Epstein Secrets

ROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00003302 EFTA00157684 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

ring the federal investigation; a letter from former CEOS attorney Stephanie Thacker that responds to CEOS's assessment of its limited review of Mr. E stein's case; and a point-by- point rebuttal to First Assistant United States Attorney recent letter which we believe contains factual inaccuracies typic

here, those problems unquestionably present multi jurisdictional obstacles that States and localities cannot confront effectively on their own. Mr. Epstcin's conduct was purely local in nature, and the State of Florida and Palm Beach County are effectively prosecuting and punishing that conduct. Althou

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

dent assessment of whether federal prosecution of Mr. Epstein is both nertcruy and warranted in view of the le

ks, it is that of Barry Kutun, a former North Miami city attorney accused of having sex with underage prostitutes and videotaping the sessions. Mr. Kutun pleaded guilty on May 18, 2007 in a Miami- Dade County courtroom as part of an agreement with State prosecutors and he received five years probation

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

ks, it is that of Barry Kutun, a former North Miami city attorney accused of having sex with underage prostitutes and videotaping the sessions. Mr. Kutun pleaded guilty on May 18, 2007 in a Miami- Dade County courtroom as part of an agreement with State prosecutors and he received five years probation

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

ks, it is that of Barry Kutun, a former North Miami city attorney accused of having sex with underage prostitutes and videotaping the sessions. Mr. Kutun pleaded guilty on May 18, 2007 in a Miami- Dade County courtroom as part of an agreement with State prosecutors and he received five years probation

w best to use the broad discretion you enjoy in choosing whether to prosecute. In this regard, we suggest that having a greater understanding of who Jeffrey Epstein is as a person may help inform how best to proceed. Jeffrey Epstein was raised in a middle class neighborhood in Brooklyn, New York, by hardworking

ourl Subject: Jeffrey Epstein Illt hope you had a great holiday season. Gerald Lefcourt and I would like to speak with you early next week on the Epstein matter. if you provide me with some convenient dates and times for us to call you, I will coordinate with Gerry and confirm same. regards Lilly A

_CE08_00079 EFTA00184637 9:08-cv-80736-KAM Document 361-46 Entered on FLSD Docket 02/10/2016 Page 5 of 24 LAW DAVICCII or ALD B. LEFCOURT. PC. Jeffrey Matthew Esq. Andrew Laurie. Esq. Esq. The United States Attorney's Office Southern District of Florida July 6, 2007 Page 4 The bulk impor

igned to address a specific a problem with which Mr. Epstein's case has nothing in common. If stretched to re

. Declining To Prosecute as an Exercise of Discretion Epstein is being prosecuted by state authorities in Florida. Even if we assume aiguendo that Epslein's conduct constitutes a federal crime that can be proven, nevertheless no "substantial Federal interest" would be served by prosecuting him. On this

for their efforts cannot justify a punishment harsher than what Mr. Epstein deserves. I ask you to look at the manner in which the state settled the Kutun case last week. As you know, Mr. Kutun was a public figure who had videotaped sexual intercourse with a 16 year old. Consider the following facto

Inc.'s sole business activities related to the operation and ownership of a Gulfstream G-1159B aircraft bearing tail number N909JE. F 9. Defendant JEFFREY EPSTEIN se as president, sole director, and sole shareholder of Hyperion Air, Inc., and had the power to direct all of its operations. 10. Pursuant to Flori

at 358 El Brillo Way, Palm Beach, Florida, in the Southern District of Florida (hereinafter referred to as '358 El Brillo Way"). 5. DefendaRFFREY EPSTEIN owned a property located at 9 East 71st Street, New York, New York (hereinafter referred to as "the New York residence"). 6. Defendant JEFFREY EPS

y Jane Doe #15. (134) In or- around the first half of 2005, Defendant led Jane Doe #15 from the kitchen of 358 El Brillo Way upstairs to Defendant JEFFREY EPSTEIN's bedroom at 358 El Brillo Way. (135) In or around the first half of 2005, Defendant JEFFREY EPSTEIN instructed Jane Doe #15, who teas the

Doe # 19? Have you testified about her previously? 2. Has she been interviewed? 3. During what period of time did Jane Doe # 19 have contact with JE? 4. How old was she during that time frame? 5. How did she meet JE? 6. And what sexual activity was she involved in with JET 7. How much was

those associated with him in the past concerning Mr. Epstein, you consider not continuing communications with

mpared to that of Barry Kutun, a former North Miami city attorney accused of having sex with underage prostitutes and videotaping the sessions. Mr. Kutun pleaded guilty on May 18, 2007 in a Miami- Dade County courtroom as part of an agreement with State prosecutors, and he received five years probatio

From: "Acosta, Alex MUSAFLSV To: " Cc: Subject: Re: Jeffrey Epstein - confidential Date: Sun, 23 Sep 2007 16:22:46 +0000 Importance: Normal Can we do a conf call? ------------------ Sent from my BlackBerry Wireles

- confidential Dear Mr. Acosta, I write to follow up on our conversation on Friday and to ask you to reconsider your decision to require that Mr. Epstein plead guilty to a registerable state charge. It appears that there was a misunderstanding at the meeting I had with Please confirm this with Bef

"Acosta, Alex MUSAFLSV To: " Cc: Subject: Re: Jeffrey Epstein - confidential Date: Sun, 23 Sep 2007 16

you to reconsider your decision to require that Mr. Epstein plead guilty to a registerable state charge. It

their efforts cannot justify a punishment harsher than what Mr. Epstein deserves. I ask you to look at the manner in which the state settled the Kutun case last week. As you know, Mr. Kutun was a public figure who had videotaped sexual intercourse with a 16 year old. Consider the following factor

Please confirm this with From: Jay Leficowitz To: "Acosta, Alex" Cc: IM r=ill= Subject: Jeffrey Epstein - confidential Date: Sun, 23 Sep 2007 15:58:14 +0000 Importance: Normal Dear Mr. Acosta, I write to follow up on our conversation on Friday and

rtance: Normal Dear Mr. Acosta, I write to follow up on our conversation on Friday and to ask you to reconsider your decision to require that Mr. Epstein plead guilty to a registerable state charge. It appears that there was a misun in at the meeting I had with Messrs. Ms. and Ms. Before the meet

owitz To: "Acosta, Alex" Cc: IM r=ill= Subject: Jeffrey Epstein - confidential Date: Sun, 23 Sep 2007 15

you to reconsider your decision to require that Mr. Epstein plead guilty to a registerable state charge. It

their efforts cannot justify a punishment harsher than what Mr. Epstein deserves. I ask you to look at the manner in which the state settled the Kutun case last week. As you EFTA00215128 know, Mr. Kutun was a public figure who had videotaped sexual intercourse with a 16 year old. Consider the f

a, Ann Marie C. (USAFLS) From: Jay Lefkowitz [[email protected] nt: Sunday, September 23, 2007 11:58 AM Acosta. Alex (USAFLS) Subject: Jeffrey Epstein - confidential Dear Mr. Acosta, I write to follow up on our conversation on Friday and to ask you to reconsider your decision to require that Mr. Ep

- confidential Dear Mr. Acosta, I write to follow up on our conversation on Friday and to ask you to reconsider your decision to require that Mr. Epstein plead guilty to a registerable state charge. It appears that there was a misunderstanding at the meeting I had with Messrs. Goldberger, Lefcourt,

, 2007 11:58 AM Acosta. Alex (USAFLS) Subject: Jeffrey Epstein - confidential Dear Mr. Acosta, I write

you to reconsider your decision to require that Mr. Epstein plead guilty to a registerable state charge. It a

for their efforts cannot justify a punishment harsher than what Mr. Epstein deserves. I ask you to look at the manner in which the state settled the Kutun case last week. As you know, Mr. Kutun was a public figure who had videotaped sexual intercourse with a 16 year old. Consider the following facto

t: Sunday, September 23, 2007 11:58 AM Acosta, Alex (USAFLS) c: Lourie, AndrewHSkxnan, Jeff (USAFLS): Villafana, Ann Marie C. (USAFLS) Subject: Jeffrey Epstein - confidential Dear Mr. Acosta, I write to follow up on our conversation on Friday and to ask you to reconsider your decision to require that Mr. Ep

- confidential Dear Mr. Acosta, I write to follow up on our conversation on Friday and to ask you to reconsider your decision to require that Mr. Epstein plead guilty to a registerable state charge. It appears that there was a misunderstanding at the meeting I had with Messrs. Lourie, Krischer, Gold

FLS): Villafana, Ann Marie C. (USAFLS) Subject: Jeffrey Epstein - confidential Dear Mr. Acosta, I write

you to reconsider your decision to require that Mr. Epstein plead guilty to a registerable state charge. It a

for their efforts cannot justify a punishment harsher than what Mr. Epstein deserves. I ask you to look at the manner in which the state settled the Kutun case last week. As you know, Mr. Kutun was a public figure who had videotaped sexual intercourse with a 16 year old. Consider the following facto

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

nds to CEOS’s assessment of its limited review of Mr. Epstein’s case; and a point-by- point rebuttal to First A

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

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

ks, it is . that of Barry Kutun, a former North Miami city attorney accused of having sex with underage prostitutes and videotaping the sessions. Mr. Kutun pleaded guilty on May 18, 2007 in a Miami- Dade County courtroom as part of an agreement with State prosecutors and he received five years probation