Epstein Secrets

Edwards Edwards Pottinger LP 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 Telephone : (800) 400-1098 E-Mail: [email protected] Paul G. Cassell Pro Hac Vice S.J. Quinney College of Law at the University of Utah* 383 S. University St. Salt Lake City, UT 84112 Telephone: (801) 585-5202 E-

: (800) 400-1098 E-Mail: [email protected] Paul G. Cassell Pro Hac Vice S.J. Quinney College of Law at the

ed, the Eleventh Circuit has clearly held that the manner in which an agreement is formed can render an otherwise-valid agreement unenforceable. In San Pedro v. United States, 79 F.3d 1065 (11th Cir. 1996), the Eleventh Circuit held that in order for any provision in a plea agreement to be enforceable, "t

pstein. The facts of San Pedro offer clear parallels to this case. There, the prosecutor offered a promise of non-deportation to criminal defendant San Pedro. The Eleventh Circuit concluded that this agreement was unenforceable, because by statute the power to enforce immigration laws rested with the Imm

Bradley J. Edwards Edwards Pottin er LP Paul G. Cassell Pro Hac Vice This daytime business address is p

TATES JANE DOE 1 AND JANE DOE 2'S REPLY TO INTERVENOR EPSTEIN'S BRIEF IN OPPOSITION TO PROPOSED REMEDIES Bradley J. Edwards Edwards Pottin er LP Paul G. Cassell Pro Hac Vice This daytime business address is provided for identification and correspondence purposes only and is not intended to imply institutio

ed, the Eleventh Circuit has clearly held that the manner in which an agreement is formed can render an otherwise-valid agreement unenforceable. In San Pedro v. United States, 79 F.3d 1065 (11th Cir. 1996), the Eleventh Circuit held that in order for any provision in a plea agreement to be enforceable, "t

v-80736-KAM Document 466 Entered on FLSD Docket 07/23/2019 Page 27 of 70 United States Attorney and the AUSAs who negotiated the plea agreement with San Pedro did not have the authority to promise that he would not be deported." Id. at 1072. So too here. Prosecutors were simply not authorized to offer Eps

h amendment right — not an alleged victim's — to insist that the defendant be represented by conflict-free counsel; c) rely heavily on the case of San Pedro v. United States, 79 f.3d 1065, 1068 (11" Cir. 1999) (DE 466:24-25, 38), an easily distinguished case not cited by Petitioners in their initial sub

AUSA Jill E. Steinberg, counsel for the government, who advises that the government does not object. Counsel for Mr. Epstein also communicated with Paul Cassell, counsel for the Petitioners, who advises that the Petitioners will likely object. Respectfully submitted, /s/Roy Black Roy Black, Esq. (FL Bar

nsel for Mr. Epstein also communicated with Paul Cassell, counsel for the Petitioners, who advises that t