Epstein Secrets

dance with Paragraph 7B, please provide me with a proposed written submission to the Special Master by Monday afternoon. Finally, as you are aware, yhe United States has been ordered to produce the Non-Prosecution Agreement. In accordance with that Order, we will produce the September Agreement with the October A

nder Acosta United States Attorney cc: Jack Goldber er, Esq. , Esq. Assistant United States Attorney EFTA00183055 U.S. Department of Justice United Stales Attorney Southern District of Florida TO: FAX NO. A. Mark PiIktfaila 500 S. Australian Ave, 4th Floor West Palm Reach, Florida 33401 (561) 820

those conditions is Epstein's agreement that the subject Jane Does, while minors, were victims of a violation of an offense enumerated in Title 18, United States Code Section 2255, and that they "will have the same rights to proceed under Section 2255 as [they] would have had if Mr. Epstein had been tried and

mate, including but not limited to, eligibility for gain time credit based on standard rules and regulations that apply in the State of Florida. At the United States' request, Epstein agrees to provide an accounting of the gain time be earned during his period of incarceration. 13. The patties anticipate that t

Gold or any selected Master determine he owes under the NPA. Respectfully submitted, /wg Black, Srebnick. Kornspan & Stumpf, P.A. EFTA00183039 J. MICHAEL BURMAN. PA" GREGORY W. COLEMAN. RA. ROBERT D. CRITTON. JR. PA I BERNARD A. LEBEDEKER MARK T. LUTTIER. P.A. MICHAEL J. PIKE MICHAEL L. SCHEVE DEAN T.

at Mr. Epstein could "agree" to the occurrence of a predicate pursuant to his NPA obligations but still contest that the plaintiff was injured, see United Stated, Scheidt, supra (finding each to be a separate element) and the letter from Mr. Acosta to Mr. Starr, supra December 4, 2007 letter at p.2 which agr

, judicial restraint, and the rule of lenity applied in construing a statute, Defendant's position as to the meaning of the statute would prevail. See United States'. Santos 128 S.Ct. 2020, 2025 (2008). As summarized by the United States Supreme Court in Santos, supra, at 2025: 5 See argument in sections (2) a

victim of one or more offenses enumerated in 18 U.S.C. § 2255, and, as such, asserts a cause of action against Defendant pursuant to this Section of the United States Code. 30. As a direct and proximate result of the offenses enumerated in 18 U.S.C. § 2255 being committed against the then minor Plaintiff by Defe

Black. Srebnick. Komspan & Stumpf. PA EFTA00194769 BURMAN, CRITTON LUTTIER&COLEMAN,ar YOUR TRUSTED ADVOCATES A LIMITED LIABILITY PARTNERSHIP J. MICHAEL BURMAN. PAP GREGORY W. COLEMAN. P.A. ROBERT D. CRITEON. JR. PA' BERNARD A. LEBEDEKER MARK T. LUTEIER. PA- MICHAEL ). PIKE DAVID A. YAREMA if LOIUDA WA

nt, any criminal prosecution against Epstein is deferred as long as he abides by the certain terms and conditions contained therein. If at any time the United State's Attorney's Office has reason to believe Epstein is in breach of the Agreement, it need only provide Epstein's counsel with notice of the breach and

asses the circumstances where the act of producing documents in response to a subpoena or production request has a compelled testimonial aspect. See United States v. Hubbell, 530 U.S. 27, 35-36 (2000). Thus, where the existence or location of the requested documents are unknown, or where production would "impl

YE, J. MICHAEL BURMAN. PAN GREGORY W. COLEMAN. PA. ROBERT D. CRITTON, JR. P.A. BERNARD LESEDEKER. MARK T. LL/TTIER. P.A. JEFFREY C. PEPIN MICHAEL J. PIKE HEATHER. M

t trial. No more; no less." 2 EFTA00192643 U.S. Department of Justice United States Attorney Southern District of Florida Ft ALEXANDER ACOSTA UNITEDSTATES ATTORNEY DELIVERY BY FACSIMILE Lilly Ann Sanchez Fowler White Burnett, PA 1395 Brickell Ave, 14'h Floor Miami, FL 33131 Re: Jeffrey Epstein D

mate, including but not limited to, eligibility for gain time credit based on standard rules and regulations that apply in the State of Florida. At the United States' request, Epstein agrees to provide an accounting of the gain time he earned during his period of incarceration. 13. The parties anticipate that t

Gold or any selected Master determine he owes under the NPA. Respectfully submitted, /wg Black, Srebnick, Kornspan & Stumpf, N.A. EFTA00192660 J. MICHAEL BURMAN. P.A.11 GREGORY W. COLEMAN. PA ROBERT D. CRITTON, JR.. PA BERNARD A. LEBEDEKER MARK T. LUTTIER. MICHAEL J. PIKE MICHAEL L. SCHEVE DEAN T. XENIC

ired by ¶8 of the NPA? 6. Whether damages are to be awarded based on injury to a plaintiff or based on the number of separately proven claims, see United States'. Raker, 2009 WL 4572785 (E.D.Tex., 2009) where the Court rejected the contention that damages were to be allocated per violation? We are not askin

s a victim of one or more offenses enumerated in 18 . § 2255, and, as such, asserts a cause of action against Defendant pursuant to this Section of the United States Code. 30. As a direct and proximate result of the offenses enumerated in 18 . § 2255 being committed against the then minor Plaintiff by Defendan

ack. Srebnick, Kornspan & Stumpf. PA EFTA00183815 BURMAN, CRITTON LUTTIER&COLEMAN, LLP YOUR TRUSTED ADVOCATES A LIMITED LIABILITY PARTNERSHIP J. MICHAEL BURMAN. P.A22 GREGORY W. COLEMAN. P.A. ROBERT D. CRITTON. JP-. PA ' BERNARD A. LEBEDEKER MARKT. LuTTIER. PA. MICHAEL J. PIKE DAVID A. YAREMA RONDA BOA

inmate, including but not limited to, divinity for gain time credit. based on standard rules and regulations that apply in the State of Florida. At the United States' request, Epstein agrees to provide an according of the gain time he earned during his period of incarceration_ 13. Thepatties anticipate that thi

J. MICHAEL BURMAN. P.A." GREGORY W. COLEMAN. PA. ROBERT D. CRITTON. JR. PA. BERNARD A. FEBEDEKER. MARK T. LUTTIER. PA. MICHAEL J. PIKE MICHAEL L. SCHEVE DEAN T.

mate, including but not limited to, eligibility for gain time credit based on standard rules and regulations that apply in the State of Florida. At the United States' request, Epstein agrees to provide an accounting of the gain time he earned during his period of incarceration. 13. The parties anticipate that t

Gold or any selected Master determine he owes under the NPA. Respectfully submitted, /wg Black, Srebnick, Kornspan & Stumpf, P.A. EFTA00223184 J. MICHAEL BURMAN. PAu GREGORY W. COLEMAN. P.A. ROBERT D. CRITTON. JR. P.A. I BERNARD k LEBEDEKER MARK T LUTTIER. PA. MICHAEL J. PIKE MICHAEL L. SCHEVE DEAN T.

t at the time of the offense (e.g., 2004-5) govern the minimum statutory damage amount ($50,000 rather than $150,000) under ex post facto laws, see United States'. Scheidt, 2010 W.L. 144837 (E.D. Cal., 2010) (indicating that the statute in effect at the time of the violation governs the minimum damage remedy)

Black, Srebnick. Komspan & Stumpf, PA EFTA00233202 BURMAN, CRITTON LUTTIER&COLEMAN, Li" YOUR TRUSTED ADVOCATES A LIMITED LIABILITY PARTNERSHIP J. MICHAEL BURMAN. PAID GREGORY W. COLEMAN. P.A. ROBERT D. CRITTON. JR. PA' BERNARD A. LEBEDEKER MARX T. LUTTIER. PA MICHAEL J. PIKE DAVID A. YAREMA I PION DA W

t at the time of the offense (e.g., 2004-5) govern the minimum statutory damage amount ($50,000 rather than $150,000) under ex post facto laws, see United States'. Scheidt, 2010 W.L. 144837 (E.D. Cal., 2010) (indicating that the statute in effect at the time of the violation governs the minimum damage remedy)

lack. Srebnick. Komspan & Stumpf. P.A EFTA00189958 BURMAN. CRITTON LUTTIER&COLEMAN. LLP YOUR TRUSTED ADVOCATES A LIMITED LIABILITY PARTNERSHIP J. MICHAEL BURMAN. P.A." GREGORY W. COLEMAN. PA. ROBERT D. CRITTON. JR.. PA' BERNARD A. LEUDEKER MARK T. WTTILR. PA MICHAEL J. PIKE DAVID A. YAREMA 'FLOIUDA BOA

y representative for the victims." Exhibit 1, June EFTA00194724 Ms. A. Marie Villafana, Esq. June 19, 2009 Page 6 15, 2009 Letter at 2. It was the United States' obligation to select a suitable attorney representative, subject to the good-faith approval of Mr. Epstein's counsel. See Exhibit 2, NPA 17. Indeed

nding issues at the intersection of the NPA and 2255. Please advise if any remain. Sincerely, Enclosure cc: Karen Atkinson, Esq. EFTA00194711 J. MICHAEL BURMAN, P.A.' GREGORY W. COLEMAN. P.A. ROBERT D. CRTITON, JR.. PA.' BERNARD LEBEDEKER MARK T. LUTHER, P.A. JEFFREY C. PEPIN MICHAEL J. PIKE HEATHER M