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 Appx. 923, 926-27 (11th Cir. 2007) (unpublished opinion);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

to take effective action to protect children and families from online harm") (emphasis added); see also United States'. Searcy, 418 F.3d 1193, 1197 (Ilth Cir. 2005) (noting that Congress enacted § 2422(b) "after the Senate Judiciary Committee held a hearing regarding child endangerment via the Internet")

until, at the earliest, a suspect's initial appearance before a judicial officer. U.S. Const. Amend. 6. *1246 On Petition for Writ of Mandamus to the United States District Court for the Southern District of Florida, D.C. Docket No. 9:08-cv-80736-KAM Attorneys and Law Firms Paul Cassell, University of Utah Co

words of the statute as they are commonly and ordinarily understood and must construe the statute so each of its provisions is given full effect." P United States it McLymont, 45 F.3d 400, 401 (I I th Cir. 1995). Therefore, "[w]e do not look at one word or term in isolation, but instead we look to the entire

nt Venture, 245 F.3d 1217, 1222 (11th Cir. 2001). We are bound to "presume that Congress said what it meant and meant what it said." Id. (quoting P. United States it Steele, 147 F.3d 1316, 1318 (11th Cir. 1998) (en bane)); see alsol° Keene Corp., 508 U.S. at 208, 113 S.Ct. 2035. Therefore, under the plain la

the Majority, Judge Tjoflat's concurring opinion, and I agree that the Executive has exclusive and complete authority over charging decisions. See? li United States v. Nixon, 418 U.S. 683, 693, 94 S.Ct. 3090, 41 L.Ed.2d 1039 (1974) ("[T]he Executive Branch has exclusive authority and absolute discretion to deci

f one method of enforcing a substantive rule suggests that Congress intended to preclude others.' " Love v. Delta Air Lines, 310 F.3d 1347, 1353 (Ilth Cir. 2002) (alteration adopted) (quoting Sandoval, 532 U.S. at 290, 121 S.Ct. 1511). The dissents' criticisms of the majority opinion's application of

DISTRICT OF FLORIDA Case No. 08-80736-Civ-Marra/Matthewman JANE DOE #1 AND JANE DOE #2, Petitioners, v. UNITED STATES OF AMERICA, Respondent, UNITED STATES' MEMORANDUM OF LAW REGARDING INTERVENORS' RIGHTS TO OBSERVE AND PARTICIPATE IN THE SETTLEMENT CONFERENCE The Respondent, United States of America, b

tim cannot be required to participate in a sentencing or restitution hearing in order to obtain an order of restitution. 18 U.S.C. § 3664(g)(1). See United States v. Speakman, 594 F.3d 1165 (10th Cir. 2010); United States v. Amara, 616 F. App'x 612 (4th Cir. 2015); United States v. Schmidt, 675 F.3d 1164 (8th

nt of each mediation participant is obtained." 11th Cir. L.R. 33-1(c)(3). Mediation statements are confidential and not made part of the court file. Ilth Cir. L.R. 33-1(d). Similarly, in this District, "[a]ll proceedings of the mediation shall be confidential and are privileged in all respects as provide

plea from state court in federal proceeding). The victims intend to admit the correspondence to prove violations of the Act allegedly committed by the United States, not "against" Epstein. And even if rescission of the non-prosecution agreement abuts Epstein's interests, the purpose of the admission does not cha

ims intend to use the correspondence against the United States, not against Epstein. Rule 410 "create[s], in effect, a privilege of the defendant," United States' Mezzanatto, 513 U.S. 196, 205, 115 S. Ct. 797, 803 (1995) (internal quotation marks and alteration omitted), but not a privilege of non-disclosure

or for rehearing en banc is timely only if received in the clerk's office within the time specified in the rules. Costs are governed by FRAP 39 and Ilth Cir.R. 39.1. The timing, format, and content of a motion for attorney's fees and an objection thereto is governed by 11th Cir. R. 39.2 and 39-3. Please

DISTRICT OF FLORIDA Case No. 08-80736-Civ-Marra/Matthewman JANE DOE #1 AND JANE DOE #2, Petitioners, 1. UNITED STATES OF AMERICA, Respondent, UNITED STATES' MEMORANDUM OF LAW REGARDING INTERVENORS' RIGHTS TO OBSERVE AND PARTICIPATE IN THE SETTLEMENT CONFERENCE The Respondent, United States of America, b

Circuit has determined that this is not a civil case, but rather is "ancillary to a criminal investigation" and "a criminal action." Jane Doe No. 1 I. United States, 749 F.3d 999, 1005, 1006 (11th Cir. 2014). Despite that designation, the petitioners filed their case as a civil action and the district court has

nt of each mediation participant is obtained." 11th Cir. L.R. 33-1(c)(3). Mediation statements are confidential and not made part of the court file. Ilth Cir. L.R. 33-1(d). Similarly, in this District, "[a]ll proceedings of the mediation shall be confidential and are privileged in all respects as provide

plea from state court in federal proceeding). The victims intend to admit the correspondence to prove violations of the Act allegedly committed by the United States, not "against" Epstein. And even if rescission of the non-prosecution agreement abuts Epstein's interests, the purpose of the admission does not cha

or for rehearing en banc is timely only if received in the clerk's office within the time specified in the rules. Costs are governed by FRAP 39 and Ilth Cir.R. 39.1. The timing, format, and content of a motion for attorney's fees and an objection thereto is governed by 1 I th Cir. R. 39.2 and 39-3. Plea