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

e no longer presents a live case or controversy, and the federal court must dismiss the case for lack of subject matter jurisdiction."); Phoenix of Broward, Inc. v. McDonald's Corp., 489 F.3d 1156, 1161 (Ilth Cir. 2007) ("[T]he issue of constitutional standing is jurisdictional ...."); National Parks Conserv

-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

e no longer presents a live case or controversy, and the federal court must dismiss the case for lack of subject matter jurisdiction;'); Phoenix of Broward, Inc. v. McDonald's Corp., 489 F.3d 1156, 1161 (11th Cir. 2007) ("[T]he issue of constitutional standing is jurisdictional . . . ."); National Parks Cons

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

e no longer presents a live case or controversy, and the federal court must dismiss the case for lack of subject matter jurisdiction."); Phoenix of Broward, Inc. v. McDonald's Corp., 489 F.3d 1156, 1161 (11th Cir. 2007) ("[T]he issue of constitutional standing is jurisdictional ...."); National Parks Conserv

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

e no longer presents a live case or controversy, and the federal court must dismiss the case for lack of subject matter jurisdiction."); Phoenix of Broward, Inc. v. McDonald's Corp., 489 F.3d 1156, 1161 (11th Cir. 2007) ("[T]he issue of constitutional standing is jurisdictional ...."); National Parks Conserv

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

e no longer presents a live case or controversy, and the federal court must dismiss the case for lack of subject matter jurisdiction."); Phoenix of Broward, Inc. v. McDonald's Corp., 489 F.3d 1156, 1161 (11th Cir. 2007) ("[T]he issue of constitutional standing is jurisdictional ...."); National Parks Conserv

-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

e no longer presents a live case or controversy, and the federal court must dismiss the case for lack of subject matter jurisdiction."); Phoenix of Broward, Inc. v. McDonald's Corp., 489 F.3d 1156, 1161 (11th Cir. 2007) ("[T]he issue of constitutional standing is jurisdictional ...."); National Parks Conserv

-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

e no longer presents a live case or controversy, and the federal court must dismiss the case for lack of subject matter jurisdiction."); Phoenix of Broward, Inc. v. McDonald's Corp., 489 F.3d 1156, 1161 (11th Cir. 2007) ("[T]he issue of constitutional standing is jurisdictional ...."); National Parks Conserv

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

167, 180-81, 185 (2000); Florida Wildlife Federation, Inc. v. South Florida Water Management Dist., 647 F.3d 1296, 1302 (11th Cir. 2011); Phoenix of Broward, Inc. v. McDonald's Corp., 489 F.3d 1156, 1161 (11th Cir. 2007); Scott v. Taylor, 470 F.3d 1014, 1018 (11th Cir. 2006); National Parks Conservation Ass'n

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

167, 180-81, 185 (2000); Florida Wildlife Federation, Inc. v. South Florida Water Management Dist., 647 F.3d 1296, 1302 (11th Cir. 2011); Phoenix of Broward, Inc. v. McDonald's Corp., 489 F.3d 1156, 1161 (11th Cir. 2007); Scott v. Taylor, 470 F.3d 1014, 1018 (11th Cir. 2006); National Parks Conservation Ass'n

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

167, 180-81, 185 (2000); Florida Wildlife Federation, Inc. v. South Florida Water Management Dist., 647 F.3d 1296, 1302 (11th Cir. 2011); Phoenix of Broward, Inc. v. McDonald's Corp., 489 F.3d 1156, 1161 (11th Cir. 2007); Scott v. Taylor, 470 F.3d 1014, 1018 (11th Cir. 2006); National Parks Conservation Ass '