Epstein Secrets

E. McHUGH P. 0. BOX 3301 CHARLESTON, WEST VIRGINIA 25333-3394 500 LEE STREET. EAST. SMITE 800 CHARLESTON. WEST VIRGINIA 25301 June 19, 2008 Mr. John Roth Senior Associate Deputy Attorney General Office of the Deputy Attorney General United States Department of Justice 950 Pennsylvania Avenue, N.W.

-69 (1994); United States v. Meek, 366 F.3d 705, 718 (9th Cir. 2004); United States v. Root, 296 F.3d 1222, 1227 (11th Cir. 2002); United States v. Bailey 228 F.3d 637, 638-639 (6ih Cir. 2000). How, then, could the USAO "plausibly argue" that a misrepresentation about an element of the crime could be v

a, I was a part of the prosecution team that prosecuted the first case in the country under the federal Violence Against Women Act. United States v. Bailey, 112 F.3d 758 (41 Cir.), cert denied, 522 U.S. 896 (1997). The case went to trial and the defendant was sentenced to life in prison. I also spearhe

E. MCHUGH P. 0. 00X 3301 CHARLESTON, WEST VIRGINIA 25333-3394 500 LEE STREET. EAST. SMITE 800 CHARLESTON. WEST VIRGINIA 25301 June 19, 2008 Mr. John Roth Senior Associate Deputy Attorney General Office of the Deputy Attorney General United States Department of Justice 950 Pennsylvania Avenue, N.W.

a, I was a part of the prosecution team that prosecuted the first case in the country under the federal Violence Against Women Act. United States v. Bailey, 112 F.3d 758 (41 Cir.), cert denied, 522 U.S. 896 (1997). The case went to trial and the defendant was sentenced to life in prison. I also spearhe

the facts underlying them, we see nothing in the conduct of the U.S. Attorney's Office that gives us any reason to alter our opinion. Sincerely, John Roth Senior Associate Deputy Attorney General cc: Alex Acosta EFTA00208767 LAW OFFICES ALLEN GUTHRIE MCHUGH & THOMAS, PLLC MALL EN REBECCA& OETS

a, I was a part of the prosecution team that prosecuted the first case in the country under the federal Violence Against Women Act. United States v. Bailey, 112 F.3d 758 (4th Cir.), cert denied, 522 U.S. 896 (1997). The case went to trial and the defendant was sentenced to life in prison. l also spearh

Madly (213) 680-8440 [email protected] 777 South Figueroa Street Los Angeles, California 90017 (213)680'8400 www.kirkland.com June 19,2008 John Roth, Esq. Principal Associate Deputy Attorney General Office of the Deputy Attorney General United States Department of Justice 950 Pennsylvania Aven

the communication itself—not the resulting act. The Court of Appeals for the Eleventh Circuit, in Murrell, underscores the point: The defendant in Bailey contended that attempt under § 2422(6) 'requires the specific intent to commit illegal sexual acts rather than just the intent to persuade or solic

he Deputy Attorney General. Additional letter briefs were submitted by Epstein's attorneys to the Deputy Attorney General. Ex. V. On June 23, 2008, John Roth, Senior Associate Deputy Attorney General, wrote to Messrs. Leflcowitz and Starr, advising them that "federal prosecution of this case is appropria

s.... This legislation will help for all of those reasons."). The presumption is that Congress intends to change the law when it enacts amendments. Bailey v. United States, 52 Fed. Cl. 105, 110 (2002), citin Wallace v. Jaffree 472 U.S. 38, 59 n.48 (1985). Here, not only did Congress change the law by c

rom U.S. Air Force Chief of Staff Gen. Charles Brown; U.S. Space Force Chief of Operations Gen. John Raymond; and Acting Secretary of the Air Force John Roth; 12:00 PM • House Select Committee on the Climate Crisis briefing on the threat of rapid sea-level rise - House Select Committee on the Climate Cri

reports Virginia resident Robert Bailey "was sentenced to 18 months in federal prison for paying a bribe to an FBI official after pleading guilty." Bailey's bribes helped his business "win a contract to build the FBI's 'Grey Wolf' Pocatello data center. The official, James Heslep, was sentenced to 39

he Deputy Attorney General. Additional letter briefs were submitted by Epstein's attorneys to the Deputy Attorney General. Ex. V. On June 23, 2008, John Roth, Senior Associate Deputy Attorney General, wrote to Messrs. Leflcowitz and Starr, advising them that "federal prosecution of this case is appropria

s.... This legislation will help for all of those reasons."). The presumption is that Congress intends to change the law when it enacts amendments. Bailey v. United States, 52 Fed. Cl. 105, 110 (2002), citin Wallace v. Jaffree 472 U.S. 38, 59 n.48 (1985). Here, not only did Congress change the law by c

th Figueroa Street Los Angeles, California 90017 Kenneth W. Starr : To Call Writer Directly: FP Facsimile: www.kirkland.com Dir. Fax: June 19, 2008 John Roth, Esq. Principal Associate Deputy Attorney General Office of the Deputy Attorney General United States Department of Justice 950 Pennsylvania Avenue

s the communication itself—not the resulting act. The Court of Appeals for the Eleventh Circuit, in Murrell, underscores the point: The defendant in Bailey contended that attempt under § 2422(b) ‘requires the specific intent to commit illegal sexual acts rather than just the intent to persuade or solicit