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w best to use the broad discretion you enjoy in choosing whether to prosecute. In this regard, we suggest that having a greater understanding of who Jeffrey Epstein is as a person may help inform how best to proceed. Jeffrey Epstein was raised in a middle class neighborhood in Brooklyn, New York, by hardworking
hen it enacted this law.5 Though §2422(b) is susceptible to multiple interpretations, it was designed to address a specific a problem with which Mr. Epstein's case has nothing in common. If stretched to reach beyond the core concern of the statute, a host of problems immediately arise. A simple reading
igned to address a specific a problem with which Mr. Epstein's case has nothing in common. If stretched to re
ERAL EXPRESS TELEPHONE FACSIMILE July 6, 2007 Jeffrey Sloman, Esq., First Assistant United States Attor
intermediary to carry out his intended objective. Id. at 1287. Fact patterns similar to Murrell's exist in United States Hornaday, 392 F.3d 1306 (11 di Cir. 2004); United States Houston, 177 Fed. Aepx. 57 (11" Cir. 2006); Chilled States' Searcy, 418 F.3d 1193 (11* Cir. 2005); United States' Scott, 426 F
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
nd ordinarily understood," and reads the statute to give full effect to each of its provisions. United States v. DBB Inc. , 180 F.3d 1277, 1281 (11 di Cir. 1999), citing United States v. McLymont , 45 F3d 400, 401 (11 di Cir. 1995). Section 3771(a)(5) grants a crime victim the reasonable right to confe
udgment, pursuant to Rule 56, Federal Rules of Civil Procedure, and states: I. STATEMENT OF UNCONTROVERTED FACTS 1. On or about September 24, 2007, Jeffrey Epstein entered into a Non-Prosecution Agreement with R. Alexander Acosta, United States Attorney, Southern District of Florida. 2. On or about October 29,
Jeffrey Epstein entered pleas of guilty to various charges in the Circuit Court, Fifteenth Judicial Circuit, in and for Palm Beach County, Florida. Epstein was sentenced the same date, and is currently imprisoned in Palm Beach County, Florida. 4. Jeffrey Epstein has not had any federal criminal charges
OVERTED FACTS 1. On or about September 24, 2007, Jeffrey Epstein entered into a Non-Prosecution Agreement
nd ordinarily understood," and reads the statute to give full effect to each of its provisions. United States v. DBB, Inc. , 180 F.3d 1277, 1281 (11 di Cir. 1999), citing United States v. McLymont , 45 F3d 400, 401 (11 th Cir. 1995). Section 3771(a)(5) grants a crime victim the reasonable right to conf
udgment, pursuant to Rule 56, Federal Rules of Civil Procedure, and states: I. STATEMENT OF UNCONTROVERTED FACTS I. On or about September 24, 2007, Jeffrey Epstein entered into a Non-Prosecution Agreement with the United States Attorney's Office for the Southern District of Florida. 2. On or about October 29,
of felony procurement of a minor to engage in prostitution in the Circuit Court, Fifteenth Judicial Circuit, in and for Palm Beach County, Florida. Epstein was sentenced the same date, and is currently imprisoned in Palm Beach County, Florida. 4. Jeffrey Epstein has not had any federal criminal charges
OVERTED FACTS I. On or about September 24, 2007, Jeffrey Epstein entered into a Non-Prosecution Agreement
uire submission to a jury or whether it is so one-sided that one party must prevail as a matter of law." Allen I Tyson Inc. , 121 F.3d 642, 646 (11 di Cir. 1997), citing Anderson I Liberty Lobby, Inc. , 477 U.S. 242, 252 (1986). Under Fed.R.Civ.P. 56(c), summary judgment is appropriate after adequate
Entities connected to both Jeffrey Epstein and di Cir
Leon Black
PERSON
Prince Andrew
PERSON
Woody Allen
PERSON
Eric Trump
PERSON
United States
LOCATIONJane Doe
PERSONthe Southern District
LOCATION
Michael Jackson
PERSON
Michigan
LOCATION
the United States District Court
ORGANIZATION
United States District Court
ORGANIZATION
the United States Government
ORGANIZATION
Anderson
PERSON
Cynthia Nixon
PERSON
Bailey
PERSON
Hayes
PERSONFifteenth Judicial Circuit
ORGANIZATIONthe Circuit Court
ORGANIZATIONBordenkircher
PERSONMcLymont
LOCATION