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UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 08-80736-Civ-Marra/Johnson JANE DOES #1 and #2 I. UNITED STATES JOINT STATEMENT OF UNDISPUTED FACTS The parties hereby stipulate and agree that the following facts are not in dispute and may be accepted as true
ensued between the United States and Epstein. Despite the investigation revealing that Epstein had molested more than 40 minor girls, in Late 2007, the United Stales entered into a non- prosecution agreement (NPA) with Epstein - esseNiatly egree:ng to immunize Epstein for al of the Federal Sex crimes he committed
copy of the terms was not provided. A notification was not provided to Jane Doe #2 because the agreement limited Epstein's liability to victims whom the United States was prepared to name in an indictment. As a result, Jane Doe #2 never received a notification a letter about the agreement. The-rietifieation4id-net
on the [NPA] when seeking civil relief against Epstein . . . and affirmatively advanced the terms of the [NPA] as a basis for relief from Epstein." United States' Reply in Support of its Motion to Dismiss for Lack of Subject Matter Jurisdiction, Doc. 205-6 at 12-13. After reaping the benefits of the NPA, the
y, no one else gets treated like that"). See Composite Exhibit 2. The publicity-generating comments by Plaintiffs' counsel have continued since the Eleventh Circuit's ruling. The wave began on April 21, 2014. That day, the Washington Post published a lengthy letter written by one of Plaintiffs' lead counsel contai
applies based upon the crime charged, then "the defendant carries the burden of production to come forward with evidence to rebut the presumption." United State v. Quartermaine , 913 F.2d 910, 916 (11th Cir. 1990). Although the statutory presumption places a burden of production on a defendant, the burden of
otice of Appeal from the Order of United States Magistrate Judge U.S. District Court for the District of , entered on April , 2008, which denied the United States' request for pre-trial detention as to defendant Jeffrey Epstein. United States Magistrate Judge set a $ cash bond, with the following conditions
ed) (discussing narcotics defendants). In United States v. Sciacca , one of the district judges in the Southern District of Florida summarized the Eleventh Circuit's approach to the analysis of the presumption as follows. Once it is determined that the statutory presumption applies based upon the crime charged, t
on the [NPA] when seeking civil relief against Epstein . . . and affirmatively advanced the terms of the [NPA] as a basis for relief from Epstein." United States' Reply in Support of its Motion to Dismiss for Lack of Subject Matter Jurisdiction, Doc. 205-6 at 12-13. After reaping the benefits of the NPA, the
y, no one else gets treated like that"). See Composite Exhibit 2. The publicity-generating comments by Plaintiffs' counsel have continued since the Eleventh Circuit's ruling. The wave began on April 21, 2014. That day, the Washington Post published a lengthy letter written by one of Plaintiffs' lead counsel contai
Entities connected to both United States and Eleventh Circuit's

Jeffrey Epstein
PERSONthe Southern District
LOCATIONLeon Black
PERSON
Alexander Acosta
PERSONJane Doe
PERSON
Kenneth Marra
PERSON
Bradley Edwards
PERSON
Prince Charles
PERSON
Scarlett Johansson
PERSONMaria Farmer
PERSONMartin Weinberg
PERSON
the United States District Court
ORGANIZATIONRoy Black
PERSON
United States District Court
ORGANIZATION
Anderson
PERSON
Apple
ORGANIZATION
Lauderdale
LOCATION
Wagner
PERSON
Jackie Perczek
PERSONMain Justice
ORGANIZATION