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inal sexual misconduct with minors. The Executive Branch enjoys exceedingly broad discretion in deciding how, or whether, to charge an individual. Bordenkircher l Hayes , 434 U.S. 357, 668 (1978)("In our system, so long as the prosecutor has probable cause to believe that the accused committed an offense def
UNCONTROVERTED FACTS I. On or about September 24, 2007, Jeffrey Epstein entered into a Non-Prosecution Agreement with the United States Attorney's Office for the Southern District of Florida. 2. On or about October 29, 2007, an Addendum to the Non-Prosecution Agreement was executed by Jeffrey Epstein, and First Assistant United States A
re a grand jury are decisions that generally rest in the prosecutor's discretion." United States v. Batchelder, 442 U.S. 114, 124 . . . (1979); see Bordenkircher v. Hayes, 434 U.S. 357, 364 . . . (1978). Fokker Services, 818 F.3d at 741. Accordingly, judicial authority is "at its most limited when reviewing
2006-CF-009454-AXXX-MB. In or around November 2006, while the state court charge was pending, Mr. Epstein learned that the United States Attorney's Office for the Southern District of Florida ("USAO-SDFL") was investigating whether Mr. Epstein's alleged conduct violated federal law. The USAO- SDFL investigation was led by honorable federa
etion." United States v. BP Products North America, Inc., 2008 WL 501321 at *11, citing United States v. Armstrong, 517 U.S. 456, 464 (1996Xquoting Bordenkircher v. Hayes, 434 U.S. 357, 364 (1978)). Allowing claims like Petitioners' to proceed would open the inner workings of that prosecutorial discretion an
ations by representing employees of Jeffrey Epstein ("Epstein") in civil litigation after the undersigned retired from the United States Attorney's Office for the Southern District of Florida (the "Office"). They also falsely allege that Movant, while still employed by the Office engaged in improper conduct relating to Epstein. The Motio
Entities connected to both Bordenkircher and Office for the Southern District of Florida

Jeffrey Epstein
PERSONthe Southern District
LOCATION
United States
LOCATIONJane Doe
PERSON
Kenneth Marra
PERSON
Department of Justice
ORGANIZATION
Bradley Edwards
PERSONFBI
ORGANIZATION
Scarlett Johansson
PERSON
Alexander Acosta
PERSON
Jay Lefkowitz
PERSONJack Goldberger
PERSONLeon Black
PERSON
Paul Cassell
PERSON
George W. Bush
PERSON
A. Marie Villafana
PERSONMaria Farmer
PERSON
Prince Andrew
PERSON
United States District Court
ORGANIZATIONGerald Lefcourt
PERSON