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USAO's conduct in this case. Background I. In March 2005, the Palm Beach Police Department opened a criminal investigation of Palm Beach resident, Jeffrey E. Epstein. The press has widely reported that Mr. Epstein is a close friend of former President Bill Clinton. 2. In July 2006, after an intensive probe, inc
LP SUMMARY OF MISCONDUCT ISSUES IN THE MATTER OF JEFFREY E. EPSTE/N The manner in which federal prosecutor
4/05. fold Detective Keeney that Epstein Did Not Take out Sex Toys. Epstein Pmhahlc Cause Affidavit at 14: see also Police Report (11/10/05) at 49 C'Epstein 'this statement appears nowhere in the transcript of -sworn 21.11/Als interviewed by Oacclivveice. once by telephone. and once in person. The port
without any foundation tie doing so by adding charges of money laundering and violations of a money transmitting business to the investigation. Mr. F.pstein's counsel explained that there could be no basis for these charges since Mr. Epstein did not commit any prerequisite act for a money laundering cha
d & Ellis LLP Joe D. Whitley Alston & Bird I.LP RFP MIA 000477 EFTA00208958 KIRKLAND & ELLIS LLP SUMMARY OF MISCONDUCT ISSUES IN THE MATTER OF JEFFREY E. EPSTE/N The manner in which federal prosecutors have pursued the allegations against Mr. Epstein is highly irregular and warrants full review by the Dep
LP SUMMARY OF MISCONDUCT ISSUES IN THE MATTER OF JEFFREY E. EPSTE/N The manner in which federal prosecutors
ded to review some of the issues and concerns of Mr. Epstein's defense team. Importantly. I appreciate your ag
hing the relevant federal statutes beyond recognition, and that federal involvement in this mutter should be precluded butt on federalism concerns, the Petite Policy, and general principles of prosecutorial disattion, the panics corn • discussions of a possible plea agreement. Around this time, we received an e
ble R. Alexander Acosta United States Attorney United States Attorney's Office Southern District of Florida 99 NE 4111Stnan Miami, FL 33132 Rc Jeffrey Epstein Dear Alex: (TIS) 680.8400 www luiluse0 corn December I I. 2IHY7 Enct:undo (Pin) 880.8500 As we discussed during our telephone conversations on
at this ease is not only extraordinary and unprecedented. ii is deeply and uniquely troubling. the constellation of issues. large and small, renders Jeffreys mutter entirely sal genesis. We say this not lightly. Indeed, as you will glean from our two letters. we are gravely concerned that, in addition to
Mr. Epstein at the sentencing. We bind no basis in law or the Agreement that pmvides the identified individuals with either a right to appear at Mr. E.pstein's plea and sentence or to submit a written statement to he filed by the State Attorney. Here. Mr. " this an.intentena does not put dose alieged "vi
id Not Tame Masseuses Under IS. Indeed, the witness slaleincots demonstrate that Mc opposite is rw hat the many of ‘• • • • VC% and visit‘ r. Epstein's home. Also, there is su canna cvr case, found in the sworn statements of the women themselves, which indicate that, to the extent others were in fac
ge 17 Attorney's Office has a different view of the case and there has been no coordination with state authoritics.6 In addition required that Mr. F.pstein's sentence include a registerahle offense. As you know, requiring sexual offender registration will have a significant impact both immediately and
ms to be able to promptly put this behind them and go ftwwards with their lives. Ilsgivcii the opportunity to opine as to the appropriateness of Mr. Fostein's proposal, in my extensive experience in these types or caws. tbe victims prefer a quick resolution with compensation for damages and will always
ng the relevant federal statutes beyond recognition, and that federal involvement in this matter should he precluded basest on federalism concerns, the Petite Policy, and general principles of prosecutorial discretion. the parties commenced discussions of a possible plea agreement. Around this time. we received a
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
federal prosecutors were taking in order to circumvent its restrictions. Mr. Menchel's articulation of the purported federal interest misrepresents the Petite Policy on two grounds. First, Mr. Menchel's position that the federal interest could not be vindicated in the absence of a jail term for Mr. Epstein is co
aveled from to Palm Beach County, Florida aboard the Gulfstream aircraft owned by Hyperion Air, Inc. (200) On or about August 18, 2005, Defendants JEFFREY EPSTEINS and traveled from to Palm Beach County, Florida aboard the Gulfstream aircraft owned by Hyperion Air, Inc. (201) On or about August 18, 2005, De
9, 2005 Jane Doe #6 JEFFREY EPSTEIN 11111 25 . July 2004 Jane Doe #7 JEFFREY EPSTEIN 26 July 2004 through December 29, 2004 Jane Doe #8 JEFFREY EPSTEL\ I wk. 27 July 2004 through January 31, 2005 Jane Doe #9 • JEFFREY EPSTEIN 44 EFTA01718620 COUNT DATE(S) MINOR(S) INVOLVED DEF
) On or about August 18, 2005, Defendants JEFFREY EPSTEINS and traveled from to Palm Beach County, Florid
pond to your asserted "policy concerns" regarding Mr. Epstein's Non- Prosecution Agreement, which will be addre
ing the relevant federal statutes beyond recognition, and that federal involvement in this matter should be precluded based on federalism concerns. the Petite Policy, and general principles or prosecutorial discretion. the parties commenced discussions an possible pica agreement. Around this time, we received an
Just and Proportional Sanctions for Buyers of Sex with Trafficking Victims, 90 N.Y.U. L. Rev. 626, 663 (2015). IV. Case Study: The Prosecution of Jeffrey Epstein A. Background. 1. State Investigation and Criminal Process. 2. Federal Intervention in the State Process. a. The Failure of Federal Prosecutors to
Amendment Right to be Informed of Criminal Charges" as well as the Fifth Amendment Right to Due Process12. 1. Federal Prosecutors Knowingly Misled Epstein and the Courts. Federal prosecutors failed to disclose to Epstein and the courts the absence of a factual predicate for a prosecution and plea unde
mes, 18 U.S.C. § 2422(b), and the Prosecution of Jeffrey Epstein" I. Introduction In 1996, 18 U.S.C. §
cutors violated the authority of state and local governments, overthrowing principles of comity, contravening the "clear statement rule" as well as the Petite Policy, and undermining a comprehensive state investigation and resolution of the case. As a result of the unwarranted interference of federal prosecutors
Just and Proportional Sanctions for Buyers of Sex with Trafficking Victims, 90 N.Y.U. L. Rev. 626, 663 (2015). IV. Case Study: The Prosecution of Jeffrey Epstein A. Background. 1. State Investigation and Criminal Process. 2. Federal Intervention in the State Process. a. The Failure of Federal Prosecutors t
Amendment Right to be Informed of Criminal Charges" as well as the Fifth Amendment Right to Due Process12. 1. Federal Prosecutors Knowingly Misled Epstein and the Courts. Federal prosecutors failed to disclose to Epstein and the courts the absence of a factual predicate for a prosecution and plea unde
mes, 18 U.S.C. § 2422(b), and the Prosecution of Jeffrey Epstein" I. Introduction In 1996, 18 U.S.C. §
cutors violated the authority of state and local governments, overthrowing principles of comity, contravening the "clear statement rule" as well as the Petite Policy, and undermining a comprehensive state investigation and resolution of the case. As a result of the unwarranted interference of federal prosecutors
Entities connected to both Jeffrey Epstein and the Petite Policy
Leon Black
PERSON
Prince Andrew
PERSON
Joi Ito
PERSON
George Mitchell
PERSON
Alan Dershowitz
PERSON
George W. Bush
PERSON
United States
LOCATION
Stephen Hawking
PERSONJack Goldberger
PERSON
Joe Biden
PERSONJane Doe
PERSON
Department of Justice
ORGANIZATION
Alexander Acosta
PERSONthe Southern District
LOCATION
Wilbur Ross
PERSON
U.S. Virgin Islands
LOCATION
A. Marie Villafana
PERSON
Jay Lefkowitz
PERSONRoy Black
PERSON
Ken Starr
PERSON