Epstein Secrets

S.D. Fla. 2001); Case 9:08-cv-80119-KAM Document 545 Entered on FLSD Docket 05/12/2010 Page 25 of 37 Doe v. Epstein 08-CV80119 Page No. 25 Cooper v. Hallgarten & Co., 34 F.R.D. 482, 483-84 (S.D.N.Y. 1964). Thus, before the Court can order production of the requested returns in this matter, the

tion. Moreover, fue NP A does not provide Epstein with any protection from criminal investigation or prosecution in any federal district other than the Southern District of Florida. The Second Amended Complaints and Plaintiff Response at DE 485, p.18 include averments that Epstein both resided in and engaged in illegal sexual

Fla. 2001); 16 Case 9:08-cv-80119-KAM Document 477 Entered on FLSD Docket 02/26/2010 Page 17 of 24 Doe v. Epstein 08-CV80119 Page No. 17 Cooper v. Hallgarten & Co., 34 F.R.D. 482, 483-84 (S.D.N.Y. 1964). Thus, before the Court can order production of the requested returns in this matter, the

ern District of Florida. However, the NP A does not provide Epstein with any protection from criminal investigation or prosecution in other than in the Southern District of Florida. As the court has acknowledged in its orders ( e.g., 9 Case 9:08-cv-80119-KAM Document 477 Entered on FLSD Docket 02/26/2010 Page 10 of 24

Specifically, the Government discloses the following: • The victim identified in the Indictment as "Victim-1" received a grand jury subpoena from the Southern District of Florida ("SDFL") in or about 2008. However, Victim-1 was never interviewed by law enforcement, including the West Palm Beach Police Department, Federal Bur

ed by authorized representatives of the Office cannot and do not constitute a "formal offer" or a "plea offer," as those terms are used in Lafier v. Cooper, 132 S. Ct. 1376 (2012); Missouri v. Fiye, 132 S. Ct. 1399 (2012). Very truly yours, GEOFFREY S. BERMAN United States Attorney by: Enclosure A