Epstein Secrets

h W. Starr JaillAtz Honorable Alice Fisher, Assistant Attorney General , First Assistant U.S. Attorney fL 003 EFTA01718525 12/06/07 'THU 15:25 FAX UNITED STATES ATTORNEY'S OFFICE SOUTHERN DISTRICT OF FLORIDA TRANSMISSION OK TX/RX NO CONNECTION TEL SUBADDRESS CONNECTION ID ST. TIME USAGE T PCS. RESUL

rc approximately two dozen Eleventh Circuit cases involving prosecutions under § 2422(b), most of which involve this prototypical fact pattern. See, e.g„ United States v. Morton. 364 F3d 1300 (11th Cir. 2004), vacated for further consideration in light stf Booker, 125 S. Ct. 1338 (2006), opinion reinstated by, 144

as a myriad of other federal crimes, and worked closely with law enforcement officials at the local and state levels. From 1973 through 1987, I was a United States District Judge for the District of New Jersey and presided over many criminal trials and proceedings. In 1979 I was selected by the United States D

seeking to persuade or induce someone to engage in activity that would constitute a crime. See Richard A. Posner & Katharine B. Silbaug, A Guide to Americas Sex Laws 44 (Univ. of Chi. Press 1998). Accordingly, to violate § 2422(b), an actor must know that he is trying to persuade not only someone under

dant believes he is interacting with an adult, he is not guilty of the federal crime even if he is dealing with a minor pretending to be a grown-up. Sec United States v. Thomas 410 F.3d 1235 (le Cir. 2005). Mr. Epstein did not use any facility of interstate commerce to do the forbidden act - to persuade, entice,

ls. Sincerely, EFTA01718518 T-1186 p °MAO F-STS Dec-07-6T 04: Om Fr am-Fail er-Whi te Burnett ei DATE: December 7, 2007 Name LAW OFFICES FOWLER WHITE 13URNETT IAMI, • LAMM 3 3 - 2 FAX TriANSMITICAL Faxeshe ex costa NUMBER OF PAGES: 3 (Excluding itansmitial page) FROM: Lilly Ann Sanch

inappropriate. The money laundering statute was designed to be used and has been construed as a "concealment" statute, not a spending statute. See United Stales v. Shepard, 396 F.3d 1116 (10th Cir.), cert. denied, 545 U.S. 1110 (2005); United States v. Hall, 434 F.3d 42 (1st Cir. 2006) (money laundering sta

d terrorism. The type of business contemplated by Congress is one which, for a fee, accepts funds for transfer within or outside the United States. See United States v. Talebnejad 460 F.3d 563, 565 (4th Cir. 2006); United States v. Velastegui, 199 F.3d 590 (2d Cir. 1999). Once the money transmitter receives the

tes v. Holland, 381 F.3d 80 (2d Cir. 2004) (woman running prostitution business convicted for recruiting and transport of prostitutes under § 2421); United States v. Footman, 215 F.3d 145 (1s1 Cir. 2000) (pimp who ran a prostitution ring convicted of violating § 2421). Likewise, in keeping with its purpose and

prostituting underage persons, either by force, fraud, or coercion. These cases bear no relationshijo to the circumstance at issue here. See, e.g., United Slates v. Norris, 188 Fed. Appx. 822 (11 Cir. 2006) (unpublished)(prosecution of several men for conspiracy to hold young women in peonage, and to traffi

hese matters. He is well aware of the ramifications of his past behavior and, accordingly, there is no concem, whatsoever, that he will re-offend. FOWLER WHITE BURNETT P.A. EFTA00310834 Page 2 The following proposal is offered as an assurance to the community that the goals of appropriate punishme

izes travel for the purpose of knowingly engaging in unlawful sexual activity with minors. United States Hayward, 359 F.3d 631, 638 (3d Cir. 2004); United Stales v Tykarsky, 446 F.3d 458, 471 (3d Cir. 2006). This is the highest level of culpability in the four tier hierarchy of culpability that the Model Pen

ternational travel, left untouched the,standard for domestic travel, and thus underscores the strict standard needed for a prosecution in this area. See United States I Clark, 435 F.3d 1100, 1104- 05 (9°' Cir. 2006). 08-80736-CV-MARRA RFP WPB 000735 EFTA00184609 Case 9:08-cv-80736-KAM Document 361-43 Entered o

thern District of Florida February 1, 2007 Page 22 Clause imposes real limitations on Congress's power to criminalize essentially local behavior. See United States' Morrison, 529 U.S. 598 (2000) (Violence Against Women Act exceeded Congressional power under the Commerce Clause or § 5 of the Fourteenth Amendment)

Whoever, using the mail or any facility or means of interstate or foreign commerce, or within the special maritime and territorial jurisdiction of the United States knowingly persuades, induces, entices or coerces any individual who has not attained the age of 18 years, to engage in prostitution or any sexual

ese matters. He is well aware of the ramifications of his past behavior and, accordingly, there is no concern, whatsoever, that he will re-offend. FOWLER WHITE BURNETT P.A. RFP MIA 000053 EFTA00184661 Case 9:08-cv-80736-KAM Document 361-48 Entered on FLSD Docket 02/10/2016 Page 3 of 4 • Page 2 Th

: 18 U.S.C. § 371 18 U.S.C. § 1591(aX1) 18 U.S.C. § 1591(aX2) 18 U.S.C. § 2422(6) 18 U.S.C. § 2423(e) 18 U.S.C. § 2423(d) 18 U.S.C. § 2423(6) UNITED STATES &AMERICA vs. JEFFREY EPSTEIN, and Defendants. A INDICTMENT The Grand Jury charges that: BACKGROUND At all times relevant to this Indictment: 1. Defe

ession. Confidential sod Privileged — Attorney Work Product EXHIBIT B-123 EFTA00224636 Division hi f o the Criminal Division , First Assistant United States Attorney , United States Attorney R. Alexander Acosta as well as various members of the Child Exploitation e i Sectio (CEOS) at the Department of

mate, including but not limited to, eligibility for gain time credit based on standard rules and regulations that apply in the State of Florida. At the United States' request, Epstein agrees to provide an accounting of the gain time he earned during his period of incarceration. 13. The parties anticipate that t

ese matters. He is well aware of the ramifications of his past behavior and, accordingly, there is no concern, whatsoever, that he will re-offend. FOWLER WHITE BURNETT P.A. EFTA00224653 Page 2 The following proposal is offered as an assurance to the community that the goals of appropriate punishme

Edwards, Fistos Et Lehrman, P.L. August 20, 2014 Wifredo A. Ferrer United States Attorney Southern District of Florida RE: Jane Does I and 21 United Stales Case No. : 08-80736-Civ-Marra/Johnson Dear Mr. Ferrer: As you know, we have been in litigation for more than six years on a case under the Crime

ce. She was sexually trafficked and abused by Mr. Epstein (and others at the direction of Mr. Epstein) not only in this jurisdiction but throughout the United Slates and beyond. Unlike Jane Doe #3. Jane Doe #4 was included as a named victim in the NPA. There is no statute of limitations in bringing such claims,

or filing an action to enforce rights under the statute. Accordingly, her motion should be granted. Jane Doe #1 and Jane Doe #2 support the motion. The United States 'insert position xxxxxxxxxxxxxxxx I. CONCLUSION Jane Doe #3 should be allowed to join this action. A proposed order allowing her to join is attache

15 Page 40 of Case 09-34791-RBR Doc 16048 Filed 04/08/11 Page 39 of 39 SERVICE LIST Christopher E. Knight, Esq. Joseph L. Ackerman, Esq. P.A. FOWLER WHITE ETJRNE'IT Jack Alan Goldberger, Esq. A b Goldber er et al. Marc S. Nurik, Esq. Law Offices of Marc S. Nurik Gary M. Farmer, Jr. Farmer,

ATTORNEY FOR JEFFREY EPSTEIN EFTA00225211 U.S. Department nfitist ire United States Attorney Southern District of Florida R ALEXANDER ACOSTA UNITEDSTATES ATTORNEY DELIVERY BY FACSIMILE Lilly Ann Sanchez Fowler White Burnett, PA 1395 Brickell Ave, 14th Floor Miami, FL 33131 Re: Jeffrey Epstein D

leged — Attorney Work Product EXHIBIT B-123 EFTA00225178 Division Andrew Lourie, Chief of the Criminal Division Matthew Menchel', First Assistant United States Attorney Jeffrey H. Sloman', United States Attorney R. Alexander Acosta as well as various members of the Child Exploitation and Obscenity Section (

mate, including but not limited to, eligibility for gain time credit based on standard rules and regulations that apply in the State of Florida. At the United States' request, Epstein agrees to provide an accounting of the gain time he earned during his period of incarceration. 13. The parties anticipate that t

ese matters. He is well aware of the ramifications of his past behavior and, accordingly, there is no concern, whatsoever, that he will re-offend. FOWLER WHITE BURNETT P.A. EFTA00225195 Page 2 The following proposal is offered as an assurance to the community that the goals of appropriate punishme

Of SALE FOR AND IN CONSIDERATION OF S 0 THE UNDERSIGNED OWNER(S) OF THE FULL LEGAL AND BENEFICIAL TITLE OF THE AIRCRAFT DES- CRIBED AS FOLLOWS; UNITED STATE'S lRI 505LS REGISTRATION NUMBER AIRCRAFT MANUFACJURER & AMODEL, 160eing /z/-..51 AIRCRAFT SERIAL No. 20115 DOES THIS \ke jr- DAYOrTOrl 'tg2-

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lls and compromises the presumptive confidentiality of written and often frank discussions between counsel. Epstein intended his communications with United States Attorney's Office to be private and protected by FRE 410. The communications from the U.S. -7- FOWLER WHITE BURNETT, PA. • PHILLIPS Peon - WIRT TOWE

LI IA.: Co-Counsel for Defendant Jeffrey Epstein bat) W:180743 \MTNPIt007-54411cia Sc. PlokrOos order USDC Dor r lipstelaiLA(9/2/10-1539) -10- FOWLER WHIZ IS BURN OTT, P.A. • PHILLIPS POINT - HUT TUMOR, SUITE 901, 777 SOUTH HAGLER INURE, WEST PALM UEACH, FLORIDA 33401 • (561) 802.9044 EFTA00206618

lls and compromises the presumptive confidentiality of written and often frank discussions between counsel. Epstein intended his communications with United States Attorney's Office to be private and protected by FRE 410. The communications from the U.S. -7- FOWLER WHITE BURNETT, PA. • PHILLIPS Peon - WIRT TOWE

lian Avenue, South Suite 1400 West Palm Beach, FL 33401-5012 561-659-8300 561-835-8691 Fax Jagesqabellsouth.net Co-counsel for Jeffiey Epstein FOWLER WRITE BURNETT, P.A. • PIELLIPS POINT • WEST TOWER, SUITS 901,777 SOLITE HAGLER DRIVE, WEST PALM BEACH, FLORIDA 33101 • (561) 802.9041 EFTA00213910

lls and compromises the presumptive confidentiality of written and often frank discussions between counsel. Epstein intended his communications with United States Attorney's Office to be private and protected by FRE 410. The communications from the U.S. -7- FOWLER WHITE BURNETT, PA. • PHILLIPS Peon - WIRT TOWE

Plaintiff Respectfully submitted, /s/ Joseph L Ackerman. Jr. Joseph L Ackerman, Jr. Fla. Bar No. 235954 Lilly Ann Sanchez Fla. Bar No. 195677 FOWLER MUTE BURNETT P.A. 901 Phillips Point West 777 South Flagler Drive West Palm Beach, Florida 33401 Co-Counsel for Defendant Jeffrey Epstein (ast)