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f Corporations' documents show that the Florida Science Foundation was incorporated in November 2007, not a "couple of years ago" as reported by Mr. Epstein. Me address provided for the "office" of the Florida Science Foundation is Jack Goldberger's office suite, and neither the office building director
) & (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. EFTA00185009 Case 9.03-evallf/35-Il
2007, not a "couple of years ago" as reported by Mr. Epstein. Me address provided for the "office" of the Flo
s of the CVRA and, indeed, pressured the U.S. Attorney's Office to commit these violations. Tr. July 11, 2008, at 9. 26. On about December 6, 2007, Jeffrey H. First Assistant U.S. Attorney sent a letter to Jay Lefkowitz, noting the U.S. Attorney's Office's legal obligations to keep victims informed of th
ome sort of objection from defendant Epstein. The U.S. Attorney's Office, however, rejected those objections In a letter on about December 6, 2007, Jeffrey First Assistant U.S. Attorney again sent a letter to Jay Lefkowitz, reiterating the U.S. Attorney's Office's legal obligations to keep victims The
t's desire that federal charges be filed against defendant Epstein. In particular, he wrote on behalf of his clients
on facts of this case; "defendant is not entitled to specific performance in this case because such action would violate the laws of this state"); Ex parte Rich, 194 S.W.3d 508, 515 (Tex. Crim. App. 2006); (where "the plea bargain seemed fair on its face when executed, it has become unenforceable due to cir
) & (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. EFTA00078993 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
on facts of this case; "defendant is not entitled to specific performance in this case because such action would violate the laws of this state"); Ex parte Rich, 194 S.W.3d 508, 515 (Tex. Crim. App. 2006); (where "the plea bargain seemed fair on its face when executed, it has become unenforceable due to cir
) & (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. EFTA00208374 Case 9:08-cv-80736-KM/
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
on facts of this case; "defendant is not entitled to specific performance in this case because such action would violate the laws of this state"); Ex parte Rich, 194 S.W.3d 508, 515 (Tex. Crim. App. 2006); (where "the plea bargain seemed fair on its face when executed, it has become unenforceable due to cir
t's desire that federal charges be filed against defendant Epstein. In particular, he wrote on behalf of his clients
ls the victims of federal sex crimes committed by Jeffrey Epstein ...." As you know, in 2008 your Office d
criminal prosecution commensurate with the crimes Mr. Epstein has committed, and we further urge you to take t
confer with the attorney for the Government in the case"). Two days later (July 91h), the Government sent her a notice that, in light of defendant, Jeffrey Epstein's entry of guilty pleas to various state charges and 18-month jail sentence, the Government had agreed to defer all federal prosecution — including a
y Epstein ...." As you know, in 2008 your Office did not object to adding Jane Doe No. 2 into this litigation, recognizing that she was a victim of Epstein's crimes and had interests at stake in the case. We continue to be perplexed that you are not extending the same consideration to Jane Doe No. 3 an
on facts of this case; "defendant is not entitled to specific performance in this case because such action would violate the laws of this stale"); Ex parte Rich, 194 S.W.3d 508 (Tex. Crim. App. 2006); (where "the plea bargain seemed fair on us face when executed, it has become unenforceable due to circumstan
, 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
State v. Wall, 348 N.C. 671 (1998) (holding that court cannot enforce a plea agreement for concurrent sentence where law mandated consecutive one); Ex parte Rich, 194 S.W.3d 508, 515 (Tex. Crim. App. 2006) (court cannot enforce an illegal sentence below the statutory range; remedy was for defendant to withdr
) & (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
on facts of this case; "defendant is not entitled to specific performance in this case because such action would violate the laws of this state"); Ex parte Rich, 194 S.W.3d 508, 515 (Tex. Crim. App. 2006); (where "the plea bargain seemed fair on its face when executed, it has become unenforceable due to cir
Entities connected to both Jeffrey Epstein and Ex parte Rich

Marc Rich
PERSONLarry Visoski
PERSONLeon Black
PERSON
Prince Andrew
PERSON
Ghislaine Maxwell
PERSON
Madison
LOCATION
George W. Bush
PERSON
Bradley Edwards
PERSON
United States
LOCATIONJack Goldberger
PERSON
Sarah Kellen
PERSONJane Doe
PERSON
Department of Justice
ORGANIZATION
Jean-Luc Brunel
PERSONMaria Farmer
PERSON
Kenneth Marra
PERSONthe Southern District
LOCATION
Paul Cassell
PERSONFBI
ORGANIZATION
A. Marie Villafana
PERSON