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KIRKLAND & ELLIS LLP SUBMISSION TO THE OFFICE OF THE DEPUTY ATTORNEY GENERAL IN THE MATTER OF JEFFREY E. EPSTEIN Jeffrey Epstein, a successful businessman and noted philanthropist with no prior criminal record, has been investigated for potential violations of
ds liberty) rather than the broader construction (which expands the federal prosecutor's arsenal) controls under the venerable rule of lenity. Mr. Epstein's conduct—including his misconduct—falls within the heartland of historic state police and prosecutorial powers. Absent a significant federal nexus,
s email, or phone—prior to their arrival at his home. See Tab 13, (deposition), p. 30. has stated that like man other women) she first met Mr. in Epste when her friend, introduced her to him. See Tab 14, Tr. A, p. 4-5. • Mr. Epstein was told the girls were over 18. o Ms. ex pressl admitted to
OF THE DEPUTY ATTORNEY GENERAL IN THE MATTER OF JEFFREY E. EPSTEIN Jeffrey Epstein, a successful businessm
OF THE DEPUTY ATTORNEY GENERAL IN THE MATTER OF JEFFREY E. EPSTEIN Jeffrey Epstein, a successful businessma
l) controls under the venerable rule of lenity. Mr. Epstein's conduct—including his misconduct—falls within t
uch usurpation does not legitimize executive action that exceeds its bounds. See Tab 12, November 2, 1994 Memorandum from Assistant Attorney General Walter Dellinger to the Hon. Abner J. Mikva, Counsel To The President, on Presidential Authority To Decline To Execute Unconstitutional Statutes, available at http:
l prosecutorial authority. IO 08-80736-CV-MARRA RFP WPB 001653 EFTA00209832 KIRKLAND & ELLIS LLP SUMMARY OF MISCONDUCT ISSUES IN THE MATTER OF JEFFREY E. EPSTEIN The manner in which federal prosecutors have pursued the allegations against Mr. Epstein is highly irregular and warrants full review by the Depar
SUMMARY OF MISCONDUCT ISSUES IN THE MATTER OF JEFFREY E. EPSTEIN The manner in which federal prosecutors have pursued the allegations against Mr. Epstein is highly irregular and warrants full review by the Department. While we repeatedly have raised our concerns regarding misconduct with the United S
LP SUMMARY OF MISCONDUCT ISSUES IN THE MATTER OF JEFFREY E. EPSTEIN The manner in which federal prosecutor
LP SUMMARY OF MISCONDUCT ISSUES IN THE MATTER OF JEFFREY E. EPSTEIN The manner in which federal prosecutors
prosecutors have pursued the allegations against Mr. Epstein is highly irregular and warrants full review by
uch usurpation does not legitimize executive action that exceeds its bounds. See Tab 12, November 2, 1994 Memorandum from Assistant Attorney General Walter Dellinger to the Hon. Abner J. Mikva, Counsel To The President, on Presidential Authority To Decline To Execute Unconstitutional Statutes, available at http:
ich friend was that? A. His name was Brian. TI don't know his last name. I really didn't know [Jand « didn't know her friends or whatever, but I met Jeffrey. And once I met Jeffrey, he was a very awesome guy and I just -- I don't know. <I ended up giving him my number so x could -- I didn't want J or Bria
time? A. Yes. Q. You would get $200 every time she came? A. Yes. Q. Good deal. Okay. What about EP A. EEE 10? Q. any i that you brought to Mr. Epstein’s house. Page 30 HOUSE_OVERSIGHT_012311 19 20 21 22 23 24 25 ay oO 11 12 13 14 15 16 17 mo AN OD uo S&F WwW KN 04-25 Po where did she go to
m. (Thereupon, the interview ended.) (Pages 10 to 13) 4 HOUSE_OVERSIGHT_012362 Page 12}: Page 13 02423 TAB 10 HOUSE_OVERSIGHT_012363 IN RE: JEFFREY EPSTEIN VZIDEOTAPED INTERVIEW as 060ml 02528 HOUSE_OVERSIGHT_012364 1 (Uhereupon, the following videotaped interview was 1 2 had:} : 2 4 BY DETECTIVE REC
GHT_012357 TAB 9 HOUSE_OVERSIGHT_012358 TN RF: JBPPREY EPSTEIN TAPED INTERVIEW OF P| DIRAF T 02420 HOUSE_OVE
bout EP A. EEE 10? Q. any i that you brought to Mr. Epstein’s house. Page 30 HOUSE_OVERSIGHT_012311 19 20
ch a provision, can be a valid and reasonable exercise of Presidential authority." Memorandum for Bernard N. Nussbaum, Counsel to the President, from Walter Dellinger, Assistant Attorney General, Office of Legal Counsel at 4 (Nov. 3, 1993). (Of course, the President is not obligated to announce his reservations in
uring the federal investigation; a letter from former CEOS attorney Stephanie Thacker that responds to CEOS’s assessment of its limited review of Mr. Epstein’s case; and a point-by- point rebuttal to First Assistant United States Attorney Jeffrey Sloman’s recent letter which we believe contains factual ina
Page: HOUSE_OVERSIGHT_012136 →nds to CEOS’s assessment of its limited review of Mr. Epstein’s case; and a point-by- point rebuttal to First A
Page: HOUSE_OVERSIGHT_012136 →BMISSION HOUSE_OVERSIGHT_012141 --- PAGE BREAK --- KIRKLAND & ELLIS LLP SUBMISSION TO THE OFFICE OF THE DEPUTY ATTORNEY GENERAL IN THE MATTER OF JEFFREY E. EPSTEIN Jeffrey Epstein, a successful businessman and noted philanthropist with no prior criminal record, has been investigated for potential violations of
Page: HOUSE_OVERSIGHT_012142 →OF THE DEPUTY ATTORNEY GENERAL IN THE MATTER OF JEFFREY E. EPSTEIN Jeffrey Epstein, a successful businessm
Page: HOUSE_OVERSIGHT_012142 →OF THE DEPUTY ATTORNEY GENERAL IN THE MATTER OF JEFFREY E. EPSTEIN Jeffrey Epstein, a successful businessma
Page: HOUSE_OVERSIGHT_012142 →such usurpation does not legitimize executive action that exceeds its bounds. See Tab 12, November 2, 1994 Memorandum from Assistant Attorney General Walter Dellinger to the Hon. Abner J. Mikva, Counsel To The President, on Presidential Authority To Decline To Execute Unconstitutional Statutes, available at http://
Page: HOUSE_OVERSIGHT_012146 →KIRKLAND & ELLIS LLP SUBMISSION TO THE OFFICE OF THE DEPUTY ATTORNEY GENERAL IN THE MATTER OF JEFFREY E. EPSTEIN Jeffrey Epstein, a successful businessman and noted philanthropist with no prior criminal record, has been investigated for potential violations of
Page: EFTA00013811 →ds liberty) rather than the broader construction (which expands the federal prosecutor's arsenal) controls under the venerable rule of lenity. Mr. Epstein's conduct—including his misconduct—falls within the heartland of historic state police and prosecutorial powers. Absent a significant federal nexus,
Page: EFTA00013811 →OF THE DEPUTY ATTORNEY GENERAL IN THE MATTER OF JEFFREY E. EPSTEIN Jeffrey Epstein, a successful businessma
Page: EFTA00013811 →l) controls under the venerable rule of lenity. Mr. Epstein's conduct—including his misconduct—falls within t
Page: EFTA00013811 →uch usurpation does not legitimize executive action that exceeds its bounds. See Tab 12, November 2, 1994 Memorandum from Assistant Attorney General Walter Dellinger to the Hon. Abner J. Mikva, Counsel To The President, on Presidential Authority To Decline To Execute Unconstitutional Statutes, available at http:
Page: EFTA00013815 →but that she 14 EFTA00013824 --- PAGE BREAK --- KIRKLAND & ELLIS LLP also had conversations with other women in which these women hoped that "Jeffrey didn't find out [their] age[s]." See Tab 6, Tr., p. 45. o Ms. also stated that she: "would tell my girlfriends just like approached me. Make sure
Page: EFTA00013825 →Entities connected to both Jeffrey Epstein and Walter Dellinger

Lesley Groff
PERSON
Marc Rich
PERSONLeon Black
PERSON
George W. Bush
PERSON
United States
LOCATIONJane Doe
PERSON
Barry Diller
PERSON
Department of Justice
ORGANIZATION
Julie K. Brown
PERSON
Bill Clinton
PERSON
Alexander Acosta
PERSONthe Southern District
LOCATION
A. Marie Villafana
PERSON
Jay Lefkowitz
PERSONRoy Black
PERSON
Ken Starr
PERSON
Harvey Weinstein
PERSONLandon Thomas Jr.
PERSONGerald Lefcourt
PERSONKirkland & Ellis LLP
ORGANIZATION