Epstein Secrets

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

iders: "11) the fitness of the issues for judicial decision, and (2) the hardship to the parties of withholding court consideration."' Id. (quoting Cheffer, 55 F.3d at 1524 (citing Abbott Labs. v. Gardner, 387 U.S. 136, 149 (1967))); 6 EFTA00076105 Case 9:08-c 3fi-19464-0CtailltdReta 2ffeeurEenteea o

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

iders: "11) the fitness of the issues for judicial decision, and (2) the hardship to the parties of withholding court consideration."' Id. (quoting Cheffer, 55 F.3d at 1524 (citing Abbott Labs. v. Gardner, 387 U.S. 136, 149 (1967))); 6 EFTA00095908 Case 9:08-c 3fi-19464-0CtailltdReta 2ffeeurEenteea o

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

iders: "(1) the fitness of the issues for judicial decision, and (2) the hardship to the parties of withholding court consideration."' Id. (quoting Cheffer, 55 F.3d at 1524 (citing Abbott Labs. v. Gardner, 387 U.S. 136, 149 (1967))); 6 EFTA00100343 Case 9:08-cv-80736-KAM Document 205-2 Entered on FLS

Jane Doe No. I and Jane Doe No. 2 v. United States, Case No. 08- 80736-Civ-Marra (S.D. Fla.), that evidence gathered in the federal investigation of Jeffrey Epstein's conduct has revealed that a number of districts outside the Southern District of Florida (including the Southern District of New York and the Distri

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

considers: "(I) the fitness of the issues for judicial decision, and (2) the hardship to the panics of withholding court consideration.- ' (quoting Cheffer, 55 F.3d at 1524 (citing Abbott Labs. v. Gardner, 387 U.S. 136. 149 (1967))); 6 EFTA00205159 see also, e.g., Association For Children for Enforce

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

iders: "(1) the fitness of the issues for judicial decision, and (2) the hardship to the parties of withholding court consideration."' Id. (quoting Cheffer, 55 F.3d at 1524 (citing Abbott Labs. v. Gardner, 387 U.S. 136, 149 (1967))); 6 EFTA00208800 see also, e.g., Association For Children for Enforce

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

iders: "(1) the fitness of the issues for judicial decision, and (2) the hardship to the parties of withholding court consideration."' Id. (quoting Cheffer, 55 F.3d at 1524 (citing Abbott Labs... Gardner, 387 U.S. 136, 149 (1967))); 6 EFTA00209774 see also, e.g., Association For Children for Enforcem

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

iders: "(1) the fitness of the issues for judicial decision, and (2) the hardship to the parties of withholding court consideration."' Id. (quoting Cheffer, 55 F.3d at 1524 (citing Abbott Labs. v. Gardner, 387 U.S. 136, 149 (1967))); 6 EFTA00795156 Case 9:08-cv-80736-KAM Document 205-2 Entered on FLS

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

iders: "(1) the fitness of the issues for judicial decision, and (2) the hardship to the parties of withholding court consideration."' Id. (quoting Cheffer, 55 F.3d at 1524 (citing Abbott Labs. v. Gardner, 387 U.S. 136, 149 (1967))); 6 EFTA00799480 Case 9:08-cv-80736-KAM Document 205-2 Entered on FLS

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

ues sufficiently defined and concrete, to permit effective decisionmaking by the court."' In re Jacks, 642 F.3d 1323, 1332 (11th Cir. 2011) (quoting Cheffer v. Reno, 55 F.3d 1517, 1524 (11th Cir. 1995)). When evaluating whether a claim is ripe, a court considers: "(1) the fitness of the issues for judi