Epstein Secrets

ortions of the correspondence written by government attorneys — all of the writings of Mr. Epstein's attorneys, excepts for a few short portions by Jack Goldberger— have been redacted. The Intervenor Attorneys ask that the Court order that the Jane Does cannot use the unredacted portions and deny their motion

orneys, excepts for a few short portions by Jack Goldberger— have been redacted. The Intervenor Attorneys as

nt between the prosecutor and the accused, sometimes loosely called 'plea bargaining,' is an essential component of the administration of justice." Santobello v. New York, 404 U.S. 257, 260, 92 S. Ct. 495, 30 L.Ed. 2d 427 (1971). The Supreme Court has declared that plea bargaining "is to be encouraged." I

s for Defendant Robert Deweese Critton, Jr. [email protected] Michael James Plke Burman Critton Luttier & Coleman Lead Counsel Paul G. Cassell Jack Alan Goldberger Atterbury Goldberger & Weiss, P.A. Co-Counsel Attorneys for Plaintiff Bradley James Edwards Rothstein Rosenfeldt Adler Lead Counsel Pm Hac Vic

n FLSD Docket 04/09/2009 Page 6 of 14 criminal defense attorneys, Jack Goldberger. Not surprisingly given the seriousness of such allegations, the Goldberger affidavit makes no such contention. Instead, the Goldberger affidavit is carefully worded to assert only that the U.S. Attorney's Office "might con

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

ortions of the correspondence written by government attorneys — all of the writings of Mr. Epstein's attorneys, excepts for a few short portions by Jack Goldberger— have been redacted. The Intervenor Attorneys ask that the Court order that the Jane Does cannot use the unredacted portions and deny their motion

orneys, excepts for a few short portions by Jack Goldberger— have been redacted. The Intervenor Attorneys as

nt between the prosecutor and the accused, sometimes loosely called 'plea bargaining,' is an essential component of the administration of justice." Santobello v. New York, 404 U.S. 257, 260, 92 S. Ct. 495, 30 L.Ed. 2d 427 (1971). The Supreme Court has declared that plea bargaining "is to be encouraged." I

d to assert only that the U.S. Attorney's Office "might consider" various actions to be a breach of the non-prosecution agreement. See Affidavit of Jack A. Goldberger, Esq., at 2 (emphasis added)) This is a far cry from what Epstein's motion to stay asserts — that °the USAO has already claimed that Epstein violat

FLSD Docket 04/09/2009' Page 6 of 14 criminal defense attorneys, Jack Goldberger. Not surprisingly given the seriousness of such allegations, the Goldberger affidavit makes no such contention. Instead, the Goldberger affidavit is carefully worded to assert only that the U.S. Attorney's Office "might con

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

portions of the correspondence written by government attorneys — all of the writings of Mr. Epstein's attorneys, except for a few short portions by Jack Goldberger — have been redacted"). 10 EFTA00583789 address Mr. Epstein's arguments regarding the recognition of a privilege under Fed. R. Civ. P. 501. As

ttorneys, except for a few short portions by Jack Goldberger — have been redacted"). 10 EFTA00583789 addr

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

were already pending against lender in bankruptcy adversary proceeding. Fed. Rules Civ.Proc.Rule 23(bX3), 28 U.S.C.A. ARGUED: Daniel P. Shapiro, Goldberg, Kohn, Bell, Black, Rosenbloom & Moritz, Ltd, Chicago, Illinois, for Appellant. Gil- bert Scott Bagnell, Bagnell & Eason, L.L.C., Columbia, South

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