Epstein Secrets

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." In its terms section, the NPA further

oth suppliers and consumers of commercial sex acts.' We conclude they do.") (alteration in original). The lone case cited by the defendant, Flom v. Taylor, No. 11 Civ. 8573, 2012 WL 13042630 (S.D.N.Y. July 2, 2012), relied heavily on the statutory interpretation undertaken by two district courts in the

h allegations that he had committed similar sex offenses against minor girls. The investigation ultimately also involved federal authorities, namely the U.S. Attorney's Office for the Southern District of Florida ("SDFL") and the FBI's Miami Office, and included interviews with victims based in the Palm Beach area, includ

prosecutors included a promise to bind other districts. See United States v. Russo, 801 F.2d 624, 626 (2d Cir. 1986). She alleges that officials in the U.S. Attorney's Office for the Southern District of Florida sought and obtained approval for the NPA from the Office of the Deputy Attorney General and communicated with a

five enumerated offenses; (2) "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"; and (3) "any offenses that arose from the Federal Grand Jury investigation." 6 EFTA00020266 --- PAGE BREAK --- Case 1:20-cr-00330-AJN Documen

is approach is analogous to the "categorical approach" employed by courts to evaluate prior convictions for immigration and sentencing purposes. See Taylor v. United States, 495 U.S. 575, 602 (1990). Generally speaking, the "categorical approach" requires that courts "look only to the statutory definit

prosecutors included a promise to bind other districts. See United States v. Russo, 801 F.2d 624, 626 (2d Cir. 1986). She alleges that officials in the U.S. Attorney's Office for the Southern District of Florida sought and obtained approval for the NPA from the Office of the Deputy Attorney General and communicated with a

five enumerated offenses; (2) "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"; and (3) "any offenses that arose from the Federal Grand Jury investigation." 6 EFTA00022096 --- PAGE BREAK --- Case 1:20-cr-00330-AJN Documen

is approach is analogous to the "categorical approach" employed by courts to evaluate prior convictions for immigration and sentencing purposes. See Taylor v. United States, 495 U.S. 575, 602 (1990). Generally speaking, the "categorical approach" requires that courts "look only to the statutory definit

he NPA to plead guilty in Florida state court to soliciting minors for prostitution and to serve eighteen months in a county jail. Id. In exchange, the U.S. Attorney's Office agreed not to charge him with federal crimes in the Southern District of Florida stemming from its investigation of his conduct between 2001 and 20

five enumerated offenses; (2) "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"; and (3) "any offenses that arose from the Federal Grand Jury investigation." 6 EFTA00029545 --- PAGE BREAK --- Case 1:20-cr-00330-AJN Documen

is approach is analogous to the "categorical approach" employed by courts to evaluate prior convictions for immigration and sentencing purposes. See Taylor v. United States, 495 U.S. 575, 602 (1990). Generally speaking, the "categorical approach" requires that courts "look only to the statutory definit

t written materials. A defendant in a capital case has a constitutionally protected right to provide the jury with mitigating evidence. Williams v. Taylor, 529 U.S. 362, 393 (2000). The Eighth Amendment prohibits the infliction of cruel and unusual punishment, and in a capital matter, while the death

cordings at issue had been destroyed (12/18/19 Proceedings: 6). Explaining, the Government stated that based on conversations with other members of the United States Attorney's Office, their understanding was that although the video did at one time exist, it had not been preserved (12/18/19 Proceedings: 7-8). The Government also a

f standing because Petitioners simply have no injury that is likely to be redressed by a favorable ruling in these proceedings. See, e.g., Scott v. Taylor, 470 F.3d 1014, 1018 (11th Cir. 2006) (holding that there was no standing where it was speculative that remedy that Plaintiff sought 5 Significant

ocument 205-2 Entered on FLSD Docket 07/05/2013 Page 10 of 20 statutes of limitations. See 18 U.S.C. §§ 3283, 3299. Petitioners are free to contact the United States Attorney's Office in those districts and seek to confer with government attorneys in those offices about investigating and potentially prosecuting Epstein based on th

1988) 12 United States v. Stein, 541 F.3d 130 (2d Cir. 2008) 10 United States v. Stokes, 733 F.3d 438 (2d Cir. 2013) 5, 6, 7 United States v. Taylor, 745 F.3d 15 (2d Cir. 2014) 12 US Bank Nat. Ass 'n v. PHL Variable Ins. Co., No. 12 CIV. 6811 CM JCF, 2012 WL 5395249 (S.D.N.Y. Nov. 5, 2012) 2

mendment to Suppress All Evidence Obtained from the government's Subpoena to Boies Schiller and to Dismiss Counts Five and Six upon the following: U.S. Attorney's Office, SDNY One Saint Andrew's Plaza New York, NY 10007 s/ Christian R. Everdell 15 EFTA00019016

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." In its terms section, the NPA further

oth suppliers and consumers of commercial sex acts.' We conclude they do.") (alteration in original). The lone case cited by the defendant, Flom v. Taylor, No. 11 Civ. 8573, 2012 WL 13042630 (S.D.N.Y. July 2, 2012), relied heavily on the statutory interpretation undertaken by two district courts in the