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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
them. R. ALEXANDER ACOSTA UNITED STATES ATTORNEY Datod: By: Dated: Dated: 711'4107 Dated: A. MARIE VILLAFARA ASSISTANT U.S. ATTORNEY LILLY ANN SANCHEZ., ESQ. ATTORNEY FOR JEFFREY EPSTEIN Page 7 of 7 EFTA00076092 Case 1:19-cr-00490-RMB Document 6-1 Filed 07/11/19 Page 10 of 15 Case 9:08-cv-8073
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
them. R. ALEXANDER ACOSTA UNITED STATES ATTORNEY Datod: By: Dated: Dated: 711'4107 Dated: A. MARIE VILLAFARA ASSISTANT U.S. ATTORNEY LILLY ANN SANCHEZ., ESQ. ATTORNEY FOR JEFFREY EPSTEIN Page 7 of 7 EFTA00095895 Case 1:19-cr-00490-RMB Document 6-1 Filed 07/11/19 Page 10 of 15 Case 9:08-cv-8073
ould effectively insulate discoverable acts merely because they were enacted in the presence of an attorney.") (emphasis added). Just a month ago, the Second Circuit addressed this issue when a defendant tried to disqualify prosecutors who had seen four documents that the defense alleged were privileged. -19- EF
2 U.S. Department Justice United States Attorney Southern District of Florida R. ALEXANDER ACOSTA UNITED STATES ATTORNEY VIA FACSIMILE Lilly Ann Sanchez, Esq. Fowler White Burnett 1395 Brickell Ave Fl 14 Miami Florida 33131-3300 Re: Jeffrey Epstein 99 N.E. 4 Simi Ma lt Tdepbone - Facsimile Au
o dozens of victims who were abused in Florida. 2 While beyond the scope of a bail hearing, as discussed further below, it is well-established in the Second Circuit that absent an express provision to the contrary in the agreement, one District is not bound by the terms of an agreement entered into between a defe
UNITED STATES ATTORNEY A. MARIE VILLAFANA ASSISTANT U.S. ATTORNEY Dated JEFFREY’ Dated: GERALD LEFCOURT, ESQ. COUNSEL TO JEFFREY EPSTEIN Dated LILLY ANN SANCHEZ, ESQ. ATTORNEY FOR JEFFREY EPSTEIN Page 7of7 CA/Aronberg-000777 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM NOT A CERTI
Entities connected to both Second Circuit and Ann Sanchez

Jeffrey Epstein
PERSON
United States
LOCATION
Ghislaine Maxwell
PERSONthe Southern District
LOCATION
Alexander Acosta
PERSON
Bradley Edwards
PERSON
Department of Justice
ORGANIZATIONGerald Lefcourt
PERSONJack Goldberger
PERSONJane Doe
PERSON
Alan Dershowitz
PERSON
Prince Andrew
PERSONLeon Black
PERSONFBI
ORGANIZATION
Jay Lefkowitz
PERSON
A. Marie Villafana
PERSON
Kenneth Marra
PERSON
George W. Bush
PERSONRoy Black
PERSONSouthern District
LOCATION