Epstein Secrets

December I I. 2007 Page 4 the final agreement was very similar to what was proposed by Ms. in her initial draft agreement on July 31. 2007: the United Stales shall provide F.pstein's attorney's with a list of individuals whom it has identified as victims, as defined in IS U.S.C. f 2255. alter Epsicin has

oth offenses. Additionally, for the sake of fairness and candor, we believe the same language contained in your letter to Judge Davis, stating that Itibe United States takes no position as to the validity of any such claim under this statute," should be included in any proposed letter. Sixth, your letter states th

of an enumerated federal crime. This requires Mr. Epstein to in essence admit guilt, though he believes he did not commit the requisite offense. The United States Attorney Manual ("USAM") 9-27.440, Principles of Federal Prosecution, sets forth' clear r,:quirement when' defendant tenders' pica of guilty but sub

fendant is gljugggI in the case in which' victim seeks to assert her statutory rights.") (emphasis added) Since there has been no offense charged in Federal district court in this matter, the identified individuals necessarily do not qualify as "crime victims". In addition, the Attorney General Guidelines furthe

of an enumerated federal crime. This requires Mr. Epstein to in essence admit guilt, though he believes he did not commit the requisite offense. The United States Attorney Manual ("USAM") 9-27.440, Principles of Federal Prosecution, sets forth a clear requirement when a defendant tenders a plea of guilty but s

fendant is charged in the case in which a victim seeks to assert her statutory rights.") (emphasis added) Since there has been no offense charged in Federal district court in this matter, the identified individuals necessarily do not qualify as "crime victims". In addition, the Attorney General Guidelines furthe

that "[w]hether to prosecute and what charge to file or bring before a grand jury are decisions that generally rest in the prosecutor's discretion," United States I. Batchelder, 442 U.S. 114, 124 (1979), and the CVRA explicitly states that "[n]othing in th[e] [Act] shall be construed to impair the prosecutoria

armed as a result of the commission of a Federal 20 EFTA00211737 offense or an offense in the District of Columbia, "if the offense is charged in Federal district court." Thus, if there was no offense charged in Federal district court, then a person could not be a crime victim for purposes of enforcing the ri

ELLIS LLP Jar P. LoAtoWte, P.C. To r W • loft 12 Woo= VIA FACSIMILE (305) 530-6444 Honorable R. Alexander Acosta I links.) States Attorney lJnited States Attorney's Office outhern District of Florida S .9 NE 4th Street Miami. FL 33132 Dear Alex: AND Anmann rosTmiunos Coagroup Cellar 159 East WO

endant is gliargz1 in the case in which a victim seeks to assert her statutory rights.") (emphasis added) Since there has been no offense charged in Federal district court in this matter, the identified individuals necessarily do not qualify as "crime victims". In addition, the Attorney General Guidelines furthe

LLIS 002/006 KIRKLAND & ELLIS LLP / P. Lolkoatt, P.C. To VIA FACSIMILE (305) 530-6444 Honorable R. Alexander Acosta I Thitix.1 States Attorney lJnited States Attorney's Office outhern District of Florida S .9 NE 4th Street Miami. FL 33132 Dear Alex: AND AntiAnn rioninains Cola/cup Cara/ 159 East San

endant is gliargz1 in the case in which a victim seeks to assert her statutory rights.") (emphasis added) Since there has been no offense charged in Federal district court in this matter, the identified individuals necessarily do not qualify as "crime victims". In addition, the Attorney General Guidelines furthe

that "[w]hether to prosecute and what charge to file or bring before a grand jury are decisions that generally rest in the prosecutor's discretion " United States v. Batchelder 442 U.S. 114, 124 (1979), and the CVRA explicitly states that "[n]othing in th[e] [Act] shall be construed to impair the prosecutorial

y and proximately harmed as a result of the commission of a Federal offense or an offense in the District of Columbia, "if the offense is charged in Federal district court." Thus, if there was no offense charged in Federal district court, then a person could not be a crime victim for purposes of enforcing the ri

IRKLANDAELLIS 002/006 KIRKLAND & ELLIS LLP Jar P. Lalkoafte, P.C. To e VIA FACSD411.E Honorable R. Alexander Acosta I links.) States Attorney lJnited States Attorney's Office outhern District of Florida S .9 NE 4th Street Miami. FL 33132 Dear Alex: AND Anmann riormiuroos Calgroup Cantor 159 East Sa

fendant is charged in the case in which a victim seeks to assert her statutory rights.") (emphasis added) Since there has been no offense charged in Federal district court in this mater, the identified individuals necessarily do not qualify as "crime victims". In addition, the Attorney General Guidelines further

of an enumerated federal crime. This requires Mr. Epstein to in essence admit guilt, though he believes he did not commit the requisite offense. The United States Attorney Manual ("USAM") 9-27.440, Principles of Federal Prosecution, sets forth a clear requirement when a defendant tenders a pica of guilty but s

fendant is charted in the case in which a victim seeks to assert her statutory rights.") (emphasis added) Since there has been no offense charged in Federal district court in this matter, the identified individuals necessarily do not qualify as "crime victims". In addition, the Attorney General Guidelines furthe

that "[w]hether to prosecute and what charge to file or bring before a grand jury are decisions that generally rest in the prosecutor's discretion " United States v. Batchelder 442 U.S. 114, 124 (1979), and the CVRA explicitly states that "[n]othing in th[e] [Act] shall be construed to impair the prosecutorial

y and proximately harmed as a result of the commission of a Federal offense or an offense in the District of Columbia, "if the offense is charged in Federal district court." Thus, if there was no offense charged in Federal district court, then a person could not be a crime victim for purposes of enforcing the ri

of an enumerated federal crime. This requires Mr. Epstein to in essence admit guilt, though he believes he did not commit the requisite offense. The United States Attorney Manual ("USAM") 9-27.440, Principles of Federal Prosecution, sets forth a clear requirement when a defendant tenders a plea of guilty but s

fendant is charged in the case in which a victim seeks to assert her statutory rights.") (emphasis added) Since there has been no offense charged in Federal district court in this matter, the identified individuals necessarily do not qualify as "crime victims". In addition, the Attorney General Guidelines furthe