Epstein Secrets

ll be deferred" provided that Epstein met certain conditions. Additionally, the Agreement extended immunity to Epstein's named co-conspirators, • Lesley Groff, [and ' as well as "any potential co-conspirators" of Epstein's. In return for federal immunity, Epstein agreed to plead guilty to two low-level

y to Epstein's named co-conspirators, • Lesley Groff, [and ' as well as "any potential co-conspirato

guage of the statute, and we are required to enforce that plain meaning even if the proper interpretation raises policy concerns. See ?" Eldred v. Ashcroft, 537 U.S. 186, 222, 123 S.Ct. 769, 154 L.Ed.2d 683 (2003). "The wisdom of Congress' action ... is not within our province to second guess." ? a Id.

It will not institute any criminal charges against any potential coconspirator* of Epstein, Including but not limited to Sarah Kellen Adrian& R033, Lesley Groff, r $.dia hiarcinkova Further, upon execution of this op temcrel sod a plea agreement with the State Attorney's Office, the federal Omni Jury invest

not limited to Sarah Kellen Adrian& R033, Lesley Groff, r $.dia hiarcinkova Further, upon execution of t

de clear that "Twombly expounded the pleading standard for 'all civil actions' and not just pleadings made in the context of an antitrust dispute," Ashcroft'. Iqbal No. 07-1015 (U.S. May 18, 2009) (slip op. at 20) (quoting Fed. R. Civ. P. 1), the need to enforce these pleading requirements is especially

ill not institute any Page 27 of 58 EFTA00225070 criminal char es a ainst any potential co-consgtors of E stein, including but not limited to M, Lesley Groff, or ' (Exhibit 52 at 5). To the extent that there was "criminal organization," the Office and the investigators considered Epstein to be the head

E stein, including but not limited to M, Lesley Groff, or ' (Exhibit 52 at 5). To the extent that the

o understand that Criminal Chief contacted SLC about moving me to Appeals after I pointed out actions that I considered to be in violation of the Ashcroft memo and victims' rights legislation. I also understand that SLC ma have knowled e of USA Acosta providing my prosecution memorandum to Main Jus

f Epstein, including but not limited to Lesley Groff, or NPA at 5; Def. Mot. 1 at 20-21. Aside from t

d States also agrees that it will not institute any criminal charges against any otential co-cons irators of Epstein, including but not limited to Lesley Groff, or NPA at 5; Def. Mot. 1 at 20-21. Aside from the reference to "United States" which, as noted above, is insufficient, the defendant does not poin

U.S. 461 (1997) 200 Kungys v. United States, 485 U.S. 759 (1988) 222 Landgraf v. USI Film Products, 511 U.S. 244 (1994) 35,36,41,42 Leocal v. Ashcroft, 543 U.S. 1 (2004) 56, 57 Madanes v. Madanes, 186 F.R.D. 279 (S.D.N.Y. 1999) 141 Martindell v. Intl Tel. and Tel. Corp., 594 F.2d 291 (2d Cir

will not institute any criminal charges against any potential co-conspirators of Epstein, including but not limited to Sarah Kellen, Adriana Ross, Lesley Groff, or Nadia Marcinkova. NPA at 5; Def. Mot. I at 20-21. Aside from the reference to "United States" which, as noted above, is insufficient, the defen

ot limited to Sarah Kellen, Adriana Ross, Lesley Groff, or Nadia Marcinkova. NPA at 5; Def. Mot. I at 2

U.S. 461 (1997) 200 Kungvs v. United States, 485 U.S. 759 (1988) 222 Landgralv. USI Film Products, 511 U.S. 244 (1994) 35,36,41,42 Leocal v. Ashcroft, 543 U.S. 1 (2004) 56, 57 Madanes v. Madanes, 186 F.R.D. 279 (S.D.N.Y. 1999) 141 Martindell v. Intl Tel. and Tel Coup., 594 F.2d 291 (2d Cir.

will not institute any criminal charges against any potential co-conspirators of Epstein, including but not limited to Sarah Kellen, Adriana Ross, Lesley Groff, or Nadia Marcinkova. NPA at 5; Def. Mot. 1 at 20-21. Aside from the reference to "United States" which, as noted above, is insufficient, the defen

ot limited to Sarah Kellen, Adriana Ross, Lesley Groff, or Nadia Marcinkova. NPA at 5; Def. Mot. 1 at 2

S. 461 (1997) 200 Kungys v. United States, 485 U.S. 759 (1988) 222 Landgraf v. USI Film Products, 511 U.S. 244 (1994) 35,36, 41, 42 Leocal v. Ashcroft, 543 U.S. 1 (2004) 56, 57 Madanes v. Madanes, 186 F.R.D. 279 (S.D.N.Y. 1999) 141 Martindell v. Intl Tel. and Tel. Corp., 594 F.2d 291 (2d Cir.

will not institute any criminal charges against any potential co-conspirators of Epstein, including but not limited to Sarah Kellen, Adriana Ross, Lesley Groff, or Nadia Marcinkova. NPA at 5; Def. Mot. 1 at 20-21. Aside from the reference to "United States" which, as noted above, is insufficient, the defen

ot limited to Sarah Kellen, Adriana Ross, Lesley Groff, or Nadia Marcinkova. NPA at 5; Def. Mot. 1 at 2

S. 461 (1997) 200 Kungys v. United States, 485 U.S. 759 (1988) 222 Landgraf v. USI Film Products, 511 U.S. 244 (1994) 35,36, 41, 42 Leocal v. Ashcroft, 543 U.S. 1 (2004) 56, 57 Madanes v. Madanes, 186 F.R.D. 279 (S.D.N.Y. 1999) 141 Martindell v. Intl Tel. and Tel. Corp., 594 F.2d 291 (2d Cir.

will not institute any criminal charges against any potential co-conspirators of Epstein, including but not limited to Sarah Kellen, Adriana Ross, Lesley Groff, or Nadia Marcinkova. NPA at 5; Def. Mot. 1 at 20-21. Aside from the reference to "United States" which, as noted above, is insufficient, the defen

ot limited to Sarah Kellen, Adriana Ross, Lesley Groff, or Nadia Marcinkova. NPA at 5; Def. Mot. 1 at 2

ungys v. United States, 485 U.S. 759 (1988) Landgraf v. US! Film Products, 148 511 U.S. 244 (1994) 27 Landgraf, 511 U.S 27, 30, 32 Leocal v. Ashcroft, 543 U.S. 1 (2004) 40 Lighte, 782 F.3d 120 Madanes v. Madanes, 186 F.R.D. 279 (S.D.N.Y. 1999) 98 Martindell v. Intl Tel. and Tel. Corp., 59

255 37 8/15/2007 Subpoena to Bear Stearns (return date 9/4/07) 8/16/2007 Subpoena to Adam Perrylang (return date 9/4/07) 8/16/2007 Subpoena to Lesley Groff (return date 9/4/07) 8/16/2007 Subpoena to Jean-Luc Brunel (return date 9/4/07) 8/16/2007 Subpoena to Harry Beller (return date 9/11/07) 8/16/20

Material EFTA00225440 EPSTEIN INVESTIGATION TIMELINE Date To From Re: Exhibit # 9/12/2007 A. Marie Villafatia Nathan Z. Dershowitz Ms. Groff will proceed by interview. 9/12/2007 Meeting (US: Andy Lourie, Rolando Garcia and Marie Villafafia, DEF: Jay Lefkowitz, Gerald Lefcourt and Jack G

Criminal Chief Matt Menchel contacted SLC Schultz about moving me to Appeals after I pointed out actions that I considered to be in violation of the Ashcroft memo and victims' rights legislation. I also understand that SLC Schultz may have knowledge of USA Acosta providing my prosecution memorandum to Cr