Epstein Secrets

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. Ouartermaine, 913 F.2d 910, 916 (11th Cir. 1990). Although the statutory presumption places a burden of production on a defendant, the burden of

original jurisdiction over the offense, a motion EFTA00191636 for revocation of the order or amendment of the conditions of release." Accordingly, the United States hereby files this emergency motion with the District Judge assigned to the case for immediate revocation of the Magistrate Judge's Order. THE CHARG

tates Supreme Court has interpreted this amendment to prohibit the imposition of excessLve bail without creating a right to bail in criminal cases. See United States' Salerno. 481 U.S. 739, 754.55 (1987)("Eighth Amendment does not grant absolute right to bail"). The subject of bail and detention also implicates t

atter for the pu ose of arriving at f its own "independent conclusion." See United States I uncan. 897 F. Supp. 688, 689-90 (N.D.N.Y. 1995) citing United States Lam, 766 F.2d Ch. 17 Bail and Deternion 553 EFTA00191622 77, 80 (2d Cir. 1985); see also U ted States ' King, 849 F.2d 485, 489-91 (11th Cir. 1988)

completed. At the time I supersede, the overt acts can be reduced. The counts have been reorganized based upon discussions with Myesha Braden from the Child Exploitation Section. She believes that our strongest counts are the child sex trafficking violations (18 U.S.C. § 1591). I have moved those counts forward in the indic

the planned indictment, the identified victims would have been eligible for restitution gad damages under Section 2255. As explained above, one of the United States' interests, which had to be satisfied by the Non-Prosecution Agreement, was providing appropriate compensation to the victims. This provision of "Ele

espite the fact that the indictment was ready for presentation to the grand jury. In the interim, AUSA and the investigators met with the Chief of the Child Exploitation Section, Drew Oosterbaan, to review, yet again, the evidence and legal theories of prosecution. Chief Oosterbaan strongly supported the indictment and even

the planned indictment, the identified victims would have been eligible for restitution Ilk damages under Section 2255. As explained above, one of the United States' interests, which had to be satisfied by the Non-Prosecution Agreement, was providing appropriate compensation to the victims. This provision of the

fact that the indictment was ready for presentation to the grand jury. In the interim, AUSA Villafafia and the investigators met with the Chief of the Child Exploitation Section, Drew Oosterbaan, to review, yet again, the evidence and legal theories of prosecution. Chief Oosterbaan strongly supported the indictment and even

the planned indictment, the identified victims would have been eligible for restitution and damages under Section 2255. As explained above, one of the United States' interests, which had to be satisfied by the Non-Prosecution Agreement, was providing appropriate compensation to the victims. This provision of the

7, 2007, despite the fact that the indictment was ready for presentation to the grand jury. In the interim AUSA investigators met with the Chief of the Child Exploitation Section, again, the evidence and legal theories of prosecution. Chief strongly supported the indictment and even offered to join the trial team and provid

the planned indictment, the identified victims would have been eligible for restitution and damages under Section 2255. As explained above, one of the United States' interests, which had to be satisfied by the Non-Prosecution Agreement, was providing appropriate compensation to the victims. This provision of the

fact that the indictment was ready for presentation to the grand jury. In the interim, AUSA Villafafia and the investigators met with the Chief of the Child Exploitation Section, Drew Oosterbaan, to review, yet again, the evidence and legal theories of prosecution. Chief Oosterbaan strongly supported the indictment and even

t the victim is a minor, regardless of what the victim says or how the victim appears. Id. (emphasis added; additional internal citations omitted). Cl United States v. Wild, 143 7 EFTA02857530 Fed. Appx. 938, 942 (4th Cir. 2005) (the parties agreed that, to prove a violation of § 2423(a), the United States h

05, even though Jane Doe #2 never went to EPSTEIN's house because at the time of his travel, EPSTEIN intended for Jane Doe #2 to come to the house. See United States v. Han, 230 F.3d 560 (2d Cir. 2000) (defendant could be convicted of violating Section 2423(b) even though no sexual activity occurred and "minor"

tigation are completed. At the time I supersede, the overt acts can be reduced. The counts have been reorganized based upon discussions with from the Child Exploitation Section. She believes that our strongest counts are the child sex trafficking violations (18 U.S.C. § 1591). I have moved those counts forward in the indic