Epstein Secrets

--pending" is ''[r]emaining undecided; awaiting decision .... " Black's Law Dictiona,y 1154 (8th ed. 2004 ). The United States Court of Appeals for the Eleventh Circuit routinely relies on Black's Law Dictionary for the definition of statutory terms, including in criminal cases. See e.g., United States , •. Young,

1 and 2 of this Agreement, nor 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, nor any offenses that arose from the Federal Grand Jury investigation will be instituted in this District, and the charges against Epstein, if any

a manner similar to the way the Court would handle victim impact statements in the context of a criminal sentencing. • All criminal prosecutors in the United States Attorney's Office for the Southern District of Florida (USAO-SDFL) will undergo additional training on the CVRA, victim rights, and victim assistance issues to be c

intentions, partial rescission would pose a significant risk of harm to certain victims, which must be considered in crafting an equitable remedy. The Eleventh Circuit has admonished courts considering equitable remedies to "bear in mind that a poorly crafted remedy may achieve justice for one by working a substan

et answers about that and other related questions will, Jane Doe 1 and 2 believe, provide the kind of information that they would have received had the U.S. Attorney's Office properly conferred in a timely fashion back in 2007"); id. at 24-25 ("If the Government had properly conferred with the two Jane Does ... [t]hese e

hief for the Section in 2004. As those who have worked with me know, I have a history of working diligently on behalf of victims of crime. While at the United States Attorney's Office for the Southern District of West Virginia, I was a part of the prosecution team that prosecuted the first case in the country under the federal Vi

the key element of age is critical. However, CEOS concludes with no apparent supporting analysis, "despite the numerous factual errors you describe, the U.S. Attorney's Office could still plausibly argue that the mistakes —whether inadvertent or intentional — were not material to the determination . ..." (CEOS letter at p

1313-1314 (11th Cir. 2007) (Jane Doe #2 stated that she traveled to Atlanta, Georgia with Madison to work as a prostitute). Thus, courts, including the Eleventh Circuit in Evans, have underscored the point that § 1591 simply is not intended to cover the kind of alleged conduct at issue here. "Section 1591 does not

by reference to the elements of the offense at issue.") (emphasis in original); United States v. Ayo, 801 F. Supp. 2d 1323, 1331 (S.D. Ala. 2011) ("The Eleventh Circuit has employed the second paragraph of Section 3237(a) when such transportation, or use of the mails, is an element of the offense charged."). The ar

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 EFTA00028924

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

. Shore, 439 U.S. 322, 332 (1979). Epstein raises no suggestions that he has been denied that opportunity here. Epstein does point to the fact that the Eleventh Circuit has previously ruled in this case that he is not "an ordinary litigant." Jane Doe 1 v. United States, 749 F.3d 999, 1005 (11th Cir. 2014). But that

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

. Shore, 439 U.S. 322, 332 (1979). Epstein raises no suggestions that he has been denied that opportunity here. Epstein does point to the fact that the Eleventh Circuit has previously ruled in this case that he is not "an ordinary litigant." Jane Doe 1 v. United States, 749 F.3d 999, 1005 (11th Cir. 2014). But that

remedies sought by the petitioners, and opposed by the government, was rescission of the NPA and federal prosecution of Epstein. On July 2, 2019, the U.S. Attorney's Office for the Southern District of New York obtained a federal grand jury indictment charging Epstein with one count of sex trafficking of minors and one

September 30, 2019, CVRA petitioner "Jane Doe 1" filed in her true name a petition for a writ of mandamus in the United States Court of Appeals for the Eleventh Circuit, seeking review of the district court's order denying all of her requested remedies. In its responsive brief, the government argued that "as a matt

ane Doe 2 — about how to resolve the petition filed by Jane Doe 1 and 2. This is a dramatic change in position by the Government, now represented by the U.S. Attorney's Office for the Northern District of Georgia. As the Court will recall, in 2015 two additional victims — Jane Doe 3 and Jane Doe 4 — sought to join this cas

ions. And not to be outdone, Epstein also intervened and succeeded in delaying the case for a year while he took a meritless interlocutory appeal to the Eleventh Circuit. See Jane Doe I and Jane Doe 2 v. U.S., 749 F.3d 999 (11th Cir. 2014). The upshot is that in this case involving federal sex offenses against two c