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

individual woman. As the statute makes clear, the essence of this crime is 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

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

ed Mr. Epstein's rights and privileges, Mr. Epstein and his counsel intervened to assert their rights, both in the district court, and on appeal to the Eleventh Circuit. See Doe No. 1, supra. That there would be no judgment against Mr. Epstein at the end of this CVRA litigation, however, was understood throughout t

258 CEOS Chief Oosterbaan told OPR this provision was “very unusual.” Principal Associate Deputy Attorney General John Roth commented, “I don’t know how it is that you give immunity to somebody who’s not identified. I just don’t know how that works.” Villafaña’s co-coun

344 In re Dean, 527 F.3d 391 (5th Cir. 2008). The Fifth Circuit opinion was not binding precedent in Florida, which is within the Eleventh Circuit. 345 United States v. BP Products North America, Inc., 2008 WL 501321, at *11 (S.D. Tex. 2008). Victims who wished to be heard were permitted t

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 to engage in a criminal sex act or (b) that Owens was under the age of 18.) (emphasis added). Again, none of these factors is present in this case. The Eleventh Circuit’s interpretation of the statute makes perfect sense: were § 1591 not limited in this fashion, it would threaten to criminalize a host of localized beha

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.

1313-1314 (11th Cir. 2007) (Jane Doe #2 stated that she traveled to Atlanta, Georgia with Madison to work as a prostitute). Thus, courts, including the Eleventh Circuit in Evans, have underscored the point that § 1591 simply is not intended to cover the kind of alleged conduct at issue here. "Section 1591 does not