Epstein Secrets

fails to demonstrate that the Government theory supports what at its essence is a federalization of underage prostitution (see Villafana letter to Lefkowitz of December 13, 2007 at pg 4, par I). This is compellingly so for several reasons: EFTA00605397 KIRKLAND & ELLIS LLP Honorable R. Alexander Acos

etermination based on the evidence. EFTA00605401 KIRKLAND &ELLIS LLP Honorable R. Alexander Acosta December 17, 2007 Page 18 Kenneth W. Starr Jay P. Lefkowitz cc: Jeffrey H. Sloman, First Assistant U.S. Attorney EFTA00605402

hat a similar policy applies, or upon the speculation that, if the legislature had thought of it, very likely broader words would have been used... McBoyle v. U.S., 283 U.S. 25, 27 (1931) (Justice Holmes). There could be no federal common law crimes because criminal law has traditionally been the provin

ll and fair review of the facts here is critical to this analysis. Yet, it is clear that CEOS did not conduct such a review. In his recent letter to Jay Leflcowitz, First Assistant United States Attorney ("FAUSA") confirmed our understanding that the USAO was to have "facilitated" an "independent de novo revi

eventually conceded that only "1 is definitely under 18 still, and I think there is another minor." See Tab 25, September 23, 2007 Email from,. to J. Lefkowitz (emphasis added). 19. The next day, retreated from the number "40," stating that she had now "compiled a list of 34 confirmed minor victbns with

ill understand, of what the law intends to do if a certain line is passed.'" Arthur Andersen LLP v. United States, 544 U.S. 696, 703 (2005) (quoting McBoyle v. United States, 283 U.S. 25, 27 (1931)) (citation omitted). Two recent Supreme Court decisions dramatically underscore these principles and help

ve of the $526,466 already paid by Mr. Epstein - meet the criteria set forth by the NPA. We assure you that both Mr. Epstein's prior civil counsel, Jay Lefkowitz, who, with you, was a primary negotiator of the NPA language, and Mr. Critton, each strongly believe that significant amounts of the fees and costs

that both Mr. Epstein's prior civil counsel, Jay Lefkowitz, who, with you, was a primary negotiator of the N

o be interpreted in favor of the defendants subjected to them. See United States I . Gradwell, 243 U.S. 476, 485, 37 5.O. 407, 61 L.Ed. 857 (1917); McBoyle . United States, 283 U.S. 25, 27, 51 S.Ct. 340, 75 L.Ed. 816 (1931); United States'. Bass, 404 U.S. 336, 347-349, 92 S.Ct. 515, 30 L.Ed.2d 488 (197

will understand, of what the law intends to do if a certain line is passed.”” Arthur Andersen LLP v. United States, 544 U.S. 696, 703 (2005) (quoting McBoyle v. United States, 283 USS. 25, 27 (1931)) (citation omitted), Two recent Supreme Court decisions dramatically underscore these principles and help t

See Tab 37, February 27, 2008 Email from J. Sloman. Again, that claim was utterly false; Mr. Thomas’s contemporaneous hand-written notes, reviewed by Jay Lefkowitz, confirm that the USAO had violated settled Department policy and ethical rules by providing case-specific information about the Department’s legal t