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applies based upon the crime charged, then "the defendant carries the burden of production to come forward with evidence to rebut the presumption." United State v. Ouartermaine, 913 F.2d 910, 916 (11th Cir. 1990). Although the statutory presumption places a burden of production on a defendant, the burden of
original jurisdiction over the offense, a motion EFTA00191636 for revocation of the order or amendment of the conditions of release." Accordingly, the United States hereby files this emergency motion with the District Judge assigned to the case for immediate revocation of the Magistrate Judge's Order. THE CHARG
tates Supreme Court has interpreted this amendment to prohibit the imposition of excessLve bail without creating a right to bail in criminal cases. See United States' Salerno. 481 U.S. 739, 754.55 (1987)("Eighth Amendment does not grant absolute right to bail"). The subject of bail and detention also implicates t
atter for the pu ose of arriving at f its own "independent conclusion." See United States I uncan. 897 F. Supp. 688, 689-90 (N.D.N.Y. 1995) citing United States Lam, 766 F.2d Ch. 17 Bail and Deternion 553 EFTA00191622 77, 80 (2d Cir. 1985); see also U ted States ' King, 849 F.2d 485, 489-91 (11th Cir. 1988)
imed that she made the money selling drugs; no one believed that either. finally admitted that she had been paid $300 to give a massage to a man on Palm Beach Island. parents approached the Palm Beach Police Department ("PBPD") about pressing charges. PBPD began investigating the recipient of the massage, Jeffre
k that physical force against the person . . . or another may be used in t the course of committing the offense." 18 U.S.C. § 16(b). Post-Johnson v. United Sta , U.S. 135 S. Ct. 2551 (2015), a court might decide differently. See, e.g., Menendez Whitaker, 908 F.3d 467 (9'b Cir. 2018). Even if not a crime
considered for work release. At some point after the NPA was signed, USA Acosta was recused from the Epstein matter. AUSA John McMillan (still at USA0): Early in the investigation, I asked AUSA McMillan if he would serve as co-counsel on the case. Before I joined the West Palm Beach Office, AUSA M
rate contact with Epstein. (See Exhibit A-1.) One of the subpoenaed victims was Individual #28, who is referred to as Jane Doe #2 in the Jane Doe' United Stales litigation. When approached for an interview, Individual #28 refused to speak with the agents, and I remember S/A Kuyrkendall telling me that she fe
GRAND JURY PROCEEDINGS SEALED ORDER GRANTING APPLICATION FOR PERMISSION TO DISCLOSE GRAND JURY MATERIAL THIS MATTER has come before the Court on the United States' Sealed Application for Permission to Disclose Grand Jury Material and for Entry of a Protective Order. The Court has considered the Motion and find
Epstein serve his time in a federal facility, rather than a state one, and I remember Mr. Goldberger saying that because Mr. Epstein's home was on Palm Beach Island and touching the Intracoastal Waterway, it was somehow in "international waters" and federal jurisdiction. Other items that were discussed were: (1)
de, or arouse or gratify the sexual desire of any person. And Chapter 109A states: "Whoever, in the special maritime and territorial jurisdiction of the United States or in a Federal prison, knowingly engages in a sexual act with another person who — (1) has attained the age of 12 years but has not attained the ag
hapter, shall order, in addition to any other sentence imposed and irrespective of any provision of State law, that such person shall forfeiture to the United States—(1) such person's interest EFTA00229874 in any property, real or personal, that was used or intended to be used to commit or to facilitate the commi
Island. was a classmate of JD#1 at Royal Palm Beach High School. asked JD#1 if she wanted to make some money giving a massage to a wealthy man on Palm Beach Island. JD#1 was told that she would be paid $200, she would have to remove some of her clothing, and that there might be some "fondling." JD#1 agreed to
internal as I tried to deal professionally with opposing counsel. In the midst of all of the post-NPA back-and-forth with Epstein, was the Jane Doe. United States litigation.4 Despite the Office's request to be recused from the case, the Justice Department decided that there was no conflict of interest and I w
ederal facility, Page 23 of 58 EFTA00225066 rather than I state one, and I remember Mr. Goldberger saying that because Mr. Epstein's home was on Palm Beach Island and touching the Intracoastal Waterway, it was somehow in "international waters" and federal jurisdiction. Other items that were discussed were: (1)
ar that the 2008 deal in Florida did not apply. "The agreement, by its terms, only binds the Southern District of Florida," Geoffrey S. Berman, the United States attorney in Manhattan, said on Monday. The indictment marked the downfall of a man who had, until then, been dogged for years by allegations that he
ed. Ma : The three of us slid into the backseat of the cab, and we drove, and I remember just driving oulevard and thinking how I had never been on Palm Beach Island before, in my whole entire life that I had lived in West Palm Beach. By the time I was 16, I brought him up to 75 girls, all the ages of, you know,
ar that the 2008 deal in Florida did not apply. "The agreement, by its terms, only binds the Southern District of Florida," Geoffrey S. Berman, the United States attorney in Manhattan, said on Monday. The indictment marked the downfall of a man who had, until then, been dogged for years by allegations that he
ee of us slid into the backseat of the cab, and we drove, and I remember just driving down Okeechobee Boulevard and thinking how I had never been on Palm Beach Island before, in my whole entire life that I had lived in West Palm Beach. By the time I was 16, I brought him up to 75 girls, all the ages of, you know,
l wrangling, Mr. Epstein pleaded guilty to lesser state charges. Upon his release from jail, he must register as a sex offender wherever he goes in the United States. People from all walks of life break the law, of course. But for the rich, wrapped in a cocoon of immense comfort, it can be easy to yield to tempt
tified his picture in an instant in a photo lineup, police threw themselves into an investigation of the modem and palatial house on El Brillo Way. Palm Beach Island is a 3.75-square-mile spit of land famous for towering ficus privacy hedges on Mediterranean-influenced architecture that begins at over $5 million
t the victim is a minor, regardless of what the victim says or how the victim appears. Id. (emphasis added; additional internal citations omitted). Cl United States v. Wild, 143 7 EFTA02857530 Fed. Appx. 938, 942 (4th Cir. 2005) (the parties agreed that, to prove a violation of § 2423(a), the United States h
Page: EFTA02857524_p7 →club on Singer Island. was a classmate of JD#1 at High School. asked JD#1 if she wanted to make some money giving a massage to a wealthy man on Palm Beach Island. JD#1 was told that she would be paid $200, she would have to remove some of her clothing, and that there might be some "fondling." JD#1 agreed to
Page: EFTA02857524_p32 →05, even though Jane Doe #2 never went to EPSTEIN's house because at the time of his travel, EPSTEIN intended for Jane Doe #2 to come to the house. See United States v. Han, 230 F.3d 560 (2d Cir. 2000) (defendant could be convicted of violating Section 2423(b) even though no sexual activity occurred and "minor"
Page: EFTA02857524_p39 →de, or arouse or gratify the sexual desire of any person. And Chapter 109A states: "Whoever, in the special maritime and territorial jurisdiction of the United States or in a Federal prison, knowingly engages in a sexual act with another person who — (1) has attained the age of 12 years but has not attained the ag
Page: EFTA02857810_p10 →hapter, shall order, in addition to any other sentence imposed and irrespective of any provision of State law, that such person shall forfeiture to the United States—(1) such person's interest in any property, real or personal, that was used or intended to be used to commit or to facilitate the commission of such v
Page: EFTA02857810_p15 →h club on Singer Island. was a classmate of JD#1 at High School. asked JD#1 if she wanted to make some money giving a massage to a wealthy man on Palm Beach Island. JD#1 was told that she would be paid $200, she would have to remove some of her clothing, and that there might be some "fondling." JD#1 agreed to
Page: EFTA02857810_p17 →med that she made the money selling drugs; no one believed that either. finally admitted that she had been paid $300 to give a massage to a man on Palm Beach Island. parents approached the Palm Beach Police Department ("PBPD") about pressing charges. PBPD began investi atin the recipient of the massage, Jeffre
Page: EFTA02857732_p1 →s chapter, shall order, in addition to any other sentence imposed and irrespective of any provision of State law, that such person shall forfeit to the United States—(1) such person's interest in any property, real or personal, that was used or intended to be used to commit or to facilitate the commission of such v
Page: EFTA02857732_p15 →Entities connected to both United States and Palm Beach Island

Jeffrey Epstein
PERSON
George W. Bush
PERSON
Ghislaine Maxwell
PERSON
Department of Justice
ORGANIZATIONthe Southern District
LOCATIONLeon Black
PERSON
Prince Andrew
PERSON
Alan Dershowitz
PERSON
John F. Kennedy
PERSON
Alexander Acosta
PERSONJane Doe
PERSONFBI
ORGANIZATION
Kenneth Marra
PERSON
Bradley Edwards
PERSON
Prince Charles
PERSON
Marc Rich
PERSON
New York
LOCATION
Donald Trump
PERSON
Bill Clinton
PERSONJack Goldberger
PERSON