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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
ex crimes perpetrated by Epstein and Maxwell.28 (Ex. 5 at I).29 At the meeting, Edwards provided AUSA-1 with details about, among other things, the USAO-SDFL's prior investigation of Epstein, as well as personal history and experience with Epstein. (See Ex. 5). The focus of the meeting was on Epstein, and
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
ex crimes perpetrated by Epstein and Maxwell.28 (Ex. 5 at 1).29 At the meeting, Edwards provided AUSA-1 with details about, among other things, the USAO-SDFL's prior investigation of Epstein, as well as personal history and experience with Epstein. (See Ex. 5). The focus of the meeting was on Epstein, and
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
ex crimes perpetrated by Epstein and Maxwell.28 (Ex. 5 at 1).29 At the meeting, Edwards provided AUSA-1 with details about, among other things, the USAO-SDFL's prior investigation of Epstein, as well as Giuffre's personal history and experience with Epstein. (See Ex. 5). The focus of the meeting was on Epst
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
ex crimes perpetrated by Epstein and Maxwell.28 (Ex. 5 at 1).29 At the meeting, Edwards provided AUSA-1 with details about, among other things, the USAO-SDFL's prior investigation of Epstein, as well as Giuffre's personal history and experience with Epstein. (See Ex. 5). The focus of the meeting was on Epst
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
ly considered and approved such an outcome, or communicated such a promise to Epstein. Further still, the record in the civil case makes clear that USAO-SDFL's position was that the NPA did not bind other districts. In a July 5, 2013 brief, USAO-SDFL stated: [T]he Non-Prosecution agreement simply obligated
the Federal Bureau of Investigation ("FBI"), will maintain the USAO-SDFL's and the FBI's files and original evidence related to the investigation of Jeffrey Epstein and his co-conspirators until December 31, 2018, notwithstanding any general rule or regulation regarding maintaining and destroying evidence in clo
rict of Florida ("the USAO-SDFL") has previously disclosed as persons whom it was prepared to name as victims in an indictment of Jeffrey Epstein ("Epstein"). That list of all Victims is attached EFTA00211475 SETTLEMENT AGREEMENT, CASE No. 08-80736-CIV-MARRA/MATTHEWMAN hereto in Sealed Appendix "A."
prepared to name as victims in an indictment of Jeffrey Epstein ("Epstein"). That list of all Victims is
s that the United States Department of Justice ("the Justice Department"), including the Federal Bureau of Investigation ("FBI"), will maintain the USAO-SDFL's and the FBI's files and original evidence related to the investigation of Jeffrey Epstein and his co-conspirators until December 31, 2018, notwithst
Entities connected to both Jeffrey Epstein and USAO-SDFL's

Lesley Groff
PERSONDarren Indyke
PERSON
Prince Andrew
PERSON
Ghislaine Maxwell
PERSON
John F. Kennedy
PERSON
George Mitchell
PERSON
George W. Bush
PERSON
Bradley Edwards
PERSON
United States
LOCATION
Sarah Kellen
PERSONJane Doe
PERSON
Department of Justice
ORGANIZATIONMaria Farmer
PERSONMartin Weinberg
PERSON
Julie K. Brown
PERSON
Alexander Acosta
PERSONthe Southern District
LOCATION
Reid Weingarten
PERSONFBI
ORGANIZATION
A. Marie Villafana
PERSON