Epstein Secrets

all pertain to the negotiation and eventual entering into of a Non-Prosecution Agreement (NPA) with the United States Attorney's Office (USAO) for the Southern District of Florida. See part I above herein. Again, the constitutional issues raised in Defendant's response permeate these discovery requests. The full te

-KAM Document 63 Entered on FLSD Docket 03/25/2009 Page 9 of 37 Jane Doe No. 2 v. Epstein Page 9 can be used at trial. Id; Pillsbury Company v. Conbov 495 U.S. 248, 103 S.Ct. 608 (1983). See also, Hubbell, supra, quoted above as to what is encompassed by the phrase "in any criminal case" contained

as long as the USAO determines EPSTEIN has complied with those terms and conditions. The threat of criminal prosecution against EPSTEIN by USAO in the Southern District of Florida continues presently and through late 2010. 6. Pursuant to the terms of the NPA, the USAO possesses the right to declare that the agree

t trial. Id• Pillsbury Company 11 EFTA00222535 Case 9:08-cv-80119-KAM Document 65 Entered on FLSD Docket 03'25'2009 Page 12 of 15 Page 12 v. Conbov, 495 U.S. 248, 103 S.Ct. 608 (1983). 5se also, Hubbell, supra, as to what is encompassed by the phrase "in any criminal case" contained in the Fifth

as long as the USAO determines EPSTEIN has complied with those terms and conditions. The threat of criminal prosecution against EPSTEIN by USAO in the Southern District of Florida continues presently and through late 2010. 6. Pursuant to the terms of the NPA, the USAO possesses the right to declare that the agree

convict the witness of a crime or could aid in the development of other incriminating evidence that can be used at trial. Id; Pillsbury Company v. Conbov, 495 U.S. 248, 103 S.Ct. 608 (1983). Certainly, if the USAO decides to prosecute EPSTEIN for an alleged violation of the NPA, it would undoubtedly