Epstein Secrets

ncluding cases against defendants as infamous as Bernie Madoff, Marc Dreier and David Brooks. To be clea

-c‘O3O3B.49664-0CtailltdReta 2fft3eurfetteSCt off ikkElEgaltket (0748/S01315Page 5 of 20 obligations undertaken therein to be set aside.4 See, e.g., Santobello v. New York 404 U.S. 257, 262 (1971) ("[W]hen a plea rests in any significant degree on a promise or agreement of the prosecutor, so that it can be

greement, the United States would still be constitutionally required to adhere to the negotiated terms of the Non-Prosecution Agreement. See, e.g., Santobello, 404 U.S. at 262; Harvey, 869 F.2d at 1443. Due process considerations further bar this Court from setting aside a non-prosecution agreement that g

ncluding cases against defendants as infamous as Bernie Madoff, Marc Dreier and David Brooks. To be clea

-c‘O3O3B.49664-0CtailltdReta 2fft3eurfetteSCt off ikkElEgaltket (0748/S01315Page 5 of 20 obligations undertaken therein to be set aside.4 See, e.g., Santobello v. New York 404 U.S. 257, 262 (1971) ("[W]hen a plea rests in any significant degree on a promise or agreement of the prosecutor, so that it can be

greement, the United States would still be constitutionally required to adhere to the negotiated terms of the Non-Prosecution Agreement. See, e.g., Santobello, 404 U.S. at 262; Harvey, 869 F.2d at 1443. Due process considerations further bar this Court from setting aside a non-prosecution agreement that g

ehalf of the court. CLERK (BY) DEPUTY CLERK DATE: December 18, 2006 Case No. 08-80736-C V-MARRA P-000219 EFTA00223899 LAW OFFICES LYONS AND SANDERS CHARTERED DALE R. SANDERS • BRUCE Ni. LYONS •• HOWARD L. OREITZER EDWARD 0. 0959-1907) •ALSO Aosainco IN wyONIN9 ° ALSO ADMITTED IN COLORADO

ot to prosecute in return for a person's cooperation binds the government to the extent that the person carries out his/her part of the bargain. See Santobello v. New York 404 U.S. 257 (1971); Wade v. United States, 112 S. Ct. 1840 (1992). Since such an agreement forecloses enforcement of the criminal law

t appl tc able. enter 'none' TobtfdaliblavolA0116 FORM ORD-227 JANA6 Case No. 08-80736-CV-MARRA 1a-000219 EFTA00226399 LAW OrriCES LYONS AND SANDERS CHARTERED DALE R. SANDERS • BRUCE M. LYONS •• HOWARD L. OREITZER EDWARD 0. BERGER 11959-1907) 'ALSO ^mimeo IN It/TORINO •• ALSO ADMITTED IN

ot to prosecute in return for a person's cooperation binds the government to the extent that the person carries out his/her part of the bargain. See Santobello v. New York 404 U.S. 257 (1971); Wade v. United States, 112 S. Ct. 1840 (1992). Since such an agreement forecloses enforcement of the criminal law