Epstein Secrets

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

d by Landgraf Only one case has applied 35 EFTA00100002 Toussie to the Landgraf analysis, see United States v. Gentile, 235 F. Supp. 3d 649, 655 (D.NJ. 2017), and that case, which did not concern Section 3283, relied extensively on a pre-Landginf opinion requiring a clear statement of congressiona

DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA JANE DOE No. 101, Case No.: 9:09-CV-80591-KAM Plaintiff, v. JEFFREY EPSTEIN, Defendant. DEFENDANT JEFFREY EPSTEIN'S MOTION TO DISMISS THE FIRST AMENDED COMPLAINT OR, IN THE ALTERNATIVE, FOR A MORE DEFINITE STATEMENT Defendant JEFFREY EPSTEIN, by and through his u

ed on FLSD Docket 05/26/2009 Page 27 of 36 Defendant's mansion in or about the spring of 2003," FAC ¶ 18, and that she later was "lured ... to the Epstein mansion on at least one and perhaps two other occasions in the spring and/or summer of 2003." Id. ¶ 19. Since these vague allegations leave open the

01, Case No.: 9:09-CV-80591-KAM Plaintiff, v. JEFFREY EPSTEIN, Defendant. DEFENDANT JEFFREY EPSTEIN'S

e.g., &nig v. Pension Ben. Guar. Com. 744 F.2d 133, 145 & n.7 (D.C. Cr. 1984); DIRECTV Inc. v. Cigoarella No. Civ.A 03-2384, 2005 WL 1252261 at *7 (D.NJ. May 24, 2005); Clohessv v. St Francis Host & Healthcare No. 98-C-4818, 1999 In 46898'2-•3 (ND. III. Jan. 28, 1999), and there is good reason to do

DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA JANE DOE No. 101, Case No.: 9:09-CV-80591-KAM Plaintiff, v. JEFFREY EPSTEIN, Defendant. DEFENDANT JEFFREY EPSTEIN'S MOTION TO DISMISS THE FIRST AMENDED COMPLAINT OR, IN THE ALTERNATIVE, FOR A MORE DEFINITE STATEMENT Defendant JEFFREY EPSTEIN, by and through his u

ed on FLSD Docket 05/26/2009 Page 27 of 36 Defendant's mansion in or about the spring of 2003," FAC ¶ 18, and that she later was "lured ... to the Epstein mansion on at least one and perhaps two other occasions in the spring and/or summer of 2003." Id. ¶ 19. Since these vague allegations leave open the

01, Case No.: 9:09-CV-80591-KAM Plaintiff, v. JEFFREY EPSTEIN, Defendant. DEFENDANT JEFFREY EPSTEIN'S

e.g., &nig v. Pension Ben. Guar. Com. 744 F.2d 133, 145 & n.7 (D.C. Cr. 1984); DIRECTV Inc. v. Cigoarella No. Civ.A 03-2384, 2005 WL 1252261 at *7 (D.NJ. May 24, 2005); Clohessv v. St Francis Host & Healthcare No. 98-C-4818, 1999 In 46898'2-•3 (ND. III. Jan. 28, 1999), and there is good reason to do

DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA JANE DOE No. 101, Case No.: 9:09-CV-80591-KAM Plaintiff, v. JEFFREY EPSTEIN, Defendant. DEFENDANT JEFFREY EPSTEIN'S MOTION TO DISMISS THE FIRST AMENDED COMPLAINT OR, IN THE ALTERNATIVE, FOR A MORE DEFINITE STATEMENT Defendant JEFFREY EPSTEIN, by and through his u

ed on FLSD Docket 05/26/2009 Page 27 of 36 Defendant's mansion in or about the spring of 2003," FAC ¶ 18, and that she later was "lured ... to the Epstein mansion on at least one and perhaps two other occasions in the spring and/or summer of 2003." Id. ¶ 19. Since these vague allegations leave open the

01, Case No.: 9:09-CV-80591-KAM Plaintiff, v. JEFFREY EPSTEIN, Defendant. DEFENDANT JEFFREY EPSTEIN'S

e.g., &nig v. Pension Ben. Guar. Com. 744 F.2d 133, 145 & n.7 (D.C. Cr. 1984); DIRECTV Inc. v. Cigoarella No. Civ.A 03-2384, 2005 WL 1252261 at *7 (D.NJ. May 24, 2005); Clohessv v. St Francis Host & Healthcare No. 98-C-4818, 1999 In 46898'2-•3 (ND. III. Jan. 28, 1999), and there is good reason to do

DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA JANE DOE No. 101, Case No.: 9:09-CV-80591-KAM Plaintiff, v. JEFFREY EPSTEIN, Defendant. DEFENDANT JEFFREY EPSTEIN'S MOTION TO DISMISS THE FIRST AMENDED COMPLAINT OR, IN THE ALTERNATIVE, FOR A MORE DEFINITE STATEMENT Defendant JEFFREY EPSTEIN, by and through his u

ed on FLSD Docket 05/26/2009 Page 27 of 36 Defendant's mansion in or about the spring of 2003," FAC ¶ 18, and that she later was "lured ... to the Epstein mansion on at least one and perhaps two other occasions in the spring and/or summer of 2003." Id. ¶ 19. Since these vague allegations leave open the

01, Case No.: 9:09-CV-80591-KAM Plaintiff, v. JEFFREY EPSTEIN, Defendant. DEFENDANT JEFFREY EPSTEIN'S

e.g., &nig v. Pension Ben. Guar. Com. 744 F.2d 133, 145 & n.7 (D.C. Cr. 1984); DIRECTV Inc. v. Cigoarella No. Civ.A 03-2384, 2005 WL 1252261 at *7 (D.NJ. May 24, 2005); Clohessv v. St Francis Host & Healthcare No. 98-C-4818, 1999 In 46898'2-•3 (ND. III. Jan. 28, 1999), and there is good reason to do

DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA JANE DOE No. 101, Case No.: 9:09-CV-80591-KAM Plaintiff, v. JEFFREY EPSTEIN, Defendant. DEFENDANT JEFFREY EPSTEIN'S MOTION TO DISMISS THE FIRST AMENDED COMPLAINT OR, IN THE ALTERNATIVE, FOR A MORE DEFINITE STATEMENT Defendant JEFFREY EPSTEIN, by and through his u

ed on FLSD Docket 05/26/2009 Page 27 of 36 Defendant's mansion in or about the spring of 2003," FAC ¶ 18, and that she later was "lured ... to the Epstein mansion on at least one and perhaps two other occasions in the spring and/or summer of 2003." Id. ¶ 19. Since these vague allegations leave open the

01, Case No.: 9:09-CV-80591-KAM Plaintiff, v. JEFFREY EPSTEIN, Defendant. DEFENDANT JEFFREY EPSTEIN'S

e.g., &nig v. Pension Ben. Guar. Com. 744 F.2d 133, 145 & n.7 (D.C. Cr. 1984); DIRECTV Inc. v. Cigoarella No. Civ.A 03-2384, 2005 WL 1252261 at *7 (D.NJ. May 24, 2005); Clohessv v. St Francis Host & Healthcare No. 98-C-4818, 1999 In 46898'2-•3 (ND. III. Jan. 28, 1999), and there is good reason to do