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 Appx. 923, 926-27 (11th Cir. 2007) (unpublished opinion);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

tiff—which they did not—§ 2255 only authorizes suit based on predicate convictions under certain federal statutes..:' (Id. at 21 (emphasis added).) States District Court and shall recover the actual damages such person sustains and the cost of the suit, including a reasonable attorney's fee. Any person as described i

n federal income tax returns stated cause of action for dis- crimination among religions prohibited by establishment clause of First Amendment. 26 U.S.C.A. § 170; Fed.Rules Civ.Proc. Rule 12(b)(6), 28 U.S.C.A.; U.S.C.A. Conan. Amend. 1. 4. Constitutional Law 4=,84(I) Establishment clause of First Ame

injunction 36. United Stater v. Dionino, 410 US. 1, 17, 93 S.Ct. 764, 773, 35 L-Edid 67 (1973). 37. /I at 16, 93 S.Q. at 772 (quoting Stirone v. United Stater, 361 US. 212, 218, 80 S.Ct. 270, 273. 4 L.Ed.2d 252 (1960)). EFTA00191835 U.S. I BURZYNSKI CANCER RESEARCH INSTITUTE 1313 ateas5M F.2d 1301 (Mb

ce which a prison has not commenced to serve. Ellison r. United State 263 F.2d 395 (10 Cir. 1969); Cain United States, 49 870 (8 Cir. 1 ). In Heflin United States, 868 U.S. 416, 79 S.Ct. 461, 3 L.Ed.2d 407 (1959), the Supreme Court stated that: "Section 2255 is available only to attack a sentence under which

violations, brought action to enforce terms of immunity agreement under United States Department of Justice's (DOJ's) corporate leniency program. The United States District Court for the Eastern Dis- trict of Pennsylvania, Timothy J. Savage, J., 352 F.Supp2d 553, enjoined prosecu- tion, and government appealed.

The Supreme Court has observed that the executive branch "has exclusive authority and absolute discretion to decide whether to prosecute a case," United States v. Nixon, 418 U.S. 683, 693, 94 S.Ct. 3090, 41 L.Ed2d 1039 (1974), and the Gov- ernment therefore argues that courts lack jurisdiction to enjoin a

r dis- crimination among religions prohibited by establishment clause of First Amendment. 26 U.S.C.A. § 170; Fed.Rules Civ.Proc. Rule 12(b)(6), 28 U.S.C.A.; U.S.C.A. Conan. Amend. 1. 4. Constitutional Law 4=,84(I) Establishment clause of First Amend- ment prohibits denominational preferences, includi

ms Against the Government 131 Neither the United States, its agen- cies, nor its officials acting in their official capacities, may be sued without the United States' specific consent's The Federal Tort Claims Act 7 permits certain claims to be asserted against the United States, as sov- ereign, and its agents bu

ages and declar- atory injunction relief arising from a pre- liminary investigation into possible viola- tions of the Voting Rights Act. The Unit- ed States District Court for the Northern District of California, Spencer Williams and Stanley A. Weigel, M., dismissed injunction claims and granted summary judgment in

SANBORN, and THOMAS, Circuit Judges. STONE, Circuit Judge- This is an appeal from a conviction for violation of the White Slave Traffic Act, IS U.S.C.A. § 397 ct seq. Appellant urges here three claimed er- rors: (1) Improper restriction of cross- examination of a witness; (2) error in the charge to

ses the emotional and psychic harm suffered by the child"). New York I Ferber. 458 U.S. 747. 758-59 & trtr9-1011982) (citations omitted); see also United Slates Yuknavich. 419 F.3d 1302. 1310 (11th Cir.2005) ("possession of child pornography is not a victimless crime")• Goff. 501 F.3d at 259 ("Consum

tside the Guidelines, the judge will explain why he has done so." 127 S.Ct. at 2468. The Supreme urt most recently addressed sentencing in Gall United Stases. 128 S.Ct. 586 (2007), and Kimbroushi United States. 128 S.Ct. 558 (2007). F" Gall reviewed the reasonableness of a sentence falling far below the

ssed; (4) submit to searches based on reasonable suspicion; and (5) register with the state sex-offender registry. After the district court denied the United States's motion to reconsider the sentence and impose either a sentence within the Guidelines, or a sentence of at least one day in prison followed by a li

f § 2423(c). Adopted in 2003 as part of the PROTECT Act, § 2423(c) provides as follows: (c) Engaging in illicit sexual conduct in foreign places. Any United States citizen or alien admitted for permanent residence who travels in foreign commerce, and engages in any illicit sexual con- duct with another person

1984 U.S.C.C.A.N. at 3258-59. "411 11. Notably, this notion of "just deserts" or retribution is a distinct consideration from general deterrence. See United States' Foss. 501 F.2d 522. 527 (1st Cir.1974) (cited with approval in the legislative history of Section 3553(a)) ("[T]he @ 2008 Thomson/West. No Claim t

immoral purposes, such act is not causing such trip within the meaning of section 2 but is, if any crime, the one stated in section 3 of the Act, U.S.C.A. Title 18, § 399. The pertinent language in the two sec- tions is: Section 2. "Any person who shall knowingly • • • cause to be transport- ed • •

7, 1978. Rehearing and Rehearing En Banc Denied in No. 77-1695 July 8 and in No. 77-1682 July 24, 1978. Defendants were convicted in the Unit- ed States District Court for the Eastern District of Missouri, H. Kenneth Wangelin, J., of violating the Mann Act, and they appealed. The Court of Appeals, Gibson, Chief

/or 1099s for all employees, and the names of all corporate directors, board members, and shareholders. EFTA00193179 U.S. Departn, • of Justice United Stales Attorney Southern District of Florida 500 S Australian Ave., Suite 400 Watt Paint Beach, FL 33401-6235 (361) 820-8711 APPEARANCE NOTICE The att

ve to depart by the court or by an officer acting on behalf of the court. CU3RIC (BY) DEPUTY CI.P.RK This subpoena is issued upon application of the United States • f America DATE: May 31, 2007 Name, Address and Phone Number of Assistant U.S. Attorney Ann Marie C. Villafaila, Assistant U.S. Attorney 500 So. Australian

ou will be asked to testify and answer questions under oath, and to produce records and documents. Only the members of the Grand Jury, attorneys for the United States and a stenographer are permitted in the Grand Jury' room while you testify. The U.S. Department of Justice encourages prosecutors to notify an indiv

th,.ted States District Court SOUTHERN DISTRIcr OF FLORIDA TO: SUBPOENA TO TESTIFY BEFORE GRAND JURY FGJ 07-103(WPB)-Tues./No. OLY-56 SUBPOENA FOR; PERSON DOCUMENTS OR OBJ

or criminal liability or a waiver of any jarisdictional or other defense as to any person, whether or not her name appears oa the list provided by the United Slates. 11. Epstein shall use his best efforts to enter his guilty plea and be Page 4 of 7 P. 009/014 EFTA00233347 ..1N- 30-2008180O 10:06 P. CI 0/0

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 pin time be earned during his period of incarceration. 13. The patties anticipate that th

ns with the State Attorney's Office and to use his bestefforts to ensure compliance with thesepareedures, whichcompliancewilt bettor:may to satisfy the United States' interest. Epstein also understands that it is lds obligation to use his best efforts to convince the Judge of the 15th Judicial Circuit to accept Ep

dividuals referred to in paragraph. (7) sups, elect to Me suit pursuant to 18 U.S.C. § 2255, Epstein will not contest the jurisdiction oftheUtrited States District Court fortbe Southern District *Merida over his person and/or the subject matter ,andEp stein waives bisrightto contemliability and also waives hi-slight

SERVED BY TITLE STATEMENT OF SERVICE FEES TRAVEL SERVICES TOTAL DECLARATION OF SERVICE' I declare under penalty of perjury under the laws of the United Stales of America that the foregoing Information contained in the Return of Service and Statement of Service Fees is true and correct. Executed on DATE Signature of

Rule 45(c), Federal Rules of Civil Procedure. 2."Fees and mileage need not be tendered to the witness upon service of a subpoena issued on behalf of the United States or an officer or agency thereof (Rule 45(c), Federal Rules of Civil Procedure; Rule 17(d), Federal Rules of Criminal Procedure) or on behalf of cert

SERVED BY TITLE STATEMENT OF SERVICE FEES TRAVEL SERVICES TOTAL DECLARATION OF SERVICE' I declare under penally of perjury under the laws of the United Slates of America that the foregoing information contained in the Return of Service and Statement of Service Fees is true and correct. Executed on DATE Signature of

Records Custodian: Case No. 08-80736-CV-MARRA P-000430 EFTA00227810 0 r . cn c" Case No. 08-80736-CV-MARRA P-00043I EFTA00227811 th. eted States District Court SOUTHERN DISTRICT OF FLORIDA TO: SUBPOENA TO TESTIFY BEFORE GRAND JURY FG.I 07-103(WPB)-Tues./No. OLY-56 SUBPOENA FOR: PERSON DOCUMENTS OR OBJ

NT OF SERVICE FEES TRAVEL SERVICES TOTAL DECLARATION OF SERVICE2 I declare under Statement of Executed on penalty of perjury under the lays of the United Slates of America that the foregoing Information contained in Service Fees is true and correct. the Return of Service and DATE Signature of Server Address of Serv

Rule 45(c), Federal Rules of Civil Procedure. 2."Fees and mileage need not be tendered to the witness upon service of a subpoena issued on behalf of the United States or an officer or agency thereof (Rule 45(c), Federal Rules of Civil Procedure; Rule 17(d), Federal Rules of Criminal Procedure) or on behalf of cert

e: EFTA01660323 • • APPENDIX A DOCUMENT INVENTORY The documents submitted are as follows: Signature of Records Custodian: EFTA01660324 ted States District Court SOUTHERN DISTRICT OF FLORIDA TO SUBPOENA TO TESTIFY BEFORE GRAND JURY FGJ 07-103(WPB)-Tues./No. OLY-59 SUBPOENA FOR: PERSON DOCUMENTS OR OBJE

ur e-mail or calls unless AUSA and/or her supervisors advise him otherwise. Furthermore, you make reference to "our July 8 deadline." Respectfully, thc United States Attorney's Office for the Southern District of Florida ("SDFL") has never agreed to any such deadline. Should to provide the SDK. with ssa itditio

lid of the attorney representative. As a result, on October 29, 2007, the parties executed an A um wherein it was mutually agreed that former ' States District Court Judge Edward B. would serve as the independent third-party. Judge selected the venerable law firm of Podhurst and Josefsberg to represent the app

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

ff—which they did not—§ 2255 only authorizes suit based on predicate convictions under certain federal statutes. . ." (Id. at 21 (emphasis added).) States District Court and shall recover the actual damages such person sustains and the cost of the suit, including a reasonable attorney's fee. Any person as described i

d to o so prior to 0/20/2006, and was told that if she did not provide the records described in the subpoena, she would be required to appear at the United States District Courthouse located at 701 Clematis Street, West Palm Beach, Florida. At this time, no further action will be taken by the New York Office i

re. Reference: 31E-MM-108062 Serial 19 Enclosure(s): Enclosed for Miami is the server copy of the referenced Grand Jury subpoena issued by lil ted States District Court, Southern District of Florida on 10/06/2006 and served at the on 10/16/2006. Details: On 10/16/2006, SA received from sa.via Federal Ex ress d