Epstein Secrets

this procedure because. as I mentIona I think It to probably in their best WOWS. In terms of plea agreement language. let me suggest the following: Thu United Slates agrees to make a minion seeking the appointment of a Guardian ad titan to mpresent the identified victims, Following the appointment of such Guardia

mber I I, 2007 Page 4 The final agreement was very similar to what was proposed by Ms. Villotbna in her initial draft agreement on July 31. 2007: The United Stoles shall provide l3poein's anomey's with u list of individuals whom ii fins identified as victims, as defined in IR U.S.C. § 2255. alter Epstein has si

hich point they were eliminated by your Office: IT APPEARING, idler an invizligation of the offenses and Epstcin's background, thin the interest or the United Stales pursuant to the Petite policy will be served by the Following procedure ... Epstein understands that the United Stales Attorney has no authority to

ms prefer a quick resolution with compensatinn for damages and will always supped any disposition UM eliminates the need For trial. See letter from Lily Ann Sanchez to Chief Matthew Menchel dated August 2. 2007.1 For the duration of the negotiations. we then continued to encourage the use of a restitution fund i

erson can be charged with a criminal 39 EFTA01718615 . offense, that is a violation of Florida Statutes Section 794.05; in violation of Title 18, United States Code, Sections 2422(b) and 2. COUNT 14 (Enticement of a Minor: 18 U.S.C. § 2422(b)) 49. Paragraphs 1 through 19 of this Indictment are re-alleged

ity or process of the prior prosecution. not the sentencing outcome. Second, the state plea agreement offered was not "manifestly inadequate" tinder U.S.A.M. § 9- 2.03ID. indeed, the only real difference hews= the state and federal plea proposals was whether Mr. Epstein served his sentence in jail or comm

n to undertake discussion with the $tate Attorney's Office In ensure compliance with these procedures, which compliance will be necessary to satisfy the United States' interest. pursuant to the Perire policy. We reiterate that this case was at heart a local matter that was being fully addressed by the state crimi

s prefer a quick mutation with etimpensation for damages and will always support any disposition lieu eliminates the need Mr trial. See letter from Lily Ann Sanchez to Chief Matthew Menehel dated August 2, 2007.1 For the duration or the negotiations, we then continued to encourage the Me of a restitution fund in

S L LP Jay P I otternWs, P C. loP 11Wr r ly blk Orland can VIA FACSIMILE (303) SM1-4444 Honorable R. Alexander Acosta united States Attorney United Slates Attorney's ()filet Southern District of Florida 99 NE itlh Street Miami. Fla 33132 Dear Alex: nap MIn IARD 'Armen-. Cinarmap Conte, 153 Emit

to undertake discussion with the Slate Attorney's 011ie,: to ensure compliance with these procedures. which compliance will he necessary to satisfy the United Status' interest. pursuant In the Poise policy. We reiterate that this ease was at heart a local matter that was being fully addressed by the state crimin

prefer a quick resolution with compensation for damages and will always support any disposition that eliminates the need fur trial. See letter from Lily Ann Sanchez to dated August 2. 2007.1 For the duration of the negotiations, we then continued to encourage the use of a restitution fund in place of civil lia

port of its motion to stay. DE 140. In that reply, the Government represented that it would voluntarily be providing information to the victims: "[Tjhe United States has agreed to provide some information to [the victims] even during the pendency of the stay and is undertaking a search for that information." DE

ernment which may be favorable to the defendant on the issues of guilty or punishment within the scope of Brady v. Maryland, 373 U.S. 83 (1963), and United States v. Agurs, 427 U.S. 97 (1976)." The Court should adopt that language to the case at hand here. Interesting, the Standing Discovery Order — and asso

y Epstein (including Jeffrey Epstein, the Florida Science Foundation, Jack Goldberger, Harvard Law Professor Alan Dershowitz, Roy Black, Ken Starr, Lily Ann Sanchez) before Reinhart left the employment of the U.S. Attorney's Office. UNITED STATES RESPONSE: Admitted. 17. The Government possesses information (in

port of its motion to stay. DE 140. In that reply, the Government represented that it would voluntarily be providing information to the victims: "[T]he United States has agreed to provide some information to [the victims] even during the pendency of the stay and is undertaking a search for that information." DE

y Epstein (including Jeffrey Epstein, the Florida Science Foundation, Jack Goldberger, Harvard Law Professor Alan Dershowitz, Roy Black, Ken Starr, Lily Ann Sanchez) before left the employment of the U.S. Attorney's Office. UNITED STATES RESPONSE: Admitted. 17. The Government ossesses information (including te

port of its motion to stay. DE 140. In that reply, the Government represented that it would voluntarily be providing information to the victims: "[T]he United States has agreed to provide some information to [the victims] even during the pendency of the stay and is undertaking a search foi that information." DE

y Epstein (including Jeffrey Epstein, the Florida Science Foundation, Jack Goldberger, Harvard Law Professor Alan Dershowitz, Roy Black, Ken Starr, Lily Ann Sanchez) before left the employment of the U.S. Attorney's Office. UNITED STATES RESPONSE: Admitted. 17. The Government nnseca infnrmntion (including tele

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 pica of guilty but s

5 530 6440 EXECUTIVE OFFICE e001 Dear Jay, On September 24, 2007, your client, Jeffrey Epstein and two of his lawyers, Gerald Lefcourt, Esq. and Lily Ann Sanchez, Esq., in consultation with numerous other experienced and highly regarded lawyers, entered into a Non-Prosecution Agreement ("the Agreement") with

port of its motion to stay. DE 140. In that reply, the Government represented that it would voluntarily be providing information to the victims: "[T]he United States has agreed to provide some information to [the victims] even during the pendency of the stay and is undertaking a search for that information." DE

y Epstein (including Jeffrey Epstein, the Florida Science Foundation, Jack Goldberger, Harvard Law Professor Alan Dershowitz, Roy Black, Ken Starr, Lily Ann Sanchez) before Reinhart left the employment of the U.S. Attorney's Office. UNITED STATES RESPONSE: Admitted. 17. The Government possesses information (in

issuade Jane Doe #1 from reporting to a law enforcement officer of the United States the T commission of a federal offense; in violation of Tide 18, United State ode, Sections 1512(d)(2) and 2. jj COUNT 2 In or around 2005, in the special territorial jurisdiction of the United States, that is, in an airc

After all, Mr. Epstein is also represented by Dean Kenneth Starr, Martin Weinberg, Roy Black, Gerald Lefcourt, Harvard Professor Alan Dershowitz, Lily Ann Sanchez, and Guy Lewis. That being said, the Southern District of Florida will only renew the offer to extend the current deadline if you and the CEOS Se

mate, including but not limited to, eligibility for gain time credit based on standard rules and 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

530 6440 EXECUTIVE OFFICE e)001 Dear Jay, On September 24, 2007, your client, Jeffrey Epstein and two of his lawyers, Gerald Lefcourt, Esq. and Lily Ann Sanchez, Esq., in consultation with numerous other experienced and highly regarded lawyers, entered into a Non-Prosecution Agreement ("the Agreement") with