Epstein Secrets

to the Illegal Concealment of the Non- Prosecution Agreement 10 2. Evidence Exists that the Epstein Defense Team Acted in Bad Faith. 18 3. The USAO-SDFL Was Not Authorized to Extend Epstein Immunity Without First Conferring with his Victims. 23 II. THE CVRA AUTHORIZES RESCISSION AS A REMEDY.

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

erences to the "Government" in this case should be generally 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 --- Ca

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

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

ision in the NPA is intended to refer only to the USAO-SDFL, it does so explicitly. See Mem. at 8-9 (citing examples of NPA's explicit references to USAO-SDFL). While the government is correct that the use of the term "the United States" in a plea agreement, without snore, is insufficient under Annabi and