Epstein Secrets

KIRKLAND & ELLIS LLP Response to Letter by FAUSA MI Dated May 19, 2008 In a May 19 2008 letter to Jay Lefkowitz (See Tab 1), SDFL First Assistant U.S. Attorney Jeffrey I= provided what purported to be a summ of the events that have occurred during the inves

ot really up to speed on the facts" o CEOS' review was not de novo: ■ B letter dated May 15, 2008 (four days before Mr. letter), Mr. advised Mr. Lefkowitz that CEOS reviewed the matter only for abuse of discretion: Mize question we sought to answer was whether U.S. Attorney Acosta would abuse his dis

on Agreement places identified individuals in a far better position than they would be in if Mr. Epstein were convicted at trial. 9. ASSIGNMENT OF RIGHT TO SELECT LEGAL REPRESENTATIVE. Mr. Letter: • "Prior to any issues arising concerning the implementation of the 2255 provision, the SDFL unilaterally agreed to a

KIRKLAND & ELLIS LLP Response to Letter by FAUSA MI Dated May 19, 2008 In a Ma 19 2008 letter to Jay Lefkowitz (See Tab 1), SDFL First Assistant U.S. Attorney provided what purported to be a summ of the events that have occurred during the investigation of

to speed on the facts" o CEOS' review was not de novo: • By letter dated May 15, 2008 (four days before Mr. letter), Mr. Oosterbaan advised Mr. Lefkowitz that CEOS reviewed the matter only for abuse of discretion: Mize question we sought to answer was whether U.S. Attorney Acosta would abuse his dis

on Agreement places identified individuals in a far better position than they would be in if Mr. Epstein were convicted at trial. 9. ASSIGNMENT OF RIGHT TO SELECT LEGAL REPRESENTATIVE. Mr. Letter: • "Prior to any issues arising concerning the implementation of the 2255 provision, the SDFL unilaterally agreed to a

KIRKLAND & ELLIS LLP Response to Letter by FAUSA Dated May 19, 2008 In a May 19 2008 letter to Jay Lefkowitz (Sec Tab 1), SDFL First Assistant U.S. Attorney Jeffrey MI provided what purported to be a summ of the events that have occurred during the inves

not really up to speed on the facts" o CEOS' review was not de novo: By letter dated May 15, 2008 (four days before Mr. letter), Mr. advised Mr. Lefkowitz that CEOS reviewed the matter only for abuse of discretion: /T/he question we sought to answer was whether U.S. Attorney Acosta would abuse his di

on Agreement places identified individuals in a far better position than they would be in if Mr. Epstein were convicted at trial. 9. ASSIGNMENT OF RIGHT TO SELECT LEGAL REPRESENTATIVE. Mr. Sloman's Letter: • "Prior to any issues arising concerning the implementation of the 2255 provision, the SDFL unilaterally ag

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

on Agreement places identified individuals in a far better position than they would be in if Mr. Epstein were convicted at trial. 9. ASSIGNMENT OF RIGHT TO SELECT LEGAL REPRESENTATIVE. Letter: • "Prior to any issues arising concerning the implementation of the 2255 provision, the SDFL unilaterally agreed to assign

avene the government's commitment to take no position regarding potential claims of government witnesses. See Tab 39, November 28, 2008 Email from J. Lefkowitz to J. Sloman. o The letter cited to an inapplicable statute (the Justice for All Act of 2004) as its justification for being sent. Id. AUSA Acosta

hearing." 2 RFP MIA 000432 EFTA00225659 KIRKLAND & ELLIS LLP Response to Letter by FAUSA Sloman Dated May 19, 2008 In a May 19, 2008 letter to Jay Lelkowitz (See Tab I), SDFL First Assistant U.S. Attorney Jeffrey Sloman provided what purported to be a summary of the events that have occurred during the

on Agreement places identified individuals in a far better position than they would be in if Mr. Epstein were convicted at trial. 9. ASSIGNMENT OF RIGHT TO SELECT LEGAL REPRESENTATIVE. Mr. Sloman's Letter: • "Prior to any issues arising concerning the implementation of the 2255 provision, the SDFL unilaterally agr