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S2 SUPERSEDING INDICTMENT Christian R. Everdell COHEN & GRESSER LLP 800 Third Avenue New York, NY 100
st levied her accusations more than a decade ago. The Palm Beach FBI and the United States Attorney's Office for the Southern District of Florida ("USAO-SDFL") interviewed Accuser-4 in or around 2007 during their three- year investigation of Epstein's alleged sexual abuse (the "Florida Investigation"). And
S2 SUPERSEDING INDICTMENT Christian R. Everdell COHEN & GRESSER LLP 800 Third Avenue New York, NY 100
secutorial overreach. It is no mystery what happened here. The Palm Beach FBI and the U.S. Attorney's Office for the Southern District of Florida ("USAO-SDFL") conducted a thorough investigation of Jeffrey Epstein from 2006-2008 (the "Florida Investigation"), but decided not to prosecute him or his "pote
FOR BREACH OF NON-PROSECUTION AGREEMENT Mark S. Cohen Christian R. Everdell COHEN & GRESSER LLP Jeff
squarely refutes the government's position. The co-conspirator immunity provision does not prohibit merely prosecutions by the USAO for the SDFL ("USAO-SDFL"), but by "the United States." This broad prohibition was intentional, as demonstrated by the express references elsewhere in the NPA to the United
k, New York Respectfully submitted, /s/ Mark S. Cohen Attorneys for Ghislaine Maxwell 32 EFTA0009938
squarely refutes the government's position. The co-conspirator immunity provision does not prohibit merely prosecutions by the USAO for the SDFL ("USAO-SDFL"), but by "the United States." This broad prohibition was intentional, as demonstrated by the express references elsewhere in the NPA to the United
to the Illegal Concealment of the Non- Prosecution Agreement 10 2. Evidence Exists that the Epstein Defense Team Acted in Bad Faith. 18 3. The USAO-SDFL Was Not Authorized to Extend Epstein Immunity Without First Conferring with his Victims. 23 II. THE CVRA AUTHORIZES RESCISSION AS A REMEDY.
Page: EFTA00021443 →or enforcement of congressionally created rights, the courts must give "appropriate judicial deference toward the will of Congress ...."Hardison v. Cohen, 375 F.3d 1262, 1264 (11th Cir. 2004) (internal quotation omitted). Congress is "in a better position to decide whether or not the public interest w
Page: EFTA00021491 →erences to the "Government" in this case should be generally understood to refer to the U.S. Attorney's Office for the Southern District of Florida (USAO-SDFL), which is currently being represented by the U.S. Attorney's Office for the Northern District of Georgia. 2 EFTA00022550 --- PAGE BREAK --- Ca
Page: EFTA00022550 →or enforcement of congressionally created rights, the courts must give "appropriate judicial deference toward the will of Congress ...."Hardison v. Cohen, 375 F.3d 1262, 1264 (11th Cir. 2004) (internal quotation omitted). Congress is "in a better position to decide whether or not the public interest w
Page: EFTA00022595 →y Electronic Mail Christian Everdell, Esq. Mark Cohen, Esq. Cohen & Gresser LLP 800 Third Avenue New
Page: EFTA00030569 →estigation and prosecution of Jeffrey Epstein, as set forth in greater detail in that letter, the Government intends to gather certain martials from USAO-SDFL and conduct targeted searches of that material aimed at identifying potential Giglio or 3500 material for victims or witnesses relevant to this pro
Page: EFTA00030573 →Entities connected to both Michael Cohen and USAO-SDFL

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
Prince Andrew
PERSONLeon Black
PERSON
Donald Trump
PERSONJeffrey Pagliuca
PERSON
Marc Rich
PERSON
United States
LOCATION
Denver
LOCATION
Department of Justice
ORGANIZATION
George W. Bush
PERSONLaura Menninger
PERSON
Joe Biden
PERSON
Colorado
LOCATIONCohen & Gresser LLP
ORGANIZATION
Christian Everdell
PERSON
Julie K. Brown
PERSON
George Mitchell
PERSONMartin Weinberg
PERSON
Alan Dershowitz
PERSON