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minority. 17. The above-described acts were perpetrated upon the person of the then minor Plaintiff on numerous occasions. 18. In June 2008, in the Fifteenth Judicial Circuit in Palm Beach County, Florida, the Defendant, Jeffrey Epstein, entered pleas of "guilty" to various Florida state crimes involving the solicitation
ot subject to being set aside, rescinded, or canceled — regardless of whether or not the government failed to comply with the CVRA. On the contrary, Santobello and its progeny require the USAO-SDFL to continue to abide by the terms of the Non-Prosecution Agreement, and due process precludes this Court from
Rescission of the Non-Prosecution Agreement Between the USAO-SDFL and Epstein In an effort to establish standing and circumvent the requirements of Santobello v. New York, 404 U.S. 257, 262 (1971), and its progeny, Petitioners argue that the Non-Prosecution Agreement between the USAO-SDFL and Epstein is a
minority. 17. The above-described acts were perpetrated upon the person of the then minor Plaintiff on numerous occasions. 18. In June 2008, in the Fifteenth Judicial Circuit in Palm Beach County, Florida, the Defendant, Jeffrey Epstein, entered pleas of "guilty" to various Florida state crimes involving the solicitation
ot subject to being set aside, rescinded, or canceled — regardless of whether or not the government failed to comply with the CVRA. On the contrary, Santobello and its progeny require the USAO-SDFL to continue to abide by the terms of the Non-Prosecution Agreement, and due process precludes this Court from
Rescission of the Non-Prosecution Agreement Between the USAO-SDFL and Epstein In an effort to establish standing and circumvent the requirements of Santobello v. New York, 404 U.S. 257, 262 (1971), and its progeny, Petitioners argue that the Non-Prosecution Agreement between the USAO-SDFL and Epstein is a
minority. 17. The above-described acts were perpetrated upon the person of the then minor Plaintiff on numerous occasions. 18. In June 2008, in the Fifteenth Judicial Circuit in Palm Beach County, Florida, the Defendant, Jeffrey Epstein, entered pleas of "guilty" to various Florida state crimes involving the solicitation
ot subject to being set aside, rescinded, or canceled — regardless of whether or not the government failed to comply with the CVRA. On the contrary, Santobello and its progeny require the USAO-SDFL to continue to abide by the terms of the Non-Prosecution Agreement, and due process precludes this Court from
Rescission of the Non-Prosecution Agreement Between the USAO-SDFL and Epstein In an effort to establish standing and circumvent the requirements of Santobello v. New York, 404 U.S. 257, 262 (1971), and its progeny, Petitioners argue that the Non-Prosecution Agreement between the USAO-SDFL and Epstein is a
minority. 17. The above-described acts were perpetrated upon the person of the then minor Plaintiff on numerous occasions. 18. In June 2008, in the Fifteenth Judicial Circuit in Palm Beach County, Florida, the Defendant, Jeffrey Epstein, entered pleas of "guilty" to various Florida state crimes involving the solicitation
ot subject to being set aside, rescinded, or canceled — regardless of whether or not the government failed to comply with the CVRA. On the contrary, Santobello and its progeny require the USAO-SDFL to continue to abide by the terms of the Non-Prosecution Agreement, and due process precludes this Court from
Rescission of the Non-Prosecution Agreement Between the USAO-SDFL and Epstein In an effort to establish standing and circumvent the requirements of Santobello v. New York, 404 U.S. 257, 262 (1971), and its progeny, Petitioners argue that the Non-Prosecution Agreement between the USAO-SDFL and Epstein is a
lead trial counsel in the case of Georgia Womack v. Wal-Mart Stores. Inc. and Willie Daniels (CASE NO.: 502007CA009230XXXXMB) currently pending in the Fifteenth Judicial Circuit before the Honorable Thomas H. Barkdull, Ill. Said case is presently the number one backup for trial Commencing Monday, April 13, 2009. As such, th
fter a court determination that Epstein had violated the agreement could the U.S. Attorney's Office move forward to prosecute Epstein. See generally Santobello v. New York, 404 U.S. 257 (1971). Finally and most fundamentally, Epstein has it entirely within his power to avoid criminal prosecution by comply
nts, and precluded by the doctrines of equitable and judicial estoppel. 7 EFTA00299027 BACKGROUND On July 19, 2006, Mr. Epstein was indicted in the Fifteenth Judicial Circuit in and for Palm Beach County on one count of solicitation of prostitution, in violation of Fla. Stat. §796.07. See State v. Jeffiey E. Epstein, 50-
, 643 F.3d 807, 874 (11th Cir. 2011), quoting United States v. Harvey, 869 F.2d 1439, 1443 (11th Cir.1989) (en banc). See, e.g., 38 EFTA00299058 Santobello v. New York, 404 U.S. 257, 262 (1971) ("when a plea rests in any significant degree on a promise ... of the prosecutor, so that it can be said to be
Entities connected to both the Fifteenth Judicial Circuit and Santobello

Jeffrey Epstein
PERSON
United States
LOCATIONJane Doe
PERSON
Kenneth Marra
PERSON
Bradley Edwards
PERSONJack Goldberger
PERSON
Scarlett Johansson
PERSONthe Southern District
LOCATION
George W. Bush
PERSON
Alexander Acosta
PERSON
Alan Dershowitz
PERSONFBI
ORGANIZATION
Palm Beach County
LOCATIONEmmy Taylor
PERSONRobert D. Critton
PERSON
Paul Cassell
PERSONLeon Black
PERSON
Jay Lefkowitz
PERSON
Department of Justice
ORGANIZATION
A. Marie Villafana
PERSON