Epstein Secrets

nduct as defined in It U.S.C. § 2423(0. with minor female., in violation of Tide United States Code, Section 2423(b), all In viobation of Title It, United Stases Code, Section 2427(e); wing a facility or means of interstate or foreign commerce to knowingly persuade, induce, or entice minor female. to engage

United Sines, the State of Florida, and the Defendant soil) be sewed by the following proodum, THEREFORE, on the authority of It. Alexander Acosta, United Slates Attorney for the Southern District of Florida, prosecution in this District foe these offenses shall be defined in favor of prosecuticm by the Stat

f civil or criminal liability or a waiver °forty jurisdktional or other defense as to any person whose name does not appear on the list provided by the United Stale. 10. Except es to those individuals who elect to proceed exclusively under IS U.S.0 f 2255, as set (whin penigntph (St manta. neither Epstein's s

gain time he eamwd during his period of Incer«ration. I3. the ponies anticipate Nat this agreement will not be mede pan of any public record. if the United Slates receive, e Freedom of Information Act request or any compubory worm conunanding the disclosure of the agreement, int will provide notice to Epstein

." United States I. lordm, 915 F.2d 622, 628 (11th Cir. 1990) (quoting Rodriguez,. United States, 480 U.S. 522, 525 (1987) (itself quoting Russell° I. United States 464 U.S. 16, 23 (1983))). There is no basis for departing from that rule. Given the strong evidence that Congress did not intend retroactively to ap

phrase. See, e.g., United States'. Garcia-M, 234 F.3d 217, 220 n.3 (5th Cir. 2000); United States I. Yang, 128 F.3d 1065, 1069-70 (7th Cir. 1997); United Statosi. Ellis 935 F.2d 385, 389-90 (1st Cir. 1991); see also United States'. Hoschouer, 224 Fed. Appx. 923, 926-27 (11th Cir. 2007) (unpublished opinion);

er Defendant Epstein's defense of the civil actions filed against him violates the non-prosecution agreement between Epstein and the United States. The United States' position in this matter would be very helpful to the Court and, accordingly, the Court requests that the United States appear at the hearing. Base

tion apaisai him h irntinned for any offense that usis the 'objecter0e grandjuria inwangation, il may be by way of anInfonnwion sIgned and filai by the United States Anone); end hereby nives Ma rie to be Indktcd by e gnnd jury as ha any aie offense, lit tyy lff hie 6of 7 Case No. 08-80736-CV-MARRA P-011809 EFTA0

leventh Circuit recently noted that federal law "does not criminalize all acts of prostitution (a vice traditionally governed by state regulation)." United States,. Evans, 476 F.3d 1176, n.1 (11th Cir. 2007); see also Offense Instruction 80, Eleventh -22- Case No. 08-80736-CV-MARRA P-011863 EFTA00192909 Ca

o. 08-80736-CV-MARRA P-01 1790 EFTA00192836 and the United States. Accordingly, I recommend that we provide Epstein's counsel with Notice of the Breach at the hearing on June 12th, and proceed to indictment promptly thereafter. BACKGROUND In the summer of 2006, the FBI approached the U.S. Attorney'

ANGES WHICH ARE SET FORTH HEREIN. IS ACCEPTED AS TO ITEMS: 30a. SIGNATURE OF OFFERORCONTRACTOR Digitally si • ned DN: cn ItialiRol emal Date: Sit UNITED STATES OF AMERICA (SIGNATURE o=Sig Net orOntoLus,...-ice. O8D i9200)30•C0 II •ISOMO046359) 20100)3113.007SI OVOCe DATE SIGNED 31b NAME OF THE CONTRACTING OFFICER

m Security Breach. B. Confirmed Breach. Contractor shall immediately (and in no event later than within 1 hour of discovery) report any Con- firmed Breach to the DOJ CO and the CO's Representative ("CUR"). If the Confirmed Breach occurs outside of regular business hours and/or neither the DOJ CO nor th

CITATION Olt6CX 5) oicLuouro ANY ADDITIONS CR GANGES LYNCH ARE SET FORTH HEREIN. IS ACCEPTED AS TO ITEMS: 30e. SONATWIE OF OFFEROPICONTRACTOR 31t WETED STATES OF AMERICA (SWARM OPOONIIMOTENPOWISER) An. NAAIE AND TITLE OF SIGNER (TYPE OR PRIM) At DATE SIGNED 13IA NAME OF THE CONTPACTIVG OFFICER (TYPE ORPawl) 314. D

Security Breach. B. Confirmed firrseh. Contractor shall immediately (and in no event later than within I hour of discovery) report any Con- firmed Breach to the Dal CO and the CO's Representative ("COR"). If the Confirmed Breach occurs outside of regular business hours and/or neither the DOJ CO nor th

13, Bekiempis, 4.19M) reports, "Maxwell is a citizen of France, prosecutors pointed out, saying that the country 'does not extradite its citizens to the United States pursuant to French law'. Maxwell also has US and UK passports. The filing added that 'the defendant has not only the motive to flee, but the means t

on in five-year grants for selected groups, including progressive and emerging organizations like the Black Voters Matter Fund and Repairers of the Breach," as well as "more established Black political organizations like the Equal Justice Initiative." Patrick Gaspard, the President of the Open Society

er Defendant Epstein's defense of the civil actions filed against him violates the non-prosecution agreement between Epstein and the United States. The United States' position in this matter would be very helpful to the Court and, accordingly, the Court requests that the United States appear at the hearing. Base

IDENTIAL ATTORNEY WORK PRODUCT EFTA00189787 and the United States. Accordingly, I recommend that we provide Epstein's counsel with Notice of the Breach at the hearing on June 12th, and proceed to indictment promptly thereafter. BACKGROUND In the summer of 2006, the FBI approached the U.S. Attorney'