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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)
ast) because her father, and ste mother have filed a civil suit against Epstein seeking "in excess of 50 million dollars." father is represented by Jeff Herman. father also has been in frequent contact with the journalist at "Vanity Fair" magazine, and, as mentioned in the original pros memo, he has a pri
etter to Mr. Goldberger that "the U.S. Attorney's modification of the 2255 portion of the Agreement now limits our victim list to those persons whom the United States was prepared to include in an indictment. This means that, pursuant to Justice Department policy, these are individuals for whom the United States b
other instances where 5 counsel other than myself, not in the civil aspects, where 6 allegations have been made and letters have been sent by the 7 United States suggesting that there's been a violation of the 8 NPA. And under those circumstances, some notification was 9 provided. 10 THE COURT: Did it have
21 until 37:23 urge 22:9 use 10:25 11:8 20:24 23:1128:25 40:11 used 28:19 U.S 2:15 4:10 7:1,9 8:6 12:8,12 16:16 26:19 27:4,18,19 43:5,11,25 U.S.A 2:16 U.S.0 33:7 I various 3:1 10:25 very 4:21 5:711:1,2 1120 12:21 16:19 162417:12,12 23:1129:4 32:1 35:18 38:10 40:18 42:2 43:18 44:14 Via
recollection that he's 14 15 A. No. 1 6 O. That he's boss? 17 A. No. 18 Q. Does it refresh your memory that he's the 19 ex-partner of Jeff Herman, the first lawyer who sued 20 you -- sued Mr. Epstein on your behalf for fifty million 21 dollars? 22 A. No, sir. I don't know who he is. 23
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 →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 →w, at least) because her father, and stepmother have fil a civil suit against Epstein seeking "in excess of 50 million dollars." s represented by Jeff Herman. IMIllfather also has been in frequent contact with the journalist at "Vanity Fair" magazine, and, as mentioned in the original pros memo, he has a
Page: EFTA02857524_p145 →Entities connected to both United States and Jeff Herman

Jeffrey Epstein
PERSON
George W. Bush
PERSONthe Southern District
LOCATIONLeon Black
PERSON
Prince Andrew
PERSON
Alan Dershowitz
PERSON
Alexander Acosta
PERSONJane Doe
PERSON
Kenneth Marra
PERSON
Bradley Edwards
PERSON
New York
LOCATION
Marc Rich
PERSON
Virginia Giuffre
PERSON
Lesley Groff
PERSONMartin Weinberg
PERSON
A. Marie Villafana
PERSON
the United States District Court
ORGANIZATIONRoy Black
PERSON
Supreme Court
ORGANIZATIONGerald Lefcourt
PERSON