From: ' (USANYS)" To: ' Subject: RE: separate research project Date: Wed, 26 Jun 2019 14:39:18 +0000 Importance: Normal The government made the claim you are referencing in its Sealed Motion to Dismiss for Lack of Subject Matter Jurisdiction, originally filed on 11/7/2011. It was unsealed and docketed on 7/5/2013 (Document 205-2). The government made these assertions to argue the plaintiffs' claims were not ripe, as plaintiffs already had access to the remedies they sought through the lawsuit, namely conferring with AUSAs to bring criminal prosecution against Epstein. The relevant portions are summarized below: Page 8: SONY and the District of New Jersey share subject matter jurisdiction and venue —"Epstein is thus subject to potential prosecution for such acts in those districts" Page 10: "that agreement does not part the United States from bringing federal charges against Epstein," quoting language from the NPA limiting it to prosecutions "in this district" in support Page 11: The NPA "does not bar the United States from bringing federal criminal charges against Epstein for the offenses set forth in the Non-Prosecution Agreement in any other district in this nation" Sorry if this turnaround was quicker than expected. While I don't want to overburden you looking for assignments for me, I am always happy to help whenever you need me! Additionally, if you have any upcoming court appearances, proffers, or other pre/post trial events, please let me know as I am always looking for opportunities to see high-quality lawyering in action. Best, From: (USANYS) Sent: Wednesday, June 26, 2019 8:49 AM To: Subject: RE: separate research project I am happy to track this down. I'll get started on some initial research and will let you know if I am encountering roadblocks and wish to discuss further in person. From: Sent: Tuesday, June 25, 2019 8:58 PM To: (USANYS) Subject: RE: separate research project This is great, thanks very much. And I've g