Epstein Secrets

verdell +I (212) 957-7600 ceventell@cohengresses com August 30, 2021 BY FIRST CLASS MAIL Mr. Kenneth A. Polite, Jr. Assistant Attorney General Criminal Division U.S. Department of Justice 950 Pennsylvania Avenue, NW Washington, D.C. 20530-0001 Re: United States v. Ghislaine Maxwell, S2 20 Cr. 330 (AJN) D

n charge of an investigation into allegations of sexual abuse by Jeffrey Epstein conducted by the Palm Beach FBI and the U.S. Attorney's Office for the Southern District of Florida from approximate) July 2006 to June 2008. We request testimony from- and concerning the scope, timeline, and resolution of the investigation, as w

99:25- 300:8). Detective Recarey shared the same view that “it wasn’t any.justice served.” Appendix at 2 (Recarey Depo. 496:1-2). 26. Deputy Chief of the Criminal Division of the U.S. Attorney’s Office, Andrew Lourie, in a transmittal letter with the prosecution memo of Assistant U.S'. Attorney Ann Marie Villafana, told

ghts for crime victi~s, including th~ right i fo be informed about plea agreements and the right to appear at sentencing. :U.S. District Judge fot the Southern District of Florida, Kenneth A. Marra, ruled in 2019 that federal prosecutors violated the CVRA by faili_ng to notify Epstein's victi111s b~f9re allowing him to p)ead g

and 2, with the two agents and Ms. Villafana. We'll be happy to sit down with them."). Indeed, on December 10, 2010, the United States Attorney for the Southern District of Florida, accompanied by supervisory and line prosecutors from the USAO-SDFL, personally conferred with Petitioners' counsel and with Petitioner Jane Doe #1

or division without the express written approval of the United States Attomey(s) in each affected district and/or the Assistant Attorney General of the Criminal Division. USAM 9-27.641 (Multi-District (Global) Agreement Requests). 12 The government acknowledges that this Court has nonetheless ruled that "as a matter

us that you already have our May 19 and May 27 communications to the Deputy Attorney General, as well as our prior written submissions to CEOS and to the Southern District of Florida. In light of the significant volume of our prior submissions and to facilitate your review, we have drafted four supplemental submissions that will

our review of this case is limited both factually and legally. We have not looked at the entire universe of facts in this case. It is not the role of the Criminal Division to conduct a complete factual inquiry from scratch.” (CEOS letter at p. 1). Indeed, entire subject areas relevant to the inquiry were not considered