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wo Petitioners, represented by the same counsel as in the instant case, filed civil complaints for damages against Mr. Epstein in federal court and Palm Beach Circuit Court. See Doe v. Epstein, 13 EFTA00299033 Case No. 08-80893-Civ-KAM (S.D.Fla.) (DE 1); L.M. v. Epstein, Case No. 09-81092-Civ- KAM (S.D.Fla.) (DE 1);
econd-guess the Executive's exercise of discretion over the initiation and dismissal of criminal charges." Id. at 738. 45 EFTA00299065 Although Fokker addressed DPAs, the same principles apply with even greater to force to NPAs, which typically involve no judicial supervision. By imposing the Epste
Accordingly, judicial authority is "at its most limited when reviewing the Executive's exercise of discretion over charging determinations." Id. In Fokker, the question before the D.C. Circuit was whether the district court had the power to decline to enter a speedy trial waiver because it believed tha
represented Jane Doe No. 1 and Jane Doe No. 2. (a) This placed both petitioners on notice that Epstein would be pleading guilty on June 30, 2008, in Palm Beach Circuit Court. I. THE GOVERNMENT DID NOT VIOLATE PETITIONERS' § 3771(a)(2) RIGHT TO REASONABLE, ACCURATE, AND TIMELY NOTICE Supreme Court has repeatedly emphas
rges — no less than decisions to initiate charges and to identify which charges to bring — lie squarely within the ken of prosecutorial discretion." Fokker, 818 F.3d at 742. The 11 EFTA00211728 As to the third time period, when the Government found out on Friday, June 27, 2008, at approximately 4:15
presented Jane Doe No. 1 and Jane Doe No. 2. (Id.) This placed both petitioners on notice that Epstein would be pleading guilty on June 30, 2008, in Palm Beach Circuit Court. Petitioners' arguments and the record in this case simply do not establish that there was any violation of the petitioners' right to confer. See a
rges — no less than decisions to initiate charges and to identify which charges to bring — lie squarely within the ken of prosecutorial discretion." Fokker, 818 F.3d at 742. The II EFTA00799835 Case 9:08-cv-80736-KAM Document 408 Entered on FLSD Docket 06/06/2017 Page 12 of 32 As to the third time p
epresented Jane Doe No. 1 and Jane Doe No. 2. (ti) This placed both petitioners on notice that Epstein would be pleading guilty on June 30, 2008, in Palm Beach Circuit Court. Petitioners' arguments and the record in this case simply do not establish that there was any violation of the petitioners' right to confer. See a
rges — no less than decisions to initiate charges and to identify which charges to bring — lie squarely within the ken of prosecutorial discretion." Fokker, 818 F.3d at 742. The 11 EFTA00591472 Case 9:08-cv-80736-KAM Document 401-2 Entered on FLSD Docket 06/02/2017 Page 13 of 33 As to the third tim
Entities connected to both Palm Beach Circuit Court and Fokker

Jeffrey Epstein
PERSONJane Doe
PERSON
Kenneth Marra
PERSON
Bradley Edwards
PERSON
George W. Bush
PERSON
United States
LOCATION
Paul Cassell
PERSON
Alexander Acosta
PERSONMaria Farmer
PERSONLeon Black
PERSON
Department of Justice
ORGANIZATIONFISTOS & LEHRMAN
ORGANIZATION
A. Marie Villafana
PERSON
Dexter Lee
PERSON
Jay Lefkowitz
PERSON
New Hampshire
LOCATION
Harvey Weinstein
PERSONJANE DOE NO
PERSON
Executive
ORGANIZATION
Paul Ryan
PERSON