.D.N.Y. 1973) 73 United States v. Dorvee, 616 F.3d 174 (2d Cir. 2010) 236 United States v. Drago, No. 18 Cr. 0394 (SJF) (AYS), 2019 WL 3072288 (E.D.N.Y. July 15, 2019) 86 United States v. Dumitru, No. 18 Cr. 243 (LAK), 2018 WL 3407703 (S.D.N.Y. June 26, 2018) 261 United States v. Eldred, 933 F.3

bit 3: Exhibit 4: Exhibit 5: Exhibit 6: Exhibit 7: Exhibit 8: Exhibit 9: Exhibit 10: Exhibit 11: Exhibit 12: Notes from the U.S. Attorney's Office for the Southern District of New York June 14, 2007 Email November 2020 Report, U.S. Department of Justice, Office of Professional Responsibility Notes from February 11, 2021 Call Note

ase The defendant seeks to dismiss the Indictment based on a 2007 non-prosecution agreement ("NPA") between Jeffrey Epstein and the U.S. Attorney's Office for the Southern District of Florida (the "USAO-SDFL"). (Def. Mot. 1). She does so despite the fact that: (1) she did not negotiate the NPA, was not a party to the NPA, and

gating Agency. Dated: New York, New York June 27, 2019 SIP.Obert W. Lehrburger THE HONORABLE ROBERT W..LEHRBURGER UNITED STAITSIMAGISTRAM JUDGE SOUTHERN DfSTRICT OF NEW YORK 3 2017.02.06 SON Y_GM_00000009 EFTA_00114093 EFTA01262790

t are dialed before the call is cut through. 2 2017.02.06 SONY_GM_00000008 EFTA_00114092 EFTA01262789 retained by the United States Attorney's Office for the Southern District of New York and the Investigating Agency. Dated: New York, New York June 27, 2019 SIP.Obert W. Lehrburger THE HONORABLE ROBERT W..LEHRBURGER UNITED STAITSI

Schwartz will step in to oversee the implementation of the settlement announced in January between the City of New York, HUD and the U.S. Attorney's Office for the Southern District of New York. Under the agreement, Schwartz will have the power to reorganize the management structure of the troubled housing authority, as well as implement t

nd Rochelle and the other accusers who have had the courage to come forward." She added that both women planned to speak with the U.S. Attorney for the Eastern District of New York. "I am speaking out because I want to encourage other victims who I know must be out there to come forward as well," Scaff said. "I want justice fo

death. As Jeffrey Epstein is now deceased, any privacy concerns are extinguished. 1. Any and all records from the from the United States Attorney's Office for the Southern District of New York relating to: a. Jeffrey Epstein (DOB: 01/20/53); b. Ghislaine Maxwell DOB: 12/25/61 ; c. . Mark E stein; Page 8 EFTA00091023 in.

Request ACTIVE All records regarding, concerning or relating to a deceased individual named Jeffrey Edward Epstein maintained by the US Attorney's Office for the Southern District of New York and/or the US Attorney's Office for the Southern District of Florida. Mr. Epstein was born on January 20, 1953 and died on or about August 10,2019.

e resolution." Exh. B (Dep't of Justice, Office of Professional Responsibility, Executive Summary of Report, Investigation into the U.S. Attorney's Office for the Southern District of Florida's Resolution of its 2006-2008 Federal Criminal Investigation of Jeffrey Epstein and Its Interactions with Victims during the Investigati

F. App'x 268 (2d Cir. 2004) 14, 22, 27, 29 United States v. Harvey, 791 F.2d 294 (4th Cir. 1986) 24 United States v. Laskow, 688 F. Supp. 851 (E.D.N.Y.), aff'd, 867 F.2d 1425 (2d Cir. 1988) 21 United States v. Marquez, 909 F.2d 738 (2d Cir. 1990), cert. denied, 498 U.S. 1084 (1991) 15 United Sta

d oral communications and other documents concerning any meetings between the Attorneys and prosecutors and staff from the United States Attorney's Office for the Southern District of New York ("SDNY") concerning Jeffrey Epstein and/or Ghislaine Maxwell. a. This request includes all communications and documents related to any meetings th

ch communications include: a. All communications between the government — including, but not limited to, attorneys and staff at the U.S. Attorney's Office for the Southern District of Florida, the United States Attorney's Office for Southern District of New York, the Department of Justice, state prosecutor's offices, the FBI,

d oral communications and other documents concerning any meetings between the Attorneys and prosecutors and staff from the United States Attorney's Office for the Southern District of New York ("SDNY") concerning Jeffrey Epstein and/or Ghislaine Maxwell. a. This request includes all communications and documents related to any meetings th

ch communications include: a. All communications between the government — including, but not limited to, attorneys and staff at the U.S. Attorney's Office for the Southern District of Florida, the United States Attorney's Office for Southern District of New York, the Department of Justice, state prosecutor's offices, the FBI,

ht pursuant to the CVRA is the setting aside of the Non-Prosecution Agreement that was entered into between Jeffrey Epstein and the U.S. Attorney's Office for the Southern District of Florida ("USAO-SDFL"). See, e.g., DE 99 at 6 (recognizing that the relief Petitioners seek "is to invalidate the non-prosecution agreement"). Bu

(S.D.N.Y. 2009); United States v. Schlegel, No. 06-CR-550, 2008 WL 11338900, at *1 (E.D.N.Y. June 13, 2008), modification denied, 2008 WL 11339654 (E.D.N.Y. July 2, 2008). See United States v. Esposito, 749 F. App'x 20 (2d Cir. 2018); United States v. Sablmani, 493 F.3d 63 (2d Cir. 2007). 10 EFTA00076

d oral communications and other documents concerning any meetings between the Attorneys and prosecutors and staff from the United States Attorney's Office for the Southern District of New York ("SDNY") concerning Jeffrey Epstein and/or Ghislaine Maxwell. a. This request includes all communications and documents related to any meetings th

ch communications include: a. All communications between the government — including, but not limited to, attorneys and staff at the U.S. Attorney's Office for the Southern District of Florida, the United States Attorney's Office for Southern District of New York, the Department of Justice, state prosecutor's offices, the FBI,

d oral communications and other documents concerning any meetings between the Attorneys and prosecutors and staff from the United States Attorney's Office for the Southern District of New York ("SDNY") concerning Jeffrey Epstein and/or Ghislaine Maxwell. a. This request includes all communications and documents related to any meetings th

ch communications include: a. All communications between the government — including, but not limited to, attorneys and staff at the U.S. Attorney's Office for the Southern District of Florida, the United States Attorney's Office for Southern District of New York, the Department of Justice, state prosecutor's offices, the FBI,

D EFTA00095727 DEPARTMENT OF JUSTICE OFFICE OF PROFESSIONAL RESPONSIBILITY EXECUTIVE SUMMARY OF REPORT Investigation into the U.S. Attorney's Office for the Southern District of Florida's Resolution of Its 2006-2008 Federal Criminal Investigation of Jeffrey Epstein and Its Interactions with Victims during the Investigati

the petitioners, and opposed by the government, was rescission of the NPA and federal prosecution of Epstein. On July 2, 2019, the U.S. Attorney's Office for the Southern District of New York obtained a federal grand jury indictment charging Epstein with one count of sex trafficking of minors and one count of conspiracy to commit sex tra

ht pursuant to the CVRA is the setting aside of the Non-Prosecution Agreement that was entered into between Jeffrey Epstein and the U.S. Attorney's Office for the Southern District of Florida ("USAO-SDFL"). See, e.g., DE 99 at 6 (recognizing that the relief Petitioners seek "is to invalidate the non-prosecution agreement"). Bu

(S.D.N.Y. 2009); United States v. Schlegel, No. 06-CR-550, 2008 WL 11338900, at *1 (E.D.N.Y. June 13, 2008), modification denied, 2008 WL 11339654 (E.D.N.Y. July 2, 2008). See United States v. Esposito, 749 F. App'x 20 (2d Cir. 2018); United States v. Sablmani, 493 F.3d 63 (2d Cir. 2007). 10 EFTA00095

can give a plaintiff time to find a new attorney to represent her without delaying trial. Gorbaty v. Wells Fargo Bank N.A., 2011 WL 318090, at *3 (E.D.N.Y. Feb. 1, 2011); [ Gleason v. Zocco 941 F. Supp. 32, 36 (S.D.N.Y. 1996) (noting that granting a motion to disqualify "immediately after the action

ative defense that a plaintiff has a right to rebut, it is not appropriate for resolution on a motion to dismis Maxwell 165 F. Supp. 3d 147, 155 (S.D.N. . e Court of Appeals has said that if "the defendant's reply was made in bad faith ... the defense fails" and that "[i]t is the function of the j

d oral communications and other documents concerning any meetings between the Attorneys and prosecutors and staff from the United States Attorney's Office for the Southern District of New York ("SDNY") concerning Jeffrey Epstein and/or Ghislaine Maxwell. a. This request includes all communications and documents related to any meetings th

ch communications include: a. All communications between the government — including, but not limited to, attorneys and staff at the U.S. Attorney's Office for the Southern District of Florida, the United States Attorney's Office for Southern District of New York, the Department of Justice, state prosecutor's offices, the FBI,

er Acting U.S. Attorney for the Southern District of New York, Audrey Strauss, or anyone else who works for or used to work for the U.S. Attorney's Office for the Southern District of New York? K Yes K No 33d. Do you or does any member of your family or a close friend personally know or have past or present dealings with any of the Ass

s a fair and impartial juror in this case? K Yes K No 3 1 c. If yes to 31b, please explain: 32. Do you have any opinion of the U.S. Attorney's Office for the Southern District of New York, the U.S. Attorney Damian Williams, or the former Acting U.S. Attorney Audrey Strauss that might make it difficult for you to be a fair

Schwartz will step in to oversee the implementation of the settlement announced in January between the City of New York, HUD and the U.S. Attorney's Office for the Southern District of New York. Under the agreement, Schwartz will have the power to reorganize the management structure of the troubled housing authority, as well as implement t

nd Rochelle and the other accusers who have had the courage to come forward." She added that both women planned to speak with the U.S. Attorney for the Eastern District of New York. "I am speaking out because I want to encourage other victims who I know must be out there to come forward as well," Scaff said. "I want justice fo

F. App'x 268 (2d Cir. 2004) 14, 22, 27, 29 United States v. Harvey, 791 F.2d 294 (4th Cir. 1986) 24 United States v. Laskow, 688 F. Supp. 851 (E.D.N.Y.), aff'd, 867 F.2d 1425 (2d Cir. 1988) 21 United States v. Marquez, 909 F.2d 738 (2d Cir. 1990), cert. denied, 498 U.S. 1084 (1991) 15 United Sta

e resolution." Exh. B (Dep't of Justice, Office of Professional Responsibility, Executive Summary of Report, Investigation into the U.S. Attorney's Office for the Southern District of Florida's Resolution of its 2006-2008 Federal Criminal Investigation of Jeffrey Epstein and Its Interactions with Victims during the Investigati

nise L. Cote in United States v. Purcell, 18 Cr. 081 (DLC); and the charge of the Hon. Ann M. Donnelly in United States v. Kelly, 19 Cr. 286 (AMD) (E.D.N.Y.). See United States v. Murphy, 942 F.3d 73, 79-84 (2d Cir. 2019) (holding under 18 U.S.C. § 2423(b) that a defendant must know the age of the vict

nd, et al., Modern Federal Jury Instructions, Instr. 64-16; the charge of the Hon. Richard J. Arcara in United States v. Vickers, 13 Cr. 128 (RJA) (W.D.N.Y.), aff'd, 708 F. App'x 732 (2d Cir. 2017); and the charge of the Hon. Thomas P. Greisa in United States v. Gilliam, 11 Cr. 1083 (TPG), ard, 842 F.3d

ch communications include: a. All communications between the government — including, but not limited to, attorneys and staff at the U.S. Attorney's Office for the Southern District of Florida, the United States Attorney's Office for Southern District of New York, the Department of Justice, state prosecutor's offices, the FBI,

d oral communications and other documents concerning any meetings between the Attorneys and prosecutors and staff from the United States Attorney's Office for the Southern District of New York ("SDNY") concerning Jeffrey Epstein and/or Ghislaine Maxwell. a. This request includes all communications and documents related to any meetings th

the petitioners, and opposed by the government, was rescission of the NPA and federal prosecution of Epstein. On July 2, 2019, the U.S. Attorney's Office for the Southern District of New York obtained a federal grand jury indictment charging Epstein with one count of sex trafficking of minors and one count of conspiracy to commit sex tra

B EFTA00095558 DEPARTMENT OF JUSTICE OFFICE OF PROFESSIONAL RESPONSIBILITY EXECUTIVE SUMMARY OF REPORT Investigation into the U.S. Attorney's Office for the Southern District of Florida's Resolution of Its 2006-2008 Federal Criminal Investigation of Jeffrey Epstein and Its Interactions with Victims during the Investigati