Epstein Secrets

of sovereign immunity bars an award of attorneys' fees against the United States unless there is express statutory authorization for such an award. Joel United States, 772 F.2d 1535, 1536 (11th Cir. 1985). Waivers of sovereign immunity are to be strictly construed in favor of the sovereign. Id. (citing United Sta

g & reh'g en banc denied, Case No. 09-15629, 435 F. App'x 914 (11th Cir. Jun. 29, 2011) (Table). Conclusion For the reasons set forth above and in the United States' Sealed Motion to Dismiss for Lack of Subject Matter Jurisdiction, the United States respectfully requests that this Court enter an order dismissing

itution. See In re W.R. Huff 409 F.3d at 563. The statute pursuant to which Petitioners urge this Court to award restitution, however, does not make the United States liable for restitution for harms caused by others. Therefore, Petitioners are not entitled to restitution in this case. 5. Remaining Relief Request

U.S.C. § 3771(a)(2)(A), (C) (curtailing notice rights and obligations even for federal proceedings when they involve a state crime); United States I. Guevara-Toloso, 2005 WL 1210982, *2 (E.D.N.Y. 2005) (recognizing that the CVRA does not require notice of public court proceedings based on violations of state cr

December I I. 2007 Page 4 the final agreement was very similar to what was proposed by Ms. in her initial draft agreement on July 31. 2007: the United Stales shall provide F.pstein's attorney's with a list of individuals whom it has identified as victims, as defined in IS U.S.C. f 2255. alter Epsicin has

oth offenses. Additionally, for the sake of fairness and candor, we believe the same language contained in your letter to Judge Davis, stating that Itibe United States takes no position as to the validity of any such claim under this statute," should be included in any proposed letter. Sixth, your letter states th

of an enumerated federal crime. This requires Mr. Epstein to in essence admit guilt, though he believes he did not commit the requisite offense. The United States Attorney Manual ("USAM") 9-27.440, Principles of Federal Prosecution, sets forth' clear r,:quirement when' defendant tenders' pica of guilty but sub

nes definition. To be' "crime victim", I person or entity must be harmed by an offense that has peen charged in Federal district court. See U.S. I. Guevara-Toloso, 2005 WL 1210982 at '12 (E.D.N.Y. May 23, zoosi (noting that § 3771's reference to "the crime" suggests 'I focus only on the crime with which I def

of an enumerated federal crime. This requires Mr. Epstein to in essence admit guilt, though he believes he did not commit the requisite offense. The United States Attorney Manual ("USAM") 9-27.440, Principles of Federal Prosecution, sets forth a clear requirement when a defendant tenders a plea of guilty but s

lines definition. To be a "crime victim", a person or entity must be harmed by an offense that has peen charged in Federal district court. See U.S. I. Guevara-Toloso, 2005 WL 1210982 at *2 (E.D.N.Y. May 23, 2005) (noting that § 3771's reference to "the crime" suggests "a focus only on the crime with which a defe