Epstein Secrets

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

the petition for removal is granted, check this box. R011013) Attach copy of ()Wei for Disnualai of Previous rase. Also complete VI. Reinstated or Reopened. (4) Check this box for cases reinstated or reopened in the district emus. Use the reopening date as the filing date. Transferred from Another Distr

4 of 7 EFTA00207419 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

he petition for removal is granted, check this box. R011013) Attach copy of <brier for Dismissal of Previous fine. Also complete VI. Reinstated or Reopened. (4) Check this box for cases reinstated or reopened in the district coati. Use the reopening date as the filing date. Transferred from Another Dist

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

inal Cl 2 Rommed from 0 3 Re-fled- Proceeding Sate Court (see VI below) Tranaltrred from LI 4 Reins/alai or el 5 another distrid 6 multidiale( Reopened (ape Litigation Appeal to Distria liWge from O ' Magistrate Judgment VI. RELATED/RE-FILED CASE(S). (See IMIniCliole second pale): a) Re-fi

efore the Court on Plaintiff's Emergency Petition for Enforcement of Crime Victim's Rights Act (DE 1), filed July 7, 2008. It is hereby ORDERED that the United States' Attorney shall file a response to this petition by 5:00 P.M. on Wednesday, July 9, 2008. DONE AND ORDERED in Chambers at West Palm Beach, Palm Beach

Palm Beach County, Florida, this 7th day of July, 2008. KENNETH A. MARRA United States District Judge Copies furnished to: R. Alexander Acosta, United States' Attorney all counsel of record EFTA00177719 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: IN RE: JANE DOE, Petitioner.

s 'X' in Oat Bo Onli) Trans erred from rJr I Original 1 2 Removed fom 3 3 Re.filed. Prccece ing Stalc Court Ian VI below) 0 4 Reinstated or Reopened 0 5 another district 3 6 Hullitlieltin 0 7 it) from Liligation Magistrate Isperifyi JorInnent Appeal to District VI. RELATED/RE-FILED CAS

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

Aclin• ORIGIN ,r) I Original Proceeding 1Place a is Oa BOA Orly) n 2 R moved from O 3 Railed- kale Court (sae VI below) Cl 4 Reinstated or Reopened n 5 Trans erred from another district l / 6 Muhidinricl (4903 Litigation 0 7 Appeal to District Judge from Magistrate Judgment VI. RELATE