Epstein Secrets

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

mounts to solicitation under State law. After all, prostitution, even when the allegations involve minors, is fundamentally a State concern, United States v. Evans, 476 F.3d 1176, n.1 (11th Cir. 2007) (noting that federal law "does not criminalize all acts of prostitution (a vice traditionally governed by

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

its conclusions here and its reasoning on the pages that follow: • Maxwell moves to dismiss counts one, three, five, and six as barred by Jeffrey Epstein's non-prosecution agreement. The Court again concludes, as it did in its April 16, 2021 Opinion & Order, that the agreement does not bind the United

iss counts one, three, five, and six as barred by Jeffrey Epstein's non-prosecution agreement. The Court a

mmary of its conclusions here and its reasoning on the pages that follow: • Maxwell moves to dismiss counts one, three, five, and six as barred by Jeffrey Epstein's non-prosecution agreement. The Court again concludes, as it did in its April 16, 2021 Opinion & Order, that the agreement does not bind the

In its April 16, 2021 Opinion & Order on Maxwell's first set of pretrial motions, the Court held that the non-prosecution agreement ("NPA") between Jeffrey Epstein and the U.S. Attorney's Office for the Southern District of Florida did not bar the charges against Maxwell in the S1 superseding indictment. See U

pare for trial, to prevent surprise, and to interpose a plea of double jeopardy should he be prosecuted a second time for the same offense." United States v. Bortnovsky, 820 F.2d 572, 574 (2d Cir. 1987). "The purpose of a bill of particulars is to supplement the allegations in the indictment when necessar

o. 198 at 27, by Judge Engelmayer in United States v. Randall, 19 Cr. 131 (PAE) (S.D.N.Y. 2020), Dkt. No. 335 at 24-30, and by Judge Cote in United States v. Torres, No. 20-CR-608 (DLC), 2021 WL 1947503, at *7 (S.D.N.Y. May 13, 2021). Their decisions are consistent with the vast majority of courts to cons

l activity without physical force. These opinions may also assist a jury in assessing evidence that some alleged victims repeatedly interacted with Jeffrey Epstein, seemingly voluntarily, even after they suffered abuse. Dr. Rocchio's fourth opinion is similarly relevant to the charges that require proving inten

leged victims repeatedly interacted with Jeffrey Epstein, seemingly voluntarily, even after they suffered

some alleged victims repeatedly interacted with Jeffrey Epstein, seemingly voluntarily, even after they s

NATHAN, District Judge: In June 2020, a grand jury returned a six-count indictment charging Ghislaine Maxwell with facilitating the late financier Jeffrey Epstein's sexual abuse of minor victims from around 1994 to 1997. The Government filed a first (S1) superseding indictment shortly thereafter, which contai

frey Epstein's non-prosecution agreement does not bar this prosecution In September 2007, under investigation by both federal and state authorities, Jeffrey Epstein entered into a non-prosecution agreement ("NPA") with the Office of the United States Attorney for the Southern District of Florida. Dkt. No.

ein's non-prosecution agreement does not bar this prosecution In September 2007, under investigation by both federal and state authorities, Jeffrey Epstein entered into a non-prosecution agreement ("NPA") with the Office of the United States Attorney for the Southern District of Florida. Dkt. No. 142 at

ugh to inform the defendant of the charges and allow the defendant to plead double jeopardy in a later prosecution based on the same events. United States v. Stavrouiakis, 952 F.2d 686, 693 (2d Cir. 1992). "Under this test, an indictment need do little more than to track the language of the statute charge

Jill Shellow Subject: RE: pstein We have attached a proposed disclosure cover letter that is modeled on a letter sent by the Government in United States v. Madonna, 17 Cr. 89 (CS). We have also attached proposed redacted disclosures. As you and I discussed, we offer this as a means to ensure our client'

a call to discuss. Original Message From: Andrew Patel Sent: Frida , December 20, 2019 8:15 AM To: Cc: Andrew Patel Jill Shellow Subject: ,.Epstein ; Don Yannella Please send us a copy of the disclosure that you are considering as to Mr. . Seeing the planned disclosure about our client will h