Epstein Secrets

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

ed, molested, and/or exploited these girls, and then gave them money. Podhurat Orseck, P.A. 2 25 West Flagler Street, Suite 800, Miami, FL 33130, Miami 305.358.2800 Fax 305.35&2382 Fort Lauderdale 954.463.4346 www.podhurst.corn EFTA00194775 ' Case 9:10-cv-80309-WJZ Document 1 Entered on FLSD Docket 03/09/2010 Pa

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

tered pleas of "guilty" to one count of solicitation of prostitution, in Podhurst Orseck, P.A. 8 25 West Flagler Street, Suite ea Miami, FL 33130, Miami 305.358.2800 Fax 305359.2382 • Fort Lauderdale 954.4634346 I www.;xxlituraleom EFTA00183827 Case 9:10-cv-80309-WJZ Document 1 Entered on FLSD Docket 03/09/2010 Pa

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

ed, molested, and/or exploited these girls, and then gave them money. Podhurst Orseck, P.A. 2 25 West Flagler Street. Suite 800. Miami, FL 33130, Miami 305.358.2800 Fax 305358.2382 • Fat Lauderdale 954.463.4316 www.podhurst.com EFTA00233472 Case 9:10-cv-80309-WJZ Document 1 Entered on FLSD Docket 03/09/2010 Page

and service ofplcadings or other parer* as required by law. c wept as pnw ided thy Weal rulesofCOWL This fain, approved by the Judicial Conferenceof the United Mates in September 1974. is required fortlw use of the Clerk of (-oust for Om nu those of Initiating the civil docket shoo. (SEE NSTRIXTKENS ON THE REVERS

d enticed impressionable, vulnerable, and relatively economically less Podhurst Orseck, P.A. 2 25 West Flagler Street, Suite 800, Miami, FL 33130, Miami 305.358.2800 Fax 305.358.2382 • Fort lauderdak 954.463.4346 www.podhonst.com EFTA00212930 Case 9:09-cv-80591-KAM Document 1 Entered on FLSD Docket 04/20/2009 P

and service ofplcadings or other parer* as required by law. c wept as pnw ided thy Weal rulesofCOWL This fain, approved by the Judicial Conferenceof the United Mates in September 1974. is required fortlw use of the Clerk of (-oust for Om nu those of Initiating the civil docket shoo. (SEE NSTRIXTKENS ON THE REVERS

d enticed impressionable, vulnerable, and relatively economically less Podhurst Orseck, P.A. 2 25 West Flagler Street, Suite 800, Miami, FL 33130, Miami 305.358.2800 Fax 305.358.2382 • Fort lauderdak 954.463.4346 www.podhonst.com EFTA00212997 Case 9:09-cv-80591-KAM Document 1 Entered on FLSD Docket 04/20/2009 P

the sake of confidentiality, we will not produce the relevant documents. One such communication, however, was made in a December 6, 2007 letter from United States Attorney Acosta to myself, in which he stated that "the Office has no intention to take any position in any civil litigation arising between Mr. Eps

the United States in consultation with and with the good faith approval of Podhurst Orseck, P.A. 25 West Plaster Street, Suite 800, Miami, F1.33130 Miami 305.358.2800 Fax 305.388.2382 • Fort Lauderdale 954.463.4546 EFTA00194701 Robert Critton, Esq. June 8, 2009 Page 2 Epstein's counsel. Judge in turn and in acco