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

REGORY 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. XENICK DAVID A. YAREMA 'FLORIDA WARD CERTIFIED CIVIL TRIM lAvAIR 2ADMITTED 70 PRACTICE IN FLORIDA AND COLORADO BURMAN, CRITTON LUTTIER&COLEMAN, LLP YOUR TRUSTED ADVO

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

ARTNERSHIP 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 WARD CERTIFIED CIVIL TRIAL LAWYER 2nomirrao TO maw! IN FLORIDA AND COLORADO Roy Black, Esq. Black, Srebnick, Komspan & Ptumpf 201 S. B

or criminal liability or a waiver of any jarisdictional or other defense as to any person, whether or not her name appears oa the list provided by the United Slates. 11. Epstein shall use his best efforts to enter his guilty plea and be Page 4 of 7 P. 009/014 EFTA00233347 ..1N- 30-2008180O 10:06 P. CI 0/0

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 pin time be earned during his period of incarceration. 13. The patties anticipate that th

ns with the State Attorney's Office and to use his bestefforts to ensure compliance with thesepareedures, whichcompliancewilt bettor:may to satisfy the United States' interest. Epstein also understands that it is lds obligation to use his best efforts to convince the Judge of the 15th Judicial Circuit to accept Ep

GREGORY W. COLEMAN. M. ROBERT D. CRITTON4IL. PA ' BERNARD A. LEBEDEKER MARK T. LUTTIER. PA. MICHAEL ). PIKE MICHAEL L. SCHEVE DEAN T. XENICK DAVID A. YAREMA I t LORIDA BOARD CERTNIED CIVIL TRIAL LAWYER 2ADmITTED TO PRACTICE IN FLORIDA AND COLORADO BURMAN, CRITTON LUTTIER&COLEMAN,LLP YOUR TRUSTED ADVO

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

.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. XENICK DAVID A. YAREMA 'HONDA WARD CERTIFIED CIVIL TRIAL LAWYER 2ADMITTLD TO PRACTICE IN FLORIDA AND COLOMOO BURMAN, CRITTON LUTTIER &COLEMAN.u.P YOUR TRUSTED ADVOCATE

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

NERSHIP 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 BOARD CERTIFIED CIVIL TRIAL LAWYER 2ADRUTTED TO PRACTICE IN FLORIDA AND COLORADO Roy Black, Esq. Black, Srebnick, Kornspan & Ptumpf 201 S.

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

REGORY 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. XENICK DAVID A. YAREMA IFUDRIDA BOARD CERTIFIED CIVIL TRIAL LAWYER 2ADMITTE0 TO PRACTICE IN FLORIDA AND COLOMDO Honorable Edward B. Akerman Senterfitt One SE Third Ave

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)

RTNERSHIP 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 WNW COMM> CIVIL TRIAL LAWYER IN/ROTTED TO PRACTICE IN FLORIDA MID COLORADO Roy Black, Esq. Black, Srebnick, Komspan & Ptumpf 201 S. Bi

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)

ARTNERSHIP 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 BOARD CERTI/ HD CIVIL TRIAL LAWYER =ADMITTED TO PRACTICE IN FLORIDA AND COLORADO Roy Black, Esq. Black, Srebnick, Kornspan & Ptumpf 201