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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
Meeting 62 3. The April and July 2016 Depositions of Maxwell 64 4. The USAO-SDNY Commences the Instant Investigation in 2018 65 68 I I I 6. Proceedin s before 5. The USAO-SDNY's Sub.. nas and Ex Pane Applications for Materials 66 a. M 68 b. April ', 70 EFTA00095068 c. Chief Judge McMah
eval service. - OR - Call 1.866.540.8818. US District Court Civil Docket U.S. District - Fiorida Souther (West Palm Beach) 9:09cv80469 Doe II'. Epstein et al This case was retrieved from the court on Sunday, July 18, 2010 Date Filed: Assigned To: Referred To: Nature of suit: Cause: Lead Docket
(Horowitz, Adam) (Entered: 10/21/2009) 10/21/2009 365 NOTICE OF WITHDRAWAL of Motion by C.M.A. re 331 MOTION for Protective Order as to Defendant, Jeffrey Epstein's. Attendance at Plaintiff's Deposition filed by C.M.A. DOCKET CORRECTION SEE DE 363 FOR IMAGE (tp) (Entered: 10/22/2009) 10/21/2009 367 REPLY to R
r) (Entered: 04/21/2008) AFFIDAVIT of Service for Summons and Complaint served on Jeffrey Epstein on May 7. 2008. filed by Jane Doe No. 4. (Herman. Jeffrey) (Entered: 05/22/2008) Plaintiff's MOTION for Entry of Default by Clerk Against Defendant by Jane Doe No. 4. (Attachments: # 1 Exhibit A and B. # 2
0/21/2009) RESPONSE/REPLY to 60 Amended Document Defendant Epstein's Answer & Affirmative Defenses to Plaintiff's F
's Office 500 South Australian Ave Suite 400 West Palm Beach , FL 33401 USA 561-820-8711 Fax: 820-8777 Email: [email protected] Proceedin. Text COMPLAINT against Jeffrey Epstein Filing fee $ 350. Receipt#: 724605, filed by Jane Doe.(rb) (Entered: 08/14/2008) MOTION to Proceed Anonymo
US District Court Civil Docket U.S. District - Florida Southern (West Palm Beach) 9:08cv80232 Doe No. 3 v. Epstein This case was retrieved from the court on Tuesday, October 28, 2008 Date Filed: 03/05/2008 Class Code: LRJ Assigned To: Judge Kenneth A Marra Cl
. Marra on 9/29/08. (ir) (Entered: 09/30/2008) 10/06/2008 41 Defendant's MOTION to Dismiss 37 Amended Complaint and for More Definite Statement by Jeffrey Epstein. Responses due by 10/24/2008 (Caton, Robert) (Entered: 10/06/2008) 10/06/2008 42 MOTION for More Definite Statement directed to amended complaint
s) (Entered: 03/11/2008) AFFIDAVIT of Service for Summons and Complaint served on Jeffrey Epstein on May 7, 2008, filed by Jane Doe No. 3. (Herman, Jeffrey) (Entered: 05/22/2008) Plaintiffs MOTION for Entry of Default by Clerk Against Defendant by Jane Doe No. 3. (Attachments: # 1 Exhibit A and B, # 2
ler Drive Suite 400 West Palm Beach, FL 33401-2918 USA Phone: (561)842-2820 Fax: (561)515-3148 Attorney to be Noticed Email: [email protected] Proceedin. Text COMPLAINT against Jeffrey Epstein Filing fee $ 350. Receipt*: 542769, filed by Jane Doe No. 4.(dj) (Entered: 04/14/2008) Summons Issued as t
Entities connected to both Jeffrey Epstein and Proceedin

Alan Dershowitz
PERSON
Bradley Edwards
PERSONJack Goldberger
PERSON
Sarah Kellen
PERSONJane Doe
PERSONMaria Farmer
PERSONMartin Weinberg
PERSON
Kenneth Marra
PERSONthe Southern District
LOCATION
Paul Cassell
PERSON
Wilbur Ross
PERSON
A. Marie Villafana
PERSON
Virginia Giuffre
PERSON
Scarlett Johansson
PERSONJeffrey Epstein VI Foundation
ORGANIZATION
Michael Jackson
PERSONRobert D. Critton
PERSONNadia Marcinkova
PERSONMichael J. Pike
PERSONRichard Horace Willits
PERSON