Epstein Secrets

o appear and provide testimony and evidence in accordance with the issued subpoenas at the next meeting of the Grand Jury. Respectfully submitted, R. ALEXANDER ACOSTA UNITED STATES ATTORNEY By: Assistant United States Attorne West Palm Beach, FL 33401 Telephone: Facsimile: CERTIFICATE OF SERVICE I HEREBY

rand Jury. Respectfully submitted, R. ALEXANDER ACOSTA UNITED STATES ATTORNEY By: Assistant United

the appearance of witnesses and production of the requested items. ARGUMENT I. THE UNITED STATES DOES NOT OPPOSE THE MOTION TO INTERVENE, IN PART. The Eleventh Circuit has ruled that a target of a grand jury investigation should be allowed to intervene once the claim of attorney-client privilege between the subpoen

ting of the Grand Jury. Respectfully submitted, R. ALEXANDER ACOSTA EFTA00222989 UNITED STATES ATTORNEY By: 500

rand Jury. Respectfully submitted, R. ALEXANDER ACOSTA EFTA00222989 UNITED STATES ATTORNEY By: 500

the appearance of witnesses and production of the requested items. ARGUMENT I. THE UNITED STATES DOES NOT OPPOSE THE MOTION TO INTERVENE, IN PART. The Eleventh Circuit has ruled that a target of a grand jury investigation should be allowed to intervene once the claim of attorney-client privilege between the subpoen

o appear and provide testimony and evidence in accordance with the issued subpoenas at the next meeting of the Grand Jury. Respectfully submitted, R. ALEXANDER ACOSTA UNITED STATES ATTORNEY By: Assistant United States Attorney Florida Bar No. 0018255 500 South Australian Avenue, Suite 400 CERTIFICATE OF SERVI

rand Jury. Respectfully submitted, R. ALEXANDER ACOSTA UNITED STATES ATTORNEY By: Assistant United St

the appearance of witnesses and production of the requested items. ARGUMENT I. THE UNITED STATES DOES NOT OPPOSE THE MOTION TO INTERVENE, IN PART. The Eleventh Circuit has ruled that a target of a grand jury investigation should be allowed to intervene once the claim of attorney-client privilege between the subpoen

Memorandum SubjectDate Re: Operation Leap Year March 15, 2007 ToFrom R. Alexander Acosta, United States Attorney Jeff Sloman, First Assistant United States Attorney M, Chief, Criminal Division MAUSA, Northern Region Chief, Northern

n Leap Year March 15, 2007 ToFrom R. Alexander Acosta, United States Attorney Jeff Sloman, First Assis

. The statute does not define "facility or means of interstate commerce" or "prostitution." 1. A telephone is a "facility of interstate commerce." The Eleventh Circuit, however, has ruled that evidence of the use of a cellular telephone satisfies the element of using a facility or means of interstate commerce. Unit

Memorandum SubjectDate Re: Operation Leap Year January 31, 2007 ToFrom R. Alexander Acosta, United States Attorney Jeff Sloman. First Assistant United States Attorney er Chief, Criminal Division , MAUSA, Northern Region Chief, Northern

Leap Year January 31, 2007 ToFrom R. Alexander Acosta, United States Attorney Jeff Sloman. First Assis

. The statute does not define "facility or means of interstate commerce" or "prostitution." 1. A telephone is a "facility of interstate commerce." The Eleventh Circuit, however, has ruled that evidence of the use of a cellular telephone satisfies the element of using a facility or means of interstate commerce. Unit

ates respectfully requests that the Application and any Order related to the Application be sealed. Dated: April 16, 2007 Respectfully submitted, R. ALEXANDER ACOSTA ASSISTANT UNITED STA1 ES A ORNEY Florida Bar No. 500 South Australian Ave, Suite 400 West Palm Beach, Florida 33401 Tel: Fax: Case No. 08-8073

rida West Palm Beach, Florida 33401 Attention: Asstetantlinited States Attorney Re: Grand Jury Investigpuion, terfrey Epstein, et al. Dcar Mr. Acosta: Pursuant to the authority vested in me by 18 U.S.C. § 6003(h) and 28 C.P.R., § 0.175(a), I hereby approve ycur request for authority to apply to °

be negated because the Government's communications facilitated "misconduct" by depriving the victims of their rights under the CVRA. (DE 265 at 6). The Eleventh Circuit has recognized that "[t]he crime-fraud exception presents one of the rare and extraordinary circumstances in which 15 EFTA00086459 Case 9:08-cv-

vents. At this time, your ease is under investigation! If anyone is charged in connection with the investigation, you will be notified. Sincerely, R. Alexander Acosta United States Attorney By: cc: Special Agent Nesbitt Kuyrkendall, A. Marie Villafana Assistant United States Attorney EFTA00177308 Case 9:08

, you will be notified. Sincerely, R. Alexander Acosta United States Attorney By: cc: Special Agent

tioner, she would have explained why this proposed disposition did not begin to reflect "the seriousness of the offense" 18 U.S.C. § 3553(aX2)(A). The Eleventh Circuit has instructed that the district courts must make substantial findings before sealing records in cases before it. For instance, in United States I O

ments regarding Epstein were not lost on his attorneys. A December 21, 2007 letter from Jay Lefkowitz, one of Epstein's attorneys, to U.S. Attorney Acosta, devoted two pages examining Jane Doe No. 2's interview testimony on April 24, 2007. Ex. D at 9-15. 4 EFTA00211721 significant because, "[i]t is

bits "parties from deliberately changing positions according to the exigencies of the moment." New Hampshire I. Maine, 532 U.S. 742, 749-50 (2001). The Eleventh Circuit has identified three factors to be considered in determining whether to apply the equitable doctrine: (1) whether there is a clear inconsistency bet

ents regarding Epstein were not lost on his attorneys. A December 21, 2007 letter from Jay Leflcowitz, one of Epstein's attorneys, to U.S. Attorney Acosta, devoted two pages examining Jane Doe No. 2's interview testimony on April 24, 2007. Ex. D at 9-15. 4 EFTA00799828 Case 9:08-cv-80736-KAM Docume

bits "parties from deliberately changing positions according to the exigencies of the moment." New Hampshire v. Maine, 532 U.S. 742, 749-50 (2001). The Eleventh Circuit has identified three factors to be considered in determining whether to apply the equitable doctrine: (1) whether there is a clear inconsistency bet

ments regarding Epstein were not lost on his attorneys. A December 21, 2007 letter from Jay Lefkowitz, one of Epstein's attorneys, to U.S. Attorney Acosta, devoted two pages examining Jane Doe No. 2's interview testimony on April 24, 2007. Ex. D at 9-15. 4 EFTA00591465 Case 9:08-cv-80736-KAM Docume

bits "parties from deliberately changing positions according to the exigencies of the moment." New Hampshire v. Maine, 532 U.S. 742, 749-50 (2001). The Eleventh Circuit has identified three factors to be considered in determining whether to apply the equitable doctrine: (1) whether there is a clear inconsistency bet