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ences; such unlawful terms/promises, unlike the lawful 4 EFTA00205627 terms in the Non-Prosecution Agreement, could not be enforced. See State I Garcia, 582 N.W.2d 879, 881-83 (Minn. 1998) (plea agreement promised a sentence that did not contain a statutorily-required 10-year conditional release te
y have limited the USAO-SDFL's capacity to prosecute Epstein in the Southern District of Florida for his federal offenses against Petitioners," the USAO-SDFL did not bargain away the possibility of federal criminal charges being instituted in other districts based on the alleged sexual acts that Epstein c
noting that if plea was induced by illegal promise, proper remedy was defendant's option to withdraw from plea agreement in its entirety); State v. Garcia, 582 N.W.2d 879, 882 (Minn. 1998) (holding that if plea agreement could not be fulfilled based on illegal term, only remedy was withdrawal from enti
s in the context of a criminal sentencing. • All criminal prosecutors in the United States Attorney's Office for the Southern District of Florida (USAO-SDFL) will undergo additional training on the CVRA, victim rights, and victim assistance issues to be completed no later than one year from the date of
0736-KAM Document 205-6 Entered on FLSD Docket 07/05/2013 Page 6 of 101 terms in the Non-Prosecution Agreement, could not be enforced. See State v. Garcia, 582 N.W.2d 879, 881-83 (Minn. 1998) (plea agreement promised a sentence that did not contain a statutorily-required 10-year conditional release te
have limited the USAO-SDFL' s capacity to prosecute Epstein in the Southern District of Florida for his federal offenses against Petitioners,17 the USAO-SDFL did not bargain away the possibility of federal criminal charges being instituted in other districts based on the alleged sexual acts that Epstein c
0736-KAM Document 205-6 Entered on FLSD Docket 07/05/2013 Page 6 of 101 terms in the Non-Prosecution Agreement, could not be enforced. See State v. Garcia, 582 N.W.2d 879, 881-83 (Minn. 1998) (plea agreement promised a sentence that did not contain a statutorily-required 10-year conditional release te
have limited the USAO-SDFL' s capacity to prosecute Epstein in the Southern District of Florida for his federal offenses against Petitioners,17 the USAO-SDFL did not bargain away the possibility of federal criminal charges being instituted in other districts based on the alleged sexual acts that Epstein c
0736-KAM Document 205-6 Entered on FLSD Docket 07/05/2013 Page 6 of 101 terms in the Non-Prosecution Agreement, could not be enforced. See State v. Garcia, 582 N.W.2d 879, 881-83 (Minn. 1998) (plea agreement promised a sentence that did not contain a statutorily-required 10-year conditional release te
have limited the USAO-SDFL's capacity to prosecute Epstein in the Southern District of Florida for his federal offenses against Petitioners,17 the USAO-SDFL did not bargain away the possibility of federal criminal charges being instituted in other districts based on the alleged sexual acts that Epstein c
ople, 986 P.2d 951, 959-60 (Colo. 1999) (court cannot enforce a plea 28 EFTA00299048 agreement that waives the mandatory parole period); State v. Garcia, 582 N.W. 2d 879, 881-82 (Minn. 1998) (plea agreement promised a sentence that did not contain the statutorily-required 10-year conditional release
2006, while the state court charge was pending, Mr. Epstein learned that the United States Attorney's Office for the Southern District of Florida ("USAO-SDFL") was investigating whether Mr. Epstein's alleged conduct violated federal law. The USAO- SDFL investigation was led by honorable federal prosecutor
ences; such unlawful terms/promises, unlike the lawful 4 EFTA00208826 terms in the Non-Prosecution Agreement, could not be enforced. See State v. Garcia, 582 N.W.2d 879, 881-83 (Minn. 1998) (plea agreement promised a sentence that did not contain a statutorily-required 10-year conditional release te
have limited the USAO-SDFL' s capacity to prosecute Epstein in the Southern District of Florida for his federal offenses against Petitioners,17 the USAO-SDFL did not bargain away the possibility of federal criminal charges being instituted in other districts based on the alleged sexual acts that Epstein c
s in the context of a criminal sentencing. • All criminal prosecutors in the United States Attorney's Office for the Southern District of Florida (USAO-SDFL) will undergo additional training on the CVRA, victim rights, and victim assistance issues to be completed no later than one year from the date of
Page: EFTA00010548 →noting that if plea was induced by illegal promise, proper remedy was defendant's option to withdraw from plea agreement in its entirety); State v. Garcia, 582 N.W.2d 879, 882 (Minn. 1998) (holding that if plea agreement could not be fulfilled based on illegal term, only remedy was withdrawal from enti
Page: EFTA00010562 →to the Illegal Concealment of the Non- Prosecution Agreement 10 2. Evidence Exists that the Epstein Defense Team Acted in Bad Faith. 18 3. The USAO-SDFL Was Not Authorized to Extend Epstein Immunity Without First Conferring with his Victims. 23 II. THE CVRA AUTHORIZES RESCISSION AS A REMEDY.
Page: EFTA00021443 →e.g., Craig v. People, 986 P.2d 951, 959-60 (Colo. 1999) (court cannot enforce a plea agreement that waives the mandatory parole period); State v. Garcia, 582 N.W.2d 879, 881-82 (Minn. 1998) (plea agreement promised a sentence that did not contain the statutorily-required 10-year conditional release t
Page: EFTA00021501 →erences to the "Government" in this case should be generally understood to refer to the U.S. Attorney's Office for the Southern District of Florida (USAO-SDFL), which is currently being represented by the U.S. Attorney's Office for the Northern District of Georgia. 2 EFTA00022550 --- PAGE BREAK --- Ca
Page: EFTA00022550 →e.g., Craig v. People, 986 P.2d 951, 959-60 (Colo. 1999) (court cannot enforce a plea agreement that waives the mandatory parole period); State v. Garcia, 582 N.W.2d 879, 881-82 (Minn. 1998) (plea agreement promised a sentence that did not contain the statutorily-required 10-year conditional release t
Page: EFTA00022605 →Entities connected to both Garcia and USAO-SDFL

Jeffrey Epstein
PERSON
A. Marie Villafana
PERSON
Prince Andrew
PERSON
Alexander Acosta
PERSON
Kenneth Marra
PERSON
United States
LOCATION
Ghislaine Maxwell
PERSON
Department of Justice
ORGANIZATION
Jeffrey Sloman
PERSONthe Southern District
LOCATION
Jay Lefkowitz
PERSON
George W. Bush
PERSONJane Doe
PERSON
Bradley Edwards
PERSONLeon Black
PERSON
Scarlett Johansson
PERSON
Joe Biden
PERSON
Marc Rich
PERSONFBI
ORGANIZATION
Alan Dershowitz
PERSON