Epstein Secrets

toward the will of Congress . . . ." Hardison v. Cohen, 375 F.3d 1262, 1264 (11th Cir. 2004) (internal

st efforts turns out to be an exercise in internal government finger pointing. Specifically, the Government in this case (i.e., the U.S. Attorney's Office for the Southern District of Florida) argues that the Office complied with the Attorney General Guidelines for Victim and Witness Assistance (May 2005) and, accordingly, the Office use

sinessmen for Free Enterprise v. City of Hollywood, 648 F.2d 956, 957 (11th Cir. 1981). See, e.g., In re Federal Grand Jury Proceedings (FGJ 91-9), Cohen, 975 F.2d 1488, 1492 (11th Cir. 1992). Those factors are amply satisfied in this case: there is a strong likelihood that intervenors will prevail on

ion. I. Preface The petitioners in this action seek to vacate a "non-prosecution agreement" ("the agreement") between the United States Attorney's Office for the Southern District of Florida (USAO/SDFL) and Jeffrey Epstein (Epstein) pursuant to the Crime Victims' Rights Act of 2004 (CVRA), 18 U.S.C. §3771. Under the agreement, Epstein a

iolation of statutory provisions. It Hardison v. Cohen, 375 F.3d 1262, 1266 (11th Cir. 2004); Nichols v

pstein's conduct. After developing substantial incriminating evidence, the FBI referred the matter for prosecution to the United States Attorney's Office for the Southern District of Florida. Beginning in January 2007, and over the course of the ensuing eight *1199 months, Epstein's defense team engaged in extensive negotiations with f

Y ELECTRONIC MAIL Christian Everdell, Esq. Mark Cohen, Esq. Cohen & Gresser LLP 800 Third Avenue New

e of caution, the Government is producing these records to you in the form in which they were stored in the files maintained by the U.S. Attorney's Office for the Southern District of Florida. The Government recognizes that its discovery obligations are ongoing and will promptly produce any additional discoverable material of which it be