Epstein Secrets

me, in violation of 18 U.S.C. §§ 2423 and 2. Counts Five and Six charge the defendant with perjury, in violation of 18 U.S.C. § 1623.i ARGUMENT I. Jeffrey Epstein's Non-Prosecution Agreement Is Irrelevant to This Case The defendant seeks to dismiss the Indictment based on a 2007 non-prosecution agreement ("NPA"

in illegal sex acts, and aiding and abetting the same, in violation 18 U.S.C. §§ 2422 and 2. Count Three charges the defendant with conspiring with Epstein and others to transport minors to participate in illegal sex acts, in violation of 18 U.S.C. § 371. Count Four charges the defendant with transporti

NARY STATEMENT 1 BACKGROUND 2 ARGUMENT 3 I. Jeffrey Epstein's Non-Prosecution Agreement Is Irrelevant

f America Assistant United States Attorneys - Of Counsel - EFTA00102999 TABLE OF CONTENTS PRELIMINARY STATEMENT 1 BACKGROUND 2 ARGUMENT 3 I. Jeffrey Epstein's Non-Prosecution Agreement Is Irrelevant to This Case 3 A. The NPA Does Not Bind the Southern District of New York 4 1. The Text of the Agreement

86 United States v. Remington, 208 F.2d 567 (2d Cir. 1953) 146 United States v. Resendiz-Ponce, 549 U.S. 102 (2007) 227, 235 United States v. Ricco, 549 F.2d 264 (2d Cir. 1977) 61 United States v. Richardson, 512 F.2d 105 (3d Cir. 1975) 49 United States v. Richardson, 537 F.3d 951 (8th Cir

e, in violation of 18 U.S.C. §§ 2423 and 2. Counts Five and Six charge the defendant with perjury, in violation of 18 U.S.C. § 1623. 1 ARGUMENT I. Jeffrey Epstein's Non-Prosecution Agreement Is Irrelevant to This Case The defendant seeks to dismiss the Indictment based on a 2007 non-prosecution agreement ("NPA"

in illegal sex acts, and aiding and abetting the same, in violation 18 U.S.C. §§ 2422 and 2. Count Three charges the defendant with conspiring with Epstein and others to transport minors to participate in illegal sex acts, in violation of 18 U.S.C. § 371. Count Four charges the defendant with transporti

NARY STATEMENT 1 BACKGROUND 2 ARGUMENT 3 I. Jeffrey Epstein's Non-Prosecution Agreement Is Irrelevant

f America Assistant United States Attorneys - Of Counsel - EFTA00099941 TABLE OF CONTENTS PRELIMINARY STATEMENT 1 BACKGROUND 2 ARGUMENT 3 I. Jeffrey Epstein's Non-Prosecution Agreement Is Irrelevant to This Case. 3 A. The NPA Does Not Bind the Southern District of New Yolk 4 1. The Text of the Agreement

86 United States v. Remington, 208 F.2d 567 (2d Cir. 1953) 146 United States v. Resendiz-Ponce, 549 U.S. 102 (2007) 227, 235 United States v. Ricco, 549 F.2d 264 (2d Cir. 1977) 61 United States v. Richardson, 512 F.2d 105 (3d Cir. 1975) 49 United States v. Richardson, 537 F.3d 951 (8th Cir

me, in violation of 18 U.S.C. §§ 2423 and 2. Counts Five and Six charge the defendant with perjury, in violation of 18 U.S.C. § 1623.1 ARGUMENT I. Jeffrey Epstein's Non-Prosecution Agreement Is Irrelevant to This Case The defendant seeks to dismiss the Indictment based on a 2007 non-prosecution agreement ("NPA"

in illegal sex acts, and aiding and abetting the same, in violation 18 U.S.C. §§ 2422 and 2. Count Three charges the defendant with conspiring with Epstein and others to transport minors to participate in illegal sex acts, in violation of 18 U.S.C. § 371. Count Four charges the defendant with transporti

NARY STATEMENT 1 BACKGROUND 2 ARGUMENT 3 I. Jeffrey Epstein's Non-Prosecution Agreement Is Irrelevant

f America Assistant United States Attorneys - Of Counsel - EFTA00077606 TABLE OF CONTENTS PRELIMINARY STATEMENT 1 BACKGROUND 2 ARGUMENT 3 I. Jeffrey Epstein's Non-Prosecution Agreement Is Irrelevant to This Case 3 A. The NPA Does Not Bind the Southern District of New York 4 1. The Text of the Agreement

286 United States v. Remington, 208 F.2d 567 (2d Cir. 1953) 146 United States v. Resendiz-Ponce, 549 U.S. 102 (2007) 227, 235 United States v. Ricco, 549 F.2d 264 (2d Cir. 1977) 61 United States v. Richardson, 512 F.2d 105 (3d Cir. 1975) 49 United States v. Richardson, 537 F.3d 951 (8th Cir

me, in violation of 18 U.S.C. §§ 2423 and 2. Counts Five and Six charge the defendant with perjury, in violation of 18 U.S.C. § 1623.1 ARGUMENT I. Jeffrey Epstein's Non-Prosecution Agreement Is Irrelevant to This Case The defendant seeks to dismiss the Indictment based on a 2007 non-prosecution agreement ("NPA"

in illegal sex acts, and aiding and abetting the same, in violation 18 U.S.C. §§ 2422 and 2. Count Three charges the defendant with conspiring with Epstein and others to transport minors to participate in illegal sex acts, in violation of 18 U.S.C. § 371. Count Four charges the defendant with transporti

NARY STATEMENT 1 BACKGROUND 2 ARGUMENT 3 I. Jeffrey Epstein's Non-Prosecution Agreement Is Irrelevant

f America Assistant United States Attorneys - Of Counsel - EFTA00039421 TABLE OF CONTENTS PRELIMINARY STATEMENT 1 BACKGROUND 2 ARGUMENT 3 I. Jeffrey Epstein's Non-Prosecution Agreement Is Irrelevant to This Case 3 A. The NPA Does Not Bind the Southern District of New York 4 1. The Text of the Agreement

286 United States v. Remington, 208 F.2d 567 (2d Cir. 1953) 146 United States v. Resendiz-Ponce, 549 U.S. 102 (2007) 227, 235 United States v. Ricco, 549 F.2d 264 (2d Cir. 1977) 61 United States v. Richardson, 512 F.2d 105 (3d Cir. 1975) 49 United States v. Richardson, 537 F.3d 951 (8th Cir

me, in violation of 18 U.S.C. §§ 2423 and 2. Counts Five and Six charge the defendant with perjury, in violation of 18 U.S.C. § 1623.1 ARGUMENT I. Jeffrey Epstein's Non-Prosecution Agreement Is Irrelevant to This Case The defendant seeks to dismiss the Indictment based on a 2007 non-prosecution agreement ("NPA"

illegal sex acts, and aiding and abetting the same, in violation of 18 U.S.C. §§ 2422 and 2. Count Three charges the defendant with conspiring with Epstein and others to transport minors to participate in illegal sex acts, in violation of 18 U.S.C. § 371. Count Four charges the defendant with transporti

NARY STATEMENT 1 BACKGROUND 2 ARGUMENT 3 I. Jeffrey Epstein's Non-Prosecution Agreement Is Irrelevant

f America Assistant United States Attorneys - Of Counsel - EFTA00095067 TABLE OF CONTENTS PRELIMINARY STATEMENT 1 BACKGROUND 2 ARGUMENT 3 I. Jeffrey Epstein's Non-Prosecution Agreement Is Irrelevant to This Case 3 A. The NPA Does Not Bind the Southern District of New York 4 1. The Text of the Agreement

Remington, 208 F.2d 567 (2d Cir. 1953) 101 United States v. Resendiz-Ponce, 549 U.S. 102 (2007) 150, 155 xviii EFTA00095085 United States v. Ricco, 549 F.2d 264 (2d Cir. 1977) 42 United States v. Richardson, 512 F.2d 105 (3d Cir. 1975) 36 United States v. Richardson, 537 F.3d 951 (8th Cir

e review of the "attorneys' eyes only" with our resource counsel, David Ruhnke and Tanya Green. Can you confirm that? Thanks. Bruce Barket Barket, Epstein, Kearon, Aldea & LoTurco 666 Old Country road Garden City, NY 11530 Barket Epstein.com On Dec 11, 2019, at 7:53 AM, > wrote: We are looking int

garding the decision to house Mr. Tartaglione and Mr. Epstein together in the same cell in SHU. After speaking

om: Bruce Barket fr-" To:' Cc: Aida Leisenrin KOFFSKY Diaz Subject: Re: Tartaglione Discovery Requests Date: Sat, 14 Dec 2019 16:24:18 +0000 Ricco BRUCE John I assume we can share our notes from the review of the "attorneys' eyes only" with our resource counsel, David Ruhnke and Tanya Green.

to ask for but we are now requesting, any photographs taken of the Tartaglione/Epstein cell after the July 22nd-23rd incident and any photographs of Epstein and/or of Mr. Tartaglione following the same incident. As for your offer to review materials at your office, I and Ms. Leisenring would like to vie

garding the decision to house Mr. Tartaglione and Mr. Epstein together in the same cell in SHU. After speaking

om: ' To: Bruce Barket Cc: Aida Leisenrin KOFFSKY Diaz Subject: Re: Tartaglione Discovery Requests Date: Wed, 11 Dec 2019 12:53:08 +0000 Ton Ricco BRUCE John We are looking into the video request. As you will see in the report, there are some photos that were taken. Friday morning works, aft

SKY Diaz Subject: Re: Tartaglione Discovery Requests Date: Sat, 14 Dec 2019 16:36:46 +0000 Ton Ricco BRUCE John Thanks. Bruce Barket Barket, Epstein, Kearon, Aldea & LoTurco 666 Old Country road Garden City, NY 11530 Barket Epstein.com On Dec 14, 2019, at 11:34 AM, > wrote: Yes that's fine.

garding the decision to house Mr. Tartaglione and Mr. Epstein together in the same cell in SHU. After speaking

From: Bruce Barket To: Cc: Aida Leisenrin KOFFSKY Diaz Subject: Re: Tartaglione Discovery Requests Date: Sat, 14 Dec 2019 16:36:46 +0000 Ton Ricco BRUCE John Thanks. Bruce Barket Barket, Epstein, Kearon, Aldea & LoTurco 666 Old Country road Garden City, NY 11530 Barket Epstein.com On De