Epstein Secrets

ictim of a violation of lenumemtod $04)(1011x of Title l8) and who suffers personal injury as a m utt of such violation ...may sue In any oppropioto United Stales 011trint Court and shall recover the actual damages such person sustains and the cost of the suit, includingii reasonable attorney's fee." toot U

litigant. to contest allegations made against him seem to contradict the principles of justice and fairness that fire embedded in the tenets of the United Slates Attorney's Office. I also assert that on both a principled and practical level. the mere involvement of your Office in the matter with respect to

NETT MIAMI • F00 LAUDERDALE • WraT PALM UfA01 • 5T. PETER5OLMO 3067800201 December 7, 2007 Jeffrey Sloman First Assisiam United States Attorney United Stales Attorney's Office Southern District of Florida Re: Jeffrey Epstein Dear Jeff: 1-(466 P.002/004 F-016 Callnac) 5810 FIALA FouNi0arni nowt 130

d victims. This letter is meant to assist you in performing your duties by providing you with background information regarding the agreement between the United States and Jeffrey Epstein and the duties that the attorney representative will have to perform. The Federal Bureau of Investigation and the U.S. Attorney

e Petitioners have not been attempting to negotiate with the government for more than 30 months. As set forth in the Procedural I Iistory Section of the United States' Opposition to Jane Doe #1 and Jane Doe #2's Motion for Finding of Violations of the Crime Victim Rights Act ("CVRA"), at the last hearing on the Pet

turns out, all those identified except two) had reached the age of majority, and, in fact, no guardian was necessary to represent their interests. Defense Counsel was Falsely Advised That the Non Prosecution Agreement Would Be Kept Confidential. 20. On September 24, Epstein and the USAO executed a Non Prosec

US DeP•Mlilla I tr4 tram Race.” Fodor& AulaSciti Attailnistratien 08-80736-CV-MARRA RFP WPB 001697 EFTA00209876 U.S. Department of Justice United Slates Attorney Southern District of Florida 500 South Australian Ave., Suite 400 West Palm Beach, FL 3340! (361)820-8711 Facsimile: (561)820-8777 May

ta United States Att A. Marie Assistant United States Attorney 08-80736-CV-MARRA RFP WPB 001698 EFTA00209877 05/15/2007 16:57 FAX 5618021787 USA0 WPB FL gaol TX REPORT IX#i TRANSMISSION OK Sals *****Atii************* TX/RX NO 4676 CONNECTION TEL 8358691 SUBADDRESS CONNECTION ID ST.

a result of the federal investigation], or acquittal on the merits shall be a bar to any subsequent federal prosecution for the same act or acts." U.S.A.M. § 9-2.031A (emphasis added). Consistent with that principle, and of particular relevance to this case, the Department itself just recently observed

inding that the defendant had an intent to persuade or to attempt to persuade.' United States I Murrell 368 F.3d 1283, 1287 (11th Cir. 2004) (citing United States'. Bailey, 228 F.3d 637, 638-39 (6th Cir.2000)). Thus, the targeted criminal conduct must occur through the interstate facility, not thereafter, and

turns out, all those identified except two) had reached the age of majority, and, in fact, no guardian was necessary to represent their interests. Defense Counsel was Falsely Advised That the Non Prosecution Agreement Would Be Kept Confidential. 20. On September 24, Epstein and the USAO executed a Non Prosec

ction 2422(b) expressly requires that the crime be committed "knowingly," and that requisite mental element applies as to each element of the crime. United Slates v, XCitement Video, Inc., 513 U.S. 64, 68.69 (1994); United States v. Meek, 366 F.3d 705, 718 (9lh Cir. 2004); United States v. Root, 296 F.3d 1222,

imited to sex trafficking that involves children or is accomplished by force, fraud, or coercion." United States v. Evans 476 F.3d at 1179 n. 1. Sec aho United States v, Sims, 171 Fed. 3505-019 Page 19 of 63 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00003291 EFTA00157673 ALLEN GUTHR

a result of the federal investigation], or acquittal on the merits shall be a bar to any subsequent federal prosecution for the same act or acts." U.S.A.M. § 9-2.031A (emphasis added). Consistent with that principle, and of particular relevance to this case, the Department itself just recently observed

ically underscore these principles and help to highlight why federal prosecution in this case would be improper as a matter of both law and policy. See United States v. Santos, No. 06-1005 (June 2, 2008); Cuellar v. United States, No. 06-1456 (June 2, 2008). Though they both address the interpretation and applica

turns out, all those identified except two) had reached the age of majority, and, in fact, no guardian was necessary to represent their interests. Defense Counsel was Falsely Advised That the Non Prosecution Agreement Would Be Kept Confidential. 20. On September 24, Epstein and the USAO executed a Non Prosec

to undcdakc discussion with the Slate Attomey's Office Ia custom caswpiiiiitim with these procedures. which compliance will be necessary to satisfy the United States' intero.t, pursuant to the Petite policy. We reiterate that this case was at heart a local mutter that was being billy addressed by the state crimi

ugh such misconduct was, as we contend it is, inextricably intertwined with the credibility of the accusations being made against Mr. Epstein by the United States Attorney's Office in Miami (''USAO"). Moreover. CEOS did not assess the terms of the Deferred Prosecution Agreement now in effect, nor did CEOS revi

turns out, all those identified except two) had reached the age of majority, and, in fact, no guardian was necessary to represent their interests. Defense Counsel was Falsely Advised Tbat the Non Prosecution Agreement Would Be Kept Confidential. 20. On September 24, Epstein and the USAO executed a Non Prosec

ial function and useful in the judicial process," thereby qualifying as a "judicial document" for purposes of the first element of the Lugosch test. United States v. Amodeo ("Amodeo 1"), 44 F.3d 141, 145 (2d Cir. 1995). Second, the Court assumes that the common law presumption of access attaches, thereby satis

s Proposed Protective Order included a provision that stated that all discovery produced by the Government "[s]hall be used by the Defendant or her Defense Counsel solely for purposes of the defense of this criminal action, and not for any civil proceeding or any purpose other than the defense of this action."

ials, or that was 16 found in cooperation with outside Agencies that 17 was trying to determent of (Indiscernible 18 *00:34:43), and cause harm to the United 19 States. These kind of guys was put in that 20 unit. 21 MR. : Sure. 22 MR. ruys you wouldn't want in the 23 24 25 1 2 that Epstein preferred not

stein was in that area, primarily, 7 until it closed. 8 MR. : All right. And that's 9 where it says, "Epstein spent most of the day 10 with his Defense Counsel, and was brought down 11 as soon as the Attorney visit opened." So, 12 would that be, like, Monday through Friday, or 13 Monday -- 14 MR. No. T

ial function and useful in the judicial process," thereby qualifying as a "judicial document" for purposes of the first element of the Lugosch test. United States v. Amodeo ("Amodeo I"), 44 F.3d 141, 145 (2d Cir. 1995). Second, the Court assumes that the common law presumption of access attaches, thereby satis

s Proposed Protective Order included a provision that stated that all discovery produced by the Government "[s]hall be used by the Defendant or her Defense Counsel solely for purposes of the defense of this criminal action, and not for any civil proceeding or any purpose other than the defense of this action."

ials, or that was 16 found in cooperation with outside Agencies that 17 was trying to determent of (Indiscernible 18 *00:34:43), and cause harm to the United 19 States. These kind of guys was put in that 20 unit. 21 : Sure. 22 : Guys you wouldn't want in the 23 general population because -- 24 : Yeah. 25 :

te Epstein was in that area, primarily, 7 until it closed. 8 : All right. And that's 9 where it says, "Epstein spent most of the day 10 with his Defense Counsel, and was brought down 11 as soon as the Attorney visit opened." So, 12 would that be, like, Monday through Friday, or 13 Monday -- 14 : No. That'

theMompliance letter. Defense will be paying for his travel/lodging/per diem. Does Sahave DOJ approval from your district to provide testimony in this United States case? Please advise, and thank you for your assistance. I would like to advise the agent this afternoon if possible that he is good to go. Respectf

bject: RE: Subpoena For MM SA Testimony RE USA v. Maxwell FBI) USANYS) Thank you CDC -nd the New York Team. As an update, we received a call from Defense Counsel (issuer of subpoena) and it looks like they in fact will need Miami Sato testify on Thursday, unless it is pushed to Friday for unforeseen circums

ials, or that was 16 found in cooperation with outside Agencies that 17 was trying to determent of (Indiscernible 18 *00:34:43), and cause harm to the United 19 States. These kind of guys was put in that 20 unit. 21 : Sure. 22 : Guys you wouldn't want in the 23 general population because -- 24 : Yeah. 25 :

te Epstein was in that area, primarily, 7 until it closed. 8 : All right. And that's 9 where it says, "Epstein spent most of the day 10 with his Defense Counsel, and was brought down 11 as soon as the Attorney visit opened." So, 12 would that be, like, Monday through Friday, or 13 Monday -- 14 : No. That'