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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
tion Agreement. 21. His attorneys asked to "please do whatever you can to keep this from limit public." See Tab 27, September 24, 2007 Email from J. Leficowitz to,. 22. -replied that she had "forwarded your message only to Alex [Acosta], [ , and I don't anticipate it going any further than that." Id.
August 4, 2009 VIA ELECTRONIC MAIL Spencer T. Kuvin, Esq. Leopold—Kuvin, P.A. 2925 PGA Boulevard Suite 200 Palm Beach Gardens, FL 33410 Re: Jeffrey Epstein/B.B. — Requested Disclosure of Non-Prosecution Agreement Dear Mr. Kuvin: Thank you for your letter regarding the disclosure of the Non-Prosecution Agree
ter giving notice of breach. I respectfully submit that the Motion to Dismiss that is referenced therein did not constitute a willful breach of Mr. Epstein's obligations under the non-prosecution agreement. Mr. Epstein's counsel unanimously determined that the filing of this Motion to Dismiss was not a
tatement [DE 29] dated May 26, 2009. Counsel for Defendant EPSTEIN Certificate of Service I HEREBY CERTIFY that a
, Suite 400 West Palm Beach, Florida 33401 Re: Jeffrey Epstein Dear Ms. Villafana, M www.kirkland.com
d therein did not constitute a willful breach of Mr. Epstein's obligations under the non-prosecution agreement
tion against Jeffrey Epstein styled B.B.I. Jeffi-ey Epstein, case no.: 502008CA037319 MB AB. We are hereby r
ovisions of the NPA. We informed the USAO of this request the very next day in a letter to Mr. Acosta. See Exhibit 3, November 29, 2007 Letter from J. Leficowitz to U.S. Attorney Acosta at 4. • In a December 4, 2007 letter, Mr. Acosta stated that he supported the defense's appeal to Washington. See Exhibit
nt to the victims in this case is clear. In 2007, the FBI determined that both Jane Doe No. I and Jane Doe No. 2 were victims of sexual assaults by Epstein while they were minors beginning when they were approximately fourteen years of age and approximately thirteen years of age respectively. These sexu
of Epstein's sex offenses in Federal Court — Jane Doe No. 1, Jane Doe No. 2, and a victim I will refer to as "S.R." and "M.J.", and other victims of Jeffrey Epstein's abuse as well. If further information is disclosed about this case, that will not discourage them from providing information, but rather will encou
he word "Epstein," " "Morrison," "Visoki," "Rogers," "Hammond," Roxburgh,' r afana, " "Florida SS Foundation," "Starr," "Black," "Goldberger," "Jeffrey," "Australian,"' "Sanchez," "358 El Brillo Way" appears and which are connected to or related to Jeffrey Epstein, Jack Goldberger, or the Jeffrey
t's desire that federal charges be filed against defendant Epstein. In particular, I wrote on behalf of my clients:
riminal prosecution commensurate with the crimes Mr. Epstein has committed, and we further urge you to take th
ich involves "File folder entitled '12/05/07 Starr to Acosta' containing drafts of 11/30/07 letters from A. Acost to K. Starr and from J. Sloman to J. Leficowitz re performance and victim notification with handwritten notes and edits by A. Marie Villafafia." This information goes very directly to the issues i
C TojCall Write, Dimctly: www.kIrkland.com June 19, 2009 VIA FEDERAL EXPRESS United States Attorney's Office Southern District of Florida Re: Jeffrey Epstein Dear Facsimile. We prepared this answer in response to your letter dated June 15, 2009 and before receiving your follow up letter of June 17, 200
nt first intervened in what was originally a matter investigated and charged by state prosecutorial authorities. It has been almost a year since Mr. Epstein pleaded guilty in state court and began serving his sentence in county jail, pursuant to the terms and as a direct result of the federal Non-Prosec
orney's Office Southern District of Florida Re: Jeffrey Epstein Dear Facsimile. We prepared this answe
rial authorities. It has been almost a year since Mr. Epstein pleaded guilty in state court and began serving
several objections to the suggested modification in my letter to Mr. Acosta, dated December 21, 2007. See Exhibit 21, December 21, 2007 Letter from J. Leficowitz to U.S. Attorney Acosta. I personally became aware of the inclusion of that language on Wednesday, August 13, 2008 and discussed the matter with yo
Dear Marie: wwwkirkland.com June 19, 2009 Re: Jeffrey Epstein Facsimile: We prepared this answer in response
Dear Marie: wwwkirkland.com June 19, 2009 Re: Jeffrey Epstein Facsimile: We prepared this answer in r
rial authorities. It has been almost a year since Mr. Epstein pleaded guilty in state court and began serving
nt first intervened in what was originally a matter investigated and charged by state prosecutorial authorities. It has been almost a year since Mr. Epstein pleaded guilty in state court and began serving his sentence in county jail, pursuant to the terms and as a direct result of the federal Non-Prosec
several objections to the suggested modification in my letter to Mr. Acosta, dated December 21, 2007. See Exhibit 21, December 21, 2007 Letter from J. Leficowitz to U.S. Attorney Acosta. I personally became aware of the inclusion of that language on Wednesday, August 13, 2008 and discussed the matter with yo
nt first intervened in what was originally a matter investigated and charged by state prosecutorial authorities. It has been almost a year since Mr. Epstein pleaded guilty in state court and began serving his sentence in county jail, pursuant to the terms and as a direct result of the federal Non-Prosec
Dear Marie: vvwkirkland.com June 19, 2009 Re: Jeffrey Epstein Facsimile: We prepared this answer in response
Dear Marie: vvwkirkland.com June 19, 2009 Re: Jeffrey Epstein Facsimile: We prepared this answer in r
rial authorities. It has been almost a year since Mr. Epstein pleaded guilty in state court and began serving
several objections to the suggested modification in my letter to Mr. Acosta, dated December 21, 2007. See Exhibit 21, December 21, 2007 Letter from J. Leficowitz to U.S. Attorney Acosta. I personally became aware of the inclusion of that language on Wednesday, August 13, 2008 and discussed the matter with yo
Entities connected to both Jeffrey Epstein and J. Leficowitz
Leon Black
PERSON
Alan Dershowitz
PERSON
George W. Bush
PERSON
Bradley Edwards
PERSON
United States
LOCATIONJack Goldberger
PERSONSouthern District
LOCATIONJane Doe
PERSON
Department of Justice
ORGANIZATIONMaria Farmer
PERSONMartin Weinberg
PERSON
Kenneth Marra
PERSON
Julie K. Brown
PERSON
Bill Clinton
PERSON
Alexander Acosta
PERSONthe Southern District
LOCATION
A. Marie Villafana
PERSON
Virginia Giuffre
PERSON
Jay Lefkowitz
PERSON
Scarlett Johansson
PERSON