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on a promise or agreement of the prosecutor, so that it can be said to be part of the inducement or consideration, such promise must be fulfilled." Santobello v. New York, 404 U.S. 257 (1971). Failure to enforce the government's side of a plea bargain violates Due Process. United States v. Yesil, 991 F.2d
jected to a full-scale trial, the states and the federal government would need to multiply by many times the number of judges and court facilities. Santobello v. New York, 404 U.S. 257, 260 (1971). "[Tjhe fact is that the guilty plea and the often concomitant plea bargain are important components of this c
ion. I. Preface The petitioners in this action seek to vacate a "non-prosecution agreement" ("the agreement") between the United States Attorney's Office for the Southern District of Florida (USAO/SDFL) and Jeffrey Epstein (Epstein) pursuant to the Crime Victims' Rights Act of 2004 (CVRA), 18 U.S.C. §3771. Under the agreement, Epstein a
fter a court determination that Epstein had violated the agreement could the U.S. Attorney's Office move forward to prosecute Epstein. See generally Santobello v. New York, 404 U.S. 257 (1971). Finally and most fundamentally, Epstein has it entirely within his power to avoid criminal prosecution by comply
isions in the agreement. Because the United States may have an interest in this motion, a copy of the motion is being served on the U.S. Attorney's Office for the Southern District of Florida. DATED: April 9.2009 Lifting the protective order may be useful for other reasons as well. For example, Jane Doe intends to question Epstein about
, 643 F.3d 807, 874 (11th Cir. 2011), quoting United States v. Harvey, 869 F.2d 1439, 1443 (11th Cir.1989) (en banc). See, e.g., 38 EFTA00299058 Santobello v. New York, 404 U.S. 257, 262 (1971) ("when a plea rests in any significant degree on a promise ... of the prosecutor, so that it can be said to be
2006-CF-009454-AXXX-MB. In or around November 2006, while the state court charge was pending, Mr. Epstein learned that the United States Attorney's Office for the Southern District of Florida ("USAO-SDFL") was investigating whether Mr. Epstein's alleged conduct violated federal law. The USAO- SDFL investigation was led by honorable federa
Entities connected to both Santobello and Office for the Southern District of Florida

Jeffrey Epstein
PERSON
United States
LOCATIONthe Southern District
LOCATIONJane Doe
PERSON
Kenneth Marra
PERSON
Scarlett Johansson
PERSONFBI
ORGANIZATION
Department of Justice
ORGANIZATION
Bradley Edwards
PERSON
Alexander Acosta
PERSON
Jay Lefkowitz
PERSONLeon Black
PERSON
George W. Bush
PERSON
A. Marie Villafana
PERSON
Paul Cassell
PERSONJack Goldberger
PERSONEmmy Taylor
PERSONMaria Farmer
PERSON
Ghislaine Maxwell
PERSONMartin Weinberg
PERSON