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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
ted States, Case No. 08-80736-CIV-MARRA/JOHNSON United States District Court, Southern District of Florida Brad Edwards, Esq., The Law Offices of Brad Edwards & Associates, LLC 2028 Harrison Street, Suite 202 Hollywood, Florida 33020 Paul G. Cassell S.J. Quinney College of Law at the University of Utah 332 S. 1400
-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
ted Slates. Case No. 08-80736-CIV-MARRA/JOHNSON United States District Court, Southern District of Florida Brad Edwards. Esq.. The Law Offices of Brad Edwards & Associates. LLC Hollywood, Florida 33020 Paul G. Cassell Quinney College of Law at the Universit of Utah Salt Lake City, Utah 84112 Attorneys for Jane Doe
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
ted States, Case No. 08-80736-CIV-MARRA/JOHNSON United States District Court, Southern District of Florida Brad Edwards, Esq., The Law Offices of Brad Edwards & Associates, LLC 2028 Harrison Street, Suite 202 Ho11 wood Florida 33020 Fax: Paul G. Cassell S.J. Quinney College of Law at the University of Utah 332 S.
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
ted States, Case No. 08-80736-CIV-MARRA/JOHNSON United States District Court, Southern District of Florida Brad Edwards, Esq., The Law Offices of Brad Edwards & Associates, LLC Paul G. Cassell S.J. Quinney College of Law at the University of Utah 16 EFTA00795166 Case 9:08-cv-80736-KAM Document 205-2 Entered on FL
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
ted States, Case No. 08-80736-CIV-MARRA/JOHNSON United States District Court, Southern District of Florida Brad Edwards, Esq., The Law Offices of Brad Edwards & Associates, LLC 2028 Harrison Street, Suite 202 Hollywood, Florida 33020 (954) 414-8033 Fax: (954) 924-1530 Paul G. Cassell S.J. Quinney College of Law at
nt between the prosecutor and the accused, sometimes loosely called 'plea bargaining,' is an essential component of the administration of justice." Santobello v. New York, 404 U.S. 257, 260, 92 S. Ct. 495, 30 L.Ed. 2d 427 (1971). The Supreme Court has declared that plea bargaining "is to be encouraged." I
ted States, Case No. 08-80736-CIV-MARRA/JOHNSON United States District Court, Southern District of Florida Brad Edwards, Esq., The Law Offices of Brad Edwards & Associates, LLC 2028 Harrison Street, Suite 202 Hollywood, Florida 33020 (954) 414-8033 Fax: (954) 924-1530 Paul G. Cassell S.J. Quinney College of Law at
nt between the prosecutor and the accused, sometimes loosely called 'plea bargaining,' is an essential component of the administration of justice." Santobello v. New York, 404 U.S. 257, 260, 92 S. Ct. 495, 30 L.Ed. 2d 427 (1971). The Supreme Court has declared that plea bargaining "is to be encouraged." I
ted States, Case No. 08-80736-CIV-MARRA/JOHNSON United States District Court, Southern District of Florida Brad Edwards, Esq., The Law Offices of Brad Edwards & Associates, LLC 2028 Harrison Street, Suite 202 Hollywood, Florida 33020 (954) 414-8033 Fax: (954) 924-1530 Paul G. Cassell S.J. Quinney College of Law at
Entities connected to both Santobello and Brad Edwards & Associates

Jeffrey Epstein
PERSON
Bradley Edwards
PERSON
Scarlett Johansson
PERSONJane Doe
PERSON
United States
LOCATION
Kenneth Marra
PERSONthe Southern District
LOCATIONFBI
ORGANIZATION
Alexander Acosta
PERSONThe Law Offices of
ORGANIZATION
Southern District of New York
ORGANIZATIONEmmy Taylor
PERSON
Department of Justice
ORGANIZATION
A. Marie Villafana
PERSONJack Goldberger
PERSON
George W. Bush
PERSON
Paul Cassell
PERSONSouthern District
LOCATIONLeon Black
PERSON
Supreme Court
ORGANIZATION