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

"mere solicitation;" it must be more than an offer or the providing of an opportunity to engage in prohibited conduct. See, e.g,. United States v. Sanchez-Berrios, 424 F.3d 65, 76-77 (1" Cir. 2005); United States v. Brown, 43 F.3d 618, 625 (I1th Cu. 1995). The government cannot fairly, or consistent with the

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

"mere solicitation;" it must be more than an offer or the providing of an opportunity to engage in prohibited conduct. See, e.g,. United States v. Sanchez-Berrios, 424 F.3d 65, 76-77 (ls' Cir. 2005); United States v. Brown, 43 F.3d 618, 625 (11th Cir. 1995). The government cannot fairly, or consistent with th

were over 18, some were under, and the identity of a given masseuse on a given day depended entirely on who was available or who was brought to Mr. Epstein home, unsolicited, by a friend. There was, in short, no deliberate effort to target underage girls; to the extent any underage girls visited Mr. Ep

tirely on who was available or who was brought to Mr. Epstein home, unsolicited, by a friend. There was, in sh

hat each has brought a civil lawsuit against Mr. Epstein, with Ms. and her family seeking $50 million from Mr. Epstein, their testimony against Mr. Epstem is per se suspect. The lawyer representing the "victims" made a public statement conceding that they had lied about their ages and then dismissed t

ED STATES DEPARTMENT OF JUSTICE IN THE MATTER OF JEFFREY E. EPSTEIN This submission addresses (i) whether e

mes such that Federal jurisdiction is necessary."). EFTA00225908 • • • SUBMISSION TO THE UNITED STATES DEPARTMENT OF JUSTICE IN THE MATTER OF JEFFREY E. EPSTEIN This submission addresses (i) whether existing federal statutes, 18 U.S.C. §§ 2422(b), 1591 and 2423, apply to the conduct at issue; and (ii) wheth

ED STATES DEPARTMENT OF JUSTICE IN THE MATTER OF JEFFREY E. EPSTEIN This submission addresses (i) whether ex

e creation of opportunities to commit an offense errises inducement, even if it creates a risk that an offense will occur. See, e.g., United States Sanchez-Berrios, 424 F.3d 65, 76-77 (1st Cir. 2005), cert. denied, 546 U.S. 1125 (2006). The Eleventh Circuit has stated in entrapment cases that government induce