Epstein Secrets

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

prosecutors included a promise to bind other districts. See United States v. Russo, 801 F.2d 624, 626 (2d Cir. 1986). She alleges that officials in the U.S. Attorney's Office for the Southern District of Florida sought and obtained approval for the NPA from the Office of the Deputy Attorney General and communicated with a

five enumerated offenses; (2) "any other offenses that have been the subject of the joint investigation by the Federal Bureau of Investigation and the United States Attorney's Office"; and (3) "any offenses that arose from the Federal Grand Jury investigation." 6 EFTA00020266 --- PAGE BREAK --- Case 1:20-cr-00330-AJN Documen

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

prosecutors included a promise to bind other districts. See United States v. Russo, 801 F.2d 624, 626 (2d Cir. 1986). She alleges that officials in the U.S. Attorney's Office for the Southern District of Florida sought and obtained approval for the NPA from the Office of the Deputy Attorney General and communicated with a

five enumerated offenses; (2) "any other offenses that have been the subject of the joint investigation by the Federal Bureau of Investigation and the United States Attorney's Office"; and (3) "any offenses that arose from the Federal Grand Jury investigation." 6 EFTA00022096 --- PAGE BREAK --- Case 1:20-cr-00330-AJN Documen

West Intl Airways, Inc., 853 F. Supp. 2d 1209 (S.D. Fla. 2012) 3, 4, 6 United States v. Gebbie, 294 F.3d 540 (3d Cir. 2002) 12 United States v. Gonzalez, 93 F. App'x 268 (2d Cir. 2004) 8 United States v. Harvey, 791 F.2d 294 (4th Cir. 1986) 12 United States v. Mariamma Viju (01), No. 3:15-CR-0

renced privilege log in a civil lawsuit filed by one of Epstein's victims, all of which contain entries reflecting the USAO-SDFL's consultation with the United States Attorney's Office for this District, travel by USAO-SDFL attorneys to New York, or interviews and/or subpoenas of New York-based witnesses. Mem. at 11 (citing Privile

pursuant Rule 2(B) of the Court's individual practices in criminal cases, the within memorandum and any accompanying exhibits upon the following: U.S. Attorney's Office, SDNY Is/ Christian Everdell EFTA00028902

he NPA to plead guilty in Florida state court to soliciting minors for prostitution and to serve eighteen months in a county jail. Id. In exchange, the U.S. Attorney's Office agreed not to charge him with federal crimes in the Southern District of Florida stemming from its investigation of his conduct between 2001 and 20

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

five enumerated offenses; (2) "any other offenses that have been the subject of the joint investigation by the Federal Bureau of Investigation and the United States Attorney's Office"; and (3) "any offenses that arose from the Federal Grand Jury investigation." 6 EFTA00029545 --- PAGE BREAK --- Case 1:20-cr-00330-AJN Documen

nerally understood to refer to the U.S. Attorney's Office for the Southern District of Florida (USAO-SDFL), which is currently being represented by the U.S. Attorney's Office for the Northern District of Georgia. 2 EFTA00021446 --- PAGE BREAK --- Case 9:08-cv-80736-KAM Document 466 Entered on FLSD Docket 07/23/2019 Pa

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

nerally understood to refer to the U.S. Attorney's Office for the Southern District of Florida (USAO-SDFL), which is currently being represented by the U.S. Attorney's Office for the Northern District of Georgia. 2 EFTA00022550 --- PAGE BREAK --- Case 9:08-cv-80736-KAM Document 466 Entered on FLSD Docket 07/23/2019 Pa

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

21 Opinion & Order on Maxwell's 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-

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

15 United States v. Ghailani, 687 F. Supp. 2d 365 (S.D.N.Y. 2010) 21 United States v. Gibbons, 602 F.2d 1044 (2d Cir. 1979) 16 United States v. Gonzalez, No. 19 Cr. 123-2 (NRB), 2020 WL 1809293, at *5 (S.D.N.Y. Apr. 9, 2020) 10 United States v. LeRoy, 687 F.2d 610 (2d Cir. 1982) 7 United States v

Discussion As described above, the Government has produced Brady, Giglio, and Rule 16 material in the possession of the prosecutors and agents at the United States Attorney's Office, the FBI, and the DOJ-OIG who have worked on this investigation and prosecution. Thomas seeks materials that are not in the possession of the Unite

15 United States v. Ghailani, 687 F. Supp. 2d 365 (S.D.N.Y. 2010) 21 United States v. Gibbons, 602 F.2d 1044 (2d Cir. 1979) 16 United States v. Gonzalez, No. 19 Cr. 123-2 (NRB), 2020 WL 1809293, at *5 (S.D.N.Y. Apr. 9, 2020) 10 United States v. LeRoy, 687 F.2d 610 (2d Cir. 1982) 7 United States v

Discussion As described above, the Government has produced Brady, Giglio, and Rule 16 material in the possession of the prosecutors and agents at the United States Attorney's Office, the FBI, and the DOJ-OIG who have worked on this investigation and prosecution. Thomas seeks materials that are not in the possession of the Unite