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s no evidence that Palm Beach County authorities and Florida prosecutors cannot effectively prosecute and punish the conduct. See also Batchelder v. Gonzalez, No. 4:07-cv-00330-SPM- AK, 2007 WL 5022105 (N.D. Fla. Oct. 19, 2007). In fact, the opposite is true—the state-elected officials, cognizant of the l
Page: EFTA00013814 →nsistent with each of the statutes prosecutors have identified. Accordingly, we respectfully request that you direct the U.S. Attorney's Office for the Southern District of Florida to discontinue its involvement in this matter, and return responsibility for this case to the State of Florida. 17 EFTA00013827
Page: EFTA00013827 →e of phrases like "the government" or "the United States." United States v. Salameh, 152 F.3d 88, 120 (2d Cir. 1998) (per curiam); United States v. Gonzalez, 93 F. App'x 268, 270 (2d Cir. 2004). Those are common shorthand. A plea agreement need not painstakingly spell out "the Office of the United States
Page: EFTA00020264 →for the NPA from the Office of the Deputy Attorney General and communicated with attorneys in other districts. Any involvement of attorneys outside the Southern District of Florida appears to have been minimal. Maxwell has already received access to an unusually large amount of information 5 EFTA00020265 --- PAGE BREAK ---
Page: EFTA00020265 →-9 ("a number of districts outside the Southern District of Florida (e.g., the Southern District of New York ...) share jurisdiction and venue with the Southern District of Florida over potential federal criminal charges based on the alleged sexual acts committed by Epstein against [Jane Doe 1 and 2]. Epstein is thus subject t
Page: EFTA00021448 →red on FLSD Docket 07/23/2019 Page 39 of 70 that violates public policy is void and unenforceable." Neiman, 217 F.Supp.2d at 1286 (citing Harris v. Gonzalez, M.D., 789 So.2d 405, 409 (Fla. 4th DCA 2001)). Here, the Court would violate "public policy" — indeed, an Act of Congress, i.e., the Crime Victims
Page: EFTA00021480 →e of phrases like "the government" or "the United States." United States v. Salameh, 152 F.3d 88, 120 (2d Cir. 1998) (per curiam); United States v. Gonzalez, 93 F. App'x 268, 270 (2d Cir. 2004). Those are common shorthand. A plea agreement need not painstakingly spell out "the Office of the United States
Page: EFTA00022094 →for the NPA from the Office of the Deputy Attorney General and communicated with attorneys in other districts. Any involvement of attorneys outside the Southern District of Florida appears to have been minimal. Maxwell has already received access to an unusually large amount of information 5 EFTA00022095 --- PAGE BREAK ---
Page: EFTA00022095 →till potentially be pursued in other districts, such as the Southern District of New York . . .."); DE 205-2 at 8-9 ("a number of districts outside the Southern District of Florida (e.g., the Southern District of New York ...) share jurisdiction and venue with the Southern District of Florida over potential federal criminal ch
Page: EFTA00022552 →red on FLSD Docket 07/23/2019 Page 39 of 70 that violates public policy is void and unenforceable." Neiman, 217 F.Supp.2d at 1286 (citing Harris v. Gonzalez, M.D., 789 So.2d 405, 409 (Fla. 4th DCA 2001)). Here, the Court would violate "public policy" — indeed, an Act of Congress, i.e., the Crime Victims
Page: EFTA00022584 →first set of pretrial motions, the Court held that the non-prosecution agreement ("NPA") between Jeffrey Epstein and the U.S. Attorney's Office for the Southern District of Florida did not bar the charges against Maxwell in the S1 superseding indictment. See United States v. Maxwell, No. 20-cr-330 (AJN), 2021 WL 1518675, at *2
Page: EFTA00023896 →1985) (per curiam). The Second Circuit's opinion in Annabi is clear, and that court has followed it steadfastly since. See, e.g., United States v. Gonzalez, 93 F. App'x 268, 270 (2d Cir. 2004); United States v. Brown, No. 99-1230(L), 2002 WL 34244994, at *2 (2d Cir. Apr. 26, 2002); United States v. Sal
Page: EFTA00023897 →e of phrases like "the government" or "the United States." United States v. Salameh, 152 F.3d 88, 120 (2d Cir. 1998) (per curiam); United States v. Gonzalez, 93 F. App'x 268, 270 (2d Cir. 2004). Those are common shorthand. A plea agreement need not painstakingly spell out "the Office of the United States
Page: EFTA00029543 →ricts. Two provisions of the NPA refer specifically to prosecution in the Southern District of Florida. The first states that the U.S. Attorney for the Southern District of Florida will defer "prosecution in this District" if Epstein complies with the agreement. Dkt. No. 142-1 at 2. The second states that no prosecution "will
Page: EFTA00029544 →Entities connected to both Southern District of Florida and Gonzalez

Jeffrey Epstein
PERSONU.S. Attorney's Office
ORGANIZATIONJane Doe
PERSON
United States
LOCATION
Alexander Acosta
PERSON
Ghislaine Maxwell
PERSONDistrict Court for the Southern District of New York
ORGANIZATION
Bradley Edwards
PERSON
Department of Justice
ORGANIZATION
Paul Cassell
PERSON
Kenneth Marra
PERSON
Reid Weingarten
PERSON
Supreme Court
ORGANIZATION
Bill Clinton
PERSON
Marc Rich
PERSONSecond Circuit
ORGANIZATIONFBI
ORGANIZATIONSalameh
PERSON
Geoffrey S. Berman
PERSON
Salt Lake City
LOCATION