Epstein Secrets

d-2(a). See, CL Superseding Indictment, United States v. Nexus Technologies, et al., No. 08-cr-522 (E.D. Pa. Oct. 28, 2009), ECF No. 106 [hereinafter Uzited States v. Nexus Technologies] (private US. company and corporate executives charged with violating FCPA for bribes paid in Vietnam), available at http ://ww

(h) Definitions For purposes of this section: (1) The term “domestic concern” means— (A) any individual who is a citizen, national, or resident of the United States; and (B) any corporation, partnership, association, joint-stock company, business trust, unincorporated organization, or sole proprietorship which h

omplaints/20 10/comp2 1454.pdf; Criminal Information at 8, United States v. Innospec Inc., No. 10-cr-61 (D.D.C. Mar. 17,2010), ECF No. 1 [hereinafter Uvited States v. Jnnospec], available at http ://www.justice.gov/ criminal/fraud/ fcpa/ cases/innospec- inc/03-17- 10innospec-info.pdf. 80 See Complaint, SEC v. In

oted that “[i]n interpreting what is lawful under the written laws and regulations’ ... the normal rules of legal construction would apply.” Jd. 143 See United States v. Kozeny, 582 FE Supp. 2d 535, 537-40 (S.D.NY. 2008). Likewise, the court found that a provision under Azeri law that relieved bribe payors of crimi

ors in Criminal Division Matters (June 24, 2009), available at hetp:/ /www. justice.gov/criminal/fraud/fcpa/docs/response3 -supp-appx-3.pdf; see also Craig S. Morford, Acting Dep. Att’y Gen., US. Dept. of Justice, Mem. to the Heads of Department Components and United States Attorneys on Selection and Use of Monitor

10T1 GEN I l OFFICE OF TH£ SOLICITOR GENERAL OFFICE SOLICI GEN OFFICE OF JUSTICE PROGRAMS OFfl, JUSTJ, PROGi EXEWTIVE O"ICE FOil THE UNITED STATB EXEWTI1 O"ICEF UNITED OFFICE OF DISPUTE RESOLUTION OFH DISPI RESOLI ASSOCIATE ATTORNEY GENERAL COMMUNITY OIIIENTED CIVIL RIGKTS -- DMS

RAL -- CRIMINAL IIUUAUOI' IN\lfSTlGATlON DIVISION DRUG BUREAU OF tNFCRClMENT -- AOMlfflSTRATION PRISONS EXEQITlVE UNITfD STATB Ol'RCEFOR -- UNITED STATl'S MARSHALS SERVICE ATTOIINEYS UNITED U.S.NATIONAL STATES -- CENTIIAL BUREAU ATTORNEYS INT1'RPOI. IUIIIAU OF OfFKEOl' THE Al.<Oo<OI., -- FED

fice for the Northern District of Georgia. 7 United States Attorney First Assistant United States Attorney Criminal Chief Managing Assistant United Stales Attorney West Palm Beach Office Assistant United States Attorney - - - -- May 23, 2006 i"' USAO opens federal • '-)~i:t~·tt:ier~~: F1IIiia U

to plea agreements, which involve the formal conviction of a corporation in a court proceeding. Memorandum from Acting Deputy Attorney General Craig S. Morford to Heads of Departmental Components and United States Attorneys at n.2 (Mar. 7, 2008), available at https://www.justice.gov/archives/jm/criminal-res

age 1 of 15 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE No. 08-80736-CIV-MARRA/JOHNSON JANE DOE 1 AND JANE DOE 2, Plaintiffs I. UNITED STATES OF AMERICA, Defendant / INTERVENOR JEFFREY EPSTEIN'S MEMORANDUM IN SUPPORT OF HIS ATTENDANCE AT OR PARTICIPATION IN SETTLEMENT CONFERENCE Intervenor Jef

ntervenors to participate in settlement negotiations "when those negotiations take place before the Court in a court-ordered settlement conference." United States' Lexington-Fayette Urban Cty. Gov't, 2007 WL 2020246, at *3 (E.D. Ky. July 6, 2007). B. Constitutional Considerations: Recent Court Decisions and

nd the defendant, are never filed with the federal court and by definition precede the institution of federal criminal charges. See Memorandum from Craig S. Morford, Acting Deputy Att'y Gen., U.S. Dep't of Justice, to Heads of Department Components, U.S. Att'ys re: Selection and Use of Monitors in Deferred Pro

58-59, 89-90). Petitioners leveraged the NPA to their advantage by arguing that it precluded Mr. Epstein from contesting liability. See Doe No. 1 v. United States, 749 F.3d 999, 1002 (11'h Cir. 2014) ("As a basis for relief against Epstein in the civil suit, the victims relied on Epstein's waiver of his right

y stems from the Constitution's delegation of "take Care" duties, U.S. Const. art. II, § 3, and the pardon power, id. § 2, to the Executive Branch. See United States v. Armstrong, 517 U.S. 456, 464 . . . (1996); In re Aiken Cnty., 725 F.3d 255, 262-63 (D.C.Cir.2013). Decisions to initiate charges, or to dismiss

4 The fact that Mr. Epstein's counsel sought to keep the NPA outside the public record was hardly unusual. The NPA is not a judicial document. See Craig S. Morford, Acting Deputy Attorney General, Selection and Use of Monitors in Deferred Prosecution Agreements and Non—Prosecution Agreements with Corporations,