Epstein Secrets

y reference in the substantive charge (Count 2, ¶ 23). Beyond that, Mr. Epstein intends to raise and litigate significant due process issues about the Department of Justice's conduct in this case. Namely, there is irrefutable evidence from the pending CVRA litigation in the Southern District of Florida that, after Mr. Eps

08), modification denied, 2008 WL 11339654 (E.D.N.Y. July 2, 2008). See United States v. Esposito, 749 F. App'x 20 (2d Cir. 2018); United States v. Sablznani, 493 F.3d 63 (2d Cir. 2007). 10 EFTA00058438 Case 1:19-cr-00490-RMB Document 6 Filed 07/11/19 Page 11 of 16 Other than his 2008 guilty plea pre

Case 1:19-cr-00490-RMB Document 11 Filed 07/12/19 Page 1 of 14 U.S. Department of Justice United States Attorney Southern District of New York The Silvio J. Mollo Building One Saint Andrew's Plaza New York. New York 10007 July 12, 20

rrectly notes, federal prisoners should be detained in facilities run by trained personnel from federal correctional facilities." Id. at 258 (citing Sablznani, 493 F.3d at 74 n.13 ("To the extent [armed private guards] implies an expectation that deadly force may need to be used to assure defendant['s] pr

Case 1:19-cr-00490-RMB Document 11 Filed 07/12/19 Page 1 of 14 U.S. Department of Justice United States Attorney Southern District of New York The Silvio J. Mollo Building One Saint Andrew's Plaza New York. New York 10007 July 12, 20

rrectly notes, federal prisoners should be detained in facilities run by trained personnel from federal correctional facilities." Id. at 258 (citing Sablznani, 493 F.3d at 74 n.13 ("To the extent [armed private guards] implies an expectation that deadly force may need to be used to assure defendant['s] pr