Latest / The Vault: The Epstein Files / Mega Edition: Brad Edwards And The Affidavit (Part 5-7) (10/16/26)

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Mega Edition: Brad Edwards And The Affidavit (Part 5-7) (10/16/26) · The Vault: The Epstein Files

• 0:00
  Speaker 1: What's up everyone and welcome to another episode of the
• 0:02
  Speaker 1: Epstein Chronicles. In this episode we're picking up where we
• 0:06
  Speaker 1: left off with Brad Edwards and the CVRA affidavit. The
• 0:11
  Speaker 1: government's fiduciary duty to crime victims bars any privilege. I'm
• 0:16
  Speaker 1: familiar with the case law recited in our pleading regarding
• 0:19
  Speaker 1: a fiduciary exception, also known as the Garner exception, in
• 0:23
  Speaker 1: some filings to privileges. In this case, the government had
• 0:27
  Speaker 1: a fiduciary obligation to protect the CVRA rights of Jane
• 0:30
  Speaker 1: Doe No. 1 and Jane Doe No. 2. Specifically because
• 0:34
  Speaker 1: they were recognized as victims under the CVRA, the government
• 0:38
  Speaker 1: had obligations to provide them rights under the CVRA, including
• 0:42
  Speaker 1: the right to confer, the right to notice, and the
• 0:44
  Speaker 1: right to be treated with fairness. Because of this fiduciary duty,
• 0:49
  Speaker 1: an exception applies to many of the government privilege claims
• 0:52
  Speaker 1: regarding interactions with the victims. The fiduciary duty of the
• 0:56
  Speaker 1: government to the victims in this case is clear. In 2007,
• 0:59
  Speaker 1: the FBI determined that both Jane Doe 1 and Jane
• 1:03
  Speaker 1: Doe 2 were victims of sexual assault by Epstein while
• 1:07
  Speaker 1: they were minors, beginning when they were approximately 14 years
• 1:10
  Speaker 1: of age and approximately 13 years of age, respectively. These
• 1:15
  Speaker 1: sexual assaults involve use of means of interstate commerce, i.e.
• 1:19
  Speaker 1: telephone and travel in interstate commerce. Both Jane Does were
• 1:23
  Speaker 1: initially identified through Palm Beach Police Department's investigation of Epstein.
• 1:28
  Speaker 1: Confirming the fact that the government had identified Jane Doe
• 1:32
  Speaker 1: 1 as a victim in its case on about June 7, 2007,
• 1:36
  Speaker 1: FBI agents had delivered to Jane Doe No. 1 a
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  Speaker 1: standard CVRA victim notification letter. The notification promises that the
• 1:45
  Speaker 1: Justice Department would make its best effort to protect Jane
• 1:48
  Speaker 1: Doe 1 and her rights, including the reasonable right to
• 1:52
  Speaker 1: confer with the attorney for the United States in the
• 1:54
  Speaker 1: case and to be reasonably heard at any public proceeding
• 1:58
  Speaker 1: in the district court involving a plea. The notification further
• 2:02
  Speaker 1: explained that at this time your case is under investigation. Similarly,
• 2:07
  Speaker 1: on or about August 11, 2007, FBI agents hand-delivered to
• 2:11
  Speaker 1: Jane Doe No. 2 a standard CVRA victim notification letter.
• 2:17
  Speaker 1: The notification promises that Justice Department would make its best
• 2:21
  Speaker 1: efforts to protect Jane Doe No. 2's rights, including the
• 2:24
  Speaker 1: right to confer with the Attorney of the U.S. and
• 2:26
  Speaker 1: to be reasonably heard at public proceedings. Early in the investigation,
• 2:31
  Speaker 1: the FBI agents and the Assistant U.S. Attorney had several
• 2:34
  Speaker 1: meetings with Jane Doe No. 1, and Jane Doe No.
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  Speaker 1: 2 was represented by counsel that was paid for by Epstein.
• 2:40
  Speaker 1: accordingly all contact or contract that was made through that attorney.
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  Speaker 1: These meetings occurred because the FBI had obligations to protect
• 2:48
  Speaker 1: victims' rights under the CVRA. In October of 2007, shortly
• 2:53
  Speaker 1: after the initial non-prosecution agreement was signed between Epstein and
• 2:57
  Speaker 1: the U.S. Attorney's Office for the Southern District of Florida,
• 3:01
  Speaker 1: Jane Doe No. 1 was contacted to be advised regarding
• 3:04
  Speaker 1: the investigation. On October 26, 2007, Special Agents E. Nesbitt
• 3:10
  Speaker 1: Kirkendall and Jason Richards met in person with Jane Doe No.
• 3:14
  Speaker 1: 1 because she was recognized as the victim of Epstein's crimes.
• 3:17
  Speaker 1: In all of the dealings between the government and the victims,
• 3:21
  Speaker 1: as well as other dealings of a similar nature, the
• 3:23
  Speaker 1: government had a fiduciary obligation to protect the interests of
• 3:27
  Speaker 1: the victims under the Crime Victims' Rights Act. Accordingly, the
• 3:31
  Speaker 1: government is precluded from raising any privilege claim to which
• 3:34
  Speaker 1: a fiduciary exception applies or, at the very least, any
• 3:38
  Speaker 1: privilege assertion would be outweighed by the victim's compelling need
• 3:42
  Speaker 1: for the material. An illustration of a situation where the
• 3:45
  Speaker 1: fiduciary duty exception applies is found on page 1 of
• 3:49
  Speaker 1: the Supplemental Privilege Log. With regard to Supplemental Box No. 3,
• 3:54
  Speaker 1: the entry here reads, In responding to Defense Attorney Goldberger's
• 3:57
  Speaker 1: letter about victim notification, the U.S. Attorney's Office had a
• 3:59
  Speaker 1: statutory duty under the CVRA to protect.
• 4:02
  Speaker 2: The victim's interests. Accordingly, the office.
• 4:19
  Speaker 1: Cannot assert privilege when questions about whether it fulfilled its
• 4:22
  Speaker 1: obligations to the victims have arisen in this case, or
• 4:26
  Speaker 1: at the very least, any privilege assertion would be outweighed
• 4:29
  Speaker 1: by the victim's compelling need for the material. Another illustration
• 4:34
  Speaker 1: of a situation where the fiduciary duty exception applies is
• 4:37
  Speaker 1: found on page 16 of the first privilege log with
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  Speaker 1: regard to box 2. The entry reads file folder entitled
• 4:46
  Speaker 1: RSRCH crime victims rights containing attorney research, handwritten notes, draft
• 4:52
  Speaker 1: victim notification letter, and draft correspondence to Jay Lefkowitz. Here again,
• 4:57
  Speaker 1: the material at issue go to the heart of the case.
• 5:00
  Speaker 1: What kind of notification were made to the victims and
• 5:03
  Speaker 1: how did the defense attorney shape and limit those notifications? Moreover,
• 5:07
  Speaker 1: in evaluating victims rights issues and determining what kind of
• 5:11
  Speaker 1: letter to send, The government was fulfilling legal duties that
• 5:14
  Speaker 1: it owed to the victims. Accordingly, the office cannot now
• 5:18
  Speaker 1: assert privilege when questions about whether it fulfilled its obligations
• 5:21
  Speaker 1: to the victims have arisen in the case. Communications facilitating crime, fraud,
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  Speaker 1: misconduct not covered. I'm familiar with the cases cited in
• 5:31
  Speaker 1: our brief regarding an exception to various privileges when the
• 5:35
  Speaker 1: communications concern crime, fraud, or government misconduct. Many of the
• 5:40
  Speaker 1: important documents about the treatment of the victims to which
• 5:42
  Speaker 1: the government is asserting privilege would fall within that exception.
• 5:47
  Speaker 1: With regard to fraud, the government misconduct a number of
• 5:49
  Speaker 1: the documents in the government's privilege log concern concealment from
• 5:53
  Speaker 1: the victims of the existence of the non-prosecution agreement between
• 5:57
  Speaker 1: the government and Epstein. I have reviewed a copy of
• 6:00
  Speaker 1: the non-prosecution agreement signed on about September 24, 2007, by
• 6:06
  Speaker 1: Epstein and his attorneys and a representative of the U.S.
• 6:09
  Speaker 1: Attorney's Office. The text of that agreement bars disclosure of
• 6:13
  Speaker 1: the agreement to the victims. On about January 10, 2008,
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  Speaker 1: my clients Jane Doe No. 1 and Jane Doe No.
• 6:20
  Speaker 1: 2 received letters from the FBI advising them that this
• 6:23
  Speaker 1: case is currently under investigation. This can be a lengthy
• 6:27
  Speaker 1: process and we request your continued patience while we conduct
• 6:31
  Speaker 1: a thorough investigation. The statement states, in the notification letter
• 6:35
  Speaker 1: was deceptive because it did not reveal that the case
• 6:38
  Speaker 1: had previously been resolved by the non-prosecution agreement entered into
• 6:42
  Speaker 1: by Epstein and the US Attorney's Office discussed previously. Moreover,
• 6:47
  Speaker 1: The FBI did not notify Jane Doe No. 1 or
• 6:50
  Speaker 1: Jane Doe No. 2 that a plea agreement had been
• 6:53
  Speaker 1: reached previously and that part of the agreement was a
• 6:56
  Speaker 1: non-prosecution agreement with the U.S. Attorney's Office for the Southern
• 6:59
  Speaker 1: District of Florida and that the non-prosecution agreement would resolve
• 7:03
  Speaker 1: the federal case completely. Whether the FBI itself had been
• 7:08
  Speaker 1: properly informed of the non-prosecution agreement is also unclear. were
• 7:12
  Speaker 1: not alleging misconduct by the FBI, but rather that the
• 7:15
  Speaker 1: FBI was not properly informed about the case or in
• 7:18
  Speaker 1: any event was acting at the direction of the U.S.
• 7:21
  Speaker 1: Attorney's Office. In about April of 2008, Jane Doe No.
• 7:25
  Speaker 1: 1 contacted the FBI because Epstein's counsel was attempting to
• 7:29
  Speaker 1: take her deposition and private investigators were harassing her. Assistant U.S.
• 7:33
  Speaker 1: Attorney Marie Villafana secured pro bono counsel to represent Jane
• 7:38
  Speaker 1: Doe No. 1 and several other identified victims in connection
• 7:43
  Speaker 1: with the criminal investigation. Pro Bono Counsel was able to
• 7:47
  Speaker 1: assist Jane Doe No. 1 in avoiding the improper deposition.
• 7:51
  Speaker 1: AUSA Villafana secured Pro Bono Counsel by contacting Meg Garvin
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  Speaker 1: of the National Crime Victims Law Center in Portland, Oregon,
• 8:00
  Speaker 1: which is based in the Lewis and Clark College of Law.
• 8:03
  Speaker 1: During the call, Ms. Garvin was not advised that a
• 8:06
  Speaker 1: non-prosecution agreement had been reached in the matter, On May 30, 2008,
• 8:11
  Speaker 1: another of my clients, who was recognized as an Epstein
• 8:15
  Speaker 1: victim by the U.S. Attorney's Office, received letters from the
• 8:18
  Speaker 1: FBI advising her that her case is currently under investigation.
• 8:23
  Speaker 1: This can be a lengthy process, and we request your
• 8:25
  Speaker 1: continued patience while we conduct a thorough investigation. The statement
• 8:30
  Speaker 1: in the notification letter was deceptive because it did not
• 8:33
  Speaker 1: reveal that the case had been resolved by the non-prosecution
• 8:37
  Speaker 1: agreement entered into by Epstein and the U.S. Attorney's Office
• 8:40
  Speaker 1: in September of 2007. In mid-June 2008, I contacted AUSA
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  Speaker 1: Villafana to inform her that I represented Jane Doe No.
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  Speaker 1: 1 and later Jane Doe No. 2. I asked to
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  Speaker 1: meet to provide information about the federal crimes committed by Epstein,
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  Speaker 1: hoping to secure a significant federal indictment against Epstein. AUSA
• 9:02
  Speaker 1: Villafana and I discussed the possibility of federal charges being filed.
• 9:06
  Speaker 1: At the end of the call, AUSA Villafana asked me
• 9:09
  Speaker 1: to send any information that I wanted considered by the U.S.
• 9:13
  Speaker 1: Attorney's Office in determining whether to file federal charges. I
• 9:17
  Speaker 1: was not informed that previously, in September of 2007, the U.S.
• 9:21
  Speaker 1: Attorney's Office had reached an agreement not to file federal charges.
• 9:25
  Speaker 1: I was also not informed that any resolution of the
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  Speaker 1: criminal matter was eminent at the time. Presumably the reason
• 9:32
  Speaker 1: the U.S. Attorney's Office withheld this information from me was
• 9:35
  Speaker 1: because of the confidentiality provision that existed in the non-prosecution agreement.
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  Speaker 1: At this point, it's clear that AUSA Villafana was restricted
• 9:45
  Speaker 1: in what she was being permitted to tell me. On
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  Speaker 1: July 3rd, 2008, I sent to AUSA Villafana a letter.
• 9:51
  Speaker 1: In the letter, I indicated my client's desire that federal
• 9:54
  Speaker 1: charges be filed against defendant Epstein. In particular, I wrote
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  Speaker 1: on behalf of my client's we urge the Attorney General
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  Speaker 1: and our United States Attorney to consider the fundamental import
• 10:05
  Speaker 1: of the vigorous enforcement of our federal laws. We urge
• 10:09
  Speaker 1: you to move forward with the traditional indictments and criminal
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  Speaker 1: prosecution commensurate with the crimes Mr. Epstein has committed. and
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  Speaker 1: we further urge you to take the steps necessary to
• 10:19
  Speaker 1: protect our children from this very dangerous sexual predator. When
• 10:23
  Speaker 1: I wrote this letter, I was still unaware that a
• 10:25
  Speaker 1: non-prosecution agreement had been reached with Epstein. In fact, that
• 10:29
  Speaker 1: continued to be concealed from me and the victims by
• 10:32
  Speaker 1: the U.S. Attorney's Office. I only learned of this fact
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  Speaker 1: later on. As alleged in the preceding paragraphs and elsewhere
• 10:39
  Speaker 1: in the affidavit, and in this case, deliberate concealment from
• 10:43
  Speaker 1: crime victims, and their legal counsel of the existence of
• 10:47
  Speaker 1: the non-prosecution agreement would be fraud and government misconduct. Documents
• 10:51
  Speaker 1: related to that fraud and misconduct would then fall outside
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  Speaker 1: of many of the privileges being asserted. An illustration of
• 10:58
  Speaker 1: a document to which the crime fraud misconduct exception applies
• 11:02
  Speaker 1: on this basis is found on page 3 of the
• 11:04
  Speaker 1: Supplemental Privilege Log. The entry reads, File Folder Entitled 12507
• 11:10
  Speaker 1: Stardew Acosta containing drafts of 1130-07 letters from Acosta to
• 11:16
  Speaker 1: Ken Starr and from Jay Sloman to Jay Lefkowitz, performance
• 11:20
  Speaker 1: and victim notification, with handwritten notes and edits by Marie Villafana. Again,
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  Speaker 1: these materials are central to the dispute in the case,
• 11:29
  Speaker 1: as they involve discussions between the U.S. Attorney's Office and
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  Speaker 1: defense attorneys about notification to crime victims. And given the
• 11:36
  Speaker 1: dates and communications, in all likelihood, they would be related
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  Speaker 1: to the deceptive notification that the government made to the
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  Speaker 1: victims a few weeks later. All right, folks, we're going
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  Speaker 1: to wrap up right here. And in the next episode,
• 11:48
  Speaker 1: we're going to pick up where we left off. All
• 11:51
  Speaker 1: of the information that goes with this episode can be
• 11:53
  Speaker 1: found in the description box. What's up, everyone? And welcome
• 11:57
  Speaker 1: to another episode of the Epstein Chronicles. In this episode,
• 12:00
  Speaker 1: we're going to pick up where we left off with
• 12:03
  Speaker 1: the Brad Edwards CVRA affidavit. Another illustration of where the
• 12:08
  Speaker 1: crime fraud misconduct exception could potentially apply is with regard
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  Speaker 1: to information that the government possesses that Matthew Menchel has
• 12:16
  Speaker 1: a personal or business relationship with defendant Jeffrey Epstein. This
• 12:20
  Speaker 1: could potentially show misconduct by Menchel and it also potentially
• 12:24
  Speaker 1: a motive to violate the victim's rights as explained previously.
• 12:28
  Speaker 1: The government's privilege log has numerous entries showing that Menchel
• 12:32
  Speaker 1: was substantially and personally involved in making decisions related to
• 12:36
  Speaker 1: the Epstein prosecution. Of the first privilege log with regard
• 12:40
  Speaker 1: to box number 3P-011-923 to P-011-966, the victims have information
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  Speaker 1: suggesting that immediately after leaving the employment with the U.S.
• 12:52
  Speaker 1: Attorney's Office, Menschel was associated with Epstein-controlled entities or had
• 12:57
  Speaker 1: some business relationship with them. The documents that the government possess,
• 13:01
  Speaker 1: showing a personal or business relationship between one of its
• 13:05
  Speaker 1: prosecutors and the man he was charged with prosecuting, should
• 13:08
  Speaker 1: be produced. The government has admitted that its internal affairs component,
• 13:13
  Speaker 1: the Office of Professional Responsibility, has collected information about possible
• 13:17
  Speaker 1: improper behavior during the investigation of the Epstein matter. Government
• 13:22
  Speaker 1: Answers to RFA-22 The fact that the government's own investigating
• 13:27
  Speaker 1: agencies have collected such information demonstrates that there is a
• 13:31
  Speaker 1: prima facie case of improper behavior which is enough to
• 13:35
  Speaker 1: trigger the crime fraud misconduct exception to various privileges. Factual
• 13:40
  Speaker 1: Materials Not Privileged As noted in the accompanying legal memorandum,
• 13:45
  Speaker 1: factual materials are generally not covered by the privileges at
• 13:48
  Speaker 1: issue in the case. Many of the material to which
• 13:51
  Speaker 1: the government is asserting privilege are factual materials. Assertion of
• 13:56
  Speaker 1: the Attorney-Client Privilege The government has asserted attorney-client privilege regarding
• 14:00
  Speaker 1: many documents, yet with regard to most of these assertions,
• 14:04
  Speaker 1: it's impossible to determine who is the attorney, who is
• 14:07
  Speaker 1: the client, whether professional legal services are being rendered, and
• 14:11
  Speaker 1: whether the communications were confidential to those involved in the
• 14:15
  Speaker 1: delivery of legal services. Accordingly, it's very difficult for me
• 14:19
  Speaker 1: to respond to many of the assertions of attorney-client privilege
• 14:23
  Speaker 1: and in any event the government has failed to carry
• 14:25
  Speaker 1: its burden of showing that privilege applies. An illustration of
• 14:30
  Speaker 1: documents at which attorney-client privilege appears to have been improperly
• 14:35
  Speaker 1: asserted or inadequately described is found on page 7 of
• 14:39
  Speaker 1: the first privilege log with regard to supplemental box number 3.
• 14:43
  Speaker 1: The entry for these 22 pages of documents reads, File
• 14:46
  Speaker 1: Folder Entitled Information Packet Drafts Containing Several Descriptions to see
• 14:52
  Speaker 1: how the attorney-client privilege applies to these documents. I could
• 14:57
  Speaker 1: provide many other illustrations of the problem. The government's attorney-client
• 15:00
  Speaker 1: privilege claim directly covers situations where it was in a
• 15:04
  Speaker 1: fiduciary relationship with the victims and therefore is limited in
• 15:08
  Speaker 1: now asserting privilege. For example, page 3 of the Supplemental
• 15:12
  Speaker 1: Privilege Log contains an entry concerning a costa containing drafts
• 15:18
  Speaker 1: of $ 1, 137 Letters from Acosta to Ken Starr and from
• 15:23
  Speaker 1: Jay Sloman to Jay Lefkowitz, performance and victim notification with
• 15:27
  Speaker 1: handwritten notes and edits by Marie Villafana. This information goes
• 15:32
  Speaker 1: very directly to the issue involved in the case as
• 15:35
  Speaker 1: it goes directly to victim notification. Yet the government has
• 15:38
  Speaker 1: asserted an attorney-client privilege to prevent the victims from learning
• 15:42
  Speaker 1: what's in these documents. The fiduciary exception to the attorney-client
• 15:46
  Speaker 1: privilege applies in this situation and and limits the government's
• 15:50
  Speaker 1: ability to invoke a privilege.
• 15:52
  Speaker 2: This also appears to be.
• 15:53
  Speaker 1: Shared communication between the government and Epstein's attorneys, and it's
• 15:57
  Speaker 1: unclear how the attorney-client privilege could ethically apply to such documents.
• 16:03
  Speaker 1: As one example of why the victims have established a
• 16:05
  Speaker 1: compelling need for material described in the preceding paragraph is
• 16:09
  Speaker 1: the fact that the court has indicated that it will
• 16:12
  Speaker 1: be considering an estoppel argument raised by the government as
• 16:16
  Speaker 1: a defense in the case. The court has noted that
• 16:19
  Speaker 1: this argument implicates a fact-sensitive, equitable defense, which must be
• 16:23
  Speaker 1: considered in the historical factual context of the entire interface
• 16:27
  Speaker 1: between Epstein, the relevant prosecutorial authorities, and the federal offense victims,
• 16:33
  Speaker 1: including an assessment of the allegation of a deliberate conspiracy
• 16:37
  Speaker 1: between Epstein and federal prosecutors to keep the victims in
• 16:40
  Speaker 1: the dark on the pendency of negotiation between Epstein and
• 16:44
  Speaker 1: federal authorities until well after the fact is and presentation
• 16:48
  Speaker 1: of the non-prosecution agreement to them was completed. The materials
• 16:54
  Speaker 1: to which the government is asserting attorney-client privilege go directly
• 16:57
  Speaker 1: to that interface between the victims, the government, and Epstein.
• 17:01
  Speaker 1: The victims have a compelling need for the information and
• 17:04
  Speaker 1: the fiduciary exception to the attorney-client privilege applies to permit
• 17:08
  Speaker 1: the court to provide these documents to the victims. The
• 17:11
  Speaker 1: government has not explained any harm that would come from
• 17:14
  Speaker 1: releasing the documents covered by attorney-client privilege to the victims.
• 17:18
  Speaker 1: If the government raises any such harm, I respectfully request
• 17:21
  Speaker 1: an opportunity to provide additional information on that alleged harm.
• 17:26
  Speaker 1: Deliberative Process Privilege Some of the correspondence that is being
• 17:30
  Speaker 1: withheld by the government under the deliberative process privilege concerns
• 17:34
  Speaker 1: an investigation that the Justice Department's Office of Professional Responsibility
• 17:38
  Speaker 1: opened with regard to the Epstein case. This investigation was
• 17:42
  Speaker 1: undertaken at the request of the victims in the case.
• 17:45
  Speaker 1: On December 10, 2010, Co-Counsel Professor Paul Cassell of the
• 17:50
  Speaker 1: University of Utah College of Law and I met with U.S.
• 17:53
  Speaker 1: Attorney for the Southern District of Florida regarding this case
• 17:56
  Speaker 1: in the U.S. Attorney's Office in Miami, Florida. On that date,
• 18:01
  Speaker 1: Professor Cassell presented a letter to the U.S.
• 18:04
  Speaker 2: Attorney, Mr.
• 18:04
  Speaker 1: Ferrer, asking him to personally investigate what happened during the
• 18:08
  Speaker 1: Epstein prosecution and how the victims were treated during that investigation.
• 18:13
  Speaker 1: Based on the privilege log that has been provided, as
• 18:16
  Speaker 1: well as subsequent correspondence sent to Professor Cassell, that request
• 18:20
  Speaker 1: for investigation was turned over to OPR in Washington. The
• 18:24
  Speaker 1: ultimate outcome of the OPR investigation is unclear. What is
• 18:27
  Speaker 1: clear is that many documents are being withheld about that investigation,
• 18:32
  Speaker 1: documents that would go to the central issue in the case.
• 18:35
  Speaker 1: Approximately three whole pages of privilege log, pages 12 through 14,
• 18:40
  Speaker 1: of the supplemental log relate to the OPR investigation of
• 18:44
  Speaker 1: how the Epstein case was handled and how the victims
• 18:46
  Speaker 1: were treated. A deliberative process privilege can only be asserted
• 18:52
  Speaker 1: with regard to the process of reaching a decision, not
• 18:55
  Speaker 1: the ultimate decision itself. The government here has apparently asserted
• 18:59
  Speaker 1: a deliberative process claim over not only the OPR process,
• 19:03
  Speaker 1: but also over the OPR decision. It's not clear which
• 19:07
  Speaker 1: document embodies the final OPR decision, or given the inadequacies
• 19:11
  Speaker 1: of the government's log, whether that final decision has been produced.
• 19:16
  Speaker 1: Given the limited description of the document that have been provided,
• 19:19
  Speaker 1: it appears that the OPR decision may be reflected in
• 19:22
  Speaker 1: a document found on page 13 of the supplemental log.
• 19:27
  Speaker 1: The description there reads, draft letter marked confidential, to be
• 19:31
  Speaker 1: opened by Address C only, Robin C. Ashton to Wafredo
• 19:36
  Speaker 1: Farrar with a handwritten correction. No dates provided regarding the letter,
• 19:40
  Speaker 1: nor is there any indication as to whether the letter
• 19:43
  Speaker 1: was or was not circulated to other persons. It is
• 19:47
  Speaker 1: also noteworthy that this letter is described as a draft
• 19:49
  Speaker 1: letter Nowhere in the privilege log is the final version
• 19:52
  Speaker 1: of that letter indicated, raising questions about what was draft
• 19:56
  Speaker 1: and what was final. If this is the final embodiment
• 19:59
  Speaker 1: of the OPR's conclusions, then this letter would not be
• 20:02
  Speaker 1: protected by process of privilege because the deliberations would have
• 20:06
  Speaker 1: come to an end. It's also worth noting that because
• 20:09
  Speaker 1: OPR is an agency that investigates misconduct by federal prosecutors,
• 20:14
  Speaker 1: it would not be providing attorney-client advice to prosecutors and
• 20:18
  Speaker 1: its documents would not be attorney-client privileged with regard to,
• 20:22
  Speaker 1: for example, the U.S. Attorney's Office for the Southern District
• 20:25
  Speaker 1: of Florida. The fact that OPR has investigated many of
• 20:29
  Speaker 1: the exact claims raised by Jango I and II and
• 20:32
  Speaker 1: were able to gather documents unobstructed by the government in
• 20:35
  Speaker 1: order to reach its conclusion, likely means that production of
• 20:38
  Speaker 1: the OPR file to the victims, in this case, could
• 20:42
  Speaker 1: significantly shortcut this discovery process and the litigation. Additionally, if
• 20:47
  Speaker 1: OPR needed the documents to investigate and make findings regarding
• 20:51
  Speaker 1: the victims' claims, then logically the victims share that need
• 20:55
  Speaker 1: and have no other means through which to obtain the documents.
• 20:58
  Speaker 1: The government has not explained any harm that would come
• 21:01
  Speaker 1: from releasing the documents covered by the process of privilege
• 21:05
  Speaker 1: to the victims. If the government raises any such harm,
• 21:09
  Speaker 1: I respectfully request an opportunity to provide additional information on
• 21:13
  Speaker 1: that alleged harm. Investigative Privilege The investigative privilege is a
• 21:18
  Speaker 1: qualified privilege which balances the need of a particular litigant
• 21:22
  Speaker 1: for access to information against any public interest in nondisclosure.
• 21:26
  Speaker 1: That balancing process is ordinarily made with reference to factors
• 21:30
  Speaker 1: discussed and Frankhauser v.
• 21:32
  Speaker 2: Rizzo.
• 21:34
  Speaker 1: On the facts of this case, favor, way in favor
• 21:37
  Speaker 1: of disclosing the information the victims have requested with regard
• 21:41
  Speaker 1: to Factor 1, the extent to which disclosure will thwart
• 21:44
  Speaker 1: governmental process by discouraging citizens from giving the government information,
• 21:49
  Speaker 1: I presented four victims of Epstein sex offenses in federal court,
• 21:53
  Speaker 1: Jane Doe No. 1, Jane Doe No. 2, and a
• 21:56
  Speaker 1: victim I will refer to as S.R. and M.J., and
• 22:01
  Speaker 1: other victims of Jeffrey Epstein's abuse as well. If further
• 22:04
  Speaker 1: information is disclosed about the case, that will not discourage
• 22:08
  Speaker 1: them from providing information, but rather will encourage them. I
• 22:12
  Speaker 1: have also talked personally to attorneys for a number of
• 22:15
  Speaker 1: other victims in the case. I have been told that
• 22:17
  Speaker 1: many of these victims hope that Jane Doe 1 and
• 22:20
  Speaker 1: Jane Doe 2 are successful in their case. With regard
• 22:24
  Speaker 1: to factor number two, the impact upon persons who have
• 22:27
  Speaker 1: given information of having their identities disclosed Jangdo 1 and
• 22:31
  Speaker 1: Jangdo 2 are not asking for information that would identify
• 22:34
  Speaker 1: any particular victim. Accordingly, there will be no effect on
• 22:38
  Speaker 1: other victims. Additionally, I'm aware of the true names of
• 22:42
  Speaker 1: many of Epstein's victims, and that information has not been
• 22:45
  Speaker 1: disseminated to the public where those individual victims did not
• 22:48
  Speaker 1: wish for their identities to be disseminated. Alright, we're going
• 22:52
  Speaker 1: to wrap up this episode right here, and in the
• 22:54
  Speaker 1: next episode dealing with a topic we're going to pick
• 22:56
  Speaker 1: up where we left off. All of the information that
• 22:59
  Speaker 1: goes with this episode can be found in the description box.
• 23:03
  Speaker 1: What's up everyone and welcome to another episode of the
• 23:06
  Speaker 1: Epstein Chronicles. In this episode, we're going to pick up
• 23:09
  Speaker 1: where we left off with Brad Edwards and the CVRA affidavit.
• 23:14
  Speaker 1: With regard to Factor 3, the degree to which governmental
• 23:18
  Speaker 1: self-evaluation and consequent program improvement will be chilled by disclosure.
• 23:23
  Speaker 1: This is a lawsuit to force the compliance by the
• 23:25
  Speaker 1: government with its CVRA obligation. Accordingly, the government's program of
• 23:30
  Speaker 1: providing victims' rights will be directly improved if the victims
• 23:34
  Speaker 1: are able to enforce their rights in this lawsuit. With
• 23:37
  Speaker 1: regard to Factor 4, whether the information sought is factual
• 23:41
  Speaker 1: data or a summary, many of the items that the
• 23:43
  Speaker 1: victims seek are factual summaries. An example of this is
• 23:47
  Speaker 1: found at page 18 of the First Privilege Log. With
• 23:50
  Speaker 1: regard to box number 3, P011778 to P011788, The entry reads,
• 23:59
  Speaker 1: file folder entitled 61209, victim notification log, containing chart with
• 24:05
  Speaker 1: victim contact information and attorney notes regarding dates and types
• 24:09
  Speaker 1: of contacts. This would include, for example, dates of contacts
• 24:13
  Speaker 1: with Jane Doe number one and Jane Doe number two,
• 24:15
  Speaker 1: which would be purely factual information. With regard to factor five,
• 24:20
  Speaker 1: whether the party seeking the discovery is an actual or
• 24:23
  Speaker 1: potential defendant in any criminal proceeding, either pending or reasonably
• 24:27
  Speaker 1: likely to follow from the incident in the question. Jane
• 24:31
  Speaker 1: Doe 1 and Jane Doe 2 are plainly victims of
• 24:33
  Speaker 1: a crime, not criminal defendants, indeed as the court is aware.
• 24:37
  Speaker 1: It's the criminal defendant, Jeffrey Epstein, who has undertaken several
• 24:41
  Speaker 1: limited intervention efforts to try and block disclosure of information
• 24:45
  Speaker 1: to the victims. With regard to the factor 6, whether
• 24:49
  Speaker 1: the police investigation has been completed, the investigation at Epstein
• 24:53
  Speaker 1: was completed years ago, and the government has not produced
• 24:56
  Speaker 1: in its privilege log any information indicating recent investigative activity.
• 25:02
  Speaker 1: With regard to Factor VII, whether any inter-department disciplinary proceedings
• 25:07
  Speaker 1: have arisen or may arise from the investigation, it appears
• 25:10
  Speaker 1: that OPR investigation has arisen as a direct result of
• 25:14
  Speaker 1: the victim's efforts in the case. However, it does not
• 25:17
  Speaker 1: appear that release of any information to the victims would
• 25:20
  Speaker 1: hamper any disciplinary proceedings. Indeed, to the extent that the
• 25:25
  Speaker 1: victims are able to obtain information about the case and
• 25:28
  Speaker 1: find information about misconduct, they can provide the information to
• 25:32
  Speaker 1: the government and other disciplinary entities as appropriate. With regard
• 25:37
  Speaker 1: to Factor VIII, whether the plaintiff's suit is non-frivolous and
• 25:40
  Speaker 1: brought in good faith, it should be clear at this
• 25:43
  Speaker 1: juncture of a five-year-long case that the victims have substantial
• 25:47
  Speaker 1: claim that is brought in good faith. With regard to
• 25:50
  Speaker 1: Factor IX, Whether the information sought is available through other
• 25:54
  Speaker 1: discovery or from other sources, as recounted throughout this affidavit,
• 25:58
  Speaker 1: the victims have no other way to obtain the information
• 26:01
  Speaker 1: at issue in this privileged debate, as it involves information
• 26:05
  Speaker 1: internal to the Justice Department. With regard to Factor 10,
• 26:09
  Speaker 1: the importance of information sought to the plaintiff's case, The
• 26:13
  Speaker 1: information that the victims are seeking is highly important to
• 26:16
  Speaker 1: their case. Indeed, without adequate proof, the court has indicated
• 26:20
  Speaker 1: that it may have to deny the victim's petition. Throughout
• 26:23
  Speaker 1: this affidavit, I have provided numerous examples and explanations of
• 26:27
  Speaker 1: why the victims need the information that they're requesting. The
• 26:31
  Speaker 1: documents to which the government is asserting investigative privilege, for example,
• 26:36
  Speaker 1: bear directly on the government's alleged estoppel defense, which victims
• 26:40
  Speaker 1: need to complete evidentiary record to dispute. Work Product Doctrine
• 26:45
  Speaker 1: A work product claim can be defeated by showing of
• 26:48
  Speaker 1: substantial need and undue hardship to obtain the material in
• 26:51
  Speaker 1: other ways. In this affidavit, I have tried to articulate
• 26:55
  Speaker 1: the specific and compelling need for all the materials that
• 26:58
  Speaker 1: victims are seeking. I will not repeat all of those
• 27:01
  Speaker 1: assertions here, but simply note that I stand ready to
• 27:04
  Speaker 1: provide any additional information that the court may require to
• 27:07
  Speaker 1: determine the compelling need that the victims have for the
• 27:11
  Speaker 1: materials they have requested. as well as the undue hardship,
• 27:14
  Speaker 1: if not actual impossibility, of obtaining the materials in other ways.
• 27:19
  Speaker 1: Any balancing of considerations tips decisively in the victim's favor.
• 27:24
  Speaker 1: As one example, the victims have a compelling need for
• 27:27
  Speaker 1: the materials that OPR collected as part of its investigation.
• 27:32
  Speaker 1: Because Justice Department attorneys are generally required to talk to
• 27:35
  Speaker 1: OPR investigators, OPR was apparently able to investigate the claim
• 27:40
  Speaker 1: of misconduct related to the Epstein case, by getting statements
• 27:43
  Speaker 1: from the attorneys involved. These interviews appear to be recorded
• 27:47
  Speaker 1: in materials found at page 14 of the Supplemental Privilege Log,
• 27:52
  Speaker 1: DE 216-1, with regard to Supplemental Box No. 3, P-013956,
• 27:59
  Speaker 1: to P-013846. A total of 14 pages. Judging from the entry,
• 28:07
  Speaker 1: these notes would be factual statements from Justice Department Prosecutors,
• 28:11
  Speaker 1: about how the Epstein case was handled and whether any
• 28:14
  Speaker 1: misconduct occurred during the handling of the case. Those are
• 28:18
  Speaker 1: central issues in the case. There's no other way for
• 28:21
  Speaker 1: the victims to obtain information about these subjects because the
• 28:24
  Speaker 1: Justice Department has declined to provide information on the subject.
• 28:30
  Speaker 1: The victims have established a substantial need for the material
• 28:33
  Speaker 1: they were requesting in the previous paragraphs of this affidavit
• 28:36
  Speaker 1: that review request by request their document production, request numbers
• 28:41
  Speaker 1: 1 through 25, and supplemental request number 1. As another
• 28:45
  Speaker 1: example of why the victims have established a compelling need
• 28:49
  Speaker 1: for the materials is the fact that the court has
• 28:51
  Speaker 1: indicated that it will be considering an estoppel argument raised
• 28:55
  Speaker 1: by the government as a defense in the case. The
• 28:58
  Speaker 1: court has noted that this argument implicates a fact-sensitive, equitable defense,
• 29:03
  Speaker 1: which must be considered in the historical, factual context of
• 29:06
  Speaker 1: the entire interface between Epstein, the relevant prosecutorial authorities, and
• 29:11
  Speaker 1: the federal offense victims. including an assessment of the allegation
• 29:16
  Speaker 1: of a deliberate conspiracy between Epstein and federal prosecutors to
• 29:20
  Speaker 1: keep the victims in the dark on the pendency of
• 29:23
  Speaker 1: negotiation between Epstein and federal authorities until after the fact
• 29:27
  Speaker 1: and presentation of the non-prosecution agreement. The materials to which
• 29:32
  Speaker 1: the government is asserting work product protection go directly to
• 29:36
  Speaker 1: that interface between the victims, the government, and Epstein. The
• 29:40
  Speaker 1: victims have no other way of showing what that interface is.
• 29:43
  Speaker 1: The government will not be harmed if the materials are
• 29:46
  Speaker 1: provided to the victims. Grand jury information. The victim's legal
• 29:50
  Speaker 1: pleading has explained why the government has not properly asserted
• 29:54
  Speaker 1: any grand jury secrecy to the documents at issue. In addition,
• 29:58
  Speaker 1: Many of the government's grand jury privilege assertions appear to
• 30:01
  Speaker 1: broadly cover both grand jury and non-grand jury information. Even
• 30:06
  Speaker 1: if the court allows the government to assert some form
• 30:08
  Speaker 1: of grand jury privilege, it should require the government to
• 30:11
  Speaker 1: sever grand jury material from non-grand jury material. An illustration
• 30:16
  Speaker 1: of this problem comes from page 12 of the first
• 30:19
  Speaker 1: privilege log with regard to box number 2, P-008616 to P-008686.
• 30:28
  Speaker 1: The entry reads file folder entitled FBI summary charts containing
• 30:32
  Speaker 1: chart prepared at direction of a USA containing victim names,
• 30:37
  Speaker 1: identifying information, summary of activity and other information relevant to
• 30:41
  Speaker 1: the indictment. This does not appear to be a document
• 30:45
  Speaker 1: that was ever presented to the grand jury or that
• 30:47
  Speaker 1: directly discloses grand jury proceeding. Moreover, to the extent that
• 30:52
  Speaker 1: it involves some kind of limited disclosure of grand jury proceedings,
• 30:56
  Speaker 1: that limited disclosure could be redacted and the other information
• 30:59
  Speaker 1: provided to the victims. It does not appear that any
• 31:02
  Speaker 1: of the alleged grand jury materials that the government is
• 31:05
  Speaker 1: asserting privilege involve ongoing grand jury issues. Moreover, it does
• 31:10
  Speaker 1: not appear that disclosing any of the materials would tip
• 31:13
  Speaker 1: off a potential target to a government investigation. Of course,
• 31:17
  Speaker 1: Jeffrey Epstein and his associates are well aware of the
• 31:20
  Speaker 1: government's investigation into their crimes against young girls for sexual purposes.
• 31:26
  Speaker 1: The government has not explained any harm that would come
• 31:29
  Speaker 1: from releasing the documents to the victims. If the government
• 31:32
  Speaker 1: raises any such harm, I respectfully request an opportunity to
• 31:35
  Speaker 1: provide additional information on that alleged harm. Privacy Rights of
• 31:40
  Speaker 1: Other Victims Jane Doe No. 1 and Jane Doe No.
• 31:44
  Speaker 1: 2 do not see confidential or identifying information about any
• 31:49
  Speaker 1: other victim. To clarify that fact, on July 31, 2013,
• 31:54
  Speaker 1: I sent a letter to the government stating in part,
• 31:56
  Speaker 1: that to avoid any interference with any privacy rights of
• 31:59
  Speaker 1: victims who are not parties to this litigation, Jane Doe No.
• 32:03
  Speaker 1: 1 and Jane Doe No. 2 are not seeking any
• 32:06
  Speaker 1: identifying information about other victims. In any of the documents
• 32:11
  Speaker 1: that Jane Doe No. 1 or Jane Doe No. 2
• 32:13
  Speaker 1: have requested from the government that they produce, the government
• 32:16
  Speaker 1: should not produce the names of other victims or other
• 32:19
  Speaker 1: identifying information, e.g. address or telephone number, but should instead
• 32:25
  Speaker 1: redact that information. I declare under penalty of perjury pursuant
• 32:29
  Speaker 1: to U.S. Code 28 Section 1746 that the foregoing is
• 32:35
  Speaker 1: true and correct to the best of my knowledge and belief.
• 32:39
  Speaker 1: Executed the 16th day of August 2013. And this document
• 32:44
  Speaker 1: was signed by Brad Edwards. All right, so that finishes
• 32:48
  Speaker 1: up the affidavit of Brad Edwards when it comes to
• 32:51
  Speaker 1: the CVRA. And now with this new dump, we have
• 32:54
  Speaker 1: a lot of court records to dive into. and the
• 32:56
  Speaker 1: Grand Jury material especially, because we've never seen that, right?
• 33:00
  Speaker 1: So I want to make sure that we get a
• 33:02
  Speaker 1: handle on that as well. So over the next couple
• 33:04
  Speaker 1: of days, we're going to be diving deep into that
• 33:07
  Speaker 1: Grand Jury material. And that way, everybody gets to see
• 33:10
  Speaker 1: for themselves what we've been saying for all these years.
• 33:13
  Speaker 1: That the fix was in, and this has been a
• 33:15
  Speaker 1: cover-up since the start. All of the information that goes
• 33:19
  Speaker 1: with this episode can be found in the description box.
• 33:22
  Speaker 1: What's up, everyone, and welcome to another episode... of the
• 33:25
  Speaker 1: Epstein Chronicles. During yesterday's press conference held by the survivors
• 33:30
  Speaker 1: of Jeffrey Epstein and Ghislaine Maxwell in Washington, D.C., we
• 33:35
  Speaker 1: heard from one of the lawyers who has been representing
• 33:38
  Speaker 1: a lot of these women for a very long time.
• 33:41
  Speaker 1: And that person is Brad Edwards. And he was talking
• 33:45
  Speaker 1: about how the American public is going to be appalled
• 33:49
  Speaker 1: when they actually see what's inside of these Epstein files.
• 33:53
  Speaker 1: And he's not just talking about the so-called powerful people
• 33:57
  Speaker 1: that are going to be caught up, but he's also
• 33:59
  Speaker 1: talking about how the system itself failed not only the
• 34:04
  Speaker 1: Epstein survivors, but all of us.
• 34:08
  Speaker 2: So today we have.
• 34:09
  Speaker 1: An article from Fox News, and we're going to talk
• 34:11
  Speaker 1: about that a little bit more. Headline, Epstein victims press
• 34:15
  Speaker 1: lawmakers to support Bill to release hidden files, say Americans
• 34:20
  Speaker 1: will be appalled. The author of this article is Greg Norman.
• 34:25
  Speaker 1: A lawyer representing victims of Jeffrey Epstein said Wednesday that
• 34:29
  Speaker 1: the American public is going to be appalled about documents
• 34:32
  Speaker 1: relating to the disgraced late financier that have not been
• 34:35
  Speaker 1: released by the federal government. The government has mistreated them
• 34:40
  Speaker 1: after Epstein mistreated them, Bradley Edwards said of the victims
• 34:44
  Speaker 1: in Washington, D.C. And we already know the court absolutely
• 34:48
  Speaker 1: hammered the government over the CVRA. But unfortunately, because of
• 34:53
  Speaker 1: Epstein's death, nothing was able to move forward. Edwards spoke
• 34:58
  Speaker 1: at a news conference that is part of an effort
• 35:00
  Speaker 1: by Representatives Ro Khanna of California and Thomas Massey of
• 35:04
  Speaker 1: Kentucky to pass through the House a procedural motion known
• 35:09
  Speaker 1: as a discharge petition, which could force a House vote
• 35:12
  Speaker 1: urging the Justice Department to release the Epstein files. The
• 35:16
  Speaker 1: fact that they have to be urged is crazy. Like,
• 35:19
  Speaker 1: you would think you'd just want to release them and
• 35:22
  Speaker 1: be done with it, right? This could have been, what,
• 35:25
  Speaker 1: a six-week story? Could have released the files back when
• 35:30
  Speaker 1: you said there was nothing left to investigate? And this
• 35:33
  Speaker 1: story would have already effectively been over, probably. But instead,
• 35:37
  Speaker 1: you continue to double down, you continue to call it
• 35:39
  Speaker 1: a hoax, and you continue to refuse to be transparent.
• 35:43
  Speaker 1: But everybody else is hostile? Everybody else has a problem?
• 35:48
  Speaker 1: I think the problem's with the people who refuse to
• 35:51
  Speaker 1: release the documents. We filed lawsuits against Jeffrey Epstein, against
• 35:57
  Speaker 1: his estate, and against two financial institutions, J.P. Morgan and
• 36:01
  Speaker 1: Deutsche Bank, that prove that they provided, knowingly provided, the
• 36:06
  Speaker 1: financial infrastructure for a sex trafficking operation. Unfortunately, all of
• 36:11
  Speaker 1: the documents and evidence that we worked so hard to gather,
• 36:14
  Speaker 1: hide behind protective orders, confidentiality agreements, and bank secrecy laws,
• 36:20
  Speaker 1: Edwards said.
• 36:21
  Speaker 2: Well, that's the whole rub, right?
• 36:23
  Speaker 1: If you want to get that settlement, you have to
• 36:26
  Speaker 1: sign these NDAs, you have to promise to be quiet,
• 36:29
  Speaker 1: you have to take your money and shut up. And
• 36:32
  Speaker 1: that's the way the system's set up. And trust me
• 36:34
  Speaker 1: when I tell you, it's not set up for you
• 36:37
  Speaker 1: or me. That's why the discharge petition is so important.
• 36:43
  Speaker 1: While we have seen the documents, you haven't, And when
• 36:45
  Speaker 1: you see the documents, you're going to be appalled. And
• 36:48
  Speaker 1: the American people deserve to see everything, he added. When
• 36:52
  Speaker 1: you sign this discharge petition, it should mean nothing is
• 36:55
  Speaker 1: off limits. The documents in possession of the CIA should
• 36:59
  Speaker 1: be made available. Those in the possession of the FBI
• 37:02
  Speaker 1: going back decades should be made available. The SEC financial
• 37:06
  Speaker 1: records should be made available. Edwards continued as he stood
• 37:11
  Speaker 1: alongside the victims. Everybody knows that evil flourishes in the darkness.
• 37:16
  Speaker 1: Corruption flourishes in secrecy. It is time right now to
• 37:19
  Speaker 1: make a difference for the women that are behind me
• 37:21
  Speaker 1: right now, Edwards added. And of course, that all starts
• 37:25
  Speaker 1: with transparency. Because if the American people aren't privy to
• 37:29
  Speaker 1: what's going on, how can we hold anybody accountable? And
• 37:33
  Speaker 1: that's what they fear the most, right? They don't want
• 37:35
  Speaker 1: to let go of the narrative. They don't want the
• 37:38
  Speaker 1: American people to know what truly happened here. You think
• 37:40
  Speaker 1: you have no faith in the institutions now. Wait until
• 37:44
  Speaker 1: you get a load of this. President Donald Trump on
• 37:48
  Speaker 1: Wednesday called the push to release the files relating to
• 37:51
  Speaker 1: Jeffrey Epstein a Democrat hoax because they're trying to get
• 37:55
  Speaker 1: people to talk about something that's totally irrelevant to the
• 37:58
  Speaker 1: success that we've had as a nation since I've been president.
• 38:02
  Speaker 1: It's always about me, me, me with this guy. It's
• 38:05
  Speaker 1: never about anybody else. I'm the greatest. I did this.
• 38:08
  Speaker 1: I did that. Well, you know what else you did?
• 38:11
  Speaker 1: You promised to be transparent, and here we are. And
• 38:14
  Speaker 1: you know what's crazy? Trump could have been a real hero.
• 38:18
  Speaker 1: He could have walked down to that press conference yesterday,
• 38:21
  Speaker 1: took the microphone, and told the world and told those survivors, look,
• 38:25
  Speaker 1: I'm with you. We're going to go through the process,
• 38:28
  Speaker 1: and we're going to get all of this stuff dumped
• 38:30
  Speaker 1: and brought out into the public. But no. Instead, we
• 38:33
  Speaker 1: get more ridiculous rhetoric and more doubling down on nonsense.
• 38:37
  Speaker 1: I understand that we were subpoenaed to give files, and
• 38:40
  Speaker 1: I understand that we've given thousands of pages of files,
• 38:43
  Speaker 1: and I know that no matter what you do, it's
• 38:46
  Speaker 1: going to keep going, Trump told reporters at the White House.
• 38:49
  Speaker 1: And really, I think it's enough because I think we
• 38:52
  Speaker 1: should talk about the greatness of our country and the
• 38:54
  Speaker 1: success that we're having. I think we're probably having, according
• 38:57
  Speaker 1: to what I read, even from two people in this room,
• 39:00
  Speaker 1: we're having the most successful eight months of any president ever.
• 39:04
  Speaker 1: And that's what I want to talk about. That's what
• 39:07
  Speaker 1: we should be talking about, not the Epstein hoax. Yo,
• 39:10
  Speaker 1: is there anybody out there that really believes this bullshit?
• 39:13
  Speaker 1: We're having the greatest eight months of any president ever.
• 39:16
  Speaker 1: I mean, maybe Cat Turd and the people that showed
• 39:18
  Speaker 1: up for the white binders. But anybody with a brain
• 39:21
  Speaker 1: in their head actually believe this nonsense? I don't know
• 39:24
  Speaker 1: about you, but this hasn't seemed like the greatest eight
• 39:27
  Speaker 1: months I've ever lived through. I thought we were getting
• 39:29
  Speaker 1: rid of the war in Ukraine. I thought that the
• 39:31
  Speaker 1: situation in Gaza was going to be rectified. I thought
• 39:34
  Speaker 1: that we were going to handle the problem with drug
• 39:36
  Speaker 1: addicts in America, and we were going to tackle addiction
• 39:39
  Speaker 1: as we make America healthy again. But instead, no, what
• 39:43
  Speaker 1: do we do? We double down on the war on drugs.
• 39:45
  Speaker 1: We talk about more interdiction policies. We don't have any
• 39:49
  Speaker 1: support for the people that really need it. You know,
• 39:51
  Speaker 1: the people actually addicted to drugs that are driving the epidemic.
• 39:55
  Speaker 1: But yeah, tell me more about this eight months. Epstein
• 40:00
  Speaker 1: died in prison six years ago while awaiting federal charges
• 40:03
  Speaker 1: related to sex trafficking.
• 40:05
  Speaker 2: This is not a hoax. This is real.
• 40:08
  Speaker 1: There are real survivors, Massey said earlier. There are real
• 40:11
  Speaker 1: victims to this criminal enterprise. And the perpetrators are being
• 40:14
  Speaker 1: protected because they're rich and powerful. and political donors to
• 40:18
  Speaker 1: the establishment here in Washington. So today we're standing with
• 40:21
  Speaker 1: the survivors, and we're giving them a voice. And kudos
• 40:26
  Speaker 1: to Mr. Massey. I mean, it takes a lot of
• 40:29
  Speaker 1: courage to do what he's doing, especially going against Donald Trump.
• 40:32
  Speaker 1: And the same goes for Marjorie Taylor Greene. That takes
• 40:36
  Speaker 1: a lot of courage, and I know a lot of
• 40:37
  Speaker 1: people don't like her, but I'll tell you what, in
• 40:39
  Speaker 1: this instance, she's leading by example, and her colleagues should
• 40:44
  Speaker 1: take note. because she's showing them the right way to
• 40:47
  Speaker 1: go here. Representative Marjorie Taylor Greene also said Wednesday that
• 40:54
  Speaker 1: the women behind me have never received justice. And do
• 40:58
  Speaker 1: you want to know why? It's because Jeffrey Epstein somehow
• 41:01
  Speaker 1: was able to walk among the most rich, powerful people,
• 41:04
  Speaker 1: not only in America, but foreign countries. Yesterday I heard
• 41:08
  Speaker 1: countries like Saudi Arabia, Russia, and even Israel, and other countries,
• 41:12
  Speaker 1: Greene said. The truth needs to come out, And the
• 41:16
  Speaker 1: government holds the truth that the cases that are sealed
• 41:19
  Speaker 1: hold the truth. Jeffrey Epstein's estate holds the truth. The FBI,
• 41:24
  Speaker 1: the DOJ, and the CIA holds the truth. And the
• 41:28
  Speaker 1: truth we are demanding. And what's so wrong about that?
• 41:32
  Speaker 1: Why is there so much pushback against that? How is
• 41:34
  Speaker 1: that a fucking hoax? The real hoax is all these
• 41:38
  Speaker 1: fake-ass MAGA influencers who said they care about children and
• 41:42
  Speaker 1: who said they care about what's going on with Epstein...
• 41:44
  Speaker 1: all of a sudden don't care anymore because their dear
• 41:47
  Speaker 1: leader told them not to?
• 41:49
  Speaker 2: I mean, for real?
• 41:50
  Speaker 1: How do you look at yourself in the mirror? How
• 41:53
  Speaker 1: do you wake up every day and pitch that bullshit
• 41:55
  Speaker 1: to your audience, to your listeners, to the people who
• 41:58
  Speaker 1: trust you, and do it with a straight face? Epstein
• 42:02
  Speaker 1: victim Jenna Lisa Jones said Wednesday that she was only
• 42:05
  Speaker 1: 14 years old when my friend brought me over to
• 42:07
  Speaker 1: Jeffrey Epstein's house in Palm Beach in 2003. I always
• 42:12
  Speaker 1: did my best in school. And I had such a
• 42:14
  Speaker 1: positive outlook on life, she said. Until that day that
• 42:17
  Speaker 1: I met Jeffrey, I have never been more scared in
• 42:19
  Speaker 1: my life than I was that first time that he
• 42:22
  Speaker 1: hurt me. I remember crying the entire way home, thinking
• 42:25
  Speaker 1: about how I couldn't ever tell anyone about what actually
• 42:28
  Speaker 1: happened in that house. It was really hard for me
• 42:31
  Speaker 1: to find my voice and to become strong enough to
• 42:34
  Speaker 1: speak about my abuse, she also said, thanking Massey and
• 42:37
  Speaker 1: Kana for hosting her. Together we can finally make a change.
• 42:41
  Speaker 1: And that is thanks to the people like these two
• 42:44
  Speaker 1: congressmen and their teams who actually care about the victims.
• 42:48
  Speaker 1: Jones also appealed to President Donald Trump directly. If you
• 42:52
  Speaker 1: are a member of Congress and you are listening to
• 42:54
  Speaker 1: all of us speak here today, please really listen to us.
• 42:57
  Speaker 1: Please vote for this bill to be passed, Jones said. Please,
• 43:00
  Speaker 1: President Trump, pass this bill and help us. Make us
• 43:03
  Speaker 1: feel like our voices are finally being heard. So what's
• 43:07
  Speaker 1: the big pushback? Why is there such an issue? And
• 43:10
  Speaker 1: why are people getting so mad that people are demanding transparency?
• 43:15
  Speaker 1: That's the real question, because there's no logical reason for it,
• 43:19
  Speaker 1: unless you're protecting someone. Or something. Another Epstein victim, Lisa Phillips,
• 43:24
  Speaker 1: said Wednesday that us Epstein survivors have been discussing creating
• 43:28
  Speaker 1: our own list. We know the names. Many of us
• 43:31
  Speaker 1: were abused by them. Now together as survivors, we will
• 43:34
  Speaker 1: confidentially compile the names we all know who were regularly
• 43:38
  Speaker 1: in the Epstein world. And it will be done by
• 43:40
  Speaker 1: survivors and for survivors. No one else is involved. Stay
• 43:44
  Speaker 1: tuned for more details. Another victim, Anouska DiGiorgio, said she
• 43:50
  Speaker 1: was abused by Jeffrey Epstein and Glenn Maxwell for over
• 43:52
  Speaker 1: 10 years. Glenn Maxwell was present for some of my abuse.
• 43:56
  Speaker 1: At the hands of Jeffrey Epstein, she was present. She
• 43:59
  Speaker 1: was complicit. She was enabling. And it's appalling and disgusting.
• 44:03
  Speaker 1: And it's one of my worst nightmares, the possibility, that
• 44:07
  Speaker 1: is very much going around, that she might be pardoned.
• 44:10
  Speaker 1: This is not okay, guys. This is not okay. And
• 44:13
  Speaker 1: I think that really sums it up. Nothing about that's okay.
• 44:18
  Speaker 1: Even the talk about Ghislaine Maxwell getting a pardon is
• 44:20
  Speaker 1: not okay. Especially considering she didn't give up any actionable intelligence.
• 44:26
  Speaker 1: She had a fireside chat with her buddy.
• 44:28
  Speaker 2: That's all that happened.
• 44:30
  Speaker 1: Nothing of consequence occurred in that proffer session, if you
• 44:33
  Speaker 1: even want to call it that. Just two people having
• 44:36
  Speaker 1: a chat, rehashing history, rewriting history. instead of looking for
• 44:40
  Speaker 1: the truth. And of course, that's what those kind of
• 44:43
  Speaker 1: sessions are supposed to be about, right? And if you
• 44:45
  Speaker 1: get accommodations from the government, you should get some kind
• 44:49
  Speaker 1: of hookup. That's how it usually goes. But Ghislaine Maxwell
• 44:53
  Speaker 1: didn't give the government shit. All she did was sit
• 44:57
  Speaker 1: down and have that conversation, and nothing has come of it.
• 45:00
  Speaker 1: Nothing's going to come from it. So why would she
• 45:02
  Speaker 1: move to Camp Ryan? We all know why. It was
• 45:05
  Speaker 1: because she played ball, right? She said what they wanted
• 45:08
  Speaker 1: her to say. It gave them some plausible deniability, and
• 45:11
  Speaker 1: it provided them the cover of them actually looking like
• 45:14
  Speaker 1: they were doing something to try and get to the
• 45:16
  Speaker 1: bottom of what happened. But those optics were bad from
• 45:19
  Speaker 1: the very beginning, and I think the whole entire fiasco
• 45:22
  Speaker 1: with Maxwell has only made things worse for the administration
• 45:26
  Speaker 1: and for the DOJ. And unless we get some transparency,
• 45:30
  Speaker 1: this story is not going away anytime soon. All of
• 45:35
  Speaker 1: the information that goes with this episode can be found
• 45:39
  Speaker 1: in the description box.