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,

04:54pm Froo-Fowler-White Burnett T-866 F.002/004 F-6T6 FOWLERWHITE ATTORNEYS AT LAW BURNETT M'AN'. FORT LAUDBROALLE • WEST PALM BEACH • ST. PETERSBURG December 7, 2007 First Assistant United States Attorney United States Attorney's Office Southern District of Florida West Palm Beach,' Florida 3

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

A00310832 AUGUST 2, 2007 - LILLY TO MENCHEL EFTA00310833 FOWLERWHITE ATTORNEYS AT LAW BURNETT MIAMI • FORT LAUDERDALE • WEST PALM BEACH • ST. PETERSBURG August 2, 2007 Mr. Matthew Menchel Chief, Criminal Division United States Attorney's Office Southern District of Florida 99 NE 4 Street Miami,

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

0736-KAM Document 361-48 Entered on FLSD Docket 02/10/2016 Page 2 of .4 • FOVVLERWHITE W BURNETT MIAMI • FORT LAUDERDALE • WEST PALI/ BEACH • ST. PETERSBURG August 2, 2007 Mr. Matthew Chief, Criminal Division United States Attorney's Office Southern District of Florida 99 NE 4 Street Miami, Florida

: 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

he U.S. Attorney's Office will close their investigations. EFTA00224652 cy g FOWLERWHITE BURNETT MUMM • FORT LAUDERDALE • WEST PALM BEACH • ST. PETERSBURG August 2, 2007 Mr. Chief, Criminal Division United States Attorney's Office Southern District of Florida 99 NE 4 Street Miami, Florida 33132

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

Attorney's Office will close their investigations. EFTA00225194 FOWLERWHITE AIII)kiaLv5 BURNETT MIAMI • FORT LAUDERDALE • WEST PALM BEACH • ST. PETERSBURG August 2, 2007 Mr. Matthew Menchel Chief, Criminal Division United States Attorney's Office Southern District of Florida 99 NE 4 Street Miami,

whether pursuant to state, federal, or common law. Notwithstanding this waiver, as to those individuals whose names appear on the list provided by the United States, Epstein's signature on this agreement, his waivers and failures to contest liability and such damages in any suit are not to be construed as an a

FOWLERWHITE ATTORNEYS AT LAW BURNETT MIAMI • FORT LAUDERDALE • WEST PALM BEACH • ST. PETERSBURG October 8, 2007 ited States Attorney United States Attorney's Office Southern District of Florida 500 South Australian Avenue, Suite 400 West P

Training (Jan 2017) (5 US.C. 552a). (3) Akentin. I (Jan 2017) of 52224-3. (xx) 52.225-26, Contractors Pafonning Pri ate Security Fun:liars Outside the United Stars (Oct 2016) (Sectiat 862, as amended, of the National Defense Authairation Act for Fiscal Year 2008 10 U.S.C. 2302 Note). (xx) 52.226-6, Promoting E

0 PEN FPC PENSAC0LA S&E SUPVY CORRECTIONAL SYSTEMS SPECIAUST GS-0006-11 1 1 0 PEN FPC PENSAC0LA S&E WARDEN GS-0006-1S 1 1 0 PET FCC PETERSBURG S&E ADVANCED PRACTICE N GS-061O11 3 0 0 PET FCC PETERSBURG S&E ASST HUMAN RESOURCE MGR GS-0201-12 1 0 0 PET FCC PETERSBURG TRUST FUN

whether pursuant to state, federal, or common law. Notwithstanding this waiver, as to those individuals whose names appear on the list provided by the United States, Epstein's signature on this agreement, his waivers and failures to contest liability and such damages in any suit are not to be construed as an a

7 Page 4 Sincerely, Jay P. Lefkowitz RFP MIA 000313 EFTA00209001 • • • FOWLERWHITE BURNETT MMMT • FORT LAUOIROALE • WEST PALM BEACH • ST. PETERSBURG October 8, 2007 Jeffrey Sloman First Assistant United States Attorney United States Attorney's Office Southern District of Florida 500 South Au

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NY $61.75 2128615791 Description Price DRY CLEANERS $64.75 Continued on next page AMEX007060 SDNY_GM_02750359 EFTA 00237615 EFTA01679018 AMERICAN EXPRESS Centurion* Card p. 9/44 JEFFREY E EPSTEIN Closing Date 02106/15 Account Ending 0.13001 Detail Continued Foreign Spend Amount 01/09

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