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s context, the terms "global" and "state and federal liability" plainly refer to 3 In fact, the NPA states that it was executed "on the authority of R. Alexander Acosta, United States Attorney for the Southern District of Florida." NPA at 2. 8 EFTA00099975 prosecutions by those two offices, and only those two of
After reviewing the facts and circumstances of the negotiation, OPR concluded that "the evidence does not show that [Former USAO-SDFL U.S. Attorney Alex] Acosta, [Former USAO-SDFL supervisor Andrew] Lourie, or Villafaiia agreed to the nonprosecution provision to protect any of Epstein's political, celebrity,
it was executed "on the authority of R. Alexander Acosta, United States Attorney for the Southern Distric
harged crimes and the victims referenced in the Indictment. Additionally, many of the defendant's requests fall within the scope of the Government's Giglio and Jencks Act obligations, which the Government intends to produce at the appropriate stage in the litigation, well in advance of trial. 20 The d
. Mot. 7 at 1). As noted above and discussed further in Section X, infra, the Government has complied with its Rule 16 obligations and will produce Giglio and Jencks Act materials well in advance of trial. The Court should reject the defendant's invitation to defer ruling on this motion. See, e.g., Uni
s context, the terms "global" and "state and federal liability" plainly refer to 3 In fact, the NPA states that it was executed "on the authority of R. Alexander Acosta, United States Attorney for the Southern District of Florida." NPA at 2. 8 EFTA00077640 prosecutions by those two offices, and only those two of
After reviewing the facts and circumstances of the negotiation, OPR concluded that "the evidence does not show that [Former USAO-SDFL U.S. Attorney Alex] Acosta, [Former USAO-SDFL supervisor Andrew] Lourie, or Villafafia agreed to the nonprosecution provision to protect any of Epstein's political, celebrity,
it was executed "on the authority of R. Alexander Acosta, United States Attorney for the Southern Distric
arged crimes and the victims referenced in the Indictment. Additionally, many of the defendant's requests fall within the scope of the Government's Giglio and Jencks Act obligations, which the Government intends to produce at the appropriate stage in the litigation, well in advance of trial. 20 The d
. Mot. 7 at 1). As noted above and discussed further in Section X, infra, the Government has complied with its Rule 16 obligations and will produce Giglio and Jencks Act materials well in advance of trial. The Court should reject the defendant's invitation to defer ruling on this motion. See, e.g., Uni
s context, the terms "global" and "state and federal liability" plainly refer to 3 In fact, the NPA states that it was executed "on the authority of R. Alexander Acosta, United States Attorney for the Southern District of Florida." NPA at 2. 8 EFTA00039455 prosecutions by those two offices, and only those two of
After reviewing the facts and circumstances of the negotiation, OPR concluded that "the evidence does not show that [Former USAO-SDFL U.S. Attorney Alex] Acosta, [Former USAO-SDFL supervisor Andrew] Lourie, or Villafafia agreed to the nonprosecution provision to protect any of Epstein's political, celebrity,
it was executed "on the authority of R. Alexander Acosta, United States Attorney for the Southern Distric
arged crimes and the victims referenced in the Indictment. Additionally, many of the defendant's requests fall within the scope of the Government's Giglio and Jencks Act obligations, which the Government intends to produce at the appropriate stage in the litigation, well in advance of trial. 20 The d
. Mot. 7 at 1). As noted above and discussed further in Section X, infra, the Government has complied with its Rule 16 obligations and will produce Giglio and Jencks Act materials well in advance of trial. The Court should reject the defendant's invitation to defer ruling on this motion. See, e.g., Uni
s conducted by the Florida State Attorney's Office and the USAO-SDFL. See id. at 3 In fact, the NPA states that it was executed "on the authority of R. Alexander Acosta, United States Attorney for the Southern District of Florida." NPA at 2. 8 EFTA00095100 1-2. Thus, in this context, the terms "global" and "stat
After reviewing the facts and circumstances of the negotiation, OPR concluded that "the evidence does not show that [Former USAO-SDFL U.S. Attorney Alex] Acosta, [Former USAO-SDFL supervisor Andrew] Lourie, or Villafafia agreed to the nonprosecution provision to protect any of Epstein's political, celebrity,
it was executed "on the authority of R. Alexander Acosta, United States Attorney for the Southern Distric
ismissal of an indictment filed within the statute of limitations must establish that the Government acted intentionally, scope of the Government's Giglio and Jencks Act obligations, which the Government intends to produce at the appropriate stage in the litigation, well in advance of trial. 20 The de
not been dismissed on other grounds." (Def. Mot. 7 at 1). As noted above, the Government has complied with its Rule 16 obligations and will produce Giglio and Jencks Act materials well in advance of trial, consistent with whatever schedule the parties agree upon or this Court sets. The Court should re
it was executed "on the authority of R. Alexander Acosta, United States Attorney for the Southern Distric
s context, the terms "global" and "state and federal liability" plainly refer to 3 In fact, the NPA states that it was executed "on the authority of R. Alexander Acosta, United States Attorney for the Southern District of Florida." NPA at 2. 8 EFTA00103033 prosecutions by those two offices, and only those two of
After reviewing the facts and circumstances of the negotiation, OPR concluded that "the evidence does not show that [Former USAO-SDFL U.S. Attorney Alex] Acosta, [Former USAO-SDFL supervisor a M, or agreed to the nonprosecution provision to protect any of Epstein's political, celebrity, or other influenti
arged crimes and the victims referenced in the Indictment. Additionally, many of the defendant's requests fall within the scope of the Government's Giglio and Jencks Act obligations, which the Government intends to produce at the appropriate stage in the litigation, well in advance of trial. The defe
. Mot. 7 at 1). As noted above and discussed further in Section X, infra, the Government has complied with its Rule 16 obligations and will produce Giglio and Jencks Act materials well in advance of trial. The Court should reject the defendant's invitation to defer ruling on this motion. See, e.g., Uni
those individuals are not the ones who at the time reviewed the evidence available for trial and assessed the likelihood of success. Respectfully, R. Alexander Acosta Former U.S. Attorney Sothern District of Florida EFTA00231603 U S.J. QUINNEY COLLEGE OF LAW , THE UNIVERSITY OF UTAH Wifredo A. Ferrer Unite
kelihood of success. Respectfully, R. Alexander Acosta Former U.S. Attorney Sothern District of Florid
ting criminals, your Office would promptly turn over to us all information in its possession that was helpful to these criminals under the Brady and Giglio decisions. We asked your Office to extend to the victims the same assistance that it would provide to criminals — i.e., we asked and to voluntari
those individuals are not the ones who at the time reviewed the evidence available for trial and assessed the likelihood of success. Respectfully, R. Alexander Acosta Former U.S. Attorney Sothern District of Florida EFTA00232723 U n, S.J. QUINNEY COLLEGE OF LAW THE UNIVERSITY OF UTAH Wifredo A. Ferrer Uni
kelihood of success. Respectfully, R. Alexander Acosta Former U.S. Attorney Sothern District of Florid
ting criminals, your Office would promptly turn over to us all information in its possession that was helpful to these criminals under the Brady and Giglio decisions. We asked your Office to extend to the victims the same assistance that it would provide to criminals — i.e., we asked and to voluntari
Entities connected to both Alexander Acosta and Giglio

Jeffrey Epstein
PERSON
Department of Justice
ORGANIZATION
United States
LOCATION
A. Marie Villafana
PERSON
Jay Lefkowitz
PERSONthe Southern District
LOCATIONLeon Black
PERSON
Kenneth Marra
PERSONJack Goldberger
PERSONFBI
ORGANIZATION
Prince Andrew
PERSONSouthern District
LOCATIONJane Doe
PERSON
Bradley Edwards
PERSON
George W. Bush
PERSONRoy Black
PERSON
Dexter Lee
PERSON
Alan Dershowitz
PERSON
Donald Trump
PERSON
Ken Starr
PERSON