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

tion Agreement — such judicial action might raise additional questions about this Court's jurisdiction under the Rooker/Feldman doctrine. See, e.g., Casale v. Tillman, 558 F.3d 1258, 1260-61 (11th Cir. 2009); Powell v. Powell, 80 F.3d 464, 466-68 (11th Cir. 1996). 4 EFTA00076103 Case 9:08-c‘080a3fi-19401-00taG

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

tion Agreement — such judicial action might raise additional questions about this Court's jurisdiction under the Rooker/Feldman doctrine. See, e.g., Casale v. Tillman, 558 F.3d 1258, 1260-61 (11th Cir. 2009); Powell v. Powell, 80 F.3d 464, 466-68 (11th Cir. 1996). 4 EFTA00095906 Case 9:08-c‘080a3fi-19401-00taG

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 Agreement — such judicial action might raise additional questions about this Court's jurisdiction under the Rooker/Feldman doctrine. See, e.g., Casale v. Tillman, 558 F.3d 1258, 1260-61 (11th Cir. 2009); Powell v. Powell, 80 F.3d 464, 466-68 (11th Cir. 1996). 4 EFTA00100341 Case 9:08-cv-80736-KAM Document

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

tion Agreement - such judicial action might raise additional questions about this Court's jurisdiction under the Rooker/Feldman doctrine. See. e.g., Casale v. Tillman. 558 F.3d 1258. 1260-61 (11th Cir. 2009); Powell v. Powell. 80 F.3d 464. 466-68 (11th Cir. 1996). 4 EFTA00205157 contract."); Lomayaktewa v. Hat

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 Agreement — such judicial action might raise additional questions about this Court's jurisdiction under the Rooker/Feldman doctrine. See, e.g., Casale v. Tillman, 558 F.3d 1258, 1260-61 (11th Cir. 2009); Powell v. Powell, 80 F.3d 464, 466-68 (11th Cir. 1996). 4 EFTA00208798 contract."); Lomayakteiva v. Ha

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 Agreement — such judicial action might raise additional questions about this Court's jurisdiction under the Rooker/Feldman doctrine. See, e.g., Casale v. Tillman, 558 F.3d 1258, 1260-61 (11th Cir. 2009); Powell v. Powell, 80 F.3d 464, 466-68 (11th Cir. 1996). 4 EFTA00795154 Case 9:08-cv-80736-KAM Document

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 Agreement — such judicial action might raise additional questions about this Court's jurisdiction under the Rooker/Feldman doctrine. See, e.g., Casale v. Tillman, 558 F.3d 1258, 1260-61 (11th Cir. 2009); Powell v. Powell, 80 F.3d 464, 466-68 (11th Cir. 1996). 4 EFTA00799478 Case 9:08-cv-80736-KAM Document