Epstein Secrets

U.S. Department of Justice United States Attorney Southern District of New York By Electronic Mail Christian Everdell, Esq. Mark Cohen, Esq. Cohen & Gresser LLP New York

vent surprise, and to interpose a plea of double jeopardy should [the defendant] be prosecuted a second time for the same offense." United States v. Bortnovsky, 820 F.2d 572, 574 (2d Cir. 1987). The Indictment contains a written statement of the essential facts constituting the offenses charged, and it des

es involved in any way in regulating or investigating the activities alleged in the Indictment or related transactions, including but not limited to the Department of Justice (including but not limited to the Federal Bureau of Investigation ("FBI") and all United States Attorney's Offices), the Securities and Exchange Com

. See also United States v. Rigas, 490 F.3d 208, 237 (2d Cir. 2007); United States v. Davidoff 845 F.2d 1151, 1154 (2d Cir. 1988); United States v. Bortnovsky, 820 F.2d 572, 574 (2d Cir. 1987). Accordingly, pursuant to the Sixth Amendment to the U.S. Constitution and Rule 7(f) of the Federal Rules of Crim

0: Exhibit 11: Exhibit 12: Notes from the U.S. Attorney's Office for the Southern District of New York June 14, 2007 Email November 2020 Report, U.S. Department of Justice, Office of Professional Responsibility Notes from February 11, 2021 Call Notes from February 29, 2016 Meeting November 30, 2018 Email December 6

tes v. Bonacorsa, 528 F.2d 1218 (2d Cir. 1976) 180, 190, 197,199 United States v. Bonventre, 646 F App'x 73 (2d Cir. 2016) 271 United States v. Bortnovsky, 820 F.2d 572 (2d Cir. 1987) 266, 267, 274 United States v. Borti, No. 08 Cr. 230 (CSH), 2009 WL 3157582 (D. Conn. Sept. 25, 2009) 218 United S

t 1: Notes from the U.S. Attorney's Office for the Southern District of New York Exhibit 2: June 14, 2007 Email Exhibit 3: November 2020 Report, U.S. Department of Justice, Office of Professional Responsibility Exhibit 4: Notes from February 11, 2021 Call Exhibit 5: Notes from February 29, 2016 Meeting Exhibit 6:

es v. Bonacorsa, 528 F.2d 1218 (2d Cir. 1976) 180, 190, 197, 199 United States v. Bonventre, 646 F App'x 73 (2d Cir. 2016) 271 United States v. Bortnovsky, 820 F.2d 572 (2d Cir. 1987) 266, 267, 274 United States v. Botti, No. 08 Cr. 230 (CSH), 2009 WL 3157582 (D. Conn. Sept. 25, 2009) 218 United S

t 1: Notes from the U.S. Attorney's Office for the Southern District of New York Exhibit 2: June 14, 2007 Email Exhibit 3: November 2020 Report, U.S. Department of Justice, Office of Professional Responsibility Exhibit 4: Notes from February 11, 2021 Call Exhibit 5: Notes from February 29, 2016 Meeting Exhibit 6:

es v. Bonacorsa, 528 F.2d 1218 (2d Cir. 1976) 180, 190, 197, 199 United States v. Bonventre, 646 F App'x 73 (2d Cir. 2016) 271 United States v. Bortnovsky, 820 F.2d 572 (2d Cir. 1987) 266, 267, 274 United States v. Botti, No. 08 Cr. 230 (CSH), 2009 WL 3157582 (D. Conn. Sept. 25, 2009) 218 United S

DFL has explained, the NPA did not bind other districts, and could not. That is because the USAO-SDFL lacked the authority to do so under applicable Department of Justice guidelines: Significantly, under the governing provision of the United States Attorney's Manual, the USAO-SDFL did not have the authority to unila

es v. Bonacorsa, 528 F.2d 1218 (2d Cir. 1976) 120, 127, 133, 135 United States v. Bonventre, 646 F App'x 73 (2d Cir. 2016) 179 United States v. Bortnovsky, 820 F.2d 572 (2d Cir. 1987) 174, 175, 182 United States v. Botti, No. 08 Cr. 230 (CSH), 2009 WL 3157582 (D. Conn. Sept. 25, 2009) 145 United S

t 1: Notes from the U.S. Attorney's Office for the Southern District of New York Exhibit 2: June 14, 2007 Email Exhibit 3: November 2020 Report, U.S. Department of Justice, Office of Professional Responsibility Exhibit 4: Notes from February 11, 2021 Call Exhibit 5: Notes from February 29, 2016 Meeting Exhibit 6:

es v. Bonacorsa, 528 F.2d 1218 (2d Cir. 1976) 180, 190, 197, 199 United States v. Bonventre, 646 F App'x 73 (2d Cir. 2016) 271 United States v. Bortnovsky, 820 F.2d 572 (2d Cir. 1987) 266, 267, 274 United States v. Botti, No. 08 Cr. 230 (CSH), 2009 WL 3157582 (D. Conn. Sept. 25, 2009) 218 United S

es involved in any way in regulating or investigating the activities alleged in the Indictment or related transactions, including but not limited to the Department of Justice (including but not limited to the Federal Bureau of Investigation ("FBI") and all United States Attorney's Offices), the Securities and Exchange Com

. See also United States v. Rigas, 490 F.3d 208, 237 (2d Cir. 2007); United States v. Davidoff 845 F.2d 1151, 1154 (2d Cir. 1988); United States v. Bortnovsky, 820 F.2d 572, 574 (2d Cir. 1987). Accordingly, pursuant to the Sixth Amendment to the U.S. Constitution and Rule 7(f) of the Federal Rules of Crim

U.S. Department of Justice United States Attorney Southern District of New York By Electronic Mail Christian Everdell, Esq. Mark Cohen, Esq. Cohen & Gresser LLP Laura Me

vent surprise, and to interpose a plea of double jeopardy should [the defendant] be prosecuted a second time for the same offense." United States v. Bortnovsky, 820 F.2d 572, 574 (2d Cir. 1987). The Indictment contains a written statement of the essential facts constituting the offenses charged, and it des

U.S. Department of Justice United States Attorney Southern District of New York By Electronic Mail Christian Everdell, Esq. Mark Cohen, Esq. ohen & Gresser LLP Laura Men

vent surprise, and to interpose a plea of double jeopardy should [the defendant] be prosecuted a second time for the same offense." United States v. Bortnovsky, 820 F.2d 572, 574 (2d Cir. 1987). The Indictment contains a written statement of the essential facts constituting the offenses charged, and it des