EFTA00206173

From: 
(USAFLS) 
Sent: Monda March 07, 2011 5:28 PM 
To: 
. (USAFLS) 
Subject: FW: Jeffrey Epstein 
See below. Is this your case? Obviously we will make no comment. 
From: 
(SMO) 
Sent: Monda March 07, 2011 5:25 PM 
To: 
.(USAFLS) 
Subject: FW: Jeffrey Epstein 
I believe 
is out. See below. 
From: 
(SMO) 
Sent: Monc
March 07, 2011 5:18 PM 
To: 
, 
(USAFLS) 
Subject: Jeffrey Epstein 
, Is your office handling this matter? A WSJ reporter is trying to get more information. 
The Justice Department is investigating Jeffrey Epstein for child trafficking, The Daily Beast 
has learned—and has widened the scope of its probe to include a famous modeling agency. 
Hedge-fund manager Jeffrey Epstein completed his sentence for soliciting prostitution with a minor last 
week. But it appears his problems may not be over. Now The Daily Beast has learned that: 
• Federal investigators continue to investigate Epstein's activities, to see whether there is 
evidence of child trafficking—a far more serious charge than the two in his non-prosecution 
agreement, the arrangement between Epstein and the Department of Justice allowing him to 
plead guilty to lower-level state crimes. Trafficking can carry a 20-year sentence. 
• The FBI is also investigating Epstein's friend Jean Luc Brunel, whose MC2 modeling agency 
appears to have been a source of girls from overseas who ended up on Epstein's private jets. 
Under the concept of double jeopardy, Epstein can no longer be prosecuted for any of the charges 
covered by his non-prosecution agreement, in which he agreed to serve a short term of incarceration, 
fund the civil suits of named victims, and register as a sex offender. The victims who accepted cash 
settlements in these civil suits agreed not to testify against him or speak publicly about the case. 
EFTA00206333

However, new evidence developed by the Department of Justice on other offenses not covered by the 
agreement, including allegations by additional victims who come forward, could lead to new charges. 
There is no statute of limitations in the federal sex-trafficking law, which was also enacted by the state 
of Florida in 2002. Because his predatory habits stretch back many years and involved dozens of 
young-looking girls, there may well be more evidence to uncover. (Several young women who claim to 
be Epstein victims have recently contacted a Ft. Lauderdale lawyer, but to date no new civil complaints 
have been filed.) 
These new developments come one week after the publication of two articles in The Daily Beast about 
Epstein's pattern of sexual contact with underage girls, which Palm Beach police began investigating 
in 2005 and the U.S. Attorney's office then settled in a 2007 plea deal. The first article quoted a 
deposition by then-Palm Beach Chief of Police Michael Reiter, in which he stated that Epstein, a 
billionaire with many powerful friends, had received special treatment in both his plea deal and the 
terms of his incarceration. Although federal investigators at one point produced a draft 53-page 
indictment against Epstein, he was eventually allowed to plead guilty to only two relatively minor state 
charges and receive a short term of incarceration: 13 months in the county jail, during which he went 
to the office every day, and one year of community control, during which he traveled frequently to New 
York and his private island in the Virgin Islands. 
The Daily Beast has now discovered another instance in which Epstein apparently received special 
consideration: As a convicted sex offender, he is required by law to undergo an impartial psychological 
evaluation prior to sentencing and to receive psychiatric treatment during and after incarceration. This 
is because child molesters tend to be repeat offenders with high rates of recidivism. According to a 
source in law enforcement, however, Epstein was allowed to submit a report by his private 
psychologist, Dr. Stephen Alexander of Palm Beach, Florida, whose phone has since been 
disconnected with no forwarding information. 
The Daily Beast's second article provided details about Epstein's systematic abuse of underage girls 
at his Palm Beach mansion, where members of his staff allegedly recruited and paid a parade of 
teenagers, most of them 16 or younger, to perform daily massages that devolved into masturbation, 
groping, and sometimes full-blown sexual contact. It also revealed a monetary relationship between 
Epstein and Jean Luc Brunel, a frequent visitor to whom he gave $1 million around the same time that 
Brunel was starting his MC2 modeling agency. Some of the young girls MC2 recruited from overseas 
-often from Eastern Europe and South America—are known to have been passengers on Epstein's 
private jets. 
The U.S. Attorney General's Office in Florida says that it is against policy to confirm or deny the 
existence of an investigation. Jeffrey Epstein's lawyer, Jack Goldberger, says he has no knowledge of 
an ongoing probe, and he told The Daily Beast, "Jeffrey Epstein has fully complied with all state and 
federal requirements that arise from the prior proceedings in Palm Beach. There are no pending civil 
lawsuits. There are not and should not be any pending criminal investigations, given Mr. Epstein's 
complete fulfillment of all the terms of his non-prosecution agreement with the federal government." 
Read more: http://www.businessinsidercom/hedge-funder-joseph-epstein-investigated-for-child-
trafficking-2010-7#ixzz1FxAJrd Fa 
EFTA00206334

From: 
(USAFLS) 
Sent: 
Monday, March 07, 2011 6:34 PM 
To: 
(USAFLS) 
Cc: 
(USAFLS) 
Subject: 
FW: Motion to Make Our Pleading Available to the Public - Government Position 
FYI — Maybe we can discuss tomorrow? 
Assistant U.S. Attorney 
Fax 
From: Paul Cassell [mailto: 
Sent: Monda , March 07, 2011 5:33 PM 
To: 
(USAFLS); 
(USAFLS) 
Cc: Brad Edwards 
Subject: Motion to Make Our Pleading Available to the Public - Government Position 
Dear 
and 
We are writing to inquire about the government's position on a motion that we will be filing on March 
18 along with our "summary judgment" motion. As you know, the summary judgment motion will 
contain quotations from e-mails that are under the magistrate judge's order requiring prior notice to the 
court before they are disclosed. Accordingly, on March 18, we will be filing a full, unredacted summary 
judgment motion under seal with Judge Marra and, for the public PACER file, a summary judgment 
motion with quotations from the e-mails redacted. 
We will be filing simultaneously a motion for with the court for unsealing of the unredacted motion. We 
will provide (at least) three ground for unsealing. First, the confidentiality order was only based on an 
agreement to give advance notice to Epstein before using materials. Once advance notice has been 
given, there is no basis for confidentiality. Second, there is truly world-wide interest in the handling of 
the Epstein prosecution, and so our pleading should not remain under seal — instead the public should 
have access to it so that they can assess how this case was handled. Third, keeping the pleading 
under seal complicates the ability of Jane Does' attorneys to consult with victims' rights specialist 
about how best to proceed in the case. 
EFTA00206335

We are writing to determine the Government's position on our motion to unseal the redacted pleading 
so that we can include that position in our motion. We hope that you will not oppose the motion, which 
might produce the need for further litigation. As you know, Judge Marra has promptly unsealed other 
pleadings in this matter when the Government tried to object. 
Sincerely, 
Paul Cassell 
Co-Counsel for Jane Doe #1 and Jane Doe #2 
Paul G. Cassell 
Ronald N. Boyce Presidential Professor of Criminal Law 
S.J. Quinney College of Law at the University of Utah 
Voice: 
Fax: 
Email: 
http://www.law.utah.edu/profiles/defaultasp?PersonID=57&name=Cassell,Paul 
CONFIDENTIAL: This electronic message - along with any/all attachments - is confidential. This 
message is intended only for the use of the addressee. If you are not the intended recipient, the 
person responsible to deliver it to the intended recipient, you may not use, disseminate, distribute or 
copy this communication. If you have received this message in error, please immediately notify the 
sender by reply electronic mail and delete the original message. Thank you. 
From: 
(USAFLS) <
> 
Sent: 
Tuesday, March 08, 2011 12:44 PM 
To: 
Owen Bowcott 
EFTA00206336

Cc: 
Subject: 
(USAFLS) 
RE: request for information 
Hello. 
Thanks for your email. That is always the best way to contact me. 
It is against DOJ policy for us to either confirm or deny the existence of any investigation. 
Thanks for checking with us. 
From: Owen Bowcott [mailto:[email protected]] 
Sent: Tuesca March 08, 2011 12:23 PM 
To: 
(USAFLS) 
Subject: request for information 
Good Morning, 
I'm afraid I have been unable to reach you directly by telephone but I understand that you are the 
public affairs official for the United States Attorney, southern district of Florida. I was referred to you by 
the FBI regional office. 
I am a journalist on The Guardian newspaper in London and am trying to establish whether a 
fresh investigation has been authorised or launched into allegations involving Jeffrey Epstein. He was 
convicted in 2008 of procuring young girls for prostitution. 
If you could confirm that, as has been reported, the FBI has launched an inquiry into the affair, I 
would be very grateful. 
Many Thanks, 
Owen Bowcott, 
Senior Reporter, 
The Guardian, 
Please consider the environment before printing this email. 
Visit guardian.co.uk - newspaper website of the year 
www.guardian.co.uk www.observer.co.uk 
EFTA00206337

To save up to 30% when you subscribe to the Guardian and the Observer 
visit http://www.guardian.co.uk/subscriber 
This e-mail and all attachments are confidential and may also 
be privileged. If you are not the named recipient, please notify 
the sender and delete the e-mail and all attachments immediately. 
Do not disclose the contents to another person. You may not use 
the information for any purpose, or store, or copy, it in any way. 
Guardian News a Media Limited is not liable for any computer 
viruses or other material transmitted with or as part of this 
e-mail. You should employ virus checking software. 
Guardian News 6 Media Limited 
A member of Guardian Media Group plc 
Registered Office 
Registered in England Number 908396 
From: 
(USAFLS) 
Sent: 
Tuesday, March 08, 2011 2:08 PM 
To: 
(USAFLS); 
(USAFLS); 
(USAFLS); 
(USAFLS) 
Cc: 
(USAFLS) 
Subject: 
RE: Epstein/Conf. Call 
I have a change of plea at 9:30 and then the Health Care Fraud Task Force meeting at 10:00. 
Could we start at 11:30? 
Assistant U.S. Attorney 
Fax 
 
Ori inal A 
ointment 
From:
(USAFLS) On Behalf Of 
(USAFLS) 
Sent: Tuesday, March 08, 2011 8:56 AM 
To: I 
(USAFLS); 
(USAFLS); 
Subject: Epstein/Conf. Call 
When: Thursday, March 10 2011 10:00 AM-10:30 AM (GMT-05:00) Eastern Time (US & Canada). 
Where: 
Clfc. 
(USAFLS); 
. (USAFLS) 
EFTA00206338

From: 
(USAFLS) 
Sent: Monday, March 07, 2011 6:53 PM 
To: 
(USAFLS) 
Can you please set up a meeting/conference call re: Epstein for Thursday morning with me, 
and 
2 Thanks. 
From: 
(USAFLS) ‹
> 
Sent: 
Thursday, March 17, 2011 8:21 PM 
To: 
(USAFLS); 
(USAFLS); 
(USAFLS); 
(USAFLS) 
Subject: 
Fw: Call from Newsweek 
Sorry. Let me try this again. 
(USAFLS); 
Can 
and I have some of your time tomorrow? Preferably in the morning. I think we need to address this. 
 
Ono ir
Sg
-
From: 
(USAFLS) 
Sent: Thursda , March 17, 2011 07:54 PM 
To: 
. (USAFLS); 
(USAFLS) 
Subject: Fw: Call from Newsweek 
Sorry it keeps getting misdirected 
 
 Ori ir
, iMIAessag
-
From: 
(USAFLS) 
Sent: Thursda , March 17, 2011 07:52 PM 
To: 
USAFLS ; 
<eis©miamidade.gov>; 
(USAFLS) 
Cc: 
(USAFLS) 
Subject: Re: Call from Newsweek 
<
E>; '[email protected]' 
Can 
and I have some of your time tomorrow? Preferably in the morning. I think we need to address this. 
From: 
(USAFLS) 
Sent: Thursda , March 17, 2011 06:32 PM 
To: 
. (USAFLS) 
Subject: Re: Call from Newsweek 
I am wading through some of it now. 
---- Or:Vat 
From: 
(USAFLS) 
Sent: Thursda , March 17, 2011 06:31 PM 
To: 
(USAFLS) 
Subject: Re: Call from Newsweek 
No 
Origirat 
From: 
(USAFLS) 
EFTA00206339

Sent: Thursda March 17, 2011 06:30 PM 
To: 
(USAFLS) 
Subject: RE: Call from Newsweek 
BTW, do we know exactly which e-mails/correspondence Cassel obtained from Epstein's counsel in the civil litigation? 
 
Ori inal Messa e 
From: 
. (USAFLS) 
Sent: Thursda March 17, 2011 6:17 PM 
To: 
(USAFLS) 
Subject: Re: Call from Newsweek 
Thx. Sending from bberry 
Original Message 
From:•(USAFLS) 
Sent: Thursda , March 17, 2011 06:15 PM 
To: 
. (USAFLS) 
Subject: RE: Call from Newsweek 
Thanks - BTW I forwarded to 
and 
I think you used the old e-mail addresses. 
F 
 
Original Message
rom: 
. (USAFLS)
Sent: Thursda , March 17, 2011 6:14 PM 
To: 
USAFLS 
Cc: 
(USAFLS); 
(USAFLS); 
(USAFLS); 
'[email protected] 
Subject: Call from Newsweek 
Hi 
Received a voicemail from Newsweek (which now includes 
) while I was at the doctor's office 
from Lee Akin (sp?) And Samoff saying they wanted comment from me on a letter they received on the Epstein 
prosecution. My guess is it is either Cassell's letter or 
response thereto. They are going to print tomorrow. 
From: 
Paul Cassell ‹
> 
Sent: 
Thursday, March 17, 2011 8:41 PM 
To: 
(USAFLS) 
Cc: 
(USAFLS); Brad Edwards 
Subject: 
RE: Government's Position on Page Limits 
Dear 
1. 
Thank you for the information sent today. 
2. 
What is the Government's position on the page limits applicable to our "summary judgment" 
pleading — do you believe we are under the civil rules? Or under the criminal rules? Do you believe 
that we need to file a separate motion for a roughly 35 page pleading with roughly 19 pages of facts? 
If so, what is your position on such a motion? 
Thank you in advance for your position. Paul Cassell, Co-Counsel for Jane Doe #1 and Jane Doe #2 
EFTA00206340

Paul G. Cassell 
Ronald N. Boyce Presidential Professor of Criminal Law 
S.J. Quinney College of Law at the University of Utah 
Voice: 
Fax: 
Email: 
http://www.law.utah.edu/profiles/defaultasp?PersonID=57&name=Cassell,Paul 
CONFIDENTIAL: This electronic message - along with any/all attachments - is confidential. This 
message is intended only for the use of the addressee. If you are not the intended recipient, the 
person responsible to deliver it to the intended recipient, you may not use, disseminate, distribute or 
copy this communication. If you have received this message in error, please immediately notify the 
sender by reply electronic mail and delete the original message. Thank you. 
From: 
(USAFLS) [mailto 
Sent: Thursday, March 17, 2011 10:56 AM 
To: Paul Cassell 
Cc:  
 
 
 . (USAFLS); Brad Edwards 
Subject: RE: Government's Position on Several Pending Issues? Still Waiting for Answer 
Paul, 
1. 
Yesterday, I provided you with the name and phone number for 
, OPR Acting 
Associate Counsel, who received your December 10, 2010 letter to Mir.
 
asking for an 
investigation of the Jeffrey Epstein prosecution. 
2. 
The government will not be making initial disclosures to plaintiffs, because we do not believe 
Fed.R.Civ.P. 26 applies to this matter. 
EFTA00206341

3. 
The CVRA applies to the criminal case which has been filed in district court, where an individual 
is deemed to be a "victim," not any civil litigation which may be initiated to enforce those claimed 
rights. We do not believe there is any 
ht to
 in this case. Moreover, we do not believe 
that whatever Kenneth Starr or 
may have said to this office, or what this office said 
to Kenneth Starr or Lilly Ann 
, has any bearing on whether a duty existed under 18 U.S.C. 
3771(a) to consult with plaintiffs prior to entering into a non-prosecution agreement, where no charges 
were filed in the district court. We will respond to your motion seeking access to this information. 
4. 
As I understand the Magistrate Judge's order in Jane Doe No. 2 v. Jeffrey Epstein (D.E. 226), 
you must give notice to Epstein, prior to making certain correspondence public by either filing the 
correspondence in a court file, attaching it to a deposition, releasing it to the media, or publically 
disseminating it in any other fashion. D.E. 226 at 4. Presumably, Epstein will raise any objections he 
believes are appropriate, and the court will resolve the matter. 
The U.S. Attorney's Office has no independent objection to the filing of "an unsealed, unredacted 
pleading reciting the U.S. Attorney's correspondence." In stating that the U.S. Attorney's Office has 
no independent objections, we wish to make clear that we are not, and cannot, relieve the plaintiffs of 
their obligation to comply with the Magistrate Judge's order by giving the appropriate notice to Epstein 
(D.E. 226). Thank you. 
From: Paul Cassell [mailto: 
Sent: Tuesda , March 15, 2011 7:21 PM 
To: 
USAFLS 
Cc: 
. (USAFLS); Brad Edwards 
Subject: RE: Government's Position on Several Pending Issues? Still Waiting for Answer 
Dear 
Brad and I have received Mr. 
letter of today. We are deeply disappointed. We will file our 
court pleadings on Friday. 
Mr. 
- again. 
letter still leaves unanswered a number of questions, which I am writing to raise with you - 
1. 
You still have not provided, as you promised you would, the name of the person coordinating the 
OPR investigation. As a result we have not been able to obtain any information about the status of the 
EFTA00206342

investigation. Just to be clear, we intend to include in our filing information that OPR has begun an 
investigation and to include the information that we currently have about 
— we assume 
that making that information public will not compromise OPR's work. 
2. 
We will be making initial disclosures to you under the Federal Rules of Civil Procedure shortly. 
We have not heard back from you on whether you will be making parallel disclosures. Accordingly, we 
understand your position to be that you are not obligated to provide to us any documents under Rule 
26. 
3. 
We understand your position to be that, despite the "best efforts" clause in the CVRA and your 
obligation to treat victims with fairness, you can withhold evidence from the victims that will help them 
prove CVRA violations. For example, we understand you to take the position that you can withhold the 
other half of the U.S. Attorney's correspondence, correspondence between the Department and Ken 
Starr and Lillian 
on behalf of Epstein, and information about 
role in the 
Epstein case. In short, we understand you to be asserting a blanket position that you can withhold 
information that will help prove the victims' CVRA case. If this is incorrect, please advise us promptly. 
If we have misunderstood you and you are willing to provide us relevant information, we will promptly 
provide you with a list of such information. If we have understood you correctly, we will be filing a 
motion with the Court shortly to block the Justice Department from suppressing such highly relevant 
information. 
4. 
You still have not given us your position on the victims' motion to file an unsealed, unredacted 
pleading reciting the U.S. Attorney's correspondence. What is your position on that motion: We have 
been asking for your position on this motion for some time now. If we have not heard back from you 
by c.o.b. Wednesday, March 16, 2011, we will include in our pleadings the following statement: "The 
Justice Department attorneys handling this case have been contacted several times for their position 
on this issue but have refused to respond to give their position." 
Thanks you in advance for your assistance. Sincerely, Paul Cassell, Co-Counsel for Jane Doe 
Paul G. Cassell 
Ronald N. Boyce Presidential Professor of Criminal Law 
S.J. Quinney College of Law at the University of Utah 
Voice: 
Fax: 
Email: 
http://www.law.utah.edu/profiles/defaultasp?PersonID=57&name=Cassell,Paul 
EFTA00206343

CONFIDENTIAL: This electronic message - along with any/all attachments - is confidential. This 
message is intended only for the use of the addressee. If you are not the intended recipient, the 
person responsible to deliver it to the intended recipient, you may not use, disseminate, distribute or 
copy this communication. If you have received this message in error, please immediately notify the 
sender by reply electronic mail and delete the original message. Thank you. 
From: 
(USAFLS) ‹
> 
Sent: 
Thursday, March 17, 2011 7:54 PM 
To: 
(USAFLS); 
(USAFLS) 
Subject: 
Fw: Call from Newsweek 
Sorry it keeps getting misdirected 
 
 Ori inal Messa e 
From: 
. (USAFLS) 
Sent: Thursda March 17, 2011 07:52 PM 
To: 
USAFLS 
<eis©miamidade.gov>; 
(USAFLS) 
Cc: 
(USAFLS) 
Subject: Re: Call from Newsweek 
; '[email protected]' 
Can 
and I have some of your time tomorrow? Preferably in the morning. I think we need to address this. 
From: • 
(USAFLS) 
Sent: Thursda , March 17, 2011 06:32 PM 
To: 
. (USAFLS) 
Subject: Re: Call from Newsweek 
I am wading through some of it now. 
---- Cris 
From: 
(USAFLS) 
Sent Thursda , March 17, 2011 06:31 PM 
To: 
(USAFLS) 
Subject: Re: Call from Newsweek 
No 
OrLigirt 
From: • 
(USAFLS) 
Sent: Thursda , March 17, 2011 06:30 PM 
To: 
. (USAFLS) 
Subject: RE: Call from Newsweek 
BTW, do we know exactly which e-mails/correspondence Cassel obtained from Epstein's counsel in the civil litigation? 
----Ori inal Messa e---
From: 
. (USAFLS) 
Sent: Thursda , March 17, 2011 6:17 PM 
To: 
(USAFLS) 
Subject: Re: Call from Newsweek 
Thx. Sending from bberry 
---- Or  ir
age 
From: 
MI=I (USAFLS) 
EFTA00206344

Sent: Thursda March 17, 2011 06:15 PM 
To: 
(USAFLS) 
Subject: RE: Call from Newsweek 
Thanks - BTW I forwarded to I= and 
I think you used the old e-mail addresses. 
---Ori inal Mess e--
From: 
. (USAFLS) 
Sent: Thursda , March 17, 2011 6:14 PM 
To: 
USAFLS 
Cc: 
(USAFLS); 
(USAFLS); 
(USAFLS); 
'[email protected]' 
Subject: Call from Newsweek 
Hi 
from 
Received a voicemail from Newsweek (which now includes 
) while I was at the doctor's office 
from 
Akin (sp?) And Samoff saying they wanted comment from me on a letter they received on the Epstein 
prosecution. My guess is it is either Cassell's letter or 
response thereto. They are going to print tomorrow. 
From: 
(USAFLS) 'c
> 
Sent: 
Thursday, March 17, 2011 6:33 PM 
To: 
. (USAFLS) 
Subject: 
Re: Call from Newsweek 
I am wading through some of it now. 
 
 Ori inal Messa e 
From: 
. (USAFLS) 
Sent: Thursda , March 17, 2011 06:31 PM 
To: 
(USAFLS) 
Subject: Re: Call from Newsweek 
No 
Ori inal Messa e 
From: 
(USAFLS) 
Sent: Thursda , March 17, 2011 06:30 PM 
To: 
.(USAFLS) 
Subject: RE: Call from Newsweek 
BTW, do we know exactly which e-mails/correspondence Cassel obtained from Epstein's counsel in the civil litigation? 
 
Ori inal Mess e--
From: 
. (USAFLS) 
Sent: Thursda , March 17, 2011 6:17 PM 
To: 
(USAFLS) 
Subject: Re: Call from Newsweek 
Thx. Sending from bberry 
inal
 te —
From: 
(USAFLS) 
Sent: Thursda , March 17, 2011 06:15 PM 
To: 
.(USAFLS) 
Subject: RE: Call from Newsweek 
Thanks - 61W I forwarded to 
and 
I think you used the old e-mail addresses. 
EFTA00206345

----Ori inal Messa e—
From: 
. (USAFLS) 
Sent: Thursda , March 17, 2011 6:14 PM 
To: 
USAFLS 
Cc: 
(USAFLS); 
(USAFLS); 
(USAFLS); 
'[email protected]' 
Subject: Call from Newsweek 
Hi 
. Received a voicemail from Newsweek (which now includes Conchita Sarnoff) while I was at the doctor's office 
from 
Akin (sp?) And Samoff saying they wanted comment from me on a letter they received on the Epstein 
prosecution. My guess is it is either Cassell's letter or 
response thereto. They are going to print tomorrow. 
From: 
(USAFLS)
). 
Sent: 
Thursday, March 17, 2011 6:32 PM 
To: 
(USAFLS) 
Subject: 
Re: Call from Newsweek 
No 
From: 
(USAFLS) 
Sent: Thursda , March 17, 2011 06:30 PM 
To: 
. (USAFLS) 
Subject: RE: Call from Newsweek 
BTW, do we know exactly which e-mails/correspondence Cassel obtained from Epstein's counsel in the civil litigation? 
 
Ori inal Messa e---
From. 
. (USAFLS) 
Sent: Thursda , March 17, 2011 6:17 PM 
To: 
(USAFLS) 
Subject: Re: Call from Newsweek 
Thx. Sending from bberry 
 
 Ori inal Messa e 
From: 
(USAFLS) 
Sent: Thursda , March 17, 2011 06:15 PM 
To: 
. (USAFLS) 
Subject: RE: Call from Newsweek 
Thanks - BTW I forwarded to I= and • 
- I think you used the old e-mail addresses. 
----Ori inal Messa e---
From: 
. (USAFLS) 
Sent: Thursda , March 17, 2011 6:14 PM 
To: 
USAFLS 
Cc: 
(USAFLS); 
(USAFLS); 
(USAFLS); 
'[email protected]' 
Subject: Call from Newsweek 
Hi 
Received a voicemail from Newsweek (which now includes Conchita Sarnoff) while I was at the doctor's office 
from Lee Akin (sp?) And Samoff saying they wanted comment from me on a letter they received on the Epstein 
prosecution. My guess is it is either Cassell's letter or 
response thereto. They are going to print tomorrow. 
EFTA00206346

From: 
Sent: 
To: 
Cc: 
Subject: 
(USAFLS)
). 
Thursday, March 17, 2011 7:53 PM 
(USAFLS); 
(USAFLS) 
(USAFLS) 
Re: Call from Newsweek 
• [email protected]; 
Can 
and I have some of your time tomorrow? Preferably in the morning. I think we need to address this. 
From: 
(USAFLS) 
Sent: Thursda , March 17, 2011 06:32 PM 
To: 
. (USAFLS) 
Subject: Re: Call from Newsweek 
I am wading through some of it now. 
From: 
(USAFLS) 
Sent: Thursda , March 17, 2011 06:31 PM 
To: 
(USAFLS) 
Subject: Re: Call from Newsweek 
No 
From: 
Seng:Thur
ch 
To:
Subject: RE: Call from 
(USAFLS) 
17, 2011 06:30 PM 
. (USAFLS) 
Newsweek 
BTW, do we know exactly which e-mails/correspondence Cassel obtained from Epstein's counsel in the civil litigation? 
 
Ori inal Messa e----
From: 
. (USAFLS) 
Sent: Thursda , March 17, 2011 6:17 PM 
To: 
(USAFLS) 
Subject: Re: Call from Newsweek 
Thx. Sending from bberry 
From: 
To: 
Sent: Thur lagm.ch 
Subject: RE: Call from 
(USAFLS) 
17, 2011 06:15 PM 
.(USAFLS) 
Newsweek 
Thanks - BTW I forwarded to 
and 
I think you used the old e-mail addresses. 
From: 
. (USAFLS) 
 
Ori inal Messa e 
Sent: Thursda , March 17, 2011 6:14 PM 
To: 
USAFLS 
Cc: 
(USAFLS); 
[email protected] 
(USAFLS); 
(USAFLS); 
EFTA00206347

Subject: Call from Newsweek 
Hi 
Received a voicemail from Newsweek (which now includes Conchita Sarnoff) while I was at the doctor's office 
from Lee Akin (sp?) And Samoff saying they wanted comment from me on a letter they received on the Epstein 
prosecution. My guess is it is either Cassell's letter or 
response thereto. They are going to print tomorrow. 
From: 
(USAFLS)
). 
Sent: 
Thursday, March 17, 2011 6:34 PM 
To: 
(USAFLS) 
Subject: 
Re: Call from Newsweek 
I am trying to convince edwards not to file tomorrow 
From: 
(USAFLS) 
Sent: Thursda , March 17, 2011 06:32 PM 
To: 
. (USAFLS) 
Subject: Re: Call from Newsweek 
I am wading through some of it now. 
Oggirat 
From: 
(USAFLS) 
Sent Thursda , March 17, 2011 06:31 PM 
To: 
(USAFLS) 
Subject: Re: Call from Newsweek 
No 
 
 Ori inal Messa e --
From. 
(USAFLS) 
Sent: Thursda , March 17, 2011 06:30 PM 
To: 
. (USAFLS) 
Subject: RE: Call from Newsweek 
BTW, do we know exactly which e-mails/correspondence Cassel obtained from Epstein's counsel in the civil litigation? 
----Ori inal Messa e---
From: 
. (USAFLS) 
Sent: Thursda , March 17, 2011 6:17 PM 
To: 
(USAFLS) 
Subject: Re: Call from Newsweek 
Thx. Sending from bberry 
From: 
(USAFLS) 
Sent Thursda , March 17, 2011 06:15 PM 
To: 
. (USAFLS) 
Subject: RE: Call from Newsweek 
Thanks - BTW I forwarded to 
and • 
- I think you used the old e-mail addresses. 
----Ori inal Messa e----
From: 
. (USAFLS) 
Sent: Thursday, March 17, 2011 6:14 PM 
To: =,M 
(USAFLS) 
EFTA00206348

Cc: 
(USAFLS); 
(USAFLS); 
(USAFLS); 
'[email protected]' 
Subject: Call from Newsweek 
Hi 
Received a voicemail from Newsweek (which now includes Conchita Sarnoff) while I was at the doctor's office 
from 
Akin (sp?) And Samoff saying they wanted comment from me on a letter they received on the Epstein 
prosecution. My guess is it is either Cassell's letter or 
response thereto. They are going to print tomorrow. 
From: 
Paul Cassell 
Sent: 
Friday, March 18, 2011 5:28 PM 
To: 
(USAFLS); 
Cc: 
Brad Edwards 
Subject: 
Courtesy Copy 
Attachments: 
motion-finding-violation-courtesy31811.doc 
Dear 
and 
. (USAFLS) 
As you know, while we strenuously disagree with your position on the CVRA, we have always tried to 
keep in close contact with you. In that spirit, attached is a courtesy copy of one of the pleadings we 
plan to file on Monday. 
Paul Cassell 
Co-Counsel for Jane Doe #1 and Jane Doe #2 
Paul G. Cassell 
Ronald N. Boyce Presidential Professor of Criminal Law 
S.J. Quinney College of Law at the University of Utah 
Voice: 
Fax: 
Email: 
http://www.law.utah.edu/profiles/defaultasp?PersonID=57&name=Cassell,Paul 
EFTA00206349

CONFIDENTIAL: This electronic message - along with any/all attachments - is confidential. This 
message is intended only for the use of the addressee. If you are not the intended recipient, the 
person responsible to deliver it to the intended recipient, you may not use, disseminate, distribute or 
copy this communication. If you have received this message in error, please immediately notify the 
sender by reply electronic mail and delete the original message. Thank you. 
Subject: 
Epstein 
Location: 
ofc 
Start: 
Fri 3/18/2011 10:30 AM 
End: 
Fri 3/18/2011 11:00 AM 
Show Time As: 
Tentative 
Recurrence: 
(none) 
Meeting Status: 
Not yet responded 
call in 
Organizer: 
(USAFLS) 
Required Attendees: 
(USAFLS); 
(USAFLS); 
(USAFLS); 
(USAFLS); 
(USAFLS); 
(USAFLS) 
When: Friday, March 18, 2011 10:30 AM-11:00 AM (GMT-05:00) Eastern Time (US & Canada). 
Where: 
ofc/ 
call in 
Note: The GMT offset above does not reflect daylight saving time adjustments. 
From: 
(USAFLS) 
Sent: Friday, March 18, 2011 9:06 AM 
To: 
(USAFLS) 
Hola. Can ot.
t
se set a conference call for 10:30 this morning in 
office re: Epstein with MI 
=. M. 
and 
and ask for a number we should call in WPB? Thanks. 
From: 
(USAFLS) 
Sent: 
Monday, March 21, 2011 10:36 AM 
To: 
(USAFLS) 
Cc: 
(USAFLS); 
(USAFLS) 
Subject: 
RE: Planned response to tomorrow's filing by Cassell 
I guess my question is, then, are we going to contest the factual misstatements in his statement of undisputed 
facts? Which will necessarily have to include filing affidavits and opening myself and the case agents up for 
depositions? 
EFTA00206350

Assistant U.S. Attorney 
Fax 
From:
 (USAFLS) 
Sent: Monday, March 21, 2011 9:57 AM 
To: 
. (USAFLS) 
Cc: 
 
(USAFLS); 
(USAFLS) 
Subject: RE: Planned response to tomorrow's filing by Cassell 
At the conclusion of the emergency hearing in July 2008, the court asked the parties to meet and decide 
whether there were any disputed facts, so the court could schedule a hearing. 
We told Edwards the only 
relevant fact was whether any charges had been filed against Epstein in federal court, and it was not disputed 
the answer was "no." Edwards disagreed and attempted to include other "facts" which he believed to be 
relevant to the resolution of the legal question of whether the government had a duty to consult with the 
victims under 18 U.S.C. 3771(a)(5). 
I don't believe the filing of the motion you suggest will achieve the result of preemptively striking Cassell's 
motion to enforce. 
The court will have to decide whether the resolution of any disputed facts is required, in 
order to resolve the legal issue. 
The government says no; the victims say yes. The court is not likely to 
resolve this question without looking at the factual issues the victims contend are relevant, and considering the 
arguments of each side as to why those issues are, or are not, relevant to the resolution of the dispute. 
If we file the motion you suggest, the victims will oppose it and argue the facts alleged in their motion to 
enforce are indeed relevant, and should be considered. We will argue the victims' factual issues are not 
material and/or relevant, and the court should only consider that no federal charges were ever filed against 
Epstein. This is what is going to happen when the government responds to the victims' motion to enforce. 
We have a number of arguments that victims are not entitled to full-blown discovery, as a party would be 
entitled to in a true civil action. It's more than a little ironic that Cassell told us he had done these cases all 
over the country, and he had never had to file a complaint. Now he claims the Federal Rules of Civil 
Procedure, to say nothing of Brady and Giglio, also apply. 
From: 
Sent: Sunda 
To: 
Cc: 
(USAFLS) 
March 20, 2011 2:40 PM 
USAFLS 
(USAFLS); 
(USAFLS) 
Subject: Planned response to tomorrow's filing by Cassell 
EFTA00206351

Hi 
What would you think about this plan for a response to tomorrow's filing by Cassell? Rather than 
wait our two weeks to file a response to his onslaught, we simply file something tomorrow (after Cassell's is 
filed) or Tuesday that is entitled: Request for Ruling on Emergency Petition. We can state that the petition was 
fully-briefed back in 2008 and that, as you stated in DEI7, the only relevant fact is that Epstein entered a guilty 
plea in state court. Their motion for summary judgment is an attempt to enlarge their "emergency petition" into 
a full fledged cause of action and 18 USC 3771(d)(6) specifically states that there is no separate cause of action 
for a violation, so they cannot file a Complaint. They also cannot reopen a plea or sentence under 3771(dX5). 
You may have already seen this, but take a look at US v. Hunter, 548 F3d 1308 (10'h Cir 2008), where Cassell 
tried to override the limitation on victims' rights to appeal sentences. Cassell represented the victims, and the 
10th Circuit has a good discussion on how victims cannot override prosecutorial discretion, quoting from 18 USC 
377I(d)(6). 
Cassell has, however, been successful in the 11th, in In re Stewart, 552 F.3d 1285 (11th Cir. 2008), where Cassell 
filed a writ of mandamus to have the Middle District of Florida recognize home purchasers as victims in a guilty 
plea to an Information by a bank executive. The executive was pleading guilty to money laundering where the 
underlying criminal activity involved charging fraudulent loan origination fees to the victims. 
With regard to the issue of discovery, I think that the language in 18 USC 3771(d)(6) that there cannot be a 
separate cause of action is helpful. That means that this is not truly a civil case — it should have been filed 
annexed to a civil case, where civil discovery rules would not apply. Since there is not criminal case, the Clerk's 
Office filed it with a civil case number, but the Court has the discretion to decide that discovery is not 
appropriate. See Alphin v. United States, 809 F.2d 236 (4th Cir.), cert. denied 480 U.S. 935 (1987) (district court 
may suspend or limit application of civil rules in summary proceedings). 
Assistant U.S. Attorney 
From: 
(USAFLS) < 
Sent: 
Thursday, March 17, 2011 10:11 PM 
To: 
(USAFLS); 
(USAFLS); 
(USAFLS); 
(USAFLS); 
(USAFLS) 
Subject: 
Re: Call from Newsweek 
I should be available. El 
--- Original Message  
From: I 
 
 . (USAFLS) 
Sent: Thursda March 17, 2011 08:20 PM 
To: 
. USAFLS); 
(USAFLS); 
(USAFLS); 
(USAFLS) 
(USAFLS); 
Subject: Fw: Call from Newsweek 
Sorry. Let me try this again. 
Can 
and I have some of your time tomorrow? Preferably in the morning. I think we need to address this. 
--- Original Message ----
From: 
 
 
. (USAFLS) 
Sent: Thursday, March 17, 2011 07:54 PM 
EFTA00206352