EFTA00299022.txt

"The Settlement Agreement and General Release entered into by the Petitioners and Mr. Epstein in the federal and state court civil lawsuits"

"The USAO-SDFL had the legal authority to provide that consideration... United States Attorney's Offices regularly enter plea and deferred and non-pros"

"their civil lawsuits against Mr. Epstein"

"Mr. Epstein's counsel acted in Good Faith"

"the Government's intention to take that course of action before it bound itself under the NPA"

"Mr. Epstein's counsel were well within their right to advocate a view of the law most favorable to their client"

"the USAO-SDFL and Mr. Epstein may legally enter into an enforceable agreement containing the very terms and promises in the NPA"

"underlying settlements between the victims and Mr. Epstein"

"immunity or non-prosecution agreement with the government"

"Petitioners litigated their CVRA case with the government"

"the government's contractual obligations to its counterparty... Compliance with the CVRA was the duty of the government, not of Mr. Epstein"

"the Court would be impairing the discretion of the USAO-SDFL to grant immunity to Mr. Epstein"

"The Petitioners ultimately settled their federal and state civil lawsuits with Mr. Epstein on or about July 22, 2010"

"The Petitioners ultimately settled their federal and state civil lawsuits with Mr. Epstein on or about July 22, 2010"

"The Petitioners ultimately settled their federal and state civil lawsuits with Mr. Epstein on or about July 22, 2010"

"then First Assistant AUSA Jeffrey Sloman"

"As summarized by AUSA Villafana, the USAO-SDFL made the decision"

"On July 19, 2006, Mr. Epstein was indicted in the Fifteenth Judicial Circuit in and for Palm Beach County on one count of solicitation of prostitution"

"Jeffrey Sloman (First Assistant U.S. Attorney)"

"Matthew Menchel (Chief, Criminal Division)"

"Andrew Lourie (Deputy Chief, Northern Region)"

"AUSA Anna Marie Villafana"

"prosecution of Epstein for crimes committed against Jane Doe 1"

"prosecution of Epstein for crimes committed against Jane Doe 1 and Jane Doe 2"

"negotiated contract between the government and Mr. Epstein"

"the NPA upon which they relied to preclude Mr. Epstein from disputing that he had sexually abused both Petitioners"

"private contracts between the government and an investigatory target entered into in the exercise of the government's sole discretion"

"Despite having themselves relied on the NPA to settle their civil lawsuits against Mr. Epstein in 2010"

"Despite having themselves relied on the NPA to settle their civil lawsuits against Mr. Epstein in 2010"

"entered into civil settlements with all such §2255 claimants, amounting to many millions of dollars"

"After the NPA was signed, Epstein's counsel and the [USAO-SDFL] began negotiations about whether the victims would be told about the NPA."

"the Government failed to advise the victims about its intention to enter into the NPA"

"Jane Doe 1 and 2 are only seeking that these particular provisions be set aside... restore Mr. Epstein to the status quo"

"Jane Doe 1 and 2 are only seeking that these particular provisions be set aside... restore Mr. Epstein to the status quo"

"Mr. Epstein and his counsel intervened to assert their rights"

"Mr. Epstein and his counsel intervened to assert their rights, both in the district court, and on appeal to the Eleventh Circuit"

"the vehicle of a CVRA case filed against the government"

"the Epstein Remedies are barred by the General Release"

"Epstein-paid attorney-representative, Robert C. Josefsberg, Esq."

"Petitioners have proposed several lopsided remedies that target only Mr. Epstein, a non-party to the underlying litigation."

"Letter from Gerald B. Lefcourt to a USAO-SDFL... Counsel made numerous presentations... to the USAO-SDFL disputing many of the alleged underlying fact"

"Letter from Kenneth Starr, Esq. to John Roth, June 19, 2008"

"settled numerous civil actions that were directly related to his obligations under the NPA"

"Roy Black, Esq. ... BLACK SREBNICK & KORNSPAN P.A."

"Jackie Perczek, Esq. ... BLACK SREBNICK & KORNSPAN P.A."

"Scott A. Srebnick, Esq. ... BLACK SREBNICK & KORNSPAN P.A."

"Martin G. Weinberg, Esq. ... MARTIN G. WEINBERG, P.C."

"Petitioners relied on the NPA as a valid, legal agreement which precluded Mr. Epstein from contesting his liability to them"

"attempt to persuade the USAO-SDFL and the DOJ of the circumstances and timing when disclosure of the NPA to the Petitioners would be appropriate"

"attempt to persuade the USAO-SDFL and the DOJ of the circumstances and timing when disclosure of the NPA to the Petitioners would be appropriate"