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

&COLEMAN, LLP YOUR TRUSTED ADVOCATES A LIMITED LIABILITY PARTNERSHIP May 25, 2010 ADELQ0 J. BENAVENTE PARALEGAVINvISTIGAToR JESSICA C.ADWELL BOBBIE M. MCKENNA ASHLIE STOKEN•BARING BETTY STOKES PARALEGALS RITA H. BuDNYK or COUNSEL EDWARD M. RICCI or COUNSEL Honorable Edward B. Sent by email and Ake

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

Weinberg, Esq. Martin G. Weinberg, PC 20 Park Plaza, Suite 1000 Boston, MA 02116 ADELCOJI J. BENAVENTE PAPALEGAL/INVISTIOATOR JESSICA CADWELL BOBBIE M. MCKENNA ASHLIE STOKEN•BARINO BETTY STOKES PARALEGALS RJTA H. BIJDNYK Of COUNSEL EDWARD M. RICCI OE COUNSEL Re: Jeffrey Epstein Dear Roy and Marty:

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

, 2010 Honorable Edward B. Davis Sent by email and by U.S. Mail to Judge Davis only ADELQVI J. BENAVENTE PARAUGAtliNVESTIGATOR JESSICA CADWELL BOBBIE M. MCKENNA ASHLIE STOKEN•BARING BETTY STOKES PARALEGALS RITA H. BUDNYK OF COUNSEL EDWARD M. RICCI Of COUNSEL We are in receipt of Mr. Josefsberg's lette

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

cember 14, 2009 UMC Hearing v. Jeffrey Epstein CASE NO.: 502008CA037319)OOOCMB AM ADELQI,PI J. BENAVENTE PAPALIOAL/INV7411GATOR JESSICA CADWEU. BOBBIE M. MCKENNA ASHLIE STOKEN-BARING BETTY STOKES PARALEGALS RITA H. BUDNYK OP COUNSEL ED RICCI SPECIAL CONSUMER JUSTICE COUNSEL Dear Judge Hafele: Enclose

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

R &COLEMAN.u.P YOUR TRUSTED ADVOCATES A LIMITED LIABILITY PARTNERSHIP May 25, 2010 AOELQUI J. BENAVENTE PARALEGAL/INVESTIGATOR JESSICA CADWELL BOBBIE M. MCKENNA ASHLIE STOKEN-BARING BETTY STOKES PARALEGALS RITA H. BUDNYK OF COUNSEL EDWARD M. RICCI OF COUNSEL Honorable Edward B. Sent by email and Ake

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

. Weinberg, Esq. Martin G. Weinberg, PC 20 Park Plaza, Suite 1000 Boston, MA 02116 ADELCW I J. BENAVENTE PARATEGAViNVESSIGATOR JESSICA CADWELL BOBBIE M. MCKENNA ASHLIE STOKEN-BARING BETTY STOKES PARALLOALS RITA H. BUONYK OF COUNSEL EDWARD M. RICCI OF COUNSEL Re: Jeffrey Epstein Dear Roy and Marty:

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

ENTIAL Sent by E-Mail and U.S. Mail William Riley Re: Epstein Matter Dear Bill: ADELE/VI J. BENAVENTE PARALEGAL/INVESTIGATOR JESSICA CADWELL BOBBIE M. MCKENNA ASHLIE STOREN-BARING BETTY STOW PAML (GALS RITA Ii. BUDNYK Of COUNSEL EDWARD M. RICCI Of COUNSEL I am enclosing a copy of a letter sent by me

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

R &COLEMAN, LLP YOUR TRUSTED ADVOCATES A LIMITED LIABILITY PARTNERSHIP May 25, 2010 ADELQIJI J. BENAVENTE PARALEOWINVESTIOATOR JESSICA CADwELL BOBBIE M. MCKENNA ASHLIE STOKEN-BARING BETTY STOKES PAMLICALS RITA H. BUDNYK OP COUNSEL EDWARD M. RiCct OF COUNSEL Sent by email and by U.S. Mall to Judge on

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)

G. Weinberg, Esq. Martin G. Weinberg, PC 20 Park Plaza, Suite 1000 Boston, MA 02116 ADELQUI J. BENAVENTE PARAUCAVINVESTICATOR JESSICA CADWELL BOBBIE M. MCKENNA ASHLIE STOKEN-BARING BETTY STOKES PARALICALS RITA H. BUDNYK OF cOUNsu EDWARD M. RICCI OF COUNSEL Re: Jeffrey Epstein Dear Roy and Marty: 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)

. Weinberg, Esq. Martin G. Weinberg, PC 20 Park Plaza, Suite 1000 Boston, MA 02116 ADELQUI J. BENAVENTE PARALEGAL/INVESTIGATOR JESSICA CADWELL BOBBIE M. MCKENNA ASHUE STOKIN-BARING BETTY STOKES PAM I IGALS RITA H. BUDNYK OP COUNSEL EDWARD M. RICCI OE COUNSEL Re: Jeffrey Epstein Dear Roy and Marty: