giuffre-maxwell
gov.uscourts.nysd.447706.185.7
26 pg
…2) Dershowitz's role representing Epstein during the criminal
investigation of Epstein; (3) Dershowitz's role in negotiating the Non-Prosecution Agreement
("the NPA") between Epstein and the United States; (4) Facts inferring that Dershowitz was
aware of Epstein's…
giuffre-maxwell
gov.uscourts.nysd.447706.1307.4
28 pg
…Marcinkova was specifically identified by the U.S. Attorney’s
Office for the Southern District of Florida as a “potential co-conspirator of Epstein” in the non-
prosecution agreement it executed with Mr. Epstein as part of his guilty plea…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.10
28 pg
…Marcinkova was specifically identified by the U.S. Attorney’s
Office for the Southern District of Florida as a “potential co-conspirator of Epstein” in the non-
prosecution agreement it executed with Mr. Epstein as part of his guilty plea…
giuffre-maxwell
gov.uscourts.nysd.447706.1137.12_2
28 pg
…Marcinkova was specifically identified by the U.S. Attorney’s
Office for the Southern District of Florida as a “potential co-conspirator of Epstein” in the non-
prosecution agreement it executed with Mr. Epstein as part of his guilty plea…
giuffre-maxwell
1320-10
28 pg
…Marcinkova was specifically identified by the U.S. Attorney’s
Office for the Southern District of Florida as a “potential co-conspirator of Epstein” in the non-
prosecution agreement it executed with Mr. Epstein as part of his guilty plea…
giuffre-maxwell
gov.uscourts.nysd.447706.773.4
5 pg
…prosecute
Epstein or his employees on federal charges contained in a 53-page
indictment. A 2007 federal non-prosecution agreement with Epstein states,
among other things, that he …
giuffre-maxwell
gov.uscourts.nysd.447706.1320.9
10 pg
…3771.
DE1. She alleged that Jeffrey Epstein had sexually abused her and that the United States had
entered into a secret non-prosecution agreement (NPA) regarding those crimes in violation of her
rights. At the first court hearing on the…
giuffre-maxwell
gov.uscourts.nysd.447706.562.1
13 pg
…Giuffre moved to join the on-going litigation previously
filed by Jane Doe 1 in the Southern District of Florida challenging Epstein’s non-prosecution
agreement by filing her own joinder motion.
5
Case
Case1:15-cv-07433-LAP…
giuffre-maxwell
gov.uscourts.nysd.447706.1090.6
10 pg
…3771.
DE1. She alleged that Jeffrey Epstein had sexually abused her and that the United States had
entered into a secret non-prosecution agreement (NPA) regarding those crimes in violation of her
rights. At the first court hearing on the…
giuffre-maxwell
1320-9
10 pg
…3771.
DE1. She alleged that Jeffrey Epstein had sexually abused her and that the United States had
entered into a secret non-prosecution agreement (NPA) regarding those crimes in violation of her
rights. At the first court hearing on the…
giuffre-maxwell
gov.uscourts.nysd.447706.1.0
12 pg
…Giuffre moved to join the on-going litigation previously
filed by Jane Doe 1 in the Southern District of Florida challenging Epstein’s non-prosecution
agreement by filing her own joinder motion.
5
Case 1:15-cv-07433-RWS…
giuffre-maxwell
gov.uscourts.nysd.447706.24.1
13 pg
…Giuffre moved to join the on-going litigation previously
filed by Jane Doe 1 in the Southern District of Florida challenging Epstein’s non-prosecution
agreement by filing her own joinder motion.
5
Case
Case1:15-cv-07433-RWS…
giuffre-maxwell
gov.uscourts.nysd.447706.1325.3
10 pg
…3771.
DE1. She alleged that Jeffrey Epstein had sexually abused her and that the United States had
entered into a secret non-prosecution agreement (NPA) regarding those crimes in violation of her
rights. At the first court hearing on the…
giuffre-maxwell
gov.uscourts.nysd.447706.1295.16
22 pg
…at which time a Non-Prosecution Agreement was signed
between Jeffrey Epstein and the United States Attorney's Office defeming fedsral
prosecution of Defendant Epstein and his numerous ceconspirators for identified
federal sex crimes against more than 30 minors.
28…
giuffre-maxwell
gov.uscourts.nysd.447706.31.0_1_1
22 pg
…805-0300
Case 1:15-cv-07433-LAP Document 31 Filed 01/28/16 Page 9 of 22 9
G1ETGIUA
1 co-conspirators were also part of that plea agreement, that
2 non-prosecution agreement, and were not prosecuted…
giuffre-maxwell
gov.uscourts.nysd.447706.1325.18
23 pg
…0300
Case 1:15-cv-07433-LAP Document 1325-18 Filed 01/04/24 Page 10 of 23
9
GlETGIUA
1 co-conspirators were also part of that plea agreement, that
2 non-prosecution agreement, and were not prosecuted…
giuffre-maxwell
gov.uscourts.nysd.447706.1137.15_2
41 pg
…Dershowitz personally helped to
negotiate the non-prosecution agreement (NPA) at issue in this case, which bars his prosecution
in the Southern District of Florida as a “potential co-conspirator of Epstein.” DE 280 at 4
(quoting NPA at 5…
giuffre-maxwell
gov.uscourts.nysd.447706.20.0
26 pg
…Notification Letter. Indeed, Epstein entered into a non-
prosecution agreement with the federal authorities obligating him to pay restitution for his crimes
against Ms. Giuffre. That agreement also protected any “co-conspirators” from prosecution.
The remaining question, then, is whether…
giuffre-maxwell
gov.uscourts.nysd.447706.172.0
28 pg
…Marcinkova was specifically identified by the U.S. Attorney’s
Office for the Southern District of Florida as a “potential co-conspirator of Epstein” in the non-
prosecution agreement it executed with Mr. Epstein as part of his guilty plea…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.4
21 pg
…S.C. § 3771. The cause
of action was premised upon the U.S. Attorney Office’s failure to timely notify Epstein’s victims
of Epstein’s non-prosecution agreement, as required under 18 U.S.C. § 3771(a). Six years…
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