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turns out, all those identified except two) had reached the age of majority, and, in fact, no guardian was necessary to represent their interests. Defense Counsel was Falsely Advised That the Non Prosecution Agreement Would Be Kept Confidential. 20. On September 24, Epstein and the USAO executed a Non Prosec
of Justice Child Exploitation and Obscenity Section ("CEOS") regarding the federal investigation of Jeffrey Epstein by the United States Attorney's Office for the Southern District of Florida ("USAO").' I will refrain from recounting Mr. Epstein's arguments in detail here, but, rather, will highlight salient points responsive
that any and all discovery material produced to the defendant by the Government, regardless of designation, "[s]hall be used by the Defendant or her Defense Counsel solely for purposes of the defense of this criminal action, and not for any civil proceeding or any purpose other than the defense of this action."
that all filings regarding those matters, including the discovery materials referenced in the Defense Letter, remain sealed' As the U.S. Attorney's Office for the Southern District of New York has stated publicly, the investigation into the conduct of the defendant in this case and other possible co-conspirators of Jeffrey Epstein remains
turns out, all those identified except two) had reached the age of majority, and, in fact, no guardian was necessary to represent their interests. Defense Counsel was Falsely Advised That the Non Prosecution Agreement Would Be Kept Confidential. 20. On September 24, Epstein and the USAO executed a Non Prosec
mergency Petition and Petitioners' Motion seeking a finding that the CVRA was violated. The only material fact is that the United States Attorney's Office for the Southern District of Florida never filed federal 'Whether or not the CVRA applies is the central question in dispute in this matter because no federal criminal case
Entities connected to both Defense Counsel and Southern District of New York

Jeffrey Epstein
PERSON
United States
LOCATIONthe Southern District
LOCATION
Department of Justice
ORGANIZATION
Ghislaine Maxwell
PERSONFBI
ORGANIZATION
Alexander Acosta
PERSON
Kenneth Marra
PERSON
Bradley Edwards
PERSON
Prince Andrew
PERSONJane Doe
PERSONJack Goldberger
PERSONSouthern District
LOCATIONLeon Black
PERSON
George W. Bush
PERSON
Scarlett Johansson
PERSON
New York
LOCATION
Julie K. Brown
PERSON
Alan Dershowitz
PERSON
United States Department of Justice
ORGANIZATION