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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
p between the parties and does not serve to make factual determinations, which is precisely what Petitioners seek here. See Medmarc Cas. Ins. Co. I Pineiro & Byrd PLLC, 783 F. Supp. 2d 1214, 1216 (S.D. Fla. 2011) (citing Sierra Equity Group, Inc. White Oak Equity Partners, LLC, 650 F. Supp. 2d 1213, 1231 (S.D. Fl
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
21 EFTA00085729 Case 9:08-cv-80736-KAM Document 462 Entered on FLSD Docket 06/24/2019 Page 22 of 32 determinations. See Medmarc Cas. Ins. Co. v. Pineiro & Byrd PLLC, 783 F. Supp. 2d 1214, 1216 (S.D. Fla. 2011) (citing Sierra Equity Group, Inc. a White Oak Equity Partners, LLC, 650 F. Supp. 2d 1213, 1231 (S.D. F
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
between the parties and does not serve to make factual determinations, which is precisely what Petitioners seek here. See Medmarc Cas. Ins. Co. v. Pineiro & Byrd PLLC, 783 F. Supp. 2d 1214, 1216 (S.D. Fla. 2011) (citing Sierra Equity Group, Inc. v. White Oak Equity Partners, LLC, 650 F. Supp. 2d 1213, 1231 (S.D.
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
between the parties and does not serve to make factual determinations, which is precisely what Petitioners seek here. See Medmarc Cas. Ins. Co. v. Pineiro & Byrd PLLC, 783 F. Supp. 2d 1214, 1216 (S.D. Fla. 2011) (citing Sierra Equity Group, Inc. v. White Oak Equity Partners, LLC, 650 F. Supp. 2d 1213, 1231 (S.D.
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
between the parties and does not serve to make factual determinations, which is precisely what Petitioners seek here. See Medmarc Cas. Ins. Co. v. Pineiro & Byrd PLLC, 783 F. Supp. 2d 1214, 1216 (S.D. Fla. 2011) (citing Sierra Equity Group, Inc. v. White Oak Equity Partners, LLC, 650 F. Supp. 2d 1213, 1231 (S.D.
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
between the parties and does not serve to make factual determinations, which is precisely what Petitioners seek here. See Medmarc Cas. Ins. Co. v. Pineiro & Byrd PLLC, 783 F. Supp. 2d 1214, 1216 (S.D. Fla. 2011) (citing Sierra Equity Group, Inc. v. White Oak Equity Partners, LLC, 650 F. Supp. 2d 1213, 1231 (S.D.
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 →--- PAGE BREAK --- Case 9:08-cv-80736-KAM Document 462 Entered on FLSD Docket 06/24/2019 Page 22 of 32 determinations. See Medmarc Co. Ins. Co. v. Pineiro & Byrd PLLC, 783 F. Supp. 2d 1214, 1216 (S.D. Fla. 2011) (citing Sierra Equity Group, Inc. v. White Oak Equity Partners, LLC, 650 F. Supp. 2d 1213, 1231 (S.D.
Page: EFTA00010563 →Entities connected to both Garcia and Pineiro & Byrd PLLC

Jeffrey Epstein
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A. Marie Villafana
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Alexander Acosta
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Kenneth Marra
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