EFTA00065989Set 9
2002-04-2638p11,008w
Prohibition on Prosecution of Potential Co-Conspirators Is Not
Limited to the SDFL. 18
1. The NPA is binding on the USAO in this District 18
2. United States ... affirmative appearance" that the co-conspirator
immunity provision was intended to apply outside the SDFL 20
b. The Second Circuit's subsequent application of Annabi
supports Ms. Maxwell's position ... Alexander Acosta, then United States Attorney for the Southern
District of Florida ("SDFL"), and approved by senior levels of Main Justice, including the Office
of the Deputy Attorney General
https://www.justice.gov/epstein/files/DataSet%209/EFTA00065989.pdf
EFTA00099352Set 9
2002-04-2638p10,958w
Prohibition on Prosecution of Potential Co-Conspirators Is Not
Limited to the SDFL. 18
1. The NPA is binding on the USAO in this District 18
2. United States ... affirmative appearance" that the co-conspirator
immunity provision was intended to apply outside the SDFL 20
b. The Second Circuit's subsequent application of Annabi
supports Ms. Maxwell's position ... Alexander Acosta, then United States Attorney for the Southern
District of Florida ("SDFL"), and approved by senior levels of Main Justice, including the Office
of the Deputy Attorney General
https://www.justice.gov/epstein/files/DataSet%209/EFTA00099352.pdf
EFTA00224728Set 9
2008-06-0214p6,969w
proposed indictment have been
extensively reviewed and re-reviewed by Southern District of Florida (SDFL) Deputy Chief of
the Criminal Division Andrew Lourie, Chief of the Criminal Division Matthew Menchel ... Public Integrity Section at DOJ as well as in several supervisory positions in the SDFL. By
mid-2006, he had returned to his position as the Deputy Chief ... request of AAG Fisher. By October 2007, Mr. Lourie
would leave the SDFL to become AAG Fisher's Chief of Staff.2 Above Mr. Lourie in the SDFL's
chain
https://www.justice.gov/epstein/files/DataSet%209/EFTA00224728.pdf
EFTA00102999Set 9
2019-03-26239p78,398w
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 ... this Circuit, the NPA is not enforceable in this District,
because the USAO-SDFL's agreement with Jeffrey Epstein is not binding on the U.S. Attorney's
Office ... reasons set forth below, the defendant
has failed to establish that the USAO-SDFL promised Epstein that the NPA would bind other
districts.
4
EFTA00103029
1. The Text
https://www.justice.gov/epstein/files/DataSet%209/EFTA00102999.pdf
EFTA00028880Set 8
2016-01-1123p6,182w
Enforce It. 2
II. The Co-Conspirator Immunity Provision is Not Limited to the SDFL. 7
III. The Co-Conspirator Immunity Provision Is Not Limited to the 2001-07 Time ... only the United States Attorney's Office for the Southern District of Florida
("USAO-SDFL"), the government asks the Court to add the words "in this District" to that
provision ... third-party beneficiary.
II. The Co-Conspirator Immunity Provision is Not Limited to the SDFL.
Ms. Maxwell demonstrated in her opening brief that the NPA, read as a whole, creates
https://www.justice.gov/epstein/files/DataSet%208/EFTA00028880.pdf
EFTA00299022Set 9
2006-07-1953p14,386w
Constitution would permit a
hypothetical future prosecution of Mr. Epstein by the USAO-SDFL (hereinafter the
"Epstein Remedies"). (DE 458:4-5, 13 n.5).
Despite having themselves relied ... even a party, this Court found:
"Epstein's counsel was aware that the [USAO-SDFL] was deliberately keeping the NPA
secret from the victims and, indeed, had sought assurances ... that the
United States Attorney's Office for the Southern District of Florida ("USAO-SDFL") was
investigating whether Mr. Epstein's alleged conduct violated federal law. The USAO-
SDFL investigation
https://www.justice.gov/epstein/files/DataSet%209/EFTA00299022.pdf
EFTA01626136Set 10
2016-01-1418p4,901w
that the United States Attorney's Office for the Southern District of
Florida (USAO-SDFL) violated the petitioners' rights under the Crime Victims Rights Act
(CVRA) when the USAO-SDFL ... these proceedings is a "claim against a local federal
prosecutorial authority [the USAO-SDFL] which did actively investigate potential charges
against Epstein in this district and formally resolved those charges ... vast array of governmental departments, components, agencies, and employees
beyond the USAO-SDFL and those governmental actors with whom the USAO-SDFL directly
worked in the course of its investigative
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01626136.pdf
EFTA00214455Set 9
2008-05-196p2,387w
Respectfully, the United
States Attorney's Office for the Southern District of Florida ("SDFL") has never agreed to any such
deadline. Should you decide to provide the SDFL with ... resolution of state and federal liabilities faced by your client ("the Agreement") with the SDFL.
Although you and other members of the defense team have since claimed that the Agreement ... signing the Agreement, Epstein gave up the right
to object to its provisions, the SDFL bent over backwards to exhaustively consider and re-consider
your objections. Since these objections have
https://www.justice.gov/epstein/files/DataSet%209/EFTA00214455.pdf
EFTA00013801Set 8
2008-05-1910p3,525w
Dated May 19, 2008
In al 2008 letter to Jay Lefkowitz (See Tab 1), SDFL First Assistant U.S.
rn
Attoey MI provided what purported to be a summ ... with reviewing his own prior decision regarding applying the
key statute under which the SDFL proposed prosecuting Mr. Epstein.
EFTA00013801
KIRKLAND & ELLIS LLP
■ The defense immediately raised concerns regardin ... dismissed the totality of the defense's objections to the inappropriate
noti 'cation the SDFL proposed to send to its witnesses, stating merely that:
"[Y]ou objected to victims['] being
https://www.justice.gov/epstein/files/DataSet%208/EFTA00013801.pdf
EFTA00224780Set 9
2008-05-196p2,420w
deadline." Respectfully, thc United
States Attorney's Office for the Southern District ofFlorida ("SDFL") has never agreed to any such
deadline. Should to provide the SDK. withssa itditional information, please ... resolution of state and federal liabilities faced by your client ("the Agreement") with the SDFL.
Although you and other members of thc defense team have since claimed that the Agreement ... signing the Agreement, Epstein gave up the right
to object to its provisions, the SDFL bent over backwards to exhaustively consider and re-consider
your objections. Since these objections have
https://www.justice.gov/epstein/files/DataSet%209/EFTA00224780.pdf
EFTA00205624Set 9
2008-07-1137p11,998w
EFTA00205625
Petitioners' rights under the CVRA were violated when Epstein and the USAO-SDFL entered
into the Non-Prosecution Agreement." Mot. to Dismiss at 3. Indeed, the basis ... Petitioners Lack Standing to Seek Rescission of the
Non-Prosecution Agreement Between the USAO-SDFL and Epstein
In an effort to establish standing and circumvent the requirements of Santobello ... progeny, Petitioners argue that the Non-Prosecution
Agreement between the USAO-SDFL and Epstein is an illegal contract that is void and cannot
be enforced by the courts. Petitioners, however
https://www.justice.gov/epstein/files/DataSet%209/EFTA00205624.pdf
EFTA01081829Set 9
2013-07-05101p27,839w
Petitioners' rights under the CVRA were violated when Epstein and the USAO-SDFL entered
into the Non-Prosecution Agreement." Mot. to Dismiss at 3. Indeed, the basis of the
government ... Petitioners Lack Standing to Seek Rescission of the
Non-Prosecution Agreement Between the USAO-SDFL and Epstein
In an effort to establish standing and circumvent the requirements of Santobello ... progeny, Petitioners argue that the Non-Prosecution
Agreement between the USAO-SDFL and Epstein is an illegal contract that is void and cannot
be enforced by the courts. Petitioners, however
https://www.justice.gov/epstein/files/DataSet%209/EFTA01081829.pdf
EFTA00087761Set 9
2020-10-078p3,830w
Office, the U.S Attorney's
Office for the Southern District of Florida ("USAO-SDFL"), and the FBI's Palm Beach Resident
Agency (the "FBI Florida Office") conducted a separate investigation ... been produced as
part of prior discovery productions in this case.
Fourth, the USAO-SDFL participated in the federal investigation of Jeffrey Epstein
between approximately 2006 and 2010. Before today ... Prosecution Team had never received
any documents from the USAO-SDFL and did not have the USAO-SDFL's investigative file.
Indeed, aside from notifying the SDFL at an executive
https://www.justice.gov/epstein/files/DataSet%209/EFTA00087761.pdf
EFTA00229646Set 9
2008-04-2321p7,926w
Letter to OPR
To From
Office of Professional Responsibility , First Assistant
United States Attorney SDFL
On April 21. 2008, I sent OPR a letter referenced "Self Reporting - FAUSA
S.D.F.L." Upon ... United States Attorney's Office for the Southern District of
Florida ("SDFL")entered into a Non-Prosecution Agreement ("the Agreement") with Jeffrey Epstein
regarding his sexual conduct involving minor victims ... signing
the Agreement. Epstein gave up the right to object to its provisions, the SDFL bent over backwards
to exhaustively consider and re-consider his objections.
The Agreement
https://www.justice.gov/epstein/files/DataSet%209/EFTA00229646.pdf