Epstein Secrets

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

ion of the Petite Policy, and an appendix, which includes significant documentary evidence including testimony by witnesses that was obtained after the Deferred Prosecution Agreement was signed. For the reasons we discuss in the submission, we do not believe this is an appropriate case for federal prosecution. I want to call you

lolkoontz. P C TO CIIISMet nWet.ily (=I 446 4670 litlkowilzaektinalid cam VIA FACSIMILE (561) 820-8777 scow t01klan0 cant August IR. 2008 Re: Jeffrey Epsicin lkar Marie: Fac,Anisle (212) 446.4100 I write in response to your letter dattxl August IS. 2008 regarding the civil restitution pinion of the De

December 19.2007 letter. the unorthodox use of a civil restitution statute in a federal plea agreement. which resulted in state charges against Mr. Epstein. has caused several miscommunications with respect to the implementation of the terms of that Agreement. In order to avoid any further miscommunica

he contact information of the selected attorney representative. We object to the inclusion of additional information about the investigation of Mr. F.pstein, the terms of the Agreement other than paragraphs 7-10. and the identity of other identified individuals. Third. as you are aware. the Addendum req

20-8777 scow t01klan0 cant August IR. 2008 Re: Jeffrey Epsicin lkar Marie: Fac,Anisle (212) 446.4100

greement. which resulted in state charges against Mr. Epstein. has caused several miscommunications with respe

psicin lkar Marie: Fac,Anisle (212) 446.4100 I write in response to your letter dattxl August IS. 2008 regarding the civil restitution pinion of the Deferred Prosecution Agreement (the "Agreement- ). Thank you Air confirming our position that the December modification proposal is not part of the Agreement. As expressed by U.S

tuted States Attorney's Othce Southern District of Florida 500 South Australian Avenue, Suite 400 West Palm Beach, Florida 33401 Dear Messrs Re: Jeffrey E. Epstein • and Ms.I=M: As you are aware, we represent Jeffrey E. Epstein in connection with your ongoing investigation. We write to you in advance of our Jun

ance unless force is involved, the victim must be under 16 years old for a prosecution to lie. We understand the Office has taken the view that Mr. Epstein targeted underage high school students. This was absolutely not the case and we will be prepared to discuss at our meeting the objective evidence de

West Palm Beach, Florida 33401 Dear Messrs Re: Jeffrey E. Epstein • and Ms.I=M: As you are aware, we rep

West Palm Beach, Florida 33401 Dear Messrs Re: Jeffrey E. Epstein • and Ms.I=M: As you are aware, we repr

We understand the Office has taken the view that Mr. Epstein targeted underage high school students. This was

sterday. 'write to you now to supplement our discussion. As you know, I feel strongly that the involvement of the federal government—culminating in the Deferred Prosecution Agreement—runs afoul of fundamental principles of federalism, the well-established Petite Policy, and issues of paramount importance with respect to the admi

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

fallen into this manifest legal error.22 In addition, federal prosecutors insisted that they dictate every detail of the State sentence pursuant to the Deferred Prosecution Agreement. Once again, this was done without any coordination with the State. Federal prosecutors went so far as to demand a restriction on the judge not to

I R, 2008 United States Attorney's Office Southern District of Florida 500 South Australian Avenue, Suite 400 West Palm Beach, Florida 33401 Re: Jeffrey Epstein Dear Marie: Fauzintikt: I write in response to your letter dated August 15. 2008 regarding the civil restitution portion of the Deferred Prosecut

lete any of the names on the list provided to Mi..Epstein's counsel, you do not confirm that the prior list

4 15:19 11:19,24 1:17 2:10,11 moment 13:24 hur 3:10 Jack 2:13 Lauderdale 15:16 months H Hefei° 4:24 2:2 4:5 2:14,21 13:20,21 10:10 Jeffrey leave morning I half 1.11,17 3:4 8:14 3:20,21 idea 13:20 14:21 4:6 let's motion handed 5:16 JR 8:6 11:11 4:7 6:2 7:6 5:13 9:1 imme

no.* CRDCOAL STATE or FLORIDA, Plaintiff, vs. JE/OVEY Eft:EYE, Defendant. rrocuormos NEW BEFORE

greement, which resulted in state charges against Mr. Epstein. has caused several miscommunications with respe

Re: Jeffrey Epstein Dear Marie: Fauzintikt: I write in response to your letter dated August 15. 2008 regarding the civil restitution portion of the Deferred Prosecution Agreement (the "Agreement"). Thank you for confirming our position that the December modification proposal is not part of the Agreement. As expressed by U.S.

R, 2008 United States Attorney's Office Southern District of Florida 501) South Australian Avenue. Suite 400 West Palm Beach, Florida 33401 .Re: Jeffrey Epstein Dear= I write in response to your letter dated August 15. 2008 regarding the civil restitution Tonic', of the Deferred Prosecution Agreement (the

cember 19. 2007 letter, the unorthodox use of a civil restitution 'statute in a federal plea agroenient, which resulted in state charges against Mr. Epstein, has caused several miscommunications with respect to the implementation of the terms of that Agreement. In order to avoid any further miscommunica

. Suite 400 West Palm Beach, Florida 33401 .Re: Jeffrey Epstein Dear= I write in response to your lette

roenient, which resulted in state charges against Mr. Epstein, has caused several miscommunications with respe

ach, Florida 33401 .Re: Jeffrey Epstein Dear= I write in response to your letter dated August 15. 2008 regarding the civil restitution Tonic', of the Deferred Prosecution Agreement (the "Agreement."). Thank you for continuing 'our .ptisit ion that the DeCenther modification proposal is not putt of the Agreement. As expresSed b

ViIlalana United States Attorney's Office Southern District of Florida MX) South Australian Avenue. Suite 400 West Palm Beach, Florida 33401 Re: Jeffrey Epstein Dear Marie: a rcsmokt: )14$.4900 1 write in response to your letter dated August 15. 2008 regarding the civil restitution portion of the Deferre

December 19.2007 letter, the unorthodox use of a civil restitution 'statute in a federal plea agreement, which resulted in state charges against Mr. Epstein. has caused several miscommunications with respect to the implementation of the terms of that Agreement. in order to avoid any further miscommunica

e. Suite 400 West Palm Beach, Florida 33401 Re: Jeffrey Epstein Dear Marie: a rcsmokt: )14$.4900 1 wr

greement, which resulted in state charges against Mr. Epstein. has caused several miscommunications with respe

rey Epstein Dear Marie: a rcsmokt: )14$.4900 1 write in response to your letter dated August 15. 2008 regarding the civil restitution portion of the Deferred Prosecution Agreement (the "Agreement"). Thank you for confirming our position that the December modification proposal is not part of the Agreement. As expressed by U.S.

lso agree to be bound by the protective order. Judge Marra stated that the plaintiffs can litigate the issue of further disclosure directly with Mr. Epstein in the context of their civil suits. When I receive the Court's order and a signed protective order. I will provide them to you. A. Mark Vilkilinla

rkland & Ellis LLP Citi ou Center New York, New York 10022.4675 Roy Black, Esq. Black Srebnick Komspan & Stumpf P.A. 201 S. Bisca ne Blvd, Re: Jeffrey Epstein Dear Jay and Roy: Thank you for your response to my earlier e-mail. Our communications with Mr. Black and later with Mr. Lefkowitz were solely'to

omspan & Stumpf P.A. 201 S. Bisca ne Blvd, Re: Jeffrey Epstein Dear Jay and Roy: Thank you for your re

ate the issue of further disclosure directly with Mr. Epstein in the context of their civil suits. When I rece

008 Re: deity Epstein nestrtolu: ) 4A13.4900 I write in response to your letter dated August 15. 2008 regarding the civil restitution portion of the Deferred Prosecution Agreement (the "Agreement"). Thank you for tumlIrmIng our position that ember modification proposal is not port of the Agreement. As expressed by U.S. Attor