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

ted expansion of federal law to cover conduct that has always been exclusively within the core of state powers. At this point in time, the need for Departmental oversight is critical. We appreciate this opportunity to submit our assessment of the key facts in this case and review of the pertinent federal st

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

ted expansion of federal law to cover conduct that has always been exclusively within the core of state powers. At this point in time, the need for Departmental oversight is critical. We appreciate this opportunity to submit our assessment of the key facts in this case and review of the pertinent federal st

77 everything, but I really do not think that Mr. Epstein is going to engage in serious negotiations until

orking on a deferred [sic] prosecution agreement because it may well be that we cannot reach agreement here.” The defense redline version required Epstein to plead guilty to a federal information charging two misdemeanor counts of attempt to intentionally harass a person to prevent testimony, the pendi

154 The Affirmation read: “I, Jeffrey E. Epstein do hereby re-affirm the Non-Prosecution

d victims of state crimes secure civil financial settlements.” 154 The Affirmation read: “I, Jeffrey E. Epstein do hereby re-affirm the Non-Prosecution Agreement and Addendum to same dated October 30, 2007.” 155 Villafaña sent Lefkowitz a five-page letter r

147 Acosta and Villafaña were copied on this email. 148 The Addendum is attached as Exhibit 4 to this Report. 94 D. Epstein Further Delays His Guilty Plea The addendum did not bring the case to conclusion. Instead, the matter entered a new, protracted phase, which inv

154 The Affirmation read: “I, Jeffrey E. Epstein do hereby re-affirm the Non-Prosecution A

rosecution should Epstein renege on his agreement, and she outlined for Acosta and Sloman the steps she proposed to take while Epstein was pursuing Departmental review. Those steps included re-establishing contact with victims, interviewing victims in New York and one victim who lived in a foreign country,

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

ted expansion of federal law to cover conduct that has always been exclusively within the core of state powers. At this point in time, the need for Departmental oversight is critical. We appreciate this opportunity to submit our assessment of the key facts in this case and review of the pertinent federal st

For A Millionaire Sex Abuser,” Huffington Post, Nov. 29, 2018; Julie K. Brown, et al., “Lawmakers issue call for investigation of serial sex abuser Jeffrey Epstein’s plea deal,” Miami Herald, Dec. 6, 2018. 5 Doe v. United States, 359 F. Supp. 3d 1201 (S.D. Fla., Feb. 21, 2019) (Opinion and Order, 9:08-80736-CIV

n by negotiating and executing a federal non-prosecution agreement (NPA). The NPA was intended to end a federal investigation into allegations that Epstein engaged in illegal sexual activity with girls.1 OPR also investigated whether USAO prosecutors committed professional misconduct by failing to con

e Parties Continue to Negotiate Issues concerning the Attorney Representative and Finally Reach Agreement on the NPA Addendum ................91 D. Epstein Further Delays His Guilty Plea .................................................................94 E. Epstein Seeks Departmental Review of the NP

Its 2006–2008 Federal Criminal Investigation of Jeffrey Epstein and Its Interactions with Victims during

me when you were first authorized to investigate Mr. Epstein that the office had concerns about taking this c

Chief] Oosterba[an] to participate by teleconference, thereby intercepting the DC meeting. Thoughts? Acosta told OPR that he had no concern about Departmental “scrutiny of the NPA scheme” and that “[i]f anything,” he was concerned whether the Department might direct the USAO to “drop this case.”96 2. Le

175 Epstein’s state guilty plea.250 As U.S. Attorney, Acosta had the authority to resolve the case in this manner, but OPR concludes that in light of all the s

to represent her “because she was unable to get anyone from the [USAO] to tell her what was actually going on with the federal criminal case against Jeffrey Epstein.”347 Villafaña told OPR that Wild did not contact her directly and she was not aware of 344 In

] OPR’s conclusion that deferring prosecution of Jeffrey Epstein to the State Attorney rather than proceed

parents finding out about their involvement with Mr. Epstein. Additionally,

uns for the first tune Feb 19 - Villafada completes third update 10 prosecution memorandum Feb 28 - USAO nmifies DOJ Civli Rights Division that Epstem investigation is ongoing Additional Key Dates Dec 17.2010 - DOJ Office of Legal Counsel issues opinion regarding CVRA Oct 20 I I - DOJ revises

ent had the “right” to address Epstein’s concerns. He told OPR that because the USAO is part of the Department of Justice, if a defendant asks for Departmental review, it would be “unseemly” to object. During his OPR interview, Sloman described Acosta as very process-oriented, which he attributed to Acosta

area of crimes against children? 6 A Yes, I have. 7 Q As part of your employment with the FBI have 8 you been involved in an investigation of Jeffrey 9 Epstein? 10 A Yes, I have. 11 Q And can you tell us who Jeffrey Epstein is? 12 A Jeffrey Epstein is an investment advisor who 13 has a part-time r

ening about going the next day. We do have on phone records two calls that were placed. One was placed to cell phone, and the other was placed to Jef rey Epstein's residence the night of February 5. The next dayais contacted a couple of times before Arrives. Each time prior to ill" eing contacted by... a

a ormal grant of use immunity or Ms. Ross. I do so here. As I indicated to you when we conversed last week, Ms. Ross is no longer employed by Mr. Epstein, but has read much of what can be found on the Internet about the investigation of Mr. Epstein. From that review, she is aware that the police co

throughout I'll refer to her as the blonde lady, if 24 that's okay. was unable to recall her name. So 25 is on the phone with the assistant for Jeffrey •••••••••11,6 EFTA00226459 Page 7 1 Epstein. 2 IIIMEIverheareon the phone 3 describing describing to the lady on 4 the phone. So when

sed last week, Ms. Ross is no longer employed by Mr. Epstein, but has read much of what can be found on the I

pervisory responsibility over the subject matter, or his/her designee, when: 1. Prior consultation or approval would be required by a statute or by Departmental policy for a declination of prosecution or dismissal of a charge with regard to which the agreement is to be made; or 2. The person is: a. A high-

2006 9:30 am YOU ARE AI SO COMMANDED to bring with you the following document(s) or object(s): Any and all records related to your employment with Jeffrey Epstein, including but not limited to paystubs, W-2 forms, correspondence, employment applications, and employment reviews. Any and all information regardi

giiiiiIIIIIite channels for a use immunity for I do so here. As I indicated to you when we conversed last week, Ms. is no longer employed by Mr. Epstein, but has read much o w at can be found on the Internet about the investigation of Mr. Epstein. From that review, she is aware that the police con

y and all records related to your employment with Jeffrey Epstein, including but not limited to paystubs,

nversed last week, Ms. is no longer employed by Mr. Epstein, but has read much o w at can be found on the In

pervisory responsibility over the subject matter, or his/her designee, when: 1. Prior consultation or approval would be required by a statute or by Departmental policy for a declination of prosecution or dismissal of a charge with regard to which the agreement is to be made; or 2. The person is: a. A high-

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

nted expansion of federal law to cover conduct that has always been exclusively within the core of state powers. At this point in time, the need for Departmental oversight is critical. We appreciate this opportunity to submit our assessment of the key facts in this case and review of the pertinent federal stat

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,

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

ted expansion of federal law to cover conduct that has always been exclusively within the core of state powers. At this point in time, the need for Departmental oversight is critical. We appreciate this opportunity to submit our assessment of the key facts in this case and review of the pertinent federal st

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