EFTA00022546.pdf

"The Government and Epstein reached a secret non-prosecution agreement (NPA) and then concealed that agreement until it was firmly in place"

"The Government and Epstein reached a secret non-prosecution agreement (NPA) and then concealed that agreement until it was firmly in place — and the v"

"Bradley J. Edwards Edwards Pottinger LP"

"Paul G. Cassell Pro Hac Vice"

"JANE DOE #1 and JANE DOE #2 v. UNITED STATES Case No. 08-80736-Civ-Marra/Johnson"

"the U.S. Attorney's Office for the Southern District of Florida (USAO-SDFL), which is currently being represented by the U.S. Attorney's Office for th"

"the NPA negotiated by Epstein with prosecutors in the Southern District of Florida only precludes his prosecution in the Southern District of Florida"

"Intervenor Epstein is currently being prosecuted by federal prosecutors in the Southern District of New York"

"quoting former First Assistant U.S. Attorney Jeffrey Sloman"

"USAO-SDFL, which is currently being represented by the U.S. Attorney's Office for the Northern District of Georgia"

"CVRA rights violation of Jane Doe 1, Jane Doe 2, and all other similarly situated victims"

"CVRA rights violation of Jane Doe 1, Jane Doe 2, and all other similarly situated victims"

"Jane Doe 1 was a victim of a federal crime committed by Epstein in the Southern District of Florida."

"the district court has granted Epstein limited intervention to challenge only the disclosure of his attorneys' correspondence and any remedy that invo"

"the Government decided to conceal the existence of the NPA and mislead the victims to believe that federal prosecution was still a possibility."

"Jane Doe 1 v. United States, 749 F.3d 999, 1005 (11th Cir. 2014)."

"the Eleventh Circuit has previously ruled in this case that he is not an ordinary litigant. Jane Doe 1 v. United States, 749 F.3d 999"

"Epstein and his lawyers signed the NPA... NPA was executed on September 24, 2007"

"USAO-SDFL and Epstein were concealing the NPA."

"line prosecutor writes to defense counsel that 'Maybe we can set a time to meet.'"

"on about June 7, 2007, FBI agents delivered a standard CVRA notification letter to Jane Doe 1."

"FBI agents delivered a standard CVRA notification letter to Jane Doe 1... the government would protect those rights"

"Epstein and his lawyers signed the NPA"

"the Government's decision to conceal the existence of the NPA and mislead the victims"

"on February I, 2007, the Epstein defense team sent a 24-page letter to the Office"

"Epstein's lawyers sent a 23-page letter to USAO-SDFL which falsely claimed that Mr. Epstein never targeted minors"

"Jane Doe 1 and 2's Motion for Finding of Waiver of Work Product"

"Epstein also argues that the NPA is a legal agreement. Epstein Remedies Br. at 25."

"Any other conclusion would require the Court to approve the illegal bargain struck by Epstein and the USAO-SDFL."

"at least with respect to crimes against Jane Doe 1 and 2 and any other victim who desires to have him prosecuted."

"at least with respect to crimes against Jane Doe 1 and 2 and any other victim who desires to have him prosecuted."

"his main defense to recent sex trafficking charges in the Southern District of New York"

"if he wants this case to be decided based on how his legal team acted"

"the Government disclosed that it had, in fact, reached a secret agreement with Epstein months earlier."

"On July 7, 2008, when counsel for Jane Doe I began to learn that a secret, non-prosecution agreement might be in the works, they filed an emergency pe"

"In view of the fact that this agreement has already been consummated, and you want me to set it aside, as opposed to something that's about to occur"

"Congress amended the CVRA in order to codify this Court's earlier rulings here and ensure that victims received timely notice of any NPA."

"he did not move to intervene in the case until September 2, 2011 (DE 93), and even then he sought only limited intervention with regard to remedy."

"the only way this Court can ensure the protection of Jane Doe 1 and 2's right to confer about prosecuting Epstein's (and his coconspirators') sex crim"

"the only way this Court can ensure the protection of Jane Doe 1 and 2's right to confer about prosecuting Epstein's (and his coconspirators') sex crim"

"the NPA's immunity provisions, which prevent the victims from being able to exercise their CVRA right to confer with the USAO-SDFL."

"the only way this Court can ensure the protection of Jane Doe 1 and 2's right to confer about prosecuting Epstein's"

"Epstein begins by citing a series of Florida state law cases. Epstein Remedies Br. at 33-34."

"Epstein retains some consideration for his NPA, because the statute of limitations may have now expired on some of the crimes covered by his NPA."

"Epstein's most serious crimes covered by the NPA — specifically, the sex trafficking charges — are not time barred"

"Jane Doe individually, and Jeffrey Epstein, individually (jointly referred to as Parties), enter into this Settlement Agreement and General Release"

"Epstein points to civil releases signed by Jane Doe 1 and 2 that resolved their civil cases against Epstein."

"if a partial rescission remedy is awarded, then he would be free to raise a collateral attack on his state court guilty plea."

"Jane Doe 1 and 2 are not arguing that the NPA is some sort of divisible agreement... position is that the NPA's immunity provisions are unenforceable"

"Jane Doe individaully, and Jeffrey Epstein, individually (jointly referred to as Parties), enter into this Settlement Agreement and General Release"