EFTA00223241
Summary
I EFTA00223241 Dec-07-01 04:53Nit Free-Fowler-White Burnett 3011990201 T-1138 P.011/004 F-0/6 • LAW °prima FOWLER WHITE BURNETT ESPIRITO SANTO PLAZA 1395 BRICKALL AVCNUE, 14711 FLOOR MIAMI 1-3302 FAX TRANSMITTAL DATE: December 7, 2007 NUMBER OF PAGES: 3 (Excluding transmittal page) Alex Acosta FROM: Lilly Ann Sanchez FAX NUMBER: MATTER NO: 71200 REMARKS: please see attached. TELEPHONE. NUMBER: Original documents will K will not K follow by mail. TIME OF TRANSMITTAL: a.m./p.m. TRANSMITTED BY: Photocopy should he token of this fitlallnillthMlfli Is to be retained sinew facsimile paper has unused storage 1(1?. THE INFORMATION CONTAINED IN THIS FACSIMILE MESSAGE IS ATTORNEY PRIVILEGED ANI3 CONFIDENTIAL INFORMATION INTENDED ONLY FOR THE USE OF THE INDIVIDUAL OR ENTITY NAMED ABOVE. IF THE READER OF THIS MESSAGE IS NOT THE INTENDED RECIPIENT. YOU ARE HEREBY NOTIFIED THAT ANY DISSEMINATION, DISTRIBUTION OR COPYING OF THIS COMMUNICATION IS STRICTLY PROHIBITE
Persons Referenced (4)
“...ERBOURG 3067889201 T-968 P.002/004 F-076 December 7, 2007 First Assistant United States Attorney United States Attorney's Office Southern District of Florida 500 So...”
United States Attorney“...ERBOURG 3067889201 T-968 P.002/004 F-076 December 7, 2007 First Assistant United States Attorney United States Attorney's Office Southern District of Florida 500 South Austr...”
Alexander AcostaJeffrey Epstein“...da 500 South Australian Avenue, Suite 400 West Palm Beach, Florida 33401 Re: Jeffrey Epstein Dear EsHaffell•NAO NSA TOJAIA3mi I•LaoA 13D6 Etkestu. Ay/Jie Kan. Ploaia•• 33131 TD.0".01•C (3015?...”
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EFTA DisclosureRelated Documents (6)
UNITED STATES DISTRICT COURT
UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA IN RE GRAND JURY SUBPOENAS FGJ 07-103(WPB) DUCES TECUM NUMBERS OLY-63 and OLY-64 UNITED STATES' UNOPPOSED MOTION FOR PERMISSION TO FILE OVERSIZED RESPONSE TO MOTION OF JEFFREY EPSTEIN TO INTERVENE AND TO QUASH GRAND JURY SUBPOENAS AND CROSS-MOTION TO COMPEL UNDER SEAL UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA IN RE GRAND JURY SUBPOENAS FGJ 07-103(WPB) DUCES TECUM NUMBERS OLY-63 and OLY-64 UNDER SEAL UNITED STATES' UNOPPOSED MOTION FOR PERMISSION TO FILE OVERSIZED RESPONSE TO MOTION OF JEFFREY EPSTEIN TO INTERVENE AND TO QUASH GRAND JURY SUBPOENAS AND CROSS-MOTION TO COMPEL The United States, by and through the undersigned Assistant United States Attorney, hereby files this Motion for Permission to File an Oversized Response, and, in support thereof, states: 1. Movant Jeffrey Epstein, by and through counsel, filed a Motion to Intervene and to Quash two grand jury subpoenas duces tecum on July
IN RE:
IN RE: INVESTIGATION OF JEFFREY EPSTEIN ADDENDUM TO THE NON-PROSECUTION AGREEMENT IT APPEARING that the panics seek to clarify certain provisions of page 4, paragraph 7 of the Non-Prosecution Agreement (hereinafter "paragraph 7"), that agreement is modified as fol lows: 7A. The United States has the right to assign to an independent third-party the responsibility fur consulting with and, subject to the good faith approval of Epstein's counsel, selecting the attorney representative for the individuals identified under the Agreement. If the United States elects to assign this responsibility to an independent third-patty, both the United States and Epstein retain the right to make good faith objections to the attorney representative suggested by the independent third-party prior to the final designation of the attorney representative. 7II. The parties will jointly prepare a short written submission to the independent third-party regarding the role of the attorney represen
Case 9:08-cv-80736-KAM Document 435 Entered on FLSD Docket 02/21/2019 Page 1 of 33
Case 9:08-cv-80736-KAM Document 435 Entered on FLSD Docket 02/21/2019 Page 1 of 33 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 08-80736-CIV-MARRA JANE DOE 1 AND JANE DOE 2, Petitioners, vs. UNITED STATES, Respondent. OPINION AND ORDER This cause is before the Court upon Jane Doe 1 and Jane Doe 2's Motion for Partial Summary Judgment (DE 361); the United States's Cross-Motion for Summary Judgment (DE 408); Jane Doe 1 and Jane Doe 2's Motion to Compel Answers (DE 348) and Jane Doe 1 and Jane Doe 2's Motion for Finding Waiver of Work Product and Similar Protections by Government and for Production of Documents (DE 414). The Motions are fully briefed and ripe for review. The Court has carefully considered the Motions and is otherwise fully advised in the premises. I. Background The facts, as culled from affidavits, exhibits, depositions, answers to interrogatories and reasonably inferred, for the purpose of these motions, are as follows: From betw
IN RE:
IN RE: INVESTIGATION OF JEFFREY EPSTEIN Non-Prosecution Agreement IT APPEARING that the City of Palm Beach Police Department and the State Attorney's Office for the 15th Judicial Circuit in and for Palm Beach County (hereinafter, the "State Attorney's Office") have conducted an investigation into the conduct of Jeffrey Epstein (hereinafter "Epstein"); IT APPEARING that the State Attorney's Office has charged Epstein with one count of solicitation of prostitution, in violation of Florida Statutes Section 796.07; IT APPEARING that the interest of the United States pursuant to the Petite policy will be served by the following procedure expressed in this Agreement; IT APPEARING that the United States Attorney's Office and the Federal Bureau of Investigation have conducted their own investigation of Epstein's background and offenses including; knowingly and willfully conspiring with others known and unknown to commit an offense against the United States, in violation of Titl
U.S. Department of Justice
U.S. Department of Justice United States Attorney Southern District of Florida 99 N. E. 4 gh Street Miami. FL 33132-2111 cto er DELIVERY BY FACSIMILE The Hon. Edward B. Davis (Ret.) rnrut ' mut rtitt Miami, Florida 33131 Re: Service as a Special Master Dear Judge Davis: Thank you for agreeing to serve as a Special Master and for assisting the United States Attorney's Office in the selection of an attorney representative to represent a group of identified victims. This letter is meant to assist you in performing your duties by providing you with background information regarding the agreement between the United States and Jeffrey Epstein and the duties that the attorney representative will have to perform. The Federal Bureau of Investigation and the U.S. Attorney's Office conducted an investigation of Mr. Epstein. As a result of that investigation, the U.S. Attorney's Office and Mr. Epstein entered into a Non-Prosecution Agreement and an Addendum that contains, inter a
UNITED STATES DISTRICT COURT
UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK x UNITED STATES OF AMERICA S 120 Cr. 330 (AJN) GHISLAINE MAXWELL, Defendant. x THE GOVERNMENT'S OMNIBUS MEMORANDUM IN OPPOSITION TO THE DEFENDANT'S PRE-TRIAL MOTIONS AUDREY STRAUSS United States Attorney Southern District of New York Attorney for the United States of America Assistant United States Attorneys - Of Counsel - EFTA00039421 TABLE OF CONTENTS PRELIMINARY STATEMENT 1 BACKGROUND 2 ARGUMENT 3 I. 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 of the Agreement Does Not Contain a Promise to 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 15 1. The 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
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