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

, to allow him to deposit $2,000,000 in Trust with the Court pending the outcome of the Complaint which confirms his commitment. Cordially yo Rob D. Critton, Jr. RDC/JPL:ab Cc EFTA00183041 L EFTA00183042 . (USAFLS) From: Acosta, Alex (USAFLS) Sent: 811:55 AM To: . (USAFLS); Sloman, Jeff (USA

4 of 7 EFTA00727912 Case 1:10-cv-21586-ASG Document 1-3 Entered on FLSD Docket 05/17/2010 Page 6 of 15 sentenced not later than October 26, 2007. The United Slates has no objection to Epstein self-reporting to begin serving his sentence not later than January 4, 2008. 12. Epstein agrees that he will not be a

circumstances of the case and the number and caliber of the attorneys who represent Mr. Epstein, in selecting the victims' attorney representative, the United States suggests that you consider the following criteria:" 1. Experience doing both plaintiffs' and defense litigation. 2. Experience with state and fed

mate, including but not limited to, eligibility for gain time credit based on standard rules end 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

rtin G. Weinberg, Esq., one of the country's most prominent criminal defense lawyers; Jack A. Goldberger, Esq., a prominent Palm Beach lawyer; and D. Critton, Jr., Esq. and Michael Burman, Esq. of the firm Burman, Critton Luttier & Coleman, LLP, a prominent Palm Beach law firm. 17. Because of the number

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

, to allow him to deposit $2,000,000 in Trust with the Court pending the outcome of the Complaint which confirms his commitment. Cordially yo Rob D. Critton, Jr. RDC/JPL:ab Cc AUSA - , AUSA — Jack Goldberger, Esq. Robert Josefsberg, Esq EFTA00233363 1 1 IN THE CIRCUIT COURT OF THE FIFTEENTH JU

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

tein EFTA00723231 v. Epstein Case No. 502008CA037319XXXXMB AB Page 14 of 14 BURMAN, CRITTON, LUTTIER & COLEMAN, LLP (561) 515-31 ax By: R D. Critton, Jr. orida Bar #224162 Michael J. Pike Florida Bar #617296 (Counsel for Defendant Jeffrey Epstein) EFTA00723232 IN THE CIRCUIT COURT OF THE 1

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

, to allow him to deposit $2,000,000 in Trust with the Court pending the outcome of the Complaint which confirms his commitment. Cordially yo Rob D. Critton, Jr. RDC/JPL:ab Cc Jeffrey H. Sloman, AUSA - [email protected] Ann Marie C. Villafana, AUSA — [email protected] Robert Senior, A

L Deanna K. Shullman James B. Lake 101 N.E. 3rd Avenue, Suite 1500 Ft. Lauderdale, Florida 33301 EFTA00233651 07/24/2009 15:22 FAX 5018059840 USA0 WPB CONFRM 07-20-'09 14:22 FROM-THOMAS & LOCICERO 8139843070 004 1-113 P003/00E-937 RESPONDENT PALM BEACH POST'S MOTION FOR APPELLATE ATTORNEYS

other instances where 5 counsel other than myself, not in the civil aspects, where 6 allegations have been made and letters have been sent by the 7 United States suggesting that there's been a violation of the 8 NPA. And under those circumstances, some notification was 9 provided. 10 THE COURT: Did it have

Office - West Palm Beach, 401 North Dixie Highway, West Palm Beach, FL 33401; Jack Alan Goldberger, Esq., Atterbury Goldberger, et al., 2 kobert D. Critton, Esq., Burman, Critton, Luther & ColemanIMININ EM., T. Kuvin, Esq., Leopold-Kuvin, P.A., and Bradley 3. Edwards, Esq. and William J. Jane Kreusle

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

JPL:ab Cc SA - Robert Senior, A Jack Goldberger, Esq. goldberger agwpa.com Robert Josefsberg, Esq. @[email protected] Cordially yo Rob D. Critton, Jr. EFTA00223186 EFTA00223187

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)

opportunity to fully defend himself, In the civil suit, except for that which is specifically required of him under the NPA. Cordially you Robe2 D. Critton, Jr. RDC/clz EFTA00233204 U.S. Department of Justice United States Attorney Southern District of Florida 500 S Australian Ave, Ste 400 West P

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

ding this motion or any other civil related pleadings or matter that may implicate the NPA. I look forward to your response. Cordially y rs, Robe, D. Critton, Jr. RDC/clz cc by pdf: Jack A. Goldberger, Esq. Martin G. Weinberg, Esq. Roy Black, Esq. Jay Lefkowitz, Esq. EFTA00194734 UNITED STATES DIS