8.7tions the7.3 doc9.3ume5.3n-.7ts it the5.3 OPR decision in document 10found supplem-12.1ental with regard to Su)9.9ppl 10to The descripti6.9on there reads Confidentia4.7l To 20Addresse-6.5e Robin Ashton to A with ha4.3ndwritte4.3n No is provide4.3d th-9.7is le4.3tte4.3r Nor 10indic4.4a4.4tion to the le4.4tte4.4r 10wa not to other pe-6.3rsons tha7.5t this is de7.5sc5.5ribe7.5d le5.5tte5.5r in the7.5 is final version of the letter indi cated que-6.3stions about wh at was and what this is the4.9 e4.9m-1.1bodime4.9nt of OPR?s conclusions this letter would prot-4.1ect-4.1ed process be cause the deliber-8.1ations would have come to end is 10also worth-9.9 that 10OPR is an misconduct feder-7.3a3.7l prosecuto-10.3rs it would not be providing a a4.7dvice4.7 to prose4.7c4.7u.7tors a4.7nd its Case Document Entered on FLSD Docket Page of Case Document Entered on FLSD Docket Page of doc4.7ume4.7n.7ts would rega4.7rd for the U.S Of-8.4fice the hern District of fact that has investig9.4ated the claims raised Does and and we-6.6re 10able to documents unobstru-10.6c3.4te the 10Governm-12.8e3.2nt 10in order to its conclusion that produ-10.4ction of OPR file5.8 to the in this short-12.4c3.6ut this discover-17.4y19.6 pro-10.4cess and 10the litig9.8ation if OPR the7.9 doc9.9ume5.9n-.1ts to ma5.9ke finding13.9s-9.1 the vic5.9tims c5.9l-.1aims the7.9n vic5.1tims a5.1nd othe5.1r to the5.1 to the vic5.4tims the5.4 Gov-8.6e5.4rnme5.4nt harm respectfull-22.4y19.6 r-7.4e3.6quest an to provi de add-9itiona7l inf6or6mation on alleg11.1e5.1d harm inve-5.1stigative privi-7.1l-3.1ege is a qua-5.1lified balan-12.5ces the of litig9.7ate for a-6.3ccess to inf-5.3ormation aga inst pu-8blic interest in non-d isclosure That balancin-11g9 process is ordinaril-12.3y19.7 ma-6.3de with referen-11.4ce to discussed in Frank13.7enhauser Rizzo Inve4.6stigative4.6 whic14.3h disc4.3losure4.3 will 10thwa4.3rt from the informa5.2tion the upon persons who have inform-12.7ation of their identities disclosed the to which 10governmental self evalu-10.7a-6.7tion and onsequent impr6.1ove9.1me5.1nt will the informa5.1tion is factual-13.2 data-7.2 or 10evaluative-7.2 wh ether-7.7 the 10se-6.7eking an actual potential d-10.8e3.2fendant in crimina-6.8l-2.8 proceedin-10.8g9.2 10either foll-11.5ow from the in 10que4.5stion inve9.3stig11.3a5.3tion ha7.3s comple5.3te5.3d or from-4.3 whet)-4.3her plaintiff9.9s suit is non-fr-7.1ivolous and broug9.9ht g9.9ood information soug9.7ht is available throug othe-6.9r discover-17.9y19.1 or from other and the importan)-11.2ce 10of the informa tion to the plaintiff9.9s On the5.4 of this ca5.4se in 10fa4.4vor disc4.4losing the4.4 i-11.6n.4forma4.4tion the4.4 vic4.4tims have requ-16.7est-4.7ed reg9.9a3.9rd to the5.9 ex-10.1tent to which disclosur4.9e will thwart proc4.8e4.8sse4.8s from in-9.2forma4.8tio-9.2n fou-9.2r vic4.3tims of Epste4.3i-1.7n?s Doe4.3 No a4.3nd victim will refer to as and and ot7.1her victims-311.9of Ep-11.5stein?s abus-10.5e as well fur5t-2h-10e4r inf5o-10r3mation is disclosed about this cas that will not discourag10.8e them from providin-9.2g.8 inf5.3or5.3mation but rather 10will encourage them have also talk to for number other vi-12.6ctims in this cas 10have been 10told that these victims hope Doe No and 10Doe No suc-7.3cessful 10in their case to f-7.6actor the upon pe rsons who have-6.5 infor-7.5m-2.5ation of ide4.2n.2titie4.2s disc4.2lose4.2d Doe4.2 No a4.2nd Doe4.2 No not informa4.2tion would ide7.5ntify21.5 partic5.5ula5.5r4.5 vic5.5tim will no on other vic5.1tims the7.5 Epste5.5in?6.5s vic5.5tims inf6.5or6.5ma5.5tion Case Document Entered on FLSD Docket Page of Case Document Entered on FLSD Docket Page of not to the4.6 public4.6 individua4.6l vic4.6tims di8.6d not wish for ide7.5ntitie5.5s to disse5.5mina7.5te5.5d to factor the degree to wh ich g9.2o-10.8vernmental luatio-10.4n and consequent impr6.4ove9.4me5.4nt w-6.6ill this is la5.4wsuit to the7.4 the4.6 Gove4.6rnme4.6nt with CVRA oblig10.6a4.6tions the4.6 Gov-9.4e4.6rnme4.6nt?s of pr6.1oviding13.1 vic5.1tims will impr6.1oved if the7.1 vic5.1tims to the7.1ir in this la5.1wsuit regard to factor whether the info rma-6.5tion soug9.5ht is factual data or evaluative-10.5 the7.5 ite5.5ms tha7.5t the7.5 summa5.5r4.5ie5.5s An thi11.5s found at of the 10first privileg9.7e3.7 with to to The F5.1ile folder entitled Victim Notif containing11.9 ch-10.1art with vic4.8tim informa4.8tion a4.8nd a4.8ttorney20.8 a4.8nd of This would10.8 include for ex-10.8ample dates of contacts with Doe No and J-12a3ne Doe 10No which would be re-7g9a-7rd to f-8actor-8 wh-11e3ther th-11e pa-7rt discover-17.4y19.6 10is an 10actual potential-12.4 defendant in c-6.8r2.2iminal proceedin-10.8g9.2 pe or 10to follow from the incident in question Doe No 10and Doe No vic6tims of a crime de5.5fe5.5nda5.5nts the Court is it is the5.5 criminal defen-10.3dant who has undertak-10.4en several limite interven-10.5tion efforts to tr block disclosure inf6.5or6.5ma5.5tion to the7.5 vic5.5tims reg8.9a2.9rd to whethe-7.1r1.9 the police investig9.3ation has completed the inve4.8stig10.8a4.8tion of Epste4.8i-1.2n wa4.8s a go and the Government not produced in its8.5 inf6.7or6.7mation indic5.7a5.7ting13.7 reg8.4a2.4rd to wheth-12er int-8r1ad-12epartment-8al the7.9 inve9.9stig11.9a5.9tion it tha7.9n OPR ha7.9s of effort-4.1s case 10Howeve-8.1r does appear informa5.1tion to the5.1 vic5.1tims would disciplina5.1r-5.9y21.1 to the the victims to ob-10.6tain information about this case find-260.1info-10.1rmation about they20.9 ca4.9n provide informa4.9tion to G12.9ove4.9rnme4.9nt a4.9nd othe4.9r e4.9n.9titie4.9s appropriate to 10fa-6.3ctor wheth-10.3er plaintiff-7.3 3s suit is non-frivolous in faith it should be clear at this juncture of a that the victims have a substa5.6ntia5.6l tha7.6t is br6.6oug15.6ht in fa5.6ith re-7gard-11 to f-8acto-11r2 wh-11e3ther-8 the in soug9.7ht availa-6.3ble othe-6.3r discover-17.9y29.1 from other-7.9 sources as recounted 10th roug9.9hout this affidavit the victims8.5 have other to obtain the informati on at issue in th10.1is privileg10.1e4.1 de bate 10as it 10involves information to the7.1 De5.1pa7.1rtme5.1nt to he importance information-10.1 to plaintiff-7.7 the information that the victims are is hi important to their case 10I13.2ndeed without-11.8 adequate the Cour-7.2t has indicated-10.2 that it ma to DE Throug9.5hout this affi-12.5davit provided nu-10.8merous ex-10.8amples and explanations-301.8of vic4.7tims the4.7 information they30.7 doc4.7ume4.7n.7ts to 10whic4.7h the4.7 Gove4.7rnme4.7nt Case Document Entered on FLSD Docket Page of Case Document Entered on FLSD Docket Page of is on the4.9 Gove4.9rnme4.9nt?s estoppel defense 10which the victims need a com-12.8p-.8lete evidentiar-17.8y19.2 to dispute 10work 10claim show-8.3ing9.7 substantial ne-6.3ed the7.1 othe7.1r th5.1is th5.1e for a5.6ll the7.6 10will 10not a5.6ll those a4.6sse4.6rtions but note4.6 tha6.6t sta4.6nd to provide4.6 10a4.6dditiona4.6l informa4.6tion the4.6 Court to determine the compelling10.9 that the tims have for the materials they9.8 have 10requested-11.3 well 10as the undu-11.3e h-11.3a2.7rdship not actual impossibilit-11.9y20.1 of obt-11.9aining the in othe4.4r of tips in the4.4 vic4.4tims fa4.4vor one ex-8.9ample the victims a compe7.1llin the material OPR collected-10.3 part of its inve8.7stig ation B6.2e-6.8cause Depart ment to talk to OPR inve9.5stig11.5a5.5tor6.5s OPR wa5.5s to the Epstein case statements from the a involved Thes-11.7e interviews be in mate-6.9rials found at of supplemental log9.8 DE to Suppl to should be a total the these not-12.4es would be f-7.4actual sta-6.4t-2.4ements from Department p-10.9r2.1osecutors 10about how the Epstei w-9a3s handled 10and wh-11ether mis-12conduct-13 occurr-8.2ed the hand-11.2ling8.8 of the Those i-3.8ssues case Ther-8.8e no for victims to obtain information about these subjects because Department-17.3 has declined to provide i-12.3n-.3formation on this subject vi-7.4ctims have est-13.4abl-7.4ished a subs-10.7tant-7.7ial need the materi als ar-8e requestin-11g9 10in 6the previous of affidavit that 10re their-7.6 document produ-10.6ction requests numbers and suppl-12.4emental r-7.4e3.6quest number of the vi-12.5ctims ha ve established a need 10for the materials is the fact th-8.7at the7.3 Cour8.3t indicat ed that it will be cons-11.3idering ar-8g9u-1ment r-8a3ised th-11e 10Government 10as def-8e3ns in this 10at Court tha7.1t this e5.1quita5.1ble5.1 must in the7.6 the5.4 inte5.4rfac5.4e5.4 be5.4twee5.4n Epst ein the 10relevant prosecutorial authorities and the federal offense 10victims an assessment of 10the alle-6.2g9.8a3.8tion a5.5nd 10fe5.5deral to the 10vic4.7tims in the4.7 on the4.8 of Epste4.8i-1.2n a4.8u.8thoritie4.8s until we4.8ll the4.8 presentation of non--7.6prosecution them as a ac-6.5compli DE at emphasis adde-7.1d 10material to which is a sse-6.1rting product p-10.1r2.9otection to be4.8twee4.8n the4.8 vic4.8tims the4.8 Gove4.8rnme4.8nt vic4.8tims9.8 no othe4.3r showing10.3 inte4.3rface4.3 is The4.3 Gove4.3rnme4.3nt will not8.3 if to vic4.9tims victims?-327.1l-2.1egal pleading9.9 ex-10.1plained wh 10the Government not the documents at issue addition of Government?s assertions appear to cove-6.5r 10both 10and information Even if the Court 10allows the Governm-12.5e3.5nt to asse rt some form it should-9.7 require the 10Government sever materi-13.1als from 10materials Jury Case Document Entered on FLSD Docket Page of Case Document Entered on FLSD Docket Page of illustration this pr5.8oblem comes from the5.8 first DE with regard to to Th reads folder entitled Charts ch-12.4art prep-12.4ared 10at rection of AUSA ning10.2 victims names,10.2 of 8and othe7.6r to indic5.6tme5.6nt does 10be a 10was 10ever 10or More5.1over to the5.1 it some5.1 kind of limite5.1d11.1 disc4.7losure4.7 of limite4.7d disc4.7losure4.7 c4.7ould the4.7 other informa4.5tion provide4.5d to the4.5 vic4.5tims not the gra-6.1nd mate-6.1rials that Gove-6.1rnment asserting12.4 p-9.6r3.4ivilege-513.6involve issues Mo reover it does not appear that disclosing12.5 the6.5 materials ould tip of4.9f a 11potential targe5.9t to a Gove8.4rnment inve8.4stigation Of cour-7.8se and associ-4.8at-4.8es awar-9.8e of into crimes for purposes Gove-6.6rnment not ex-10.6plained 10ha that would releasin-10.7g doc5ume5n1ts to the5 vic5tims th-9e5 Gove5rnm-11e5nt ra5ise5s0 suc5h1 harm re5spe5c5t-1full-21y21 re5qu-9e5s0t a5n1 opportunit-12y20 to provide ad-10ditional in formation on alleg10.2e4.2d harm 10No 14and 10No do not 10confidential info-11.3rmation-11.3 about other victims To that f-7.6act on sent a letter to the Government in pa4.5rt 10a4.5void 10with of vic4.5tims who parties to this litig10.4ation Doe and J-12a3ne Doe ar-8e not seeking9 identif-18y19i-3n-11g9 information about other 10victims the do cuments that Doe and Doe requested Gove-6.9rnme-6.9nt produce Gove-6.9rn ment should not produc-6.6e the of othe-6.6r victims or other information ad-10.9dress or telephone num ber but should instead)9.3 tha7.4t unde-6.5r to U.S.C that the is true to the be-7.3st of knowled-11.3g-1.3e and 10belief Ex-11ecut-7ed of-8 Aug9u-1st Edwards BRAD-9L10E0Y EDW-7A1RDS-5,1 ES-5Q October for production supple13.5m-2.5ental request produ-10.5ction and for 10Admissions a4.1nd Gove4.1rn-9.9me4.1nt Answe4.1r3.1s Case Document Entered on FLSD Docket Page of Case Document Entered on FLSD Docket Page of
