Epstein Secrets

concede that neither Jane Doe I nor Jane Doe 2 were victims of the crimes to which Epstein entered guilty pleas to on June 30, 2008. D.E. 416 at 40. The United States was not a party to the state court criminal proceeding against Epstein, nor had it initiated those proceedings. Despite all of these facts, petitio

numerated in article 1.B, a victim is 'a person directly and proximately harmed as a result of the commission of a Federal offense or an offense in the District of Columbia' (18 U.S.C. § 3771(e)) if the offense is charged in Federal district court." Petitioners contend the Guidelines did not prevent the U.S. Attorney's

of an enumerated federal crime. This requires Mr. Epstein to in essence admit guilt, though he believes he did not commit the requisite offense. The United States Attorney Manual ("USAM") 9-27.440, Principles of Federal Prosecution, sets forth a clear requirement when a defendant tenders a plea of guilty but s

numerated in article I.B, a victim is 'a person directly and proximately harmed as a result of the commission of a Federal offense or an offense in the District of Columbia' (18 U.S.C. § 3771(e)) if the offense is charted in Federal district court. If a victim is under 18 years of age, incompetent, incapacitated, or Chi

erence to a non- prosecution agreement is the responsibility of the prosecutor alone while a plea agreement is subject to the approval of the court; United States'. Dorsett 2009 WL 2386070 at *4 (D.Neb. Jul, 23, 2009), citin United States I. Minnesota Mining & Mfg. Co. 551 F.2d 1106, 1112 (8th Cir. 1977). Since

.S.C. § 3771(a)(1) — (8), "a victim is 'a person directly and proximately harmed as a result of the commission of a Federal offense or an offense in the District of Columbia' (18 U.S.C. § 3771(e)) if the offense is charged in Federal district court." At no time was Epstein ever charged with an offense in Federal district

ELLIS LLP Jar P. LoAtoWte, P.C. To r W • loft 12 Woo= VIA FACSIMILE (305) 530-6444 Honorable R. Alexander Acosta I links.) States Attorney lJnited States Attorney's Office outhern District of Florida S .9 NE 4th Street Miami. FL 33132 Dear Alex: AND Anmann rosTmiunos Coagroup Cellar 159 East WO

enumerated in article LB, a victim is 'a person directly and pmsimately harmed as a result of the commission of a Federal offense cc an offense in the District of Columbia' (18 U.S.C. § 3771(e)) if thc offense is charted in Federal district court. If a victim is undis 18 years of age, incompetent, incapacitated, or Chi

LLIS 002/006 KIRKLAND & ELLIS LLP / P. Lolkoatt, P.C. To VIA FACSIMILE (305) 530-6444 Honorable R. Alexander Acosta I Thitix.1 States Attorney lJnited States Attorney's Office outhern District of Florida S .9 NE 4th Street Miami. FL 33132 Dear Alex: AND AntiAnn rioninains Cola/cup Cara/ 159 East San

numerated in article 1.B, a victim is 'a penion directly and proximately harmed as a result of the commission of a Federal offense cc an offense in the District of Columbia' (18 U.S.C. § 3771(e)) if the offense is charted in Federal district court. If a victim is undo 18 years of age, incompetent, incapacitated, or Chic

concede that neither Jane Doe 1 nor Jane Doe 2 were victims of the crimes to which Epstein entered guilty pleas to on June 30, 2008. D.E. 416 at 40. The United States was not a party to the state court criminal proceeding against Epstein, nor had it initiated those proceedings. Despite all of these facts, petitio

numerated in article 1.B, a victim is 'a person directly and proximately harmed as a result of the commission of a Federal offense or an offense in the District of Columbia' (18 U.S.C. § 3771(e)) if the offense is charged in Federal district court." Petitioners contend the Guidelines did not prevent the U.S. Attorney's

IRKLANDAELLIS 002/006 KIRKLAND & ELLIS LLP Jar P. Lalkoafte, P.C. To e VIA FACSD411.E Honorable R. Alexander Acosta I links.) States Attorney lJnited States Attorney's Office outhern District of Florida S .9 NE 4th Street Miami. FL 33132 Dear Alex: AND Anmann riormiuroos Calgroup Cantor 159 East Sa

numerated in article 1.B, a victim is 'a penion directly and proximately harmed as a result of the commission of a Federal offense cc an offense in the District of Columbia' (18 U.S.C. § 3771(e)) if the offense is charted in Federal district court. If a victim is undo 18 years of age, incompetent, incapacitated, or Chic

of an enumerated federal crime. This requires Mr. Epstein to in essence admit guilt, though he believes he did not commit the requisite offense. The United States Attorney Manual ("USAM") 9-27.440, Principles of Federal Prosecution, sets forth a clear requirement when a defendant tenders a pica of guilty but s

numerated in article 1.9, a victim is 'a person directly and proximately harmed as a result of the commission of a Federal offense or an offense in the District of Columbia' (18 U.S.C. § 3771(e)) if the offense is charged in Federal district court. If a victim is under 18 years of age, incompetent, incapacitated, or Chi

of an enumerated federal crime. This requires Mr. Epstein to in essence admit guilt, though he believes he did not commit the requisite offense. The United States Attorney Manual ("USAM") 9-27.440, Principles of Federal Prosecution, sets forth a clear requirement when a defendant tenders a plea of guilty but s

umerated in article 1.13, a victim is 'a person directly and proximately harmed as a result of the commission of a Federal offense or an offense in the District of Columbia' (18 U.S.C. § 3771(e)) if the offense is cbarged in Federal district cowl. If a victim is under 18 years of age, incompetent, incapacitated, or • C