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

t them in his house if they were under the age of 18. See United States v. Kennard, 472 F.3d 851, 857-858 (1 3'Cir. 2006), quoting, United States v Puche, 350 F.3d t 137, 1149 (11th Cir. 2003) (An instruction on deliberate ignorance is appropriate only if it is shown [among other things] ... that the

orney The United States Attorney's Office Southern District of Florida 500 South Australian Avenue, Suite 400 West Palm Beach, Florida 33401 Re: Jeffrey E. Epstein Dear Messrs. Sloman, Menchcl and Lourie and Ms. Villafatia: TELEPHONE 12121737.0400 FACSIMILE As you are aware, we represent Jeffrey E. Epstein

rce is involved, the victim must be under 16 years old for a prosecution to lie. -.1-12C1)1 ) We understand the Office has taken the view that Mr. Epstein targeted underage high school students. This was absolutely not the case and we will be prepared to discuss at our meeting the objective evidence de

We understand the Office has taken the view that Mr. Epstein targeted underage high school students. This was

e, Suite 400 West Palm Beach, Florida 33401 Re: Jeffrey E. Epstein Dear Messrs. Sloman, Menchcl and Lourie

e, Suite 400 West Palm Beach, Florida 33401 Re: Jeffrey E. Epstein Dear Messrs. Sloman, Menchcl and Lourie

Page 4 proceeds of specified unlawful activity,' orAc) `to avoid a transaction reporting requirement under State or Federal law". United States'. Puche, 350 F.3d 1137 (11th Cir. 2003);5 see also United States" Arditti, 955 F.2d 331 (5th Cir.), reh'g denied, cert denied 506 U.S. 998 (1992), cert. de

tuted States Attorney's Othce Southern District of Florida 500 South Australian Avenue, Suite 400 West Palm Beach, Florida 33401 Dear Messrs Re: Jeffrey E. Epstein • and Ms.I=M: As you are aware, we represent Jeffrey E. Epstein in connection with your ongoing investigation. We write to you in advance of our Jun

ance unless force is involved, the victim must be under 16 years old for a prosecution to lie. We understand the Office has taken the view that Mr. Epstein targeted underage high school students. This was absolutely not the case and we will be prepared to discuss at our meeting the objective evidence de

West Palm Beach, Florida 33401 Dear Messrs Re: Jeffrey E. Epstein • and Ms.I=M: As you are aware, we rep

West Palm Beach, Florida 33401 Dear Messrs Re: Jeffrey E. Epstein • and Ms.I=M: As you are aware, we repr

We understand the Office has taken the view that Mr. Epstein targeted underage high school students. This was

age 4 proceeds of specified unlawful activity,' or (c) 'to avoid a transaction reporting requirement under State or Federal law"'. United States v. Puche, 350 F.3d 1137 (11 Cir. 2003);5 see also United States v. Arditti, 955 F.2d 331 (5th Cir.), reh'g denied, cert. denied 506 U.S. 998 (1992), cert. d

f, Northern Region Assistant United States Attorney e rue a es ttorney's Office Southern District of Florida West Palm Beach, Florida 33401 Re: Jeffrey E. Epstein Dear Messrs. TELEPHONC FACSIMILE As you are aware, we represent Jeffrey E. Epstein in connection with your ongoing investigation. We write to yo

nce unless force is involved, the victim must be under 16 years old fora prosecution to lie. 3 We understand the Office has taken the view that Mr. Epstein targeted underage high school students. This was absolutely not the case and we will be prepared to discuss at our meeting the objective evidence de

We understand the Office has taken the view that Mr. Epstein targeted underage high school students. This was

t of Florida West Palm Beach, Florida 33401 Re: Jeffrey E. Epstein Dear Messrs. TELEPHONC FACSIMILE As

t of Florida West Palm Beach, Florida 33401 Re: Jeffrey E. Epstein Dear Messrs. TELEPHONC FACSIMILE As y

age 4 proceeds of specified unlawful activity,' or (c) `to avoid a trenchetion reporting requirement under State or Federal law"'. United States v. Puche, 350 F.3d 1137 (11th Cir. 2003);5 see also United States v. Arditti, 955 F.2d 331 (5th Cir.), reh's denied cert. denied 506 U.S. 998 (1992), cert.

00 South Australian Avenue, Suite 400 West Palm Beach, Florida 33401 Dear and Re: Jeffrey E Epstein and MIS ASS As you are aware, we represent Jeffrey E. Epstein in connection with your ongoing investigation. We write to you in advance of our June 26, 2007, meeting to address some of the concerns that have b

ance unless force is involved, the vice must be under 16 years old for a prosecution to lie. 3 We understand the Office has taken the view that Mr. Epstein targeted underage high school students. This vra absolutely not the case and we will be prepared to discuss at our meeting the objective evidence de

0 West Palm Beach, Florida 33401 Dear and Re: Jeffrey E Epstein and MIS ASS As you are aware, we repre

ein and MIS ASS As you are aware, we represent Jeffrey E. Epstein in connection with your ongoing investig

We understand the Office has taken the view that Mr. Epstein targeted underage high school students. This vra

Page 4 proceeds of specified unlawful activity,' or (c) `to avoid a transaction reporting requirement under State or Federal law'. United States v. Puche, 350 F.3d 1137 (11th Cir. 2003);5 see also United States v. Arditti, 955 F.2d 331 (5'h Cir.), reh'g denied, cert. denied 506 U.S. 998 (1992), cert.

orney The United States Attorney's Office Southern District of Florida 500 South Australian Avenue, Suite 400 West Palm Beach, Florida 33401 Re: Jeffrey E. Epstein Dear Messrs. Sloman, Menchel and Lourie and Ms. Villafana: LLLLL .R3Nt .2o2I 7370400 FACSIMILE 221/066102 As you are aware, we represent Jeffre

sent I Jeffrey Epstein, the target of a pending Grand Jury investigation. Prior to the initiation of this federal investigation, I represented Mr. Epstein on a Palm Beach Florida State Attorney's Office investigation and subsequently an Information, the factual basis of which is identical to, and gave

e, Suite 400 West Palm Beach, Florida 33401 Re: Jeffrey E. Epstein Dear Messrs. Sloman, Menchel and Lourie

tion of this federal investigation, I represented Mr. Epstein on a Palm Beach Florida State Attorney's Office

e, Suite 400 West Palm Beach, Florida 33401 Re: Jeffrey E. Epstein Dear Messrs. Sloman, Menchel and Lourie

Int:our, P.G I proceeds of specified unlawful activity,' or ) 'to avoid araction reporting requirement under State orf ederal law"'. United States Puche, 350 3d 1137 (11" Cir. 2003);' see also United States I Arditti, 955'.2d 331 (5° Cir.), reh'g denied cert. denied 506 U.S. 998 (1992), cert. denie

orrespondence from the United States Department of Justice Child Exploitation and Obscenity Section ("CEOS") regarding the federal investigation of Jeffrey Epstein by the United States Attorney's Office for the Southern District of Florida ("USAO"),I I will refrain from recounting Mr. Epstein's arguments in det

igation of Jeffrey Epstein by the United States Attorney's Office for the Southern District of Florida ("USAO"),I I will refrain from recounting Mr. Epstein's arguments in detail here, but, rather, will highlight salient points responsive to the CEOS letter. In particular, I write from a background well

Florida ("USAO"),I I will refrain from recounting Mr. Epstein's arguments in detail here, but, rather, will hi

by Ms. , testified in her federal sworn interview that Ms. told her to lie to Epstein. agc Tr. at 8 ("she just said make sure you're 18 because Jeffrey doesn't want an underage girls') (emphasis added). Ms. testimon strongly suggests that Ms. lied to Mr. Epstein about her own age as well. Ms. als

hem in his house if they were under the age of 18. ss& United States v. Kennard, 472 F.3d 851, 857-858 (I 1th Cir. 2006), quoting, United States v. Puche 350 F.3d 1137, 1149 (111° Cir. 2003) (An instruction on deliberate ignorance is appropriate only if it is shown [among other things] ... that the de

orrespondence from the United States Department of Justice Child Exploitation and Obscenity Section ("CEOS") regarding the federal investigation of Jeffrey Epstein by the United States Attorney's Office for the Southern District of Florida ("USAO"),I I will refrain from recounting Mr. Epstein's arguments in det

igation of Jeffrey Epstein by the United States Attorney's Office for the Southern District of Florida ("USAO"),I I will refrain from recounting Mr. Epstein's arguments in detail here, but, rather, will highlight salient points responsive to the CEOS letter. In particular, I write from a background well

by Ms. , testified in her federal sworn interview that Ms. told her to lie to Epstein. agg Tr. at 8 ("she just said make sure you're 18 because Jeffrey doesn't want an underage girls') (emphasis added). Ms. testimon strongly suggests that Ms. lied to Mr. Epstein about her own age as well. Ms. als

Florida ("USAO"),I I will refrain from recounting Mr. Epstein's arguments in detail here, but, rather, will hi

them in his house if they were under the age of 18. ss& United States v. Kennard, 472 F.3d 851, 857-858 (11th Cir. 2006), quoting, United States v. Puche 350 F.3d 1137, 1149 (111° Cir. 2003) (An instruction on deliberate ignorance is appropriate only if it is shown [among other things] ... that the de

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

et them in his house if they were under the age of 18. See United States v. Kennard, 472 F.3d 851, 857-858 (11" Cir. 2006), quoting, United States v. Puche, 350 F.3d 1137, 1149 (11™ Cir. 2003) (An instruction on deliberate ignorance is appropriate only if it is shown [among other things] . . . that the d