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.

ution ring in Evans was not, in fact, entirely intrastate as the companion case of one of the Evans co-defendants makes clear. See, United States v. Madison, 477 F.3d 1312, 1313-1314 (11th Cir. 2007) (Jane Doe #2 stated that she traveled to Atlanta, Georgia with Madison to work as a prostitute). Thus, c

coercive components that Congress, and administration policy statements intended in 18 U.S.C. § 1591 prosecutions. Evans, and his co-conspirators (Madison and Yearby) were not "Johns." They operated a for profit prostitution ring marked by control of, and extreme violence toward, the victims, who they

r. Epstein's alleged conduct. See Lefcourt Letter (Exhibit 1); see also Letter from Stephanie D. Thacker, former Principal Deputy Chief of CEOS, to John Roth, Senior Associate Deputy Attorney General, June 19, 2008 (attached as Exhibit ) (noting that "[t]his is a case about purely local activity, involv

against Mr. Epstein.3 III. THE CVRA ITSELF DOES NOT AUTHORIZE IMPOSITION OF THE EPSTEIN REMEDIES Citing a line of cases beginning with Marbury v. Madison, 5 U.S. 137 (1803), the Petitioners contend that the CVRA authorizes "the invalidation of an illegal non- prosecution agreement so that they can con

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

nd coercive components that Congress, and administration policy statements intended in 18 U.S.C. § 1591 prosecutions. Evans, and his co-conspirators (Madison and Yearby) were not “Johns.” They operated a for profit prostitution ring marked by control of, and extreme violence toward, the victims, who they k

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.

coercive components that Congress, and administration policy statements intended in 18 U.S.C. § 1591 prosecutions. Evans, and his co-conspirators (Madison and Yearby) were not "Johns." They operated a for profit prostitution ring marked by control of, and extreme violence toward, the victims, who they