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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
EFTA00076104 Case 9:08-c 3E-194M-0Otailitletil affoeurEenieiffea off ired3317O.0ftet (/46/201315Page 7 of 20 would redress claimed injury). II. The Claims Raised in the Petition Are Not Constitutionally Ripe, and These Proceedings Must Thus Be Dismissed for Lack of Subject Matter Jurisdiction. This Court mus
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
EFTA00095907 Case 9:08-c 3E-194M-0Otailitletil affoeurEenieiffea off ired3317O.0ftet (/46/201315Page 7 of 20 would redress claimed injury). II. The Claims Raised in the Petition Are Not Constitutionally Ripe, and These Proceedings Must Thus Be Dismissed for Lack of Subject Matter Jurisdiction. This Court mus
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
onduct. 5 EFTA00100342 Case 9:08-cv-80736-KAM Document 205-2 Entered on FLSD Docket 07/05/2013 Page 7 of 20 would redress claimed injury). II. The Claims Raised in the Petition Are Not Constitutionally Ripe, and These Proceedings Must Thus Be Dismissed for Lack of Subject Matter Jurisdiction. This Court mus
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
ot suffered a concrete injury that is fairly traceable to the challenged government conduct. 5 EFTA00208799 would redress claimed injury). II. The Claims Raised in the Petition Are Not Constitutionally Ripe, and These Proceedings Must Thus Be Dismissed for Lack of Subject Matter Jurisdiction. This Court mus
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
ot suffered a concrete injury that is fairly traceable to the challenged government conduct. 5 EFTA00209773 would redress claimed injury). II. The Claims Raised in the Petition Are Not Constitutionally Ripe, and These Proceedings Must Thus Be Dismissed for Lack of Subject Matter Jurisdiction. This Court mus
Entities connected to both Jeffrey Epstein and The Claims Raised

Marc Rich
PERSON
George Mitchell
PERSON
Bradley Edwards
PERSON
United States
LOCATION
Harry Reid
PERSON
David Mitchell
PERSONJane Doe
PERSON
Department of Justice
ORGANIZATIONMartin Weinberg
PERSON
Kenneth Marra
PERSON
Alexander Acosta
PERSONthe Southern District
LOCATION
Paul Cassell
PERSON
New York
LOCATION
Samantha Power
PERSON
Reid Weingarten
PERSONFBI
ORGANIZATION
A. Marie Villafana
PERSON
Scarlett Johansson
PERSONDoug Band
PERSON