Epstein Secrets

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or criminal liability or a waiver of any jurisdictional or other defense as to any person, whether or not her name appears on the list provided by Ste United States. Pursuant to the teams ofthe agreernentand an addendum, to assist you in making such a claim, the U.S. Attorney's Office has asked an independent S

reached (defense counsel has reserved the right to challenge such litigation). 8. The ability to negotiate effectively. Pursuant to this letter, thcUnited States assigns toyou tho responaibilityfor consulting with and selecting the attorney representative for the individuals. The United States and Epstein re

tatute. I would note that the United States provided tide draft letter to defense as a courtesy. in addition, First Assistant United States Attorney Simian already incorporated in the letter several edits that had been requested by defense counsel. !agree that Section 3771 applies to notice of proceedi

rdance with Paragraph 7B, please provide me with a proposed written submission to the Special Master by Monday afternoon. Finally, as you are aware, yhe United States has been ordered to produce the Non-Prosecution Agreement. In accordance with that Order, we will produce the September Agreement with the October A

Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 Phone 561 209-1047 Fax 561 820-8777 Original Message From: Simian, Jeff (USAFLS) Sent: Friday, August IS, 2008 1:52 PM To: Villafana, Ann Marie C. (USAFLS); Senior, Robert (USAFLS); Acosta, Alex (USAFLS); Lee, Dex

of an enumerated federal crime. This requires Mr. Epstein to in essence admit guilt, though he believes he did not commit the requisite offense. The United States Attorney Manual ("USAM") 9-27.440, Principles of Federal Prosecution, sets forth a clear requirement when a defendant tenders a plea of guilty but s

' that you hold Mr. Epstein in breach of the Agreement by his failure to pica and he sentenced on October 26, 2007 is directly contradicted by Mr.. Simian's e-mail to me dated October $1 in which he states. "Your understanding from Jack Goldberger con:hems tomy understanding that Mr.. Epstein's plea an