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 Appx. 923, 926-27 (11th Cir. 2007) (unpublished opinion);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

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(3) CONFORMING REPEAL- section 3486A, and the item relating to that section in the table of sections at the beginning of chapter 223. of title IA. United Stites Code, arc repealed. . (c) TCCIINICAL AMENDMENT- Section 3486 of tide IS, United Sea Code, is amended -- (I) in subsection (aX4), by striking 'summo

hreats against tanner Presidents and members of their families, and for other purposes. Re it enacted by the Senate and House of Represe,mm i yes of the United Slates of America in Congress assembled. SEC. 5 (a) N GENERAL- Section 3486(a) of title 18, United States Code, is amended -- (1) so that paragraph (I) reads as foll

roduction of records': and (B) by adding at the end the following: 'The production of things in any other case may he required from any place within the United States or subject to tho Insys or jurisdiction of the United States.': and (3) by adding ul the end the following: (5) At any time before the return date

esides, petition for an order modifying or satiag aside the summons, or a prohibition of disclosure ordered by n court under paragraph (6). (6XA) A United State district court for the district in which the Ammons is a will be served, upon application of the United States; may issue an ex pane order hat no pe

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sides, petition Par at or:1a modifying or setting aside the mritmons or a prohibition of disclosure ordered by a coat under paragraph (6). (6)(A) A United State district tote for the digna In which the summons is or will be served, upon application of the 'Wilted Steles, may isnie an ex pane order that no pa

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