Epstein Secrets

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

l court decisions watering down the "for the purpose of " requi ment fly in the face of the two Suprems Court decisions addressing that element. See Hansen'. Huff, 291 U.S. 559 (1934); Mortensen. United States, 322 U.S. 369 (1944). Santos and Cuellar speak loudly and clearly against prosecutors seeing

was prepared again, and was reviewed in anticipation of presentation to the grand jury. On June 23, 2008, Senior Associate Deputy Attorney General John Roth denied the various appeals of Epstein's attorneys and wrote, "Even if we were to substitute our judgment for that of the U.S. Attorney, we believe

Page 28 of 36 the same act are intended to have the same meaning.") (quotation and citation omitted). Two Mann Act cases are particularly apt. In Hansen', Half, 291 U.S. 559 (1934), the Government charged the defendant with violating the Mann Act after she returned to the country with a man with who

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

l court decisions watering down the “for the purpose of “ requirement fly in the face of the two Supreme Court decisions addressing that element. See Hansen v. Huff, 291 U.S. 559 (1934); Mortensen v. United States, 322 U.S. 369 (1944). Santos and Cuellar speak loudly and clearly against prosecutors seeing