Epstein Secrets

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

g 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: Enclosed, please find

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

ED 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 Akerman Senterfitt

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, 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: This letter rep

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

TED 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 only We are In r

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, 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: This letter repr

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

1 Jeffrey Epstein Case No. 09-CV- 0802-Marra/Johnson Dear Ms. Villafana: ADF1QUI 1. BENAVEWIE PARALEGAL/INVESTIGATOR BARBARA M. McKENNA ASIILIE STOKEN-BARING BEITY STOKES PARALEGALS RITA H. BUDNYK OF COIMPI. As you are aware, I am Mr. Epstein's attorney in the civil cases that have been filed

vices of an attorney representative for the victims." Exhibit 1, June EFTA00183770 Ms. 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 ¶ 7. Indee

Doe No. 8'. Jeffrey Epstein Case No. 09-CV-80802-Marra/Johnson Dear Ms. ADELQUI J. BENAVENTE PARALEGAL/ INVESTIGATOR BARBARA M. McKINNA ASHLIE STOKEN-BARING BETTY STOKES PARALEGALS RITA II. BUDNYK OP COUNSEL As you are aware, I am Mr. Epstein's attorney in the civil cases that have been filed