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 Appx. 923, 926-27 (11th Cir. 2007) (unpublished opinion);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

December 19, 2007 I write to follow up on the December le meeting between defense counsel and the Eps prosecutors, as well as our First Assistant, the Miami FBI Special A ent in Charge and mysel . 'Section 2255 provides that: Imlay person who, while a minor, was a victim of a violation of (enumerated SCCII0115 of Title I

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

ember 19, 2007 I write to follow up on the December 14" meeting between defense counsel and the Eps 'n prosecutors, as well as our First Assistant, the Miami FBI Special A ent in Ch e and mysel . 2 Section 2255 provides that: "Itt]ny person who, while a minor, was a victim of a violation of [enumerated sections of Title

te commerce for the purpose of engaging in illicit sexual conduct, as defined in 18 U.S.C. § 2423(1), with minor females, in violation of Title 18, United States Cod; Section 2423(b); all in violation of Title 18, United States Code, Section 2423(e); (3) using a facility or means of interstate or foreign commer

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

ear Ms. Sanchez: I write to follow up on the December I4th meeting between defense counsel and the Eps prosecutors, as well as our First Assistant, the Miami FBI Special A ent in Charge and mysel . 1 Section 2255 provides that: lajny person who, while a minor, was a victim of a violation of [enumerated sections of Title 1

t trial. No more; no less." 2 EFTA00192643 U.S. Department of Justice United States Attorney Southern District of Florida Ft ALEXANDER ACOSTA UNITEDSTATES ATTORNEY DELIVERY BY FACSIMILE Lilly Ann Sanchez Fowler White Burnett, PA 1395 Brickell Ave, 14'h Floor Miami, FL 33131 Re: Jeffrey Epstein D

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

ecember 19, 2007 I write to follow up on the December 14th meeting between defense counsel and the Eps prosecutors, as well as our First Assistant, the Miami FBI Special A ent in Char e and mysel . a Section 2255 provides that: "(a)ny person who, while a minor, was a victim of a violation of (enumerated sections of Title

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

ecember 19, 2007 I write to follow up on the December I41h meeting between defense counsel and the Eps prosecutors, as well as our First Assistant, the Miami FBI Special A ent in Charge and mysel . 2 Section 2255 provides that: tiny person who, while a minor, was a victim of a violation of [enumerated sections of Title I

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

December 19, 2007 I write to follow up on the December 14" meeting between defense counsel and the Eps prosecutors, as well as our First Assistant, the Miami FBI Special A ent in Charge and mysel all11111111111t 2 Section 2255 provides that: "Hay person who, while a minor, was a victim of a violation of (enumerated sectio

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

er 19, 2007 I write to follow up on the December 14th meeting between defense counsel and the lips • n prosecutors, as well as our First Assistant, the Miami FBI Special A ent in Charge and myscl . 'Section 2255 provides that: lajny person who, while a minor, was a victim of a violation of [enumerated sections of Title l8