Epstein Secrets

, vs UNITED STATES OF AMERICA, Respondent. I JEFFREY EPSTEIN, Intervenor. I INTERVENOR JEFFREY EPST

PRECLUDE IMPOSITION OF THE EPSTEIN REMEDIES A. Mr. Epstein was not a Party to the Underlying Litigation and

o prosecuting what was, at heart, a local sex abuse case." See Jeffrey Sloman, Alex Acosta Acted with Professionalism and Integrity in Handling the Jeffrey Epstein Case, Miami Herald Op-Ed, Feb. 15, 2019. The USAO-SDFL's decision to enter into the NPA was also influenced by its consideration of the privacy interest

EEMENT 1 EFTA00299022 TABLE OF CONTENTS INTRODUCTION BACKGROUND ARGUMENT I. PRINCIPLES OF PROCEDURAL DUE PROCESS PRECLUDE IMPOSITION OF THE EPSTEIN REMEDIES A. Mr. Epstein was not a Party to the Underlying Litigation and There is no Judgment Against him B. There is no Judicial Finding of "Bad

teenth Judicial Circuit in and for Palm Beach County on one count of solicitation of prostitution, in violation of Fla. Stat. §796.07. See State v. Jeffiey E. Epstein, 50-2006-CF-009454-AXXX-MB. In or around November 2006, while the state court charge was pending, Mr. Epstein learned that the United States Attorn

pensatory or punitive damages that said First Parties ever had or now have, or that any personal representative, successor, heir, or assign of said First Parties hereafter can, shall, or may have, against Jeffrey Epstein ... for, upon, or by reason of any matter, cause, or thing whatsoever (whether known or

ther civil or criminal. First and Second Parties further stipulate and agree that this Settlement Agreement is pursuant to and is in fulfillment of Jeffrey Epstein's obligations to exclusive of attorneys' fees and costs, pursuant to and in conformity with the Non- Prosecution Agreement, its Addendum, and Its Affi

RAL RELEASE f/k/a ), individually, and Jeffrey Epstein, individually (jointly referred to as "Parties"),

AND GENERAL RELEASE f/k/a ), individually, and Jeffrey Epstein, individually (jointly referred to as "P

mpensatory or punitive damages that said First Parties ever had or now have, or that any personal representative, successor, heir, or assign of said First Parties hereafter can, shall, or may have, against Jeffrey Epstein, or Other Potential Defendants for, upon, or by reason of any matter, cause, or thing wh

nd Parties further stipulate and agree that this Settlement Agreement; whisp Is pursuant, exclusively, to 18 U.S.C. § 2255, and is in fulfillment of Jeffrey Epstein's obligations to exclusive of attorneys' fees and costs, pursuant to andja conformity with the Non-Prosecution Agreement, its Addendum, and its Aff

ssion No.: My Commission Expires: for Any Notice Provision; 1. For Robert C. JosSbe a. Eso. or Katherine W. Ezell. Esq, P dh 7. For .leflrey Epstein - Burman. Critton. Luttier & Coleman. LLP { Formatted: Indent Left 0.25• EFTA00609487

AGREEMENT AND GENERAL RELEASE individually, and Jeffrey Epstein, individually (jointly referred to as 'P

pensatory or punitive damages that said First Parties ever had or now have, or that any personal representative, successor. heir, or assign of said First Parties hereafter can, shall, or may have, against Jeffrey Epstein or Other Potential Defendants for upon, or by reason of any matter, cause, or thing wha

ubpoena and depose and call her at trial(s). Except as provided in this Settlement Agreement, nothing shall prohibit Second Parties from conducting Jeffrey Epstein's defense, investigation, and trial(s) in these other matters as his lawyers deem appropriate. Robert Josefsberg and Katherine Ezell are hereby deemed

NT AND GENERAL RELEASE individually, and Jeffrey Epstein, individually (jointly referred to as "Parties")

AGREEMENT AND GENERAL RELEASE individually, and Jeffrey Epstein, individually (jointly referred to as "P

mpensatory or punitive damages that said First Parties ever had or now have, or that any personal representative, successor, heir, or assign of said First Parties hereafter can, shall, or may have against Jeffrey Epstein, or Other Potential Defendants for, upon, or by reason of any matter, cause, or thing wha

Parties (whose identities must be provided as "Eyes Only" to Robert Josefsberg or Katherine Ezell for disclosures and to Robert D. Griffon, Jr. for Jeffrey Epstein's disclosures, in a sealed envelope to be opened only if a third party is alleged to have breached this provision); 2 EFTA00729902 (b) to the exte

NT AND GENERAL RELEASE individually, and Jeffrey Epstein, individually (jointly referred to as "Parties")

AGREEMENT AND GENERAL RELEASE individually, and Jeffrey Epstein, individually (jointly referred to as "P

s expressly acknowledge and agree that, If either First or Second Parties allege that a breach of the confidentiality provision has occurred, or if First Parties allege that a breach of the anonymity or no contact provision has occurred, the aggrieved First or Second Parties may seek an appropriate remedy in