Epstein Files Search

EFTA00099352Set 9

2002-04-2638p10,958w

CONTENTS Page PRELIMINARY STATEMENT 1 STATEMENT OF FACTS 7 U The Structure of the NPA 8 B. The Negotiation of the NPA 11 ARGUMENT 12 I. The Indictment Should ... Dismissed for Breach of the NPA. 14 a Ms. Maxwell Has Standing to Enforce the NPA. 15 B. The NPA's Prohibition on Prosecution of Potential Co-Conspirators ... Limited to the SDFL. 18 1. The NPA is binding on the USAO in this District 18 2. United States v. Annabi does not alter the analysis. 19 1. There

https://www.justice.gov/epstein/files/DataSet%209/EFTA00099352.pdf

EFTA00065989Set 9

2002-04-2638p11,008w

CONTENTS Page PRELIMINARY STATEMENT 1 STATEMENT OF FACTS 7 A. The Structure of the NPA 8 B. The Negotiation of the NPA 11 ARGUMENT 12 I. The Indictment Should ... Dismissed for Breach of the NPA. 14 A. Ms. Maxwell Has Standing to Enforce the NPA. 15 B. The NPA's Prohibition on Prosecution of Potential Co-Conspirators ... Limited to the SDFL. 18 1. The NPA is binding on the USAO in this District 18 2. United States v. Annabi does not alter the analysis. 19 a. There

https://www.justice.gov/epstein/files/DataSet%209/EFTA00065989.pdf

EFTA00299022Set 9

2006-07-1953p14,386w

Such Findings i. Mr. Epstein's Counsel Acted in Good Faith ii. The NPA is not an "Illegal Agreement" II. PRINCIPLES OF CONTRACT LAW PRECLUDE IMPOSITION OF THE EPSTEIN REMEDIES ... underlying litigation. Specifically, Petitioners seek: 1) a judicially-imposed reformation of the NPA to excise the "immunity provisions" and eliminate all contractual consideration that induced Mr. Epstein to enter into ... NPA in the first place, and 2) an advisory opinion that the Constitution would permit a hypothetical future prosecution of Mr. Epstein by the USAO-SDFL (hereinafter the "Epstein Remedies

https://www.justice.gov/epstein/files/DataSet%209/EFTA00299022.pdf

EFTA00804328Set 9

2016-02-1057p17,298w

crime for Epstein to plead to, which could accompany a federal non-prosecution agreement (NPA). Incredibly, the offense to which Epstein and the Government ultimately agreed, labeled the minor victims ... NPA, rather than its true purpose of vindicating the victims' rights and securing for the victims a right to confer about prosecuting Epstein free from the backdrop of the NPA ... Making a commitment to Epstein not to contact victims about the NPA (1 62, supra); • Entering into a NPA with a confidentiality provision that precluded compliance with CVRA victim notification obligations

https://www.justice.gov/epstein/files/DataSet%209/EFTA00804328.pdf

EFTA01186131Set 9

2016-02-1057p17,269w

crime for Epstein to plead to, which could accompany a federal non-prosecution agreement (NPA). Incredibly, the offense to which Epstein and the Government ultimately agreed, labeled the minor victims ... NPA, rather than its true purpose of vindicating the victims' rights and securing for the victims a right to confer about prosecuting Epstein free from the backdrop of the NPA ... Making a commitment to Epstein not to contact victims about the NPA (1 62, supra); • Entering into a NPA with a confidentiality provision that precluded compliance with CVRA victim notification obligations

https://www.justice.gov/epstein/files/DataSet%209/EFTA01186131.pdf

EFTA00591605Set 9

2016-02-1057p17,296w

crime for Epstein to plead to, which could accompany a federal non-prosecution agreement (NPA). Incredibly, the offense to which Epstein and the Government ultimately agreed, labeled the minor victims ... NPA, rather than its true purpose of vindicating the victims' rights and securing for the victims a right to confer about prosecuting Epstein free from the backdrop of the NPA ... Making a commitment to Epstein not to contact victims about the NPA (1 62, supra); • Entering into a NPA with a confidentiality provision that precluded compliance with CVRA victim notification obligations

https://www.justice.gov/epstein/files/DataSet%209/EFTA00591605.pdf

EFTA00102999Set 9

2019-03-26239p78,398w

Jeffrey Epstein's Non-Prosecution Agreement Is Irrelevant to This Case 3 A. The NPA Does Not Bind the Southern District of New York 4 1. The Text ... Bind Other Districts 5 2. The Defendant Has Offered No Evidence That the NPA Binds Other Districts 9 B. The NPA Does Not Immunize Maxwell from Prosecution ... NPA Is Limited to Particular Crimes Between 2001 and 2007 15 2. The NPA Does Not Confer Enforceable Rights on Maxwell 17 C. The Defendant Has Offered No Basis

https://www.justice.gov/epstein/files/DataSet%209/EFTA00102999.pdf

EFTA00022546Set 8

2019-07-2370p21,586w

CONTENTS INTRODUCTION 1 THIS CASE MUST BE DECIDED ON THE AGREED PREMISE THAT THE NPA ONLY COVERS THE U.S. ATTORNEY'S OFFICE FOR THE SOUTHERN DISTRICT OF FLORIDA. 3 DISCUSSION ... Intervenor Epstein. The Government2 and Epstein reached a secret non-prosecution agreement (NPA) and then concealed that agreement until it was firmly in place — and the victims lost any opportunity ... that violation. DE 454. Jane Doe I and 2 have proposed rescission of the NPA's "immunity" provisions, which have prevented victims from conferring with prosecutors in the USAO-SDFL

https://www.justice.gov/epstein/files/DataSet%208/EFTA00022546.pdf

EFTA00021442Set 8

2019-07-2370p21,698w

CONTENTS INTRODUCTION 1 THIS CASE MUST BE DECIDED ON THE AGREED PREMISE THAT THE NPA ONLY COVERS THE U.S. ATTORNEY'S OFFICE FOR THE SOUTHERN DISTRICT OF FLORIDA. 3 DISCUSSION ... Intervenor Epstein. The Government2 and Epstein reached a secret non-prosecution agreement (NPA) and then concealed that agreement until it was firmly in place — and the victims lost any opportunity ... that violation. DE 454. Jane Doe I and 2 have proposed rescission of the NPA's "immunity" provisions, which have prevented victims from conferring with prosecutors in the USAO-SDFL

https://www.justice.gov/epstein/files/DataSet%208/EFTA00021442.pdf

EFTA00183732Set 9

2008-09-02136p42,094w

rough attempt to do so. The Agreement Paragraph 7 of the Non-Prosecution Agreement ("NPA") provides for the selection of an attorney representative ("Atty Rep") for the individualsMire ... provided to Epstein's attorneys, Jack Goldberger and Michael Tien, after Epstein signed the NPA and was sentenced. Subsequently, there was an Addendum to the Non-Prosecution Agreement ("Addendum ... which was to clarify certain provisions of page 4, paragraph 7 of the NPA. In paragraph 7A of the Addendum, it was agreed that the United States had the right

https://www.justice.gov/epstein/files/DataSet%209/EFTA00183732.pdf

EFTA00194687Set 9

2008-09-02135p42,589w

rough attempt to do so. The Agreement Paragraph 7 of the Non-Prosecution Agreement ("NPA") provides for the selection of an attorney representative ("Atty Rep") for the individuals ... provided to Epstein's attorneys, Jack Goldberger and Michael Tien, after Epstein signed the NPA and was sentenced. Subsequently, there was an Addendum to the Non-Prosecution Agreement ("Addendum ... which was to clarify certain provisions of page 4, paragraph 7 of the NPA. In paragraph 7A of the Addendum, it was agreed that the United States had the right

https://www.justice.gov/epstein/files/DataSet%209/EFTA00194687.pdf

EFTA00799888Set 9

2017-08-1176p27,084w

nine months, the Government and Epstein conspired to conceal a non-prosecution agreement (NPA) from Epstein's victims in order to prevent them from voicing any objection to the agreement ... facts of this particular case, they had a right to confer about the NPA. Part IV explains that the Government violated their right to confer about the NPA and about ... victims' right to reasonable and accurate notice about Epstein's guilty pleas triggering the NPA. Part VI explains that the Government violated the victims' right to fair treatment. Part

https://www.justice.gov/epstein/files/DataSet%209/EFTA00799888.pdf

EFTA00028880Set 8

2016-01-1123p6,182w

Bobbi C. Stemheim Phone: Attorneysfor Ghislaine Maxwell EFTA00028880 TABLE OF CONTENTS Page I. The NPA Applies to Ms. Maxwell, and She Has Standing to Enforce ... wielding an invisible ink pen, the government adds language to its Non-Prosecution Agreement ("NPA") with Jeffrey Epstein that does not exist in the text, and then pretends ... clear, unambiguous language that does appear there. The plain language of the NPA states, without limitation, that "the United States .. . will not institute any criminal charges against any potential

https://www.justice.gov/epstein/files/DataSet%208/EFTA00028880.pdf

EFTA00211718Set 9

2007-04-2432p10,140w

period between the videotaped interview and the signing of the Non- Prosecution Agreement ("NPA"), she wished to confer with an attorney for the Government or any Government agent, felt that ... into a non- prosecution agreement with Epstein. The Government does not dispute that the NPA was signed on September 24, 2007, and Jane Doe No. 1 was not told about ... NPA until October 2007. However, the Government disagrees with petitioners' implicit assertion that a victim's statutory "right to confer" is a "right to be notified." In section

https://www.justice.gov/epstein/files/DataSet%209/EFTA00211718.pdf

EFTA00799825Set 9

2017-06-0632p10,748w

period between the videotaped interview and the signing of the Non- Prosecution Agreement ("NPA"), she wished to confer with an attorney for the Government or any Government agent, felt that ... into a non- prosecution agreement with Epstein. The Government does not dispute that the NPA was signed on September 24, 2007, and Jane Doe No. 1 was not told about ... NPA until October 2007. However, the Government disagrees with petitioners' implicit assertion that a victim's statutory "right to confer" is a "right to be notified." In § 377I

https://www.justice.gov/epstein/files/DataSet%209/EFTA00799825.pdf

EFTA00591461Set 9

2017-06-0233p10,820w

period between the videotaped interview and the signing of the Non- Prosecution Agreement ("NPA"), she wished to confer with an attorney for the Government or any Government agent, felt that ... into a non- prosecution agreement with Epstein. The Government does not dispute that the NPA was signed on September 24, 2007, and Jane Doe No. I was not told about ... NPA until October 2007. However, the Government disagrees with petitioners' implicit assertion that a victim's statutory "right to confer" is a "right to be notified." In § 377I

https://www.justice.gov/epstein/files/DataSet%209/EFTA00591461.pdf

EFTA01089193Set 9

2009-06-12174p43,641w

CONTENTS TAB DATE DESCRIPTION 1. 6/12/09 M. hr to J. Goldberger notifying breach of NPA 2. 6-12-09 J. Lefkowitz Itr. to M. in response ... civil suits. 5. 6-17-09 M. hr to J. Lefkowitz re compliance with NPA. 6. 6-19-09 J. Lefkowitz ltr to M. re obligations under NPA ... filing may be perceived as implicating any of the issues generically addressed in the NPA (a document including sentences within paragraph 8 that even Mr. Acosta agreed were "far from

https://www.justice.gov/epstein/files/DataSet%209/EFTA01089193.pdf

EFTA00731113Set 9

2009-06-1711p5,120w

terms and as a direct result of the federal Non-Prosecution Agreement (the "NPA"). When Mr. Epstein was sentenced, the U.S. Attorney promised me and my co-counsel that ... Attorney's Office's involvement would cease with Mr. Epstein's execution of the NPA and incarceration in state custody.—Mest importantly; Wwe were also promised that the federal government ... your eententien—position that Mr. Epstein has engaged in a pattern of breaching the NPA. We respectfully submit (and support through documentary evidence) that Mr. Epstein has done nothing

https://www.justice.gov/epstein/files/DataSet%209/EFTA00731113.pdf

EFTA00597318Set 9

2017-08-1133p10,597w

Government cannot contest that it concealed from the victims a non-prosecution agreement (NPA) that it reached with a sex offender, Jeffrey Epstein, who had committed federal crimes against dozens ... Government violating their CVRA rights. Undisputed facts show the Government's concealment of the NPA. And, in the particular circumstances of this case, that concealment clearly violated three provisions ... Epstein and Government reached a formal non-prosecution agreement, embodied in the NPA, DE 361-62 (Ex. 62), whereby the federal prosecutors would defer federal prosecution in favor

https://www.justice.gov/epstein/files/DataSet%209/EFTA00597318.pdf

EFTA00027666Set 8

2019-02-2133p11,282w

September 10, 2007, multiple drafts of a non-prosecution agreement ("NPA") had been exchanged between Epstein's counsel and the Office. (DE 407 at ¶ 18.) On September 12, 2007, while ... about September 16, 2007, Epstein's counsel provided a proposed NPA to the Government that extended immunity from federal prosecution not only to Epstein, but also to certain co-conspirators ... minors." (DE 407 at ¶ 36.) As correspondence continued on September 24, 2007, and the NPA was being executed, Lefkowitz sent an email to the line prosecutor stating: `=I— Please

https://www.justice.gov/epstein/files/DataSet%208/EFTA00027666.pdf