Epstein Secrets

ecution is to the facts in this case. Importantly, we note that the CEOS review was conducted prior to the Supreme Court's very recent decisions in Santos and Cuellar, which we believe—illuminating as they do the Court's interpretive methodology when it comes to federal criminal law—powerfully demonst

AO to do so, it is not in accord with the principles of justice. Indeed, as noted, just a few weeks ago, the Supreme Court underscored this point in Santos and Cuellar. The Court made clear that prosecutorial discretion does not provide the USAO cart blanche to expand criminal statutes as they seek to

ll of the terms and conditions of the [Deferred Prosecution] Agreement, as modified by the United States Attorney's December 19, 2007 letter to Ms. Sanchez by close of business on Monday, June 2, 2008, the SDFL will elect to terminate the Agreement." Id., p.1 The Truth: • The Deferred Prosecution Agre

, and the rule of lenity applied in construing a statute, Defendant's position as to the meaning of the statute would prevail. See United States'. Santos 128 S.Ct. 2020, 2025 (2008). As summarized by the United States Supreme Court in Santos, supra, at 2025: 5 See argument in sections (2) and (3) t

meaning of the statute would prevail. See United States'. Santos 128 S.Ct. 2020, 2025 (2008). As summarized by the United States Supreme Court in Santos, supra, at 2025: 5 See argument in sections (2) and (3) that follow which represent the predicate for the rule of lenity issue discussed in B. 9

willful breach. Paragraph 8 and its waiver provisions are not clear (or as stated by Mr. Acosta are "far from simple," see Mr. Acosta letter to Ms. Sanchez, December 19, 2007). Paragraph 8 does not "speak for itself." That the provisions of ¶8 are "far from simple" is illustrated in the construction of

of inertia upon the party that can best induce Congress to speak more clearly and keeps courts from making criminal law in Congress's stead. ... In Santos. the Court was faced with the interpretation of the term "proceeds" in the federal money laundering statute, 18 . §1956. "The federal money-launder

aning of the statute would prevail. See United Statcs I. Santos, 128 S.Ct. 2020, 2025 (2008). As summarized by the United States Supreme Court in Santos, supra, at 2025: See argument in sections (2) and (3) that follow which represent the predicate for the rule of lenity issue discussed in B. 9 EF

willful breach. Paragraph 8 and its waiver provisions are not clear (or as stated by Mr. Acosta are "far from simple," see Mr. Acosta letter to Ms. Sanchez, December 19, 2007). Paragraph 8 does not "speak for itself." That the provisions of ¶8 are "far from simple" is illustrated in the construction of

ecution is to the facts in this case. Importantly, we note that the CEOS review was conducted prior to the Supreme Court's very recent decisions in Santos and Cuellar, which we believe—illuminating as they do the Court's interpretive methodology when it comes to federal criminal law—powerfully demonst

Lefcourt and Lilly Ann Sanchez, both counsel to Jeffrey Epstein, that as a result of a telephone conversation had amongst you, Mr. Lefcourt and Ms. Sanchez, you are now seeking documents reflecting: 1. Ownership of JEGE and Hyperion; 2. Assets of JEGE and Hyperion; and 3. Employees of JEGE and Hyperio

) 14 United States v. Reuter, 463 F.3d 792 (7th Cir. 2006) 9, 10 United States v. Sanchez, 30 F.4th 1063 (11th Cir. 2022) 13 United States v. Santos, No. 21-10381, 2022 WL 1196761 (5th Cir. Apr. 22, 2022) 13 United States v. Skys, 637 F.3d 146 (2d Cir. 2011) 16 United States v. Suarez, No.

. 2009) 21 United States v. Pope, 554 F.3d 240 (2d Cir. 2009) 14 United States v. Reuter, 463 F.3d 792 (7th Cir. 2006) 9, 10 United States v. Sanchez, 30 F.4th 1063 (11th Cir. 2022) 13 United States v. Santos, No. 21-10381, 2022 WL 1196761 (5th Cir. Apr. 22, 2022) 13 United States v. Skys, 6

ts to Congress. Prosecutors said the charges resulted from "fraudulent schemes and brazen misrepresentations" designed to mislead donors, enrich Mr. Santos, and win a seat in Congress as a Republican from Queens. The article included an overview of the charges contained in the 20- page indictment, which

mentioned that last November, Israeli and American media outlets reported that the FBI launched an investigation into the incident. NBC News (05/11, Sanchez, Jabari) also reported on the story. Mexico Arrests Two More in March Kidnap, Killing of Americans The Associated Press (05/11, Staff Writer) repor

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, and the rule of lenity applied in construing a statute, Defendant's position as to the meaning of the statute would prevail. See United States'. Santos 128 S.Ct. 2020, 2025 (2008). As summarized by the United States Supreme Court in Santos supra, at 2025: 3 See argument in sections (2) and (3) th

NITED STATES ATTORNEY NLIVERY BY FACSIMILE Lilly Ann Sanchez Fowler White Burnett, PA 11Of II.;•.1.A.111 A. . Igh Re: Jeffrey Epstein Dear Ms. Sanchez: 99 N.E 4 Simi Mann* FL 33132 (305) 961-9I00 • Telephone O0O530-6444 • Facsimile December 19, 2007 I write to follow up on the December I41h me

secution is to the facts in this case. Importantly, we note that the CEOS review was conducted prior to the Supreme Court’s very recent decisions in Santos and Cuellar, which we believe—illuminating as they do the Court’s interpretive methodology when it comes to federal criminal law—powerfully demonstra

an “mere solicitation;” it must be more than an offer or the providing of an opportunity to engage in prohibited conduct. See, e.g,. United States v. Sanchez-Berrios, 424 F.3d 65, 76-77 (1* Cir. 2005); United States v. Brown, 43 F.3d 618, 625 (11™ Cir. 1995). The government cannot fairly, or consistent wit

t cannot be shown that Mr. Epstein violated any of the three federal statutes identified by prosecutors. As the Supreme Court's recent decisions in Santos and Cuellar make clear, federal law may not be stretched in that manner, and the current federal investigation relies, as its foundation, on imperm

"mere solicitation;" it must be more than an offer or the providing of an opportunity to engage in prohibited conduct. See, e.g,. United States v. Sanchez-Berrios, 424 F.3d 65, 76-77 (ls' Cir. 2005); United States v. Brown, 43 F.3d 618, 625 (11th Cir. 1995). The government cannot fairly, or consistent