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me, 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"
illegal sex acts, and aiding and abetting the same, in violation of 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 - EFTA00095067 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 York 4 1. The Text of the Agreement
media. See, e.g., "Read the report: Investigation into the U.S. Attorney's Office for the Southern District of Florida's Resolution of Its 2006-2008 Federal Criminal Investigation of Jeffrey Epstein and Its Interactions with Victims during the Investigation," Washington Post, Nov. 12, 2020 (https://www.washingtonpost.corn/context/
For A Millionaire Sex Abuser," Huffington Post, Nov. 29, 2018; Julie K. Brown, et al., "Lawmakers issue call for investigation of serial sex abuser Jeffrey Epstein's plea deal," Miami Herald, Dec. 6, 2018. Doe v. United States, 359 F. Supp. 3d 1201 (S.D. Fla., Feb. 21, 2019) (Opinion and Order, 9:08.80736-C1V- Ma
in by negotiating and executing a federal non-prosecution agreement (NPA). The NPA was intended to end a federal investigation into allegations that Epstein engaged in illegal sexual activity with girls.' OPR also investigated whether USAO prosecutors committed professional misconduct by failing to cons
Its 2006-2008 Federal Criminal Investigation of Jeffrey Epstein and Its Interactions with Victims during
LITY EXECUTIVE SUMMARY OF REPORT Investigation into the U.S. Attorney's Office for the Southern District of Florida's Resolution of Its 2006-2008 Federal Criminal Investigation of Jeffrey Epstein and Its Interactions with Victims during the Investigation November 2020 EFTA00095559 EXECUTIVE SUMMARY The Department of Justice
For A Millionaire Sex Abuser," Huffington Post, Nov. 29, 2018; Julie K. Brown, et al., "Lawmakers issue call for investigation of serial sex abuser Jeffrey Epstein's plea deal," Miami Herald, Dec. 6, 2018. Doe v. United States, 359 F. Supp. 3d 1201 (S.D. Fla., Feb. 21, 2019) (Opinion and Order, 9:08.80736-CIV- Ma
in by negotiating and executing a federal non-prosecution agreement (NPA). The NPA was intended to end a federal investigation into allegations that Epstein engaged in illegal sexual activity with girls.' OPR also investigated whether USAO prosecutors committed professional misconduct by failing to cons
Its 2006-2008 Federal Criminal Investigation of Jeffrey Epstein and Its Interactions with Victims during
LITY EXECUTIVE SUMMARY OF REPORT Investigation into the U.S. Attorney's Office for the Southern District of Florida's Resolution of Its 2006-2008 Federal Criminal Investigation of Jeffrey Epstein and Its Interactions with Victims during the Investigation November 2020 EFTA00095728 EXECUTIVE SUMMARY The Department of Justice
For A Millionaire Sex Abuser," Halfington Post, Nov. 29, 2018; Julie K. Brown, et al., "Lawmakers issue call for investigation of serial sex abuser Jeffrey Epstein's plea deal," Miami Herald, Dec. 6, 2018. Doe v. United States, 359 F. Supp. 3d 1201 (S.D. Fla., Feb. 21, 2019) (Opinion and Order, 9:08-80736-CIV- Ma
in by negotiating and executing a federal non-prosecution agreement (NPA). The NPA was intended to end a federal investigation into allegations that Epstein engaged in illegal sexual activity with girls.' OPR also investigated whether USAO prosecutors committed professional misconduct by failing to cons
Its 2006-2008 Federal Criminal Investigation of Jeffrey Epstein and Its Interactions with Victims during
LITY EXECUTIVE SUMMARY OF REPORT Investigation into the U.S. Attorney's Office for the Southern District of Florida's Resolution of Its 2006-2008 Federal Criminal Investigation of Jeffrey Epstein and Its Interactions with Victims during the InvCstigation November 2020 EFTA01726257 EXECUTIVE SUMMARY The Department of Justice
Entities connected to both Jeffrey Epstein and Federal Criminal Investigation of

Donald Trump
PERSONJane Doe
PERSON
Kenneth Marra
PERSON
Julie K. Brown
PERSON
Alexander Acosta
PERSONthe Southern District
LOCATIONFBI
ORGANIZATIONFederal Bureau of Prisons
ORGANIZATION
Metropolitan Correctional Center
ORGANIZATION
Southern District of New York
ORGANIZATION
Palm Beach County
LOCATIONthe Eleventh Circuit
ORGANIZATION
Cynthia McFadden
PERSON
Ben Sasse
PERSONSheriff
ORGANIZATIONRon DeSantis
PERSONthe Court of Appeals
ORGANIZATIONPolice Department
ORGANIZATIONSasse
PERSONFederal Courts
ORGANIZATION