Epstein Secrets

24 F.2d 158 (11th Cir. 1955) 55 *Perlman v. United States, 247 U.S. 7 (1918) passim Reichenbach v. Smith, 528 F.2d 1072 (11th Cir. 1976) 32 Ross v. City of Memphis, 423 F.3d 596 (6th Cir. 2007) 54 *Santobello v. United States, 404 U.S. 257 (1971) 15, 16,31 S.E.C. v. CMKM Diamonds, Inc.

on a promise or agreement of the prosecutor, so that it can be said to be part of the inducement or consideration, such promise must be fulfilled." Santobello v. New York, 404 U.S. 257 (1971). Rescission of the NPA would violate Epstein's constitutional and contractual rights. See, e.g., United States v.

247 U.S. 7 (1918) passim Reichenbach v. Smith, 528 F.2d 1072 (11th Cir. 1976) 32 Ross v. City of Memphis, 423 F.3d 596 (6th Cir. 2007) 54 *Santobello v. United States, 404 U.S. 257 (1971) 15, 16,31 S.E.C. v. CMKM Diamonds, Inc., 656 F.3d 829 (9th Cir. 2011) 55 Sheldone v. Pennsylvania Turn

cluding but not limited to Sarah Kellen, Adrian& Ross, Lesley Groff, or Nadia Mareinkova. Further, upon

-c‘O3O3B.49664-0CtailltdReta 2fft3eurfetteSCt off ikkElEgaltket (0748/S01315Page 5 of 20 obligations undertaken therein to be set aside.4 See, e.g., Santobello v. New York 404 U.S. 257, 262 (1971) ("[W]hen a plea rests in any significant degree on a promise or agreement of the prosecutor, so that it can be

greement, the United States would still be constitutionally required to adhere to the negotiated terms of the Non-Prosecution Agreement. See, e.g., Santobello, 404 U.S. at 262; Harvey, 869 F.2d at 1443. Due process considerations further bar this Court from setting aside a non-prosecution agreement that g

r Jack Patrick Hill Michael James Pike Michael Ross Tein Richard Horace Willits Robert Deweese Crit

fter a court determination that Epstein had violated the agreement could the U.S. Attorney's Office move forward to prosecute Epstein. See generally Santobello v. New York, 404 U.S. 257 (1971). Finally and most fundamentally, Epstein has it entirely within his power to avoid criminal prosecution by comply

ct Court for the Dis- trict of South Carolina, G. Ross Anderson, Jr., J., certified class, and lender a

cluding plea, cooperation, and im- munity agreements—to the extent the agreements require defendants to sacrifice constitutional rights. See, e.g., Santobello v. New York 404 U.S. 257, 262, 92 S.Ct. 495, 30 L.Ed.2d 427 (1971); United States v. Hodge, 412 F.3d 479, 485 (3d Cir.2005) ("The government must

on from disclosure to the plaintiffs. See, e.g., Ross v. City of Memphis, 423 F.3d 596, 599 (6th Cir. 2

ited States v. Hill, 643 F.3d 807, 874 (11th Cir. 2011), quoting United States v. Harvey, 869 F.2d 1439, 1443 (11th Cir.1989) (en bane). See, e.g., Santobello v. New York, 404 U.S. 257, 262 (1971)(` when a plea rests in any significant degree on a promise ... of the prosecutor, so that it can be said to be

ed. You have asked me to set out the basis for my request and that you apply thirugh appropriate channels for a ormal grant of use immunity or Ms. Ross. I do so here. As I indicated to you when we conversed last week, Ms. Ross is no longer employed by Mr. Epstein, but has read much of what can be

ot to prosecute in return for a person's cooperation binds the government to the extent that the person carries out his/her part of the bargain. See Santobello v. New York 404 U.S. 257 (1971); Wade v. United States, 112 S. Ct. 1840 (1992). Since such an agreement forecloses enforcement of the criminal law