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 Appx. 923, 926-27 (11th Cir. 2007) (unpublished opinion);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

ime, Plaintiff Weal Palm Beach (EXCEPT NUS. PLAINTS'S CASES) (C) Anomeys Sinn Nana. Addrem, endTelephone Asti Robert C. losefsberg, EsqACatherine W. Ezell, Esq. Podhurst Orseck, P.A. 25 W. Magic: St., Suite 800 mini"; Pt O9_ O41 sosq, ... Morro, Id) Check County When Anion Atom 0 MIAM6 DAVE 0 SICHR

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

U.S. PLAINTIPP CASES) S int. NTS 0 it Fey stein (c) Attorney's (Tina Nam, Address. nod Telephone Hornbill) Robert C..losefsbag, Esq./Katherine W. Ezell, Esq. Podhurst Orseck, P.A. 25 W. Flag' er St., Suite 800 Miami Pf 1111(1 FILED b . County of Residence of Drst LiSted Dekria m nt U tales V

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

intiff West Palm Beach (EXCEPT IN U.S. PLAINTIFF CASES) ft Attorney's (Um Nome. Addieti. and Telepheee Nuanns) Robert'. Josefsberg, EsqJKatherine W. Ezell, Esq. Podhurst Orseck, P.A. 25 W. Flagler St., Suite 800 Miami RI -4 I lft FILED County of Residency of Pint Listed Dcfcrient Uniretrebates VIE

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

2251A, 2252, 2252A, 2260, 2421, 2422, or 2423 of this title and who suffers personal injury as a result of such violation may sue in any appropriate United States District Court and shall recover the actual damages such minor sustains and the cost of the suit, including a reasonable attorney's fee. Any minor a

tiff West Palm Beach (EXCEPT IN U.S. PLAINTIFF CASES) (c) Attorney's (Firm Nets*. Addrtu. one Tapirs/ Number) Robert C. Josefsberg, Esq./Katherine W. Ezell, F.sq. Podhurst °meek, P.A. My. stein M n NTS e FILED by rp__ D C. County of Residence of First Listed Dcfcriam Unite . tales Virgin (IN U.S

and service ofplcadings or other parer* as required by law. c wept as pnw ided thy Weal rulesofCOWL This fain, approved by the Judicial Conferenceof the United Mates in September 1974. is required fortlw use of the Clerk of (-oust for Om nu those of Initiating the civil docket shoo. (SEE NSTRIXTKENS ON THE REVERS

West Palm Reach (EXCEPT TN U.S. PLAINTIFF CASES) (C) Attorney's (Finn Name. Address. and Tekplane Nutrtherl Robert C. Joseisberg, Esq./Katherine W. Ezell, Esq. Podhurst Orseek, P.A. 25 W. Flagler St., Suite 800 Worn: RI Al I an 09__ so set n un% ND Check County Where Action Arose: 0 MIAMI- DADE 0

and service ofplcadings or other parer* as required by law. c wept as pnw ided thy Weal rulesofCOWL This fain, approved by the Judicial Conferenceof the United Mates in September 1974. is required fortlw use of the Clerk of (-oust for Om nu those of Initiating the civil docket shoo. (SEE NSTRIXTKENS ON THE REVERS

West Palm Reach (EXCEPT TN U.S. PLAINTIFF CASES) (C) Attorney's (Finn Name. Address. and Tekplane Nutrtherl Robert C. Joseisberg, Esq./Katherine W. Ezell, Esq. Podhurst Orseek, P.A. 25 W. Flagler St., Suite 800 Worn: RI Al I an 09__ so set n un% ND Check County Where Action Arose: 0 MIAMI- DADE 0

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' RESPONSE TO PETITIONERS' FIRST REOUEST FOR ADMISSIONS TO THE GOVERNMENT The United States (hereinafter the "government") hereby responds to Jane Do

Plaintiff West Palm Beach tExcErr IN U.S. PLAINTIff CASES) (e) Attorney's (Firm Nut. Aden= ad lambent Numbed Robert C. Josefsbergy Esq./Katherine W. Ezell, Esq. Podhurst Orseck, P.A. 25 W. Flagler St., Suite 800 Minima SI 1111A O81 OD Check County Where Action Arose 0 MIAMI. DADE CI MONROE vt3 BR