Epstein Secrets

tervenor Date Filed: 07/07/2008 Jury Demand: None Nature of Suit: 440 Civil Rights: Other Jurisdiction: U.S. Government Defendant represented by Bradley James Edwards Farmer Jaffe Wcissing Edwards Fistos &Lehrman PL 425 N Andrews Avenue Suite 2 Fort Lauderdale, FL 33301 954-524-2820 Fax: 954-524-2822 Email:

toj2 Response in Opposition to Motion to Unseal Non—Prosecution Agreement filed by Jane Doe. (Attachments: fll. Exhibit October 9, 2008 letter from Brad Edwards, Esquire to AUSA Dexter Lee, #.2 Exhibit October 15, 2008 Letter from Brad Edwards, Esquire to AUSA Dexter Lee)(Edwards, Bradley) (Entered: 10/16/2

otion to Unseal Document. Signed by Judge- on 2/12/2009. (ir) (Entered: 02/12/2009) 04/09/2009 E NOTICE by Jane Doe of Change of Finn Affiliation (Edwards, Bradley) (Entered: 04/09/2009) 09/08/2010 a Administrative Order Closing Case. Signed by Judge on 9/8/2010. (tb) (Entered: 09/09/2010) 09/13/

m of trials," it is insufficient simply to point to the guarantee of a fair trial as a backstop that inoculates any errors in the pretrial process. Lafler v. Cooper, 132 S. Ct. 1376, 1388 (2012); Missouri v. Frye, 132 S. Ct. 1399, 1407 (2012). In Lafler and Frye, the Supreme Court ruled that the Sixth

. . Mr. Epstein, in a sense, would then be adversely affected by my actions when he acted in reliance upon the agreement. How does that work? MR. EDWARDS: Certainly, we are only asking you to vacate the agreement. I understand and your point is well taken. And I believe that at that point in time his

d Epstein re-file this reply, which is identical to the reply that was previously filed during the litigation on intervention. We only add that, in Lafler' Cooper, 132 S. Ct. 1376 (2012) and Missouri.. Frye, 132 S. Ct. 1399 (2012), the United States Supreme Court flatly rejected the arguments by Jane D

rsons have an interest in the outcome of this case: 1. Marra, The Honorable Kenneth 2. Acosta, R. Alexander 3. Black, Roy 4. Cassell, Paul G. 5. Edwards, Bradley J. 6. Epstein, Jeffrey 7. Ferrer, Wifredo A. 8. Howell, Jay 9. 10 11 12 13 14 15 11 Page C-1 of 2 EFTA00209658 Case: 13-12923

s is "a system o f pleas, not a system of trials." Lafler v. Cooper, 132 S.Ct. 1376, 1388 (2012); Missouri v. Frye, 132 S. Ct. 1399, 1407 (2012). In Lafler and Frye, the Supreme Court ruled that the Sixth Amendment right to effective assistance of counsel "extends to the plea bargaining process" and th