Epstein Secrets

nduct as defined in It U.S.C. § 2423(0. with minor female., in violation of Tide United States Code, Section 2423(b), all In viobation of Title It, United Stases Code, Section 2427(e); wing a facility or means of interstate or foreign commerce to knowingly persuade, induce, or entice minor female. to engage

United Sines, the State of Florida, and the Defendant soil) be sewed by the following proodum, THEREFORE, on the authority of It. Alexander Acosta, United Slates Attorney for the Southern District of Florida, prosecution in this District foe these offenses shall be defined in favor of prosecuticm by the Stat

f civil or criminal liability or a waiver °forty jurisdktional or other defense as to any person whose name does not appear on the list provided by the United Stale. 10. Except es to those individuals who elect to proceed exclusively under IS U.S.0 f 2255, as set (whin penigntph (St manta. neither Epstein's s

gain time he eamwd during his period of Incer«ration. I3. the ponies anticipate Nat this agreement will not be mede pan of any public record. if the United Slates receive, e Freedom of Information Act request or any compubory worm conunanding the disclosure of the agreement, int will provide notice to Epstein

." United States I. lordm, 915 F.2d 622, 628 (11th Cir. 1990) (quoting Rodriguez,. United States, 480 U.S. 522, 525 (1987) (itself quoting Russell° I. United States 464 U.S. 16, 23 (1983))). There is no basis for departing from that rule. Given the strong evidence that Congress did not intend retroactively to ap

phrase. See, e.g., United States'. Garcia-M, 234 F.3d 217, 220 n.3 (5th Cir. 2000); United States I. Yang, 128 F.3d 1065, 1069-70 (7th Cir. 1997); United Statosi. Ellis 935 F.2d 385, 389-90 (1st Cir. 1991); see also United States'. Hoschouer, 224 Fed. Appx. 923, 926-27 (11th Cir. 2007) (unpublished opinion);

er Defendant Epstein's defense of the civil actions filed against him violates the non-prosecution agreement between Epstein and the United States. The United States' position in this matter would be very helpful to the Court and, accordingly, the Court requests that the United States appear at the hearing. Base

tion apaisai him h irntinned for any offense that usis the 'objecter0e grandjuria inwangation, il may be by way of anInfonnwion sIgned and filai by the United States Anone); end hereby nives Ma rie to be Indktcd by e gnnd jury as ha any aie offense, lit tyy lff hie 6of 7 Case No. 08-80736-CV-MARRA P-011809 EFTA0

leventh Circuit recently noted that federal law "does not criminalize all acts of prostitution (a vice traditionally governed by state regulation)." United States,. Evans, 476 F.3d 1176, n.1 (11th Cir. 2007); see also Offense Instruction 80, Eleventh -22- Case No. 08-80736-CV-MARRA P-011863 EFTA00192909 Ca

U.S.C. § 590c CA share or interest payable to enrollees less than eighteen years of age or under legal Similarly, the official summary prepared by the Congressional Research Service ("CRS") explained that Masha's Law "(devises provisions allowing victims of certain sex-related crimes to seek civil remedies to: (I) allow adults

) Whoever, using the mail or any facility or means of interstate or foreign commerce, or within the special maritime and territorial jurisdiction of the United States knowingly persuades, induces, entices, or coerces any individual who has not attained the age of 18 years, to engage in prostitution or any sexual a

in Santos, supra, at 2025: ... The rule of lenity requires ambiguous criminal laws to be interpreted in favor of the defendants subjected to them. See United States v. Gradwell, 243 U.S. 476, 485, 37 S.Ct. 407, 61 L.Ed. 857 (1917); AfcBoyle v. United States, 283 U.S. 25, 27, 51 S.Ct. 340, 75 L.Ed. 816 (1931); U

al. Aug. 19, 2009); U.S. v. Monk, 2009 WL 2567831, fn. 1 (ED. Cal. Aug. 18, 2009); U.S. v. Zane, 2009 WL 2567832, fill (E.D. Cal. Aug. 18 2009). 18 U.S.C.A. §2255 - Civil Remedy for Personal Injuries, creates a federal cause of action or "civil remedy" for a minor victim of sexual, abuse, molestation and

d expressly. In these circumstances, the traditional rules against surplusage and redundancy apply with Similarly, the official summary prepared by the Congressional Research Service (CRS") explained that Masha's Law Irlevises provisions allowing victims of certain sex-related crimes to seek civil remedies to: (1) allow adults a

special maritime and territorial jurisdiction of the United States knowingly persuades, induces, entices, or coerces

sult of such violation may sue in any appropriate United States District Court and shall recover the actual damag

t 4 Similarly, the official summary prepared by the Congressional Research Service ("CRS") explained that Masha's Law "[r]evises pr

son who travels in interstate commerce or travels into the United States, or a United States citizen or an alien admitted for permanent residence in the United States who travels in foreign commerce, for the purpose of engaging in any illicit sexual conduct with another person shall be fined under this title or im

leventh Circuit recently noted that federal law "does not criminalize all acts of prostitution (a vice traditionally governed by state regulation)." United States v. Evans 476 F.3d 1176, n.1 (11th Cir. 2007); see also Offense Instruction 80, Eleventh -22- EFTA00212914 Case 9:09-cv-80591-KAM Document 29 Ent

U.S.C. § 590c ("A share or interest payable to enrollees less than eighteen years of age or under legal Similarly, the official summary prepared by the Congressional Research Service ("CRS") explained that Masha's Law Itievises provisions allowing victims of certain sex-related crimes to seek civil remedies to: (I) allow adults

son who travels in interstate commerce or travels into the United States, or a United States citizen or an alien admitted for permanent residence in the United States who travels in foreign commerce, for the purpose of engaging in any illicit sexual conduct with another person shall be fined under this title or im

leventh Circuit recently noted that federal law "does not criminalize all acts of prostitution (a vice traditionally governed by state regulation)." United States v. Evans 476 F.3d 1176, n.1 (11th Cir. 2007); see also Offense Instruction 80, Eleventh -22- EFTA00212981 Case 9:09-cv-80591-KAM Document 29 Ent

U.S.C. § 590c ("A share or interest payable to enrollees less than eighteen years of age or under legal Similarly, the official summary prepared by the Congressional Research Service ("CRS") explained that Masha's Law Itievises provisions allowing victims of certain sex-related crimes to seek civil remedies to: (I) allow adults

son who travels in interstate commerce or travels into the United States, or a United States citizen or an alien admitted for permanent residence in the United States who travels in foreign commerce, for the purpose of engaging in any illicit sexual conduct with another person shall be fined under this title or im

leventh Circuit recently noted that federal law "does not criminalize all acts of prostitution (a vice traditionally governed by state regulation)." United States v. Evans 476 F.3d 1176, n.1 (11th Cir. 2007); see also Offense Instruction 80, Eleventh -22- EFTA00221384 Case 9:09-cv-80591-KAM Document 29 Ent

U.S.C. § 590c ("A share or interest payable to enrollees less than eighteen years of age or under legal Similarly, the official summary prepared by the Congressional Research Service ("CRS") explained that Masha's Law Itievises provisions allowing victims of certain sex-related crimes to seek civil remedies to: (I) allow adults

son who travels in interstate commerce or travels into the United States, or a United States citizen or an alien admitted for permanent residence in the United States who travels in foreign commerce, for the purpose of engaging in any illicit sexual conduct with another person shall be fined under this title or im

leventh Circuit recently noted that federal law "does not criminalize all acts of prostitution (a vice traditionally governed by state regulation)." United States v. Evans 476 F.3d 1176, n.1 (11th Cir. 2007); see also Offense Instruction 80, Eleventh -22- EFTA00221481 Case 9:09-cv-80591-KAM Document 29 Ent

U.S.C. § 590c ("A share or interest payable to enrollees less than eighteen years of age or under legal Similarly, the official summary prepared by the Congressional Research Service ("CRS") explained that Masha's Law Itievises provisions allowing victims of certain sex-related crimes to seek civil remedies to: (I) allow adults

son who travels in interstate commerce or travels into the United States, or a United States citizen or an alien admitted for permanent residence in the United States who travels in foreign commerce, for the purpose of engaging in any illicit sexual conduct with another person shall be fined under this title or im

leventh Circuit recently noted that federal law "does not criminalize all acts of prostitution (a vice traditionally governed by state regulation)." United States v. Evans 476 F.3d 1176, n.1 (11th Cir. 2007); see also Offense Instruction 80, Eleventh -22- EFTA00189770 Case 9:09-cv-80591-KAM Document 29 Ent

U.S.C. § 590c ("A share or interest payable to enrollees less than eighteen years of age or under legal Similarly, the official summary prepared by the Congressional Research Service ("CRS") explained that Masha's Law Itievises provisions allowing victims of certain sex-related crimes to seek civil remedies to: (I) allow adults

nce to achieve his or her potential, this rise in inequality and the effects on economic mobility are increasingly recognized as defining issues for Americ='s future. The Declaration of Independence proclaimed a continuing commitment to the ideal of human equality.</=> While =his ideal has often been ch

ucts were distributed to people who needed assistance. In th= current era, food stamps has been paired with every farm bill since 1973, according to the Congressional Research Service. 7 EFTA_R1_02132714 EFTA02712867 The truth is that it is such a tradition that Obama did=not really have to threaten a veto, as the Democratic-c

to be incompatible with the superior power of the Constitution,-- it is their duty to pronounce it void . . . . In the same manner, the President of the United States could shield himself, and refuse to carry into effect an act that violates the Constitution." Id. at 445-46. 2) Letter from Chief Justice Chase to G

ing Executive objections to law and is a constitutionally impermissible absolute veto HOUSE_OVERSIGHT_012392 power." Id. at 13. 2) Memorandum from the Congressional Research Service to the Committee on Government Operations concerning “The Executive's Duty to Enforce the Laws" (Feb. 6, 1985), reprinted in Constitutionality of GAO