Epstein Secrets

-c‘O3O3B.49664-0CtailltdReta 2fft3eurfetteSCt off ikkElEgaltket (0748/S01315Page 5 of 20 obligations undertaken therein to be set aside.4 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 be

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

sed by a favorable decision. Friends of the Earth, Inc. v. Laidlaw Environmental Services (TOG), Inc., 528 U.S. 167, 180-81 (2000); see also, e.g., Young Apartments, Inc. v. Town of Jupiter, 529 F.3d 1027, 1038 (11th Cir. 2008) (quoting Harris v. Evans, 20 F.3d 1118, 1121 (11th Cir. 1994) (en bane)). Moreover, "a pla

-c‘O3O3B.49664-0CtailltdReta 2fft3eurfetteSCt off ikkElEgaltket (0748/S01315Page 5 of 20 obligations undertaken therein to be set aside.4 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 be

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

sed by a favorable decision. Friends of the Earth, Inc. v. Laidlaw Environmental Services (TOG), Inc., 528 U.S. 167, 180-81 (2000); see also, e.g., Young Apartments, Inc. v. Town of Jupiter, 529 F.3d 1027, 1038 (11th Cir. 2008) (quoting Harris v. Evans, 20 F.3d 1118, 1121 (11th Cir. 1994) (en bane)). Moreover, "a pla

40 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

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

ed by a favorable decision. Friends of the Earth, Inc. v. Laidlaw Environmental Services (7'OC), Inc., 528 U.S. 167, 180-81 (2000); see also, e.g., Young Apartments, Inc. v. Town of Jupiter, 529 F.3d 1027, 1038 (11th Cir. 2008) (quoting Harris v. Evans, 20 F.3d 1118, 1121 (11th Cir. 1994) (en banc)). Moreover, "a pla

-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

sed by a favorable decision. Friends of the Earth, Inc. v. Laidlaw Environmental Services (TOC), Inc., 528 U.S. 167, 180-81 (2000); see also. e.g., Young Apartments, Inc. v. Town ofJupiter, 529 F.3d 1027, 1038 (1 I th Cir. 2008) (quoting Harris v. Evans, 20 F.3d 1118, 1121 (11th Cir. 1994) (en banc)). Moreover, "a pl

Prosecution Agreement led to his guilty plea to state charges and his 3 EFTA00208797 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

ed by a favorable decision. Friends of the Earth, Inc. v. Laidlaiv Environmental Services (TOC), Inc., 528 U.S. 167, 180-81 (2000); see also, e.g., Young Apartments, Inc. v. Town of Jupiter, 529 F.3d 1027, 1038 (11th Cir. 2008) (quoting Harris v. Evans, 20 F.3d 1118, 1121 (11th Cir. 1994) (en banc)). Moreover, "a pla

-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

ssed by a favorable decision. Friends of the Earth, Inc... Laidlaw Environmental Services (TOC), Inc., 528 U.S. 167, 180-81 (2000); see also, e.g., Young Apartments, Inc. I Town of Jupiter, 529 F.3d 1027, 1038 (11th Cir. 2008) (quoting Harris Evans, 20 F.3d 1118, 1121 (1 I th Cir. 1994) (en banc)). Moreover, "a plai

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

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

ssed by a favorable decision. Friends of the Earth, Inc. v. Laidlaiv Environmental Services (MCI Inc., 528 U.S. 167, 180-81 (2000); see also, e.g., Young Apartments, Inc. v. Town of Jupiter, 529 F.3d 1027, 1038 (11th Cir. 2008) (quoting Harris v. Evans, 20 F.3d 1118, 1121 (11th Cir. 1994) (en banc)). Moreover, "a pla

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

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

ssed by a favorable decision. Friends of the Earth, Inc. v. Laidlaiv Environmental Services (MCI Inc., 528 U.S. 167, 180-81 (2000); see also, e.g., Young Apartments, Inc. v. Town of Jupiter, 529 F.3d 1027, 1038 (11th Cir. 2008) (quoting Harris v. Evans, 20 F.3d 1118, 1121 (11th Cir. 1994) (en banc)). Moreover, "a pla

cases that stand for the generic proposition that the Government must abide by its promises in plea agreements. See Gov't Mot. Dismiss at 4 (citing Santobello v. New York, 404 U.S. 257, 262 (1971); United States v. Harvey, 869 F.2d 1439, 1443 (11th Cir. 1989)). But the very point of all the cases cited by

ernal quotation omitted). And, "[a]t the initial pleading stage, a plaintiff may establish standing based on general factual allegations of injury." Young Apartments, Inc. v. Town of Jupiter, Florida, 529 F.3d 1027, 1038 (11th Cir. 2008). In this case, however, it is clear that the Government's alleged "jurisdictional

ed by a favorable decision. Friends of the Earth, Inc. v. Laidlaw Environmental Services (7'OC), Inc., 528 U.S. 167, 180-81 (2000); see also, e.g., Young Apartments, Inc. v. Town of Jupiter, 529 F.3d 1027, 1038 (11th Cir. 2008) (quoting Harris v. Evans, 20 F.3d 1118, 1121 (11th Cir. 1994) (en banc)). Moreover, "a pla

--- 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