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ument 361-62 Entered on FLSD Docket 02/10/2016 Page 2 of 15 CV RE: INVESTIGATION OF JEFFREY EPSTEIN NON-PROSECUTION AGREEMENT IT APPEARING that the City of Palm Beach Police Department and the State Attorney's Office for the 15th Judicial Circuit in and for Palm Beach County (hereinafter, the "State Attorney's Office") have conduc
— has proven effective in meeting those goals in many prominent cases prosecuted in our Circuit, including cases against defendants as infamous as Bernie Madoff, Marc Dreier and David Brooks. To be clear, defense counsel are fully confident Mr. Epstein will appear as required without resort to this measure.
es v. Seng, No. 15-CR-706, 2017 WL 2693625 (S.D.N.Y. Oct. 23, 2015); United States v. Dreier, 596 F. Supp. 2d 831 (S.D.N.Y. 2009); United States v. Madoff, 586 F. Supp. 2d 240 (S.D.N.Y. 2009); United States v. Schlegel, No. 06-CR-550, 2008 WL 11338900, at *1 (E.D.N.Y. June 13, 2008), modification denie
ument 361-62 Entered on FLSD Docket 02/10/2016 Page 2 of 15 CV RE: INVESTIGATION OF JEFFREY EPSTEIN NON-PROSECUTION AGREEMENT IT APPEARING that the City of Palm Beach Police Department and the State Attorney's Office for the 15th Judicial Circuit in and for Palm Beach County (hereinafter, the "State Attorney's Office") have conduc
es v. Seng, No. 15-CR-706, 2017 WL 2693625 (S.D.N.Y. Oct. 23, 2015); United States v. Dreier, 596 F. Supp. 2d 831 (S.D.N.Y. 2009); United States v. Madoff, 586 F. Supp. 2d 240 (S.D.N.Y. 2009); United States v. Schlegel, No. 06-CR-550, 2008 WL 11338900, at *1 (E.D.N.Y. June 13, 2008), modification denie
— has proven effective in meeting those goals in many prominent cases prosecuted in our Circuit, including cases against defendants as infamous as Bernie Madoff, Marc Dreier and David Brooks. To be clear, defense counsel are fully confident Mr. Epstein will appear as required without resort to this measure.
e Epstein/Staley relationship, Staley understood that Epstein's money was only a part of the incentive to protect Epstein's operation. 147. During the Palm Beach Police Department's 2005 investigation into Epstein's sexual abuse of minor children, the detectives pulled message pads left by Epstein's assistant from his trash as
in was pleading guilty to felony sex offenses and registering as a lifetime sex offender, JP Morgan learned that another of its high value clients, Bernie Madoff, was running the largest Ponzi- scheme in modern history through his accounts at JP Morgan. This led to .n) Morgan 52 EFTA00162172 Case 1:22-cv-1
Entities connected to both Palm Beach Police Department and Bernie Madoff

Jeffrey Epstein
PERSON
Alexander Acosta
PERSONLeon Black
PERSON
United States
LOCATION
George W. Bush
PERSONFBI
ORGANIZATIONthe Southern District
LOCATION
Prince Andrew
PERSON
Donald Trump
PERSON
Marc Rich
PERSON
Ghislaine Maxwell
PERSON
Jared Kushner
PERSON
J. Robert Oppenheimer
PERSONBerger
PERSONGerald Lefcourt
PERSON
Department of Justice
ORGANIZATION
Bill Clinton
PERSONJack Goldberger
PERSON
Julie K. Brown
PERSONMartin Weinberg
PERSON