Epstein Secrets

hurgood Marshall U.S. Courthouse 40 Foley Square, New York, NY 10007 Telephone: 2124574500 MOTION INFORMATION STATEMENT Docket Number(s): 18-2888 Morton for. Leave to File Brief as Amicus Curiae in Support of Defendant-Appellee Maxwell's Objections to The Court's March 11, 2019 Order to Show Cause

dale, FL, 33301 202.681-5432; [email protected] 954 377 4223; [email protected] Cowl- Judge/ Agency appealed from: U.S. District Court for the Southern District of New York (Sweet, J.) Please check appropriate boxes: I las movant notificdApposing counsel (required by Local Rub 27.1): ZYes jNo (explain):

re silly, unfounded and alleged violations which are not defined as violations under the NPA but arrived at by the USAO. Thus, EPSTEIN is left with "Morton's Fork" in his side - the undesirable choice of taking the 5th Amendment and having a judgment (summary or otherwise) entered against him in the ci

as long as the USAO determines EPSTEIN has complied with those terms and conditions. The threat of criminal prosecution against EPSTEIN by USAO in the Southern District of Florida continues presently and through late 2010. 6. Pursuant to the terms of the NPA, the USAO possesses the right to declare that the agree

re silly, unfounded and alleged violations which are not defined as violations under the NPA but arrived at by the USAO. Thus, EPSTEIN is left with "Morton's Fork" in his side - the undesirable choice of taking the 5h Amendment and having a judgment (summary or otherwise) entered against him in the civ

as long as the USAO determines EPSTEIN has complied with those terms and conditions. The threat of criminal prosecution against EPSTEIN by USAO in the Southern District of Florida continues presently and through late 2010. 6. Pursuant to the terms of the NPA, the USAO possesses the right to declare that the agree

ozen Eleventh Circuit cases involving prosecutions under § 2422(b), most of which involve this prototypical fact pattern. See. e.g., United States Morton. 364 F.3d 1300 (11th Cir. 2004), vacated for further consideration in light of Booker, 125 S. Ct. 1338 (2006), opinion reinstated by, 144 Fed. Appx.

Dershowitz, Esq. December 7, 2007 Page 6 1 have reviewed the submissions made on behalf of Mr. Epstein to the United States Attorney's office in the Southern District of Florida, which concluded that the cited federal statutes are inapplicable to the allegations made against Mr. Epstein and therefore, as a matter

zen Eleventh Circuit cases that include a prosecutio under §2422(b), most of which involve the prototypical fact pattern. See, e.g., United States'. Morton, 364 F.3d 1300 (I I* Cir. 2004), judgment vacated for Booker consideration, 115 S. Ct. 1338 (2006); United Stalest Grego, 363 F.3d 1093 (II* Cir. 2

using the intemet, acted with a specific intent to persuade a means to engage in unlawful sex). In fact, we have reviewed every indictment filed in the Southern District of Florida in which there is at least one allegation of a violation of §2422(b). To the extent the facts could be discerned from the indictment, we

zen Eleventh Circuit cases involving prosecutions under § 2422(b), most of which involve this prototypical fact pattern. See, e.g„ United States v. Morton. 364 F3d 1300 (11th Cir. 2004), vacated for further consideration in light stf Booker, 125 S. Ct. 1338 (2006), opinion reinstated by, 144 Fed. Appx.

n Dcrshowitz, Esq. December 7,2007 Page 6 I have reviewed the submissions made on behalf of Mr. Epstein to the United States Attorney's office in the Southern District of Florida, which concluded that the cited federal statutes are inapplicable to the allegations made against Mr. Epstein and therefore, as a matter

week (08/15, Slisco), The Daily Beast (08/15, Folk), Newsmax (08/15, Staff Writer), The Independent (08/15, Kilander), and Washington Times (08/15, Morton). FBI Probed for Info on Alleged Iranian Agent's Assassination Plot Targeting Trump Fox News (08/15, Johnson) reported that bipartisan senators are

igation has dragged on for several months and first became public after it was reported the FBI and investigators with the US Attorney's Office for the Southern District of New York raided the home of Brianna Suggs, Adams' chief fundraiser. The New York Post (08/15, McCarthy, Bhole, et al.), Fox News (08/15, Whitten)

7 S.Ct 2434, 2440, 58 L.Ed.2d 383 (1977) (Hunt k Simon, 426 U.S. at 40, 96 S.Ct. at 1925; Worth, 422 U.S. at 611, 96 S.Ct at 2211; Sierra Club v. Morton, 405 U.S. 727, 739, 92 S.Ct. 1361, 1868, 81 L.Ed.2d 636 (1972) (Sierra Club). In Hunt, the Supreme Court established a three-part test to determin

ven transac- tional immunity. Finally, the prosecutor most intimately involved with the agree- ment Patrick Sullivan, an Assistant U.S. Attorney in the Southern District of Flor- ida had no recollection of any involvement with Jerry Lee Harvey.' He could not remember speaking to the Mobile U.S. At- torney's office o

ense Information Systems Agency." FBI Visits Home Of Omaha Man After Congressman Alleged Threats. EFTA01659540 The Omaha (NE) World-Herald (7/19, Morton, 641K) reports, "Omahan Clark Rutledge got a visit this week from the FBI after calling the office of his congressman, Rep. Don Bacon. `Our office t

okesman for the AG says. That means that for now, Attorney General Hector Balderas' team is working as fact-gatherer for the US Attorney's Office in the Southern District of New York, where Epstein pleaded not guilty last week to charges of sex trafficking of minors and sex trafficking conspiracy, says Matt Baca, seni

n Eleventh Circuit cases that include a prosecution under §2422(b), most of which involve the prototypical fact pattern. See, e.g., United States v. Morton, 364 F.3d 1300 (I Is Cir. 2004),judgment vacated for Booker consideration, 125 S. Ct. 1338 (2006); United States v. Orrega, 363 F.3d 1093 (11th Cir

using the intemet, acted with a specific intent to persuade a means to engage in unlawful sex). In fact, we have reviewed every indictment filed in the Southern District of Florida in which there is at least one allegation of a violation of §2422(b). To the extent the facts could be discerned from the indictment, we