Epstein Secrets

this Court should calculate Jenne's combined offense level to be 15 and his advisory guideline range to be 18 - 24 months. Respectfully submitted, R. ALEXANDER ACOSTA UNITED STATES ATTORNEY By: s/ Matthew S. Axelrod Michael Patrick Sullivan Fla. Bar No. 134814 Matthew S. Axelrod Court ID No. A5500771 Assista

24 months. Respectfully submitted, R. ALEXANDER ACOSTA UNITED STATES ATTORNEY By: s/ Matthew S. Axelro

rules in the manner contemplated by the parties' plea agreement and, thereby, to arrive at the proper advisory sentencing range of 18 to 24 months. Jenne's defense attorney, J. David Bogenschutz, has advised the undersigned Assistant United States Attorneys that he has no objection to this request.

should reject the PSI's conclusion that the four counts of conviction should be grouped together pursuant to § 3D1.2(c) and should instead compute Jenne's advisory guideline sentence in accordance with the joint recommendation contained in the parties' plea agreement. As a result, this Court should c

not aware of any "special circumstances" that warrant staying all of the civil cases pending the "expiration" of the NPA. Respectfully submitted, R. ALEXANDER ACOSTA UNITED STATES ATTORNEY By: ssistant United States Attorne 500 East Broward Boulevard, 7th Floor Ft. Lauderdale, FL 33394 Telephone: Facsimile:

you and your client to agree to unconscionable contract terms cannot square with the true facts of this case. As explained in letters from Messrs. Acosta and Sloman, the indictment was postponed for more than five months to allow you and Mr. Epstein's other attorneys to make presentations to the Offi

mendment right against compelled self-incrimination in connection with civil litigation, a court can stay discovery or the entire civil case. Diaz'. Jenne, 2007 WL 624286 al (S.D. Fl. Feb. 23, 2007) (Cooke, J.). "However, 'the Constitution does not require a stay of civil proceedings pending the outco

ion” of the NPA. Respectfully submitted, R. ALEXANDER ACOSTA UNITED STATES ATTORNEY By: s/A. Marie Villafa

endment right against compelled self-incrimination in connection with civil litigation, a court can stay discovery or the entire civil case. Diaz v. Jenne, 2007 WL 624286 *1 (S.D. Fl. Feb. 23, 2007) (Cooke, J.). “However, ‘the Constitution does not require a stay of civil proceedings pending the outcom

ion” of the NPA. Respectfully submitted, R. ALEXANDER ACOSTA UNITED STATES ATTORNEY By: s/A. Marie Villafa

stay discovery or the entire civil case. Diaz v. Jenne, 2007 WL 624286 *1 (S.D. Fl. Feb. 23, 2007) (Cook