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) & (8). It is now beyond dispute, for example, that in September 2007, the U.S. Attorney's Office formally signed a non-prosecution agreement with Jeffrey Epstein that barred his The victims are contemporaneously filing a motion to have their facts accepted by the Court. EFTA00177009 Case 9:08-cv-80736-KAM
ein agreed to a "confidentiality" provision in the agreement barring its disclosure to anyone — including the victims. For the next nine months, as Epstein was well aware, the U.S. Attorney's Office assiduously concealed from the victims the existence of this signed non-prosecution agreement. Indeed, th
t's desire that federal charges be filed against defendant Epstein. In particular, he wrote on behalf of his clients
formally signed a non-prosecution agreement with Jeffrey Epstein that barred his The victims are contempo
criminal prosecution commensurate with the crimes Mr. Epstein has committed, and we further urge you to take t
pel while actions involving the exercise of exclusively governmental or sovereign powers are not." Id. at 411. In a subsequent case, United States' Vondereau, 837 F.2d 1540 (I I th Cir. 1988), the Eleventh Circuit observed: This Court has held that for estoppel to apply against the Government (I) the tra
l relevant times, the Office had approximately 20 Assistant U.S. Attorneys assigned to the West Palm Beach location. The prosecutor assigned to the Epstein case, I I end I were assigned to different sections within the Office. We reported to different supervisors. 11. I did not participate in any way
ent 79 Entered on FLSD Docket 05/03/2011 Page 2 of 4 violated Florida Bar rules and Department of Justice regulations by representing employees of Jeffrey Epstein ("Epstein") in civil litigation after the undersigned retired from the United States Attorney's Office for the Southern District of Florida (the "Of
Justice regulations by representing employees of Jeffrey Epstein ("Epstein") in civil litigation after the
s retained to represent several other members of Mr. Epstein's staff in their civil depositions. I5.. After
l while actions involving the exercise of exclusively governmental or sovereign powers are not." Id. at 411. In a subsequent case, United States v. Vondereau, 837 F.24 1540 (I I* Cir. 1988), the Eleventh Circuit observed: This Court has held that for estoppel to apply against the Government (1) the tradi
eference to the position taken by employees of the Department of Justice (DOJ) in letters to the petitioners, or the defense attorneys representing Jeffrey Epstein. Nor are the subjective beliefs of DOJ employees relevant to the issue of whether a duty existed under § 3771(a)(5) to consult with petitioners prio
later, on July 9, 2008, the Government filed its Response and an accompanying Declaration, establishing that (1) no federal criminal case charging Epstein had ever been filed and that a non- prosecution agreement ("NPA") had been signed and (2) despite this, the U.S. Attorney's Office had used its best
titioners, or the defense attorneys representing Jeffrey Epstein. Nor are the subjective beliefs of DOJ em
l while actions involving the exercise of exclusively governmental or sovereign powers are not." Id. at 411. In a subsequent case, United States v. Vondereau, 837 F.2d 1540 (11t Cir. 1988), the Eleventh Circuit observed: This Court has held that for estoppel to apply against the Government (1) the tradi
case, the victims had (for example) no CVRA right to confer with prosecutors about a secret non-prosecution agreement barring federal prosecution of Epstein for crimes committed against the victims. This position contravenes the CVRA's plain language. The CVRA covers agencies involved in the "detection"
REC. S4260, 54269 (statement of Sen. Feinstein) (discussing § 377 l(d)(1) and explaining "[tjhis provision " The Government also attempts to raise Jeffrey Epstcin's "rights to Due Process." Gov't Resp. at 46. The victims are mystified as to why the Government would want to assert the rights of the criminal who
n- prosecution agreement (NPA) it negotiated with Jeffrey Epstein — an agreement that blocked federal pros
sovereign capacity dealt with a different subject entirely: when an agent of the Government can bind the Government. For instance, United States v. Vondereau, 837 F.2d 1540 (11th Cir. 1988), held that a government loan officer had no authority to waive payment on a government loan. The reason was that ag
eference to the position taken by employees of the Department of Justice (DOJ) in letters to the petitioners, or the defense attorneys representing Jeffrey Epstein. Nor are the subjective beliefs of DOJ employees relevant to the issue of whether a duty existed under § 3771(a)(5) to consult with petitioners prio
later, on July 9, 2008, the Government filed its Response and an accompanying Declaration, establishing that (1) no federal criminal case charging Epstein had ever been filed and that a non- prosecution agreement ("NPA") had been signed and (2) despite this, the U.S. Attorney's Office had used its best
titioners, or the defense attorneys representing Jeffrey Epstein. Nor are the subjective beliefs of DOJ em
l while actions involving the exercise of exclusively governmental or sovereign powers are not." Id. at 411. In a subsequent case, United States v. Vondereau, 837 F.2d 1540 (11t Cir. 1988), the Eleventh Circuit observed: This Court has held that for estoppel to apply against the Government (1) the tradi
reference to the position taken by employees of the Department of Justice (DOJ) in letters to the petitioners, or the defense attorneys representing Jeffrey Epstein. Nor are the subjective beliefs of DOJ employees relevant to the issue of whether a duty existed under § 3771(a)(5) to consult with petitioners prio
later, on July 9, 2008, the Government filed its Response and an accompanying Declaration, establishing that (1) no federal criminal case charging Epstein had ever been filed and that a non-prosecution agreement ("NPA") had been signed and (2) despite this, the U.S. Attorney's Office had used its best
etitioners, or the defense attorneys representing Jeffrey Epstein. Nor are the subjective beliefs of DOJ e
el while actions involving the exercise of exclusively governmental or sovereign powers are not." Id. at 411. In a subsequent case, United States v. Vondereau , 837 F.2d 1540 (11 ih Cir. 1988), the Eleventh Circuit observed: This Court has held that for estoppel to apply against the Government (1) the tr
Entities connected to both Jeffrey Epstein and Vondereau
Leon Black
PERSON
Prince Andrew
PERSON
Eric Trump
PERSON
Madison
LOCATION
Bradley Edwards
PERSON
United States
LOCATIONJane Doe
PERSON
Martha Stewart
PERSON
Department of Justice
ORGANIZATIONMaria Farmer
PERSON
Kenneth Marra
PERSONthe Southern District
LOCATION
Paul Cassell
PERSONFBI
ORGANIZATION
Virginia Giuffre
PERSON
Jay Lefkowitz
PERSON
Bradley Cooper
PERSON
Scarlett Johansson
PERSON
Michael Jackson
PERSON
Eric Holder
PERSON