Epstein Secrets

-Prosecution Agreement led to his guilty plea to state charges and his 3 EFTA00205156 obligations undertaken therein to be set aside.' See, e.g., Santobello v. New York, 404 U.S. 257, 262 (1971) ("(W]hen a plea rests in any significant degree on a promise or agreement of the prosecutor, so that it can b

greement, the United States would still be constitutionally required to adhere to the negotiated terms of the Non-Prosecution Agreement. See, e.g., Santobello, 404 U.S. at 262; Harvey, 869 F.2d at 1443. Due process considerations further bar this Court from setting aside a non-prosecution agreement that g

Epstein's conduct has revealed that a number of districts outside the Southern District of Florida (including the Southern District of New York and the District of New Jersey) share jurisdiction and venue with the Southern District of Florida over potential federal criminal charges based on the alleged sexual acts commit

-Prosecution Agreement led to his guilty plea to state charges and his 3 EFTA00209771 obligations undertaken therein to be set aside.4 See, e.g., Santobello I New York, 404 U.S. 257, 262 (1971) ("[W]hen a plea rests in any significant degree on a promise or agreement of the prosecutor, so that it can b

greement, the United States would still be constitutionally required to adhere to the negotiated terms of the Non-Prosecution Agreement. See, e.g., Santobello, 404 U.S. at 262; Harvey, 869 F.2d at 1443. Due process considerations further bar this Court from setting aside a non-prosecution agreement that g

stein's conduct has revealed that a number of other districts outside the Southern District of Florida (e.g., the Southern District of New York and the District of New Jersey) share jurisdiction and venue with the Southern District of Florida over potential federal criminal charges based on the alleged sexual acts commit

ot subject to being set aside, rescinded, or canceled — regardless of whether or not the government failed to comply with the CVRA. On the contrary, Santobello and its progeny require the USAO-SDFL to continue to abide by the terms of the Non-Prosecution Agreement, and due process precludes this Court from

Rescission of the Non-Prosecution Agreement Between the USAO-SDFL and Epstein In an effort to establish standing and circumvent the requirements of Santobello v. New York, 404 U.S. 257, 262 (1971), and its progeny, Petitioners argue that the Non-Prosecution Agreement between the USAO-SDFL and Epstein is a

sion, including documents and correspondence, that they could use to present to the U.S. Attorney's Office in the Southern District of New York and the District of New Jersey to help persuades those offices to initiate criminal prosecutions of Epstein (Sealed Response, at 3, Bullet 4); • An order from this Court pursua

ot subject to being set aside, rescinded, or canceled — regardless of whether or not the government failed to comply with the CVRA. On the contrary, Santobello and its progeny require the USAO-SDFL to continue to abide by the terms of the Non-Prosecution Agreement, and due process precludes this Court from

Rescission of the Non-Prosecution Agreement Between the USAO-SDFL and Epstein In an effort to establish standing and circumvent the requirements of Santobello v. New York, 404 U.S. 257, 262 (1971), and its progeny, Petitioners argue that the Non-Prosecution Agreement between the USAO-SDFL and Epstein is a

sion, including documents and correspondence, that they could use to present to the U.S. Attorney's Office in the Southern District of New York and the District of New Jersey to help persuades those offices to initiate criminal prosecutions of Epstein (Sealed Response, at 3, Bullet 4); • An order from this Court pursua

ot subject to being set aside, rescinded, or canceled — regardless of whether or not the government failed to comply with the CVRA. On the contrary, Santobello and its progeny require the USAO-SDFL to continue to abide by the terms of the Non-Prosecution Agreement, and due process precludes this Court from

Rescission of the Non-Prosecution Agreement Between the USAO-SDFL and Epstein In an effort to establish standing and circumvent the requirements of Santobello v. New York, 404 U.S. 257, 262 (1971), and its progeny, Petitioners argue that the Non-Prosecution Agreement between the USAO-SDFL and Epstein is a

sion, including documents and correspondence, that they could use to present to the U.S. Attorney's Office in the Southern District of New York and the District of New Jersey to help persuades those offices to initiate criminal prosecutions of Epstein (Sealed Response, at 3, Bullet 4); • An order from this Court pursua

ot subject to being set aside, rescinded, or canceled — regardless of whether or not the government failed to comply with the CVRA. On the contrary, Santobello and its progeny require the USAO-SDFL to continue to abide by the terms of the Non-Prosecution Agreement, and due process precludes this Court from

Rescission of the Non-Prosecution Agreement Between the USAO-SDFL and Epstein In an effort to establish standing and circumvent the requirements of Santobello v. New York, 404 U.S. 257, 262 (1971), and its progeny, Petitioners argue that the Non-Prosecution Agreement between the USAO-SDFL and Epstein is a

sion, including documents and correspondence, that they could use to present to the U.S. Attorney's Office in the Southern District of New York and the District of New Jersey to help persuades those offices to initiate criminal prosecutions of Epstein (Sealed Response, at 3, Bullet 4); • An order from this Court pursua

ot subject to being set aside, rescinded, or canceled — regardless of whether or not the government failed to comply with the CVRA. On the contrary, Santobello and its progeny require the USAO-SDFL to continue to abide by the terms of the Non-Prosecution Agreement, and due process precludes this Court from

sion, including documents and correspondence, that they could use to present to the U.S. Attorney's Office in the Southern District of New York and the District of New Jersey to help persuades those offices to initiate criminal prosecutions of Epstein (Sealed Response, at 3, Bullet 4); • An order from this Court pursua

cluding plea, cooperation, and im- munity agreements—to the extent the agreements require defendants to sacrifice constitutional rights. See, e.g., Santobello v. New York 404 U.S. 257, 262, 92 S.Ct. 495, 30 L.Ed.2d 427 (1971); United States v. Hodge, 412 F.3d 479, 485 (3d Cir.2005) ("The government must

MAPIRI and Joseph Carmine UNITED STATES of America, John N. Mitchell, Attorney General of the V. S., Frederick II. InceY, United States AtFy for the District of New Jersey, and John Doe, any Federal Law Enforce- ment Officer Joseph Caruano, Appellant In No. 18903 Charles Majurf, Appellant in No. 15904. Nos. 18003, 1

--- Case 9:08-cv-80736-KAM Document 205-2 Entered on FLSD Docket 07/05/2013 Page 5 of 20 obligations undertaken therein to be set aside! See, e.g., Santobello v. New York, 404 U.S. 257, 262 (1971) ("[W]hen a plea rests in any significant degree on a promise or agreement of the prosecutor, so that it can b

ted on federal charges.8 Additionally, a number of districts outside the Southern District of Florida (e.g., the Southern District of New York and the District of New Jersey) share jurisdiction and venue with the Southern District of Florida over potential federal criminal charges based on the alleged sexual acts commit