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y have limited the USAO-SDFL's capacity to prosecute Epstein in the Southern District of Florida for his federal offenses against Petitioners," the USAO-SDFL did not bargain away the possibility of federal criminal charges being instituted in other districts based on the alleged sexual acts that Epstein c
y erroneous construction of 18 U.S.C. § 3858(b) — and where rescission "would [have] restore[d] the defendant to the approximate status quo ante"); Craig,. People, 986 P.2d 951, 959-60, 961-93 (Colo. 1999) (holding that plea agreement made no unlawful promises, but concluding that court would not have
s in the context of a criminal sentencing. • All criminal prosecutors in the United States Attorney's Office for the Southern District of Florida (USAO-SDFL) will undergo additional training on the CVRA, victim rights, and victim assistance issues to be completed no later than one year from the date of
Page: EFTA00010548 →(holding that complete rescission of plea agreement was only permissible remedy when defendant was induced to enter plea based on mistake of law); Craig v. People, 986 P.2d 951, 966 (Colo. 1990) (noting that if plea was induced by illegal promise, proper remedy was defendant's option to withdraw fro
Page: EFTA00010562 →to the Illegal Concealment of the Non- Prosecution Agreement 10 2. Evidence Exists that the Epstein Defense Team Acted in Bad Faith. 18 3. The USAO-SDFL Was Not Authorized to Extend Epstein Immunity Without First Conferring with his Victims. 23 II. THE CVRA AUTHORIZES RESCISSION AS A REMEDY.
Page: EFTA00021443 →terpreting plea agreements. Indeed, numerous cases hold that such agreements are unenforceable when they deviate from legal requirements. See, e.g., Craig v. People, 986 P.2d 951, 959-60 (Colo. 1999) (court cannot enforce a plea agreement that waives the mandatory parole period); State v. Garcia, 582
Page: EFTA00021500 →erences to the "Government" in this case should be generally understood to refer to the U.S. Attorney's Office for the Southern District of Florida (USAO-SDFL), which is currently being represented by the U.S. Attorney's Office for the Northern District of Georgia. 2 EFTA00022550 --- PAGE BREAK --- Ca
Page: EFTA00022550 →terpreting plea agreements. Indeed, numerous cases hold that such agreements are unenforceable when they deviate from legal requirements. See, e.g., Craig v. People, 986 P.2d 951, 959-60 (Colo. 1999) (court cannot enforce a plea agreement that waives the mandatory parole period); State v. Garcia, 582
Page: EFTA00022604 →Entities connected to both USAO-SDFL and Craig Martin

Jeffrey Epstein
PERSON
Marc Rich
PERSON
Joe Biden
PERSON
United States
LOCATION
Department of Justice
ORGANIZATIONLeon Black
PERSON
Ghislaine Maxwell
PERSON
Donald Trump
PERSON
Bradley Edwards
PERSON
George W. Bush
PERSON
Prince Andrew
PERSONEmmy Taylor
PERSON
Michael Cohen
PERSONJane Doe
PERSON
Virginia Giuffre
PERSON
Kenneth Marra
PERSON
Julie K. Brown
PERSONthe Southern District
LOCATION
Scarlett Johansson
PERSONFBI
ORGANIZATION