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15th Judicial Circuit in and for Palm Beach County (hereinafter, the "State Attorney's Office") have conducted an investigation into the conduct of Jeffrey Epstein (hereinafter "Epstein"); IT APPEARING that the State Attorney's Office has charged Epstein by indictment with solicitation of prostitution, in viol
he relitigation of which is barred by a prior federal nonprosecution agreement (the "NPA"). The government makes this drastic demand even though Mr. Epstein has never once attempted to flee the United States — despite a Florida federal judge's stated belief that he could void the NPA in appropriate circ
Street New York, NY 10007 RE: United States v. Jeffrey Epstein, Criminal No. 19-490 Dear Judge Berman:
government makes this drastic demand even though Mr. Epstein has never once attempted to flee the United Stat
ion] by looking to matters outside the pleadings, and we do not accord any presumptive truthfulness to the allegations in the complaint."); &info v. Ginsberg, 175 F.3d 957, 960-61 (11th Cir. 1999). 2 Although Petitioners also fail to satisfy the first and second prongs of the standing test, 2 EFTA00076
15th Judicial Circuit in and for Palm Beach County (hereinafter, the "State Attorney's Office") have conducted an investigation into the conduct of Jeffrey Epstein (hereinafter "Epstein"); IT APPEARING that the State Attorney's Office has charged Epstein by indictment with solicitation of prostitution, in viol
he relitigation of which is barred by a prior federal nonprosecution agreement (the "NPA"). The government makes this drastic demand even though Mr. Epstein has never once attempted to flee the United States — despite a Florida federal judge's stated belief that he could void the NPA in appropriate circ
Street New York, NY 10007 RE: United States v. Jeffrey Epstein, Criminal No. 19-490 Dear Judge Berman:
government makes this drastic demand even though Mr. Epstein has never once attempted to flee the United Stat
ion] by looking to matters outside the pleadings, and we do not accord any presumptive truthfulness to the allegations in the complaint."); &info v. Ginsberg, 175 F.3d 957, 960-61 (11th Cir. 1999). 2 Although Petitioners also fail to satisfy the first and second prongs of the standing test, 2 EFTA00095
THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO. 502009CA040800XXXXMBAG JUDGE: HAFELE PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S MOTION TO DISQUALIFY TRIAL JUDGE Plaintiff/Counter-Defendant Jeffrey Epstein (hereinafter "Epstein"), by and through his undersigned attorney and
: HAFELE PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S MOTION TO DISQUALIFY TRIAL JUDGE Plaintiff/Counter-Defendant Jeffrey Epstein (hereinafter "Epstein"), by and through his undersigned attorney and pursuant to Rule 2.330 of the Florida Rules of Judicial Administration and § 38.10 of the Florida St
JEFFREY EPSTEIN, Plaintiff, vs. SCOTT ROTHSTEIN, indiv
ts that I have 16 reviewed, for example, reflect Mr. Epstein's 17 access to airplanes. See Transcript of Oct
ng such comments and annunciating such opinions regarding his financial status and his counsel. Accordingly, disqualification is required. See also Ginsberg v. Holt, 86 So. 2d 650, 651 (Fla. 1956); Olszewska v. Ferro, 590 So. 2d 11 (Fla. 3d DCA 1991). CONCLUSION Accordingly, based upon the aforemention
legal relief that Petitioners have sought pursuant to the CVRA is the setting aside of the Non-Prosecution Agreement that was entered into between Jeffrey Epstein and the U.S. Attorney's Office for the Southern District of Florida ("USAO-SDFL"). See, e.g., DE 99 at 6 (recognizing that the relief Petitioners se
oners seek "is to invalidate the non-prosecution agreement"). But even assuming arguendo that Petitioners' rights under the CVRA were violated when Epstein and the USAO-SDFL entered into the Non- Prosecution Agreement, constitutional due process guarantees do not allow either the Non- Prosecution Agreeme
secution Agreement that was entered into between Jeffrey Epstein and the U.S. Attorney's Office for the So
ion] by looking to matters outside the pleadings, and we do not accord any presumptive truthfulness to the allegations in the complaint."); Stag° v. Ginsberg, 175 F.3d 957, 960-61 (11th Cir. 1999). 2 Although Petitioners also fail to satisfy the first and second prongs of the standing test, 2 EFTA00100
legal relief that Petitioners have sought pursuant to the CVRA is the setting aside of the Non-Prosecution Agreement that was entered into between Jeffrey Epstein and the U.S. Attorney's Office for the Southern District of Florida ("USAO-SDFL"). See, e.g., DE 99 at 6 (recognizing that the relief Petitioners se
oners seek "is to invalidate the non-prosecution agreement"). But even assuming arguendo that Petitioners' rights under the CVRA were violated when Epstein and the USAO-SDFL entered into the Non- Prosecution Agreement, constitutional due process guarantees do not allow either the Non- Prosecution Agreeme
secution Agreement that was entered into between Jeffrey Epstein and the U.S. Attorney's Office for the So
tion] by looking to matters outside the pleadings, and we do not accord any presumptive truthfulness to the allegations in the complaint."); &info t Ginsberg, 175 F.3d 957, 960-61 (11th Cir. 1999). 2 Although Petitioners also fail to satisfy the first and second prongs of the standing test, 2 EFTA00209
ices Say They're Helping Immigration Enforcement • Continued Reporting: Prince Andrew 'Terrified' to Visit U.S. After Fresh Calls for FBI Probe Into Epstein Scandal INTERNATIONAL NEWS • Trump Aides Defend Gaza Takeover Proposal but Walk Back Some Elements • Rwanda-Backed Rebels Have Seized Another Tow
ly too "terrified" to ever set foot in the U.S. again as the FBI is facing fresh calls to launch a probe into his late pal and convicted pedophile, Jeffrey Epstein. The article noted that the disgraced Duke of York, 64, has left the UK once in the last six years — and insiders claim that fears of an arrest, civi
probe into his late pal and convicted pedophile, Jeffrey Epstein. The article noted that the disgraced Duk
the Jewish community. Since mid-2024, ISIS and AI-Qaeda have been upgrading their propaganda by incorporating generative Al programs, according to Ginsberg and his team's research. The Al programs create a "super stylized" version of extremist web content. It also allows terrorist groups to manipulate a
References IIJ Richard P. Gabriel, Jilin Chen, Jeffrey Nichols, InkWell: A Creative Writer's Creative A
itten over a period of nearly two years with critical evaluation by friends brought to bear and specific writing techniques explored and exploited. Ginsberg himself com- mented on the intellectually directed choices and investiga- tions he made while creating the poem. InkWell can be thought of as operat
ion] by looking to matters outside the pleadings, and we do not accord any presumptive truthfulness to the allegations in the complaint."); Stag° v. Ginsberg, 175 F.3d 957, 960-61 (11th Cir. 1999). 2 Although Petitioners also fail to satisfy the first and second prongs of the standing test, 2 EFTA00010
Page: EFTA00010476 →legal relief that Petitioners have sought pursuant to the CVRA is the setting aside of the Non-Prosecution Agreement that was entered into between Jeffrey Epstein and the U.S. Attorney's Office for the Southern District of Florida ("USAO-SDFL"). See, e.g., DE 99 at 6 (recognizing that the relief Petitioners se
Page: EFTA00010477 →oners seek "is to invalidate the non-prosecution agreement"). But even assuming arguendo that Petitioners' rights under the CVRA were violated when Epstein and the USAO-SDFL entered into the Non- Prosecution Agreement, constitutional due process guarantees do not allow either the Non- Prosecution Agreeme
Page: EFTA00010477 →secution Agreement that was entered into between Jeffrey Epstein and the U.S. Attorney's Office for the So
Page: EFTA00010477 →Entities connected to both Jeffrey Epstein and Ginsberg

Marc Rich
PERSON
Prince Andrew
PERSON
George Mitchell
PERSON
Donald Trump
PERSON
Bradley Edwards
PERSON
United States
LOCATION
Harry Reid
PERSON
David Mitchell
PERSON
Prince Charles
PERSONJane Doe
PERSON
Department of Justice
ORGANIZATIONMaria Farmer
PERSONMartin Weinberg
PERSON
Kenneth Marra
PERSON
Julie K. Brown
PERSON
Alexander Acosta
PERSONthe Southern District
LOCATION
Paul Cassell
PERSON
New York
LOCATION
Samantha Power
PERSON