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 Appx. 923, 926-27 (11th Cir. 2007) (unpublished opinion);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

ed his guilty plea and was sentenced on June 30, 2008. In accordance with the terms of the Non-Prosecution Agreement, later that day, Special Agent Kuyrkcndall and I met with Attorneys Jack Goldberger and Michael Tein and provided them with a written list of the 32 identified victims. Since the entry of th

pecialist TOTAL P.O? EFTA00177316 Case 9:08-cv-t -KAM Document 14 Entered on FLSD Docket 07/1 38 Page 18 of 21 U.S. Department of Justice %sr United States Attorney Southern District of Florida 500 South Australian Ave., Suite 400 West Palm Beach. FL 33401 (361)8204711 Facsimile: (561) 820-8777 Jul

efore the Court on Plaintiff's Emergency Petition for Enforcement of Crime Victim's Rights Act (DE 1), filed July 7, 2008. It is hereby ORDERED that the United States' Attorney shall file a response to this petition by 5:00 P.M. on Wednesday, July 9, 2008. DONE AND ORDERED in Chambers at West Palm Beach, Palm Beach

RT SOUTHERN DISTRICT OF FLORIDA NO. 08-80736-C1V-MARRA/JOHNSON 38 Page 1 of 1 ORDER DENYING MOTION TO SEAL THIS CAUSE comes before the Court on the United States of America's Motion to Seal its Response to Victim's Emergency Petition for Enforcement of Crime Victim Rights Act, filed July 9, 2008. The Court has carefully

Government claims is troublesome, the Fifth Circuit cited to the district coirt opinion under review, which had quoted all the words in the statute. See United States'. SP Peoducts, 2008 WL 501321 at *7 (noting victims right to confer "in the case"), cited in In re Dean, 527 F.3d at 394. The Government finally no

viders can be provided to you, if you so desire. If you or your family is subjected to any intimidation or harassment, please contact Special Agent Kuyrkcndall or myself immediately. It is possible that someone working on behalf of the targets of the investigation may contact you. Such contact does not vio

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

tion with the investigation, you will be notified. Sincerely, United States Attorney By: A. Assistant United States Attorney cc: Special Agent Kuyrkcndall, P.B.I. OR-807364 :II-MAR RA 000979 EFTA00184409 Case 9:08-cv-80736-KAM Document 361-29 Entered on FLSD Docket 02/10/2016 Page 1 of 4 ( ( EXH