Epstein Secrets

rs' Submission on Proposed Remedies The United States of America, by Byung J. Pak, United States Attorney for the Northern District of Georgia, and Jill E. Steinberg and Nathan P. Kitchens, Special Attorneys for the Southern District of Florida, files this response to Petitioners' proposed remedies. INTRODUCTIO

agreement to a third party. Second, none of Petitioners cases authorizes partial rescission, the remedy they request here.16 16 See United States v. Walker, 98 F.3d 944 (7th Cir. 1996) (holding that complete rescission of plea agreement was only permissible remedy when defendant was induced to enter pl

se) that Epstein's legal team had no knowledge whatsoever that the Government was violating its CVRA obligations. A helpful case is United States v. Walker, 98 F.3d 944 (7th Cir. 1996). 55 EFTA00021499 --- PAGE BREAK --- Case 9:08-cv-80736-KAM Document 466 Entered on FLSD Docket 07/23/2019 Page 59 o

0 CERTIFICATE OF SERVICE I certify that the foregoing document was served on July 23, 2019, on counsel of record using the Court's CM/ECF system: Jill E. Steinberg Nathan P. Kitchens U.S. Attorneys' Office for the Northern District of Georgia 600 U.S. Courthouse 75 Ted Turner Drive, S.W. Atlanta, GA 30303

to respond; g) mischaracterize Mr. Epstein's discussion of the Walke• case (DE 464:55-56), inasmuch as it was not the Seventh Circuit's ruling in Walker that Mr. Epstein claimed was "entirely confused," but rather the Petitioners' discussion of it in their initial submission. (DE 463:25); and h) a

is more time-consuming to review drafts of a submission with him before the submission is filed. 6. Counsel for Mr. Epstein communicated with AUSA Jill E. Steinberg, counsel for the government, who advises that the government does not object. Counsel for Mr. Epstein also communicated with Paul Cassell, counsel