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secutorial overreach. It is no mystery what happened here. The Palm Beach FBI and the U.S. Attorney's Office for the Southern District of Florida ("USAO-SDFL") conducted a thorough investigation of Jeffrey Epstein from 2006-2008 (the "Florida Investigation"), but decided not to prosecute him or his "pote
79) 13, 14 United States v. Carter, 454 F.2d 426 (4th Cir. 1972) 10 United States v. Dionisio, 503 F.3d 78 (2d Cir. 2007) 12 United States v. Gebbie, 294 F.3d 540 (3d Cir. 2002) 6, 7, 10 United States v. Gonzalez, 93 F. App'x 268 (2d Cir. 2004) 7 United States v. Korfant, 771 F.2d 660 (2d C
t because Annabi did not address the circumstances of this case; it is also consistent with fundamental fairness. As the Third Circuit cautioned in Gebbie, individual U.S. Attorney's Offices should not view themselves as "sovereigns of autonomous fiefdoms" with the ability to charge a defendant with t
st levied her accusations more than a decade ago. The Palm Beach FBI and the United States Attorney's Office for the Southern District of Florida ("USAO-SDFL") interviewed Accuser-4 in or around 2007 during their three- year investigation of Epstein's alleged sexual abuse (the "Florida Investigation"). And
20 United States v. Carter, 454 F.2d 426 (4th Cir. 1972) 17 United States v. Garcia-Gonzalez, 714 F.3d 306 (5th Cir. 2013) 21 United States v. Gebbie, 294 F.3d 540 (3rd Cir. 2002) 14, 15, 16, 17 United States v. Gonzalez, 93 F. App'x 268 (2d Cir. 2004) 14, 16 United States v. Harvey, 791 F.2
squarely refutes the government's position. The co-conspirator immunity provision does not prohibit merely prosecutions by the USAO for the SDFL ("USAO-SDFL"), but by "the United States." This broad prohibition was intentional, as demonstrated by the express references elsewhere in the NPA to the United
82 (2d Cir. 2019) 13, 26, 29, 30 United States v. Florida West Intl Airways, Inc., 853 F. Supp. 2d 1209 (S.D. Fla. 2012) 16, 17 United States v. Gebbie, 294 F.3d 540 (3d Cir. 2002) 24, 25 United States v. Gonzalez, 93 F. App'x 268 (2d Cir. 2004) 14, 22, 27, 29 United States v. Harvey, 791 F.2d
squarely refutes the government's position. The co-conspirator immunity provision does not prohibit merely prosecutions by the USAO for the SDFL ("USAO-SDFL"), but by "the United States." This broad prohibition was intentional, as demonstrated by the express references elsewhere in the NPA to the United
82 (2d Cir. 2019) 13, 26, 29, 30 United States v. Florida West Intl Airways, Inc., 853 F. Supp. 2d 1209 (S.D. Fla. 2012) 16, 17 United States v. Gebbie, 294 F.3d 540 (3d Cir. 2002) 24, 25 United States v. Gonzalez, 93 F. App'x 268 (2d Cir. 2004) 14, 22, 27, 29 United States v. Harvey, 791 F.2d
182 (2d Cir. 2019) 5, 6, 10, 17 United States v. Florida West Intl Airways, Inc., 853 F. Supp. 2d 1209 (S.D. Fla. 2012) 3, 4, 6 United States v. Gebbie, 294 F.3d 540 (3d Cir. 2002) 12 United States v. Gonzalez, 93 F. App'x 268 (2d Cir. 2004) 8 United States v. Harvey, 791 F.2d 294 (4th Cir. 19
Page: EFTA00028882 →ision in the NPA is intended to refer only to the USAO-SDFL, it does so explicitly. See Mem. at 8-9 (citing examples of NPA's explicit references to USAO-SDFL). While the government is correct that the use of the term "the United States" in a plea agreement, without snore, is insufficient under Annabi and
Page: EFTA00028892 →Entities connected to both USAO-SDFL and Gebbie

Jeffrey Epstein
PERSON
United States
LOCATIONthe Southern District
LOCATION
Department of Justice
ORGANIZATIONFBI
ORGANIZATION
Southern District of New York
ORGANIZATION
Ghislaine Maxwell
PERSONSantobello
PERSON
Alexander Acosta
PERSON
Harvey Weinstein
PERSONSecond Circuit
ORGANIZATION
A. Marie Villafana
PERSON
New York
LOCATIONFeldman
PERSON
Brady
PERSON
Samantha Power
PERSON
Michael Cohen
PERSONAnnabi
PERSONSalameh
PERSON
Julie K. Brown
PERSON