Epstein Secrets

least one act in furtherance of the conspiracy to traffic while in the Southern District of New York. As to substantive sex trafficking offenses, the Second Circuit recently affirmed an SDNY sex trafficking conviction under 18 U.S.C. § 1591 where the minor victim testified that she was in SDNY when the defendan

lly relevant to our case. We are in the process of reviewing that subset of emails. Third, we are still in the process of loading scans of the full USAO-SDFL file into Relativity so that our team can conduct a full review of that file. Due to technical issues with the vendor who scanned the files in Flori

e's the only one who takes the blame for what happened").3 The government further asserts that Ms. Maxwell's position is not supported by subsequent Second Circuit cases that apply Annabi. (Opp. 5-6). But this argument simply begs the question. Although courts in this Circuit have applied Annabi to evaluate whe

secutorial overreach. It is no mystery what happened here. The Palm Beach FBI and the U.S. Attorney's Office for the Southern District of Florida ("USAO-SDFL") conducted a thorough investigation of Jeffrey Epstein from 2006-2008 (the "Florida Investigation"), but decided not to prosecute him or his "pote

of jail pending trial. Id. at *2, *9-10, *13 (citation omitted). Nonetheless, a band of other courts in our area have endorsed the procedure,' and the Second Circuit has affirmed its use, For reasons explained elsewhere, round-the-clock, privately funded security guards will virtually guarantee — not just reason

mber 24, 2007, after a year-long investigation, the Department of Justice, through the United States Attorney for the Southern District of Florida ("USAO-SDFL"), entered into the NPA with Mr. Epstein. The NPA immunized Mr. Epstein from five distinct potential federal charges that "may have been committed

t in this District as barred by what they claimed was an earlier "plea agreement" in the Eastern District, and the court denied the motion. Id. The Second Circuit, in affirming the denial, stated simply that "[a] plea agreement binds only the office of the United States Attorney for the district in which the p

squarely refutes the government's position. The co-conspirator immunity provision does not prohibit merely prosecutions by the USAO for the SDFL ("USAO-SDFL"), but by "the United States." This broad prohibition was intentional, as demonstrated by the express references elsewhere in the NPA to the United

of jail pending trial. Id. at *2, *9-10, *13 (citation omitted). Nonetheless, a band of other courts in our area have endorsed the procedure,' and the Second Circuit has affirmed its use.' For reasons explained elsewhere, round-the-clock, privately funded security guards will virtually guarantee — not just reaso

mber 24, 2007, after a year-long investigation, the Department of Justice, through the United States Attorney for the Southern District of Florida ("USAO-SDFL"), entered into the NPA with Mr. Epstein. The NPA immunized Mr. Epstein from five distinct potential federal charges that "may have been committed

of jail pending trial. Id. at *2, *9-10, *13 (citation omitted). Nonetheless, a band of other courts in our area have endorsed the procedure,' and the Second Circuit has affirmed its use.' For reasons explained elsewhere, round-the-clock, privately funded security guards will virtually guarantee — not just reaso

mber 24, 2007, after a year-long investigation, the Department of Justice, through the United States Attorney for the Southern District of Florida ("USAO-SDFL"), entered into the NPA with Mr. Epstein. The NPA immunized Mr. Epstein from five distinct potential federal charges that "may have been committed

of jail pending trial. Id. at *2, *9-10, *13 (citation omitted). Nonetheless, a band of other courts in our area have endorsed the procedure,' and the Second Circuit has affirmed its use, For reasons explained elsewhere, round-the-clock, privately funded security guards will virtually guarantee — not just reason

mber 24, 2007, after a year-long investigation, the Department of Justice, through the United States Attorney for the Southern District of Florida ("USAO-SDFL"), entered into the NPA with Mr. Epstein. The NPA immunized Mr. Epstein from five distinct potential federal charges that "may have been committed

t in this District as barred by what they claimed was an earlier "plea agreement" in the Eastern District, and the court denied the motion. Id. The Second Circuit, in affirming the denial, stated simply that "[I] plea agreement binds only the office of the United States Attorney for the district in which the p

squarely refutes the government's position. The co-conspirator immunity provision does not prohibit merely prosecutions by the USAO for the SDFL ("USAO-SDFL"), but by "the United States." This broad prohibition was intentional, as demonstrated by the express references elsewhere in the NPA to the United

an, 939 F.3d 182 (2d Cir. 2019), for the proposition that "plea agreements differ from commercial contracts" (Opp. 18), the "differ[ence]" to which the Second Circuit was referring was that in construing a plea agreement, 3 Accuser-2 is identified in the Indictment as Minor Victim-2. 5 EFTA00028888 --- PAGE BR

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

ns omitted), and the government is held "responsible for imprecisions or ambiguities in the agreement." United States v. Padilla, 186 F.3d 136, 142 (2d Cir. 1999). While the government argues that Annabi relieves it of this responsibility where the "imprecisions or ambiguities" relate to the geographic

s 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 completed no later than one year from the date of

vestigation, and otherwise to prevent interference with an investigation." In re Dep't of Investigation of the City of New York, 856 F.2d 481, 482 (2nd Cir. 1988) (citations omitted). Disclosure to third parties of the interview reports of the young women sexually abused by Epstein could cause their ide