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against Mr. Epstein.3 III. THE CVRA ITSELF DOES NOT AUTHORIZE IMPOSITION OF THE EPSTEIN REMEDIES Citing a line of cases beginning with Marbury v. Madison, 5 U.S. 137 (1803), the Petitioners contend that the CVRA authorizes "the invalidation of an illegal non- prosecution agreement so that they can con
is a disagreement between two contracting parties, courts cannot simply re-write agreements between them to change the terms. Cf. United States v. Fernandez, 960 F.2d 771, 773 (9'h Cir. 1991) (district court erred in rejecting one paragraph of the plea agreement rather than accepting or rejecting the en
ain language, the NPA has no application to prosecutors in other judicial districts, such as the Southern District of New York. See United States v. Fernandez, No. 17-CR- 167 (JMF), 2017 WL 6372783 at *2 (S.D.N.Y. 2017) ("The Second Circuit has squarely held that "[w]hen the express terms of a plea agreeme
Page: EFTA00022551 →olely, to decide on the rights of individuals.'" Hein v. Freedom from Religion Found., Inc., 551 U.S. 587, 598 (2007) (Alito, J.) (citing Marbwy v. Madison, 1 Cranch 137, 170, 2 L.Ed. 60 (1803)). Epstein does not have a "right" to separation of powers. Second, as discussed above in connection with the
Page: EFTA00022608 →ain language, the NPA has no application to prosecutors in other judicial districts, such as the Southern District of New York. See United States v. Fernandez, No. 17-CR- 167 (JMF), 2017 WL 6372783 at *2 (S.D.N.Y. 2017) ("The Second Circuit has squarely held that "[w]hen the express terms of a plea agreeme
Page: EFTA00021447 →olely, to decide on the rights of individuals.'" Hein v. Freedom from Religion Found., Inc., 551 U.S. 587, 598 (2007) (Alito, J.) (citing Marbwy v. Madison, 1 Cranch 137, 170, 2 L.Ed. 60 (1803)). Epstein does not have a "right" to separation of powers. Second, as discussed above in connection with the
Page: EFTA00021504 →Entities connected to both Madison and Fernandez

Jeffrey Epstein
PERSON
Lesley Groff
PERSON
Marc Rich
PERSON
Prince Andrew
PERSON
Woody Allen
PERSONLeon Black
PERSON
John F. Kennedy
PERSON
United States
LOCATION
Alan Dershowitz
PERSON
George Mitchell
PERSON
George W. Bush
PERSONDarren Indyke
PERSON
Julie K. Brown
PERSON
Richard Kahn
PERSON
Department of Justice
ORGANIZATION
Ghislaine Maxwell
PERSON
Justin Trudeau
PERSON
Prince Charles
PERSON
Eric Trump
PERSON
Joe Biden
PERSON