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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
subject matter jurisdiction cannot be conferred by estoppel, Micklerl Nimishillen and Tuscarawas Railway Co., 13 F.3d 184, 189 (6' Cir. 1993), and Intercontinental Travel 44 EFTA00177094 Case 9:08-cv-80736-KAM Document 62 Entered on FLSD Docket 04/08/2011 Page 45 of 54 Marketing, Inc.' FDIC, 45 F.3d 1278, 1286 (9
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
ject matter jurisdiction cannot be conferred by estoppel, Mickley. v. Nimishillen and Tuscarawas Railway Co., 13 F.3d 184, 189 (611' Cir. 1993), and Intercontinental Travel 44 EFTA00078878 Case 9:08-cv-80736-KAM Document 62 Entered on FLSD Docket 04/08/2011 Page 45 of 54 Marketing, Inc. v. FDIC, 45 F.3d 1278, 1286 (
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
bject matter jurisdiction cannot be conferred by estoppel, Mickler v. Nimishillen and Tuscarawas Railway Co., 13 F.3d 184, 189 (611' Cir. 1993), and Intercontinental Travel 44 Respondent's Exhibit A Case No. 08-80736-CIV-MARRAMOHNSON EFTA00208080 Case 9:08-cv-80736-KAM Document 57-1 Entered on FLSD Docket 04/07/20
Entities connected to both Jeffrey Epstein and Intercontinental Travel
Leon Black
PERSON
Prince Andrew
PERSON
Eric Trump
PERSON
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
Scarlett Johansson
PERSON
Michael Jackson
PERSON
Eric Holder
PERSON
Southern District of New York
ORGANIZATION
Salt Lake City
LOCATION
Michigan
LOCATION