Epstein Secrets

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

80736-Civ-Marra, and any dissemination of such grand jury information shall be accompanied by a copy of this Order. DONE AND ORDERED in Chambers at West Palm Florida, this 7" day of November, 2011. DONICLD M. M1DDLEBROOKS UNITED STATES DISTRICT JUDGE 2 • • EFTA00100356

-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

80736-Civ-Marra, and any dissemination of such grand jury information shall be accompanied by a copy of this Order. DONE AND ORDERED in Chambers at West Palm Florida, this 7 day of November, 2011. D M. MIDDLEBROOKS UNITED STATES DISTRICT JUDGE 2 r * • - • I i N.. at ..-- , ....i '.-- ...-, .-

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

80736-Civ-Marra, and any dissemination of such grand jury information shall be accompanied by a copy of this Order. DONE AND ORDERED in Chambers at West Palm Florida, this 7 day of November, 2011. DONICLD M. MIDDLEBROOKS UNITED STATES DISTRICT JUDGE 2 EFTA00208813

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

80736-Civ-Marra, and any dissemination of such grand jury information shall be accompanied by a copy of this Order. DONE AND ORDERED in Chambers at West Palm Florida, this 7" day of November, 2011. DONICLD M. MIDDLEBROOKS UNITED STATES DISTRICT JUDGE 2 k 1- 1 trst€ EFTA00795169

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

80736-Civ-Marra, and any dissemination of such grand jury information shall be accompanied by a copy of this Order. DONE AND ORDERED in Chambers at West Palm Florida, this 7" day of November, 2011. DONICLD M. MIDDLEBROOKS UNITED STATES DISTRICT JUDGE 2 k 1- 1 trst€ EFTA00799493

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

80736-Civ-Marra, and any dissemination of such grand jury information shall be accompanied by a copy of this Order. DONE AND ORDERED in Chambers at West Palm Florida, this 7" day of November, 2011. DUDIICLD M. MIDDLEBROOKS UNITED STATES DISTRICT JUDGE 2 DatE EFTA00081053 Case 9:08-cv-80736-KAM Do

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

80736-Civ-Marra, and any dissemination of such grand jury information shall be accompanied by a copy of this Order. DONE AND ORDERED in Chambers at West Palm Florida, this 7 day of November, 2011. DONICLD M. MIDDLEBROOKS UNITED STATES DISTRICT JUDGE 2 EFTA00208860 Exhibit A EFTA00208861 IN THE

ot to prosecute in return for a person's cooperation binds the government to the extent that the person carries out his/her part of the bargain. See Santobello v. New York 404 U.S. 257 (1971); Wade v. United States, 112 S. Ct. 1840 (1992). Since such an agreement forecloses enforcement of the criminal law

HOWARD L. OREITZER EDWARD 0. 0959-1907) •ALSO Aosainco IN wyONIN9 ° ALSO ADMITTED IN COLORADO February 14, 2007 Assistant 500 South Ste 400 West Palm Re: client, indicated that Fifth Amendment extended. You request and that formal grant of US Attorney Australian Ave Beach, FL sery WO N

ot to prosecute in return for a person's cooperation binds the government to the extent that the person carries out his/her part of the bargain. See Santobello v. New York 404 U.S. 257 (1971); Wade v. United States, 112 S. Ct. 1840 (1992). Since such an agreement forecloses enforcement of the criminal law

orney Foreperson TESTIMONY OF CRIGI\AL Exhibit 18 EFTA00226454 Page 2 1 The sworn testimony of 2 was taken before the Federal Grand Jury, West Palm 3 Beach Division, West Palm Beach, Palm Beach County, 4 State of Florida, on the 27th day of February, 2007. Court Reporter, was authorized to