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

r T. Kuvin, Esq. Leo Jack Goldberger, Esq. ss, P.A. Fax: Co-counsel for Defendant Jeffrey Epstein BURMAN, CRITTON, LUTTIER & COLEMAN, LLP 303 Banyan Blvd., Suite 400 FL 33401 By: F Robert . Critton, Jr. Florid ar #224162 Michael J. Pike Florida Bar #617296 EFTA00723293 v, Epstein Case No. 5

LEX SINK; (C2) $40,000 IN CAMPAIGN CONTRIBUTIONS TO REPUBLICAN PARTY OF FLORIDA, "FLORIDA" ACCOUNT AND VOLUNTARILY OFFERED, AND TURNED OVER, TO 'HIE UNITED STATES BY THE REPUBLICAN PARTY OF FLORIDA, (C3) $10,000 IN CAMPAIGN CONTRIBUTIONS TO REPUBLICAN PARTY OF FLORIDA, "FEDERAL" ACCOUNT AND VOLUNTARILY OFFE

directed. DATED this 16th day of April, 2010. BY: CRITTON, JR. ( ttorneys for Defendant Jeffrey Epstein) Burman, Critton, Luttier & Coleman 303 Banyan Blvd., Suite 400 est Palm Beach, FL 33401 . CRITTON, JR., ESQ. For the Court EFTA00725168 EXHIBIT A DEFINITIONS AND INSTRUCTIONS A. "Document" me

OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing was served by U.S. Mail and facsimile on Mr. Robert D. Critton, Jr., 303 Banyan Blvd., Suite 400 West Palm Beach Fl; Mr. Marc Nurik, One East Broward Blvd., Suite 700, Ft. Lauderdale, FL 33301; Mr. Jack Scarola, 2139 Palm Beach Lake

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

24,201, THE TA ACT LAND INVOLVED. TOMO AS U30)M0Erk AUOITIO9SOTKomrol CLERK U. e DIST. CT. Robed D. Critton, Esq., Burman, co"akastin ibP, 303 Banyan Blvd., Suite 400, West Palm Beach, FL 33401 (d) Cheek County Where Action Aran (' M IAMI. DADE 0 MONROE 0 IROWARD 08 PALM BEACH 0 MARTIN 0 ST. LUCK 0 IND

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

2251A, 2252, 2252A, 2260, 2421, 2422, or 2423 of this title and who suffers personal injury as a result of such violation may sue in any appropriate United States District Court and shall recover the actual damages such minor sustains and the cost of the suit, including a reasonable attorney's fee. Any minor a

D 'IWO/val. SYEVEm R4 LARluODE AC I Attorneys Or Keen) CLERK U.S. DIST. CT. Robert D. Critton, Esq., Burman, (..sitioltaataCaitIL.L...p, • 303 Banyan Blvd., Suite 400, West Palm Beach, FL 33401 WI Check County Whine Mien &OM CI MIAMI. OAHE O MONROE fl BROW AR D 16 PALM BEACH 3 MARTIN 0 SI. LUCIE 3 I