Epstein Secrets

enge to the statute: "The statute only applies to those who `knowingly' persuade or entice, or attempt to persuade or entice minors. United States' Bailey, 228 F.3d 637, 639 (6th Cir. 2000). See United States' Panfil, 338 F.3d 1° indeed, this last problem is best illustrated by any calls Haley Robson m

s Office Southern District of Florida 500 South Australian Avenue, Suite 400 West Palm Beach, Florida 33401 Jeffrey Epstein Dear Messrs. Sloman, Menchel and Lourie and Ms. Villafafia: TELEPHONE (alai 737-0400 FACSIMILE 1212)124384192 We write as counsel to Jeffrey Epstein to follow-up on our meet

urlaw.com FAITH A. FRIEDMAN flriolmsnalccostlawcom BY FEDERAL EXPRESS July 6, 2007 Jeffrey Sloman, Esq., First Assistant United States Attorney Matthew Menchel, Esq., Chief, Criminal Division The United States Attorney's Office Southern District of Florida 99 NE 4'h Street Miami, Florida 33132 Andrew Lo

of jurisdiction because judge knew that she could depart downward. 19 EFTA00224153 COURT CASES FACILITY FACTS/COMMUNICATION CHARGE U.S. I Bailey, 228 F.3d 637 (6s Cir. 2000) Internet Defendant contacted minors through Internet; used graphic language describing how he wanted to perform o

Chief of the Criminal Division The United States Attorney's Office Southern District of Florida 99 NE 41' Street Miami, Florida 33132 Dear Mr. Menchel: July 25, 2007 Jeffrey Epstein TELEPHONE '212)737-0400 FACSIMILE 12i P) 9/313-SI92 We have previously provided you with a memo as to why we be

leNtwurtlarzwn SHERYL E. REICH fOCROIRICOURRIP.COM RENATO C. STABILE SiblOSWCOURISW.0:en FAITH A. FRIEDMAN ffriedinarylletcouttlaNcom BY HAND Matthew Menchel, Esq. Chief of the Criminal Division The United States Attorney's Office Southern District of Florida 99 NE 41' Street Miami, Florida 33132 Dea

enge to the statute: "The statute only applies to those who `knowingly' persuade or entice, or attempt to persuade or enticesminors. United States' Bailey, 228 F.3d 637, 639 (6th Cir. 2000). See United States'. Pcmfil, 338 F.3d 1° Indeed, this last problem is best illustrated by any cal may claim to h

EDMAN [email protected] BY FEDERAL EXPRESS TELEPHONE FACSIMILE July 6, 2007 Jeffrey Sloman, Esq., First Assistant United States Attorney Matthew Menchel, Esq., Chief, Criminal Division The United States Attorney's Office Southern District of Florida 99 NE 4th Street Miami, Florida 33132 Andrew Lo

s Office Southern District of Florida 500 South Australian Avenue, Suite 400 West Palm Beach, Florida 33401 Jeffrey Epstein Dear Messrs. Sloman, Menchel and Lourie and Ms. Villafafia: We write as counsel to Jeffrey Epstein to follow-up on our meeting on June 26, 2007. We thought the meeting was extr

— communicate or otherwise interact improperly with persons who turn out to be minors. A prosecution of Mr. Epstein would violate the teachings of Bailey and Panfil. As we believe we persuaded you at the June 26th meeting, Mr. Epstein never targeted minors. On the contrary, what he did — at worst — w

kswilawoom FAITH A. FRIEDMAN IM•cimweelcoutlaw.com BY FEDERAL EXPRESS July 6, 2007 Jeffrey Sloman, Esq., First Assistant United States Attorney Matthew Menchel, Esq., Chief, Criminal Division The United States Attorney's Office Southern District of Florida 99 NE 4'h Street Miami, Florida 33132 Andrew Lo

s Office Southern District of Florida 500 South Australian Avenue, Suite-400 West Palm Beach, Florida 33401 Jeffrey Epstein Dear Messrs. Sloman, Menchel and Lourie and Ms. Villafafia: We write as counsel to Jeffrey Epstein to follow-up on our meeting on June 26, 2007. We thought the meeting was extr

, 311 I. 3d 557, 161-63 (9" Cir. 2004); U.S.' Meek, 366 3d 705, 720- 22 (9" Cir. 2004); U.S. Panti I, 338 3d 1299, 1300-01 (I I" Cir. 2003); U.S. Bailey, 228 F. 3d 637, 639 (6" Cir. 2000). Case No. 08-80736-C V-MARRA P-011949 EFTA00226737 eattWithentiali th umse Ct. S.An r•&it EIVVY,_ LOHen 1

- communicate or otherwise interact improperly with persons who turn out to be minors. A prosecution of Mr. Epstein would violate the teachings of Bailey and Panfil. As we believe we persuaded you at the June 26th meeting, Mr. Epstein never targeted minors. On the contrary, what he did — at worst — w

he state would put an appropriate end to the matter for everyone. EFTA00226776 r LAW 00 ICC,. Y. GERALD B. LEFCOURT. P.C. Jeffrey Sloman, Esq. Matthew Menchel, Esq. Andrew LS. A. Marie , Esq. The Unite!1Mttorney's Office Southern District of Florida July 6,2007 Page 23 Again, we and our colleagues t

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

d Epstein's sentencing exposure . . . " See Tab 1, May 19, 2008 Letter from J. . In fact, by a email dated August 3, 2007, Criminal Division Chief Matthew Menchel advised the defense that the federal government required a minimum term of two years of incarceration. See Tab 40, August 3, 2007 Email from M. Men

sex act himself, he would nevertheless violate §2422(b)." United States v. Murrell, 368 F.3d 1283, 1286 (11th Cu. 2004). See also United States v. Bailey 228 F.3d 637, 639 (61° Cir. 2000) ("Congress has made a clear choice to criminalize persuasion and the attempt to persuade, not the performance of t

en to use "a" versus "the" and other minutiae. When you and I could not reach agreement, you repeatedly went over my head, involving Messrs. Lourie, Menchel, Sloman, and Acosta in the negotiations at various times. In any and all plea negotiations the defendant understands that his options are to plead

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

ed Epstein’s sentencing exposure...” See Tab 1, May 19, 2008 Letter from J. Sloman. In fact, by a email dated August 3, 2007, Criminal Division Chief Matthew Menchel advised the defense that the federal government required a minimum term of two years of incarceration. See Tab 40, August 3, 2007 Email from M. Mench

he State, nor even discussed with. the State, the length of Mr. Epstein’s incarceration. In a letter to the defense, Criminal Division Chief, Matthew Menchel rejected the sentence contemplated by the State’s plea agreement, writing that “the federal interest will not be vindicated in the absence of a two-y