Epstein Secrets

nduct as defined in It U.S.C. § 2423(0. with minor female., in violation of Tide United States Code, Section 2423(b), all In viobation of Title It, United Stases Code, Section 2427(e); wing a facility or means of interstate or foreign commerce to knowingly persuade, induce, or entice minor female. to engage

United Sines, the State of Florida, and the Defendant soil) be sewed by the following proodum, THEREFORE, on the authority of It. Alexander Acosta, United Slates Attorney for the Southern District of Florida, prosecution in this District foe these offenses shall be defined in favor of prosecuticm by the Stat

f civil or criminal liability or a waiver °forty jurisdktional or other defense as to any person whose name does not appear on the list provided by the United Stale. 10. Except es to those individuals who elect to proceed exclusively under IS U.S.0 f 2255, as set (whin penigntph (St manta. neither Epstein's s

gain time he eamwd during his period of Incer«ration. I3. the ponies anticipate Nat this agreement will not be mede pan of any public record. if the United Slates receive, e Freedom of Information Act request or any compubory worm conunanding the disclosure of the agreement, int will provide notice to Epstein

." United States I. lordm, 915 F.2d 622, 628 (11th Cir. 1990) (quoting Rodriguez,. United States, 480 U.S. 522, 525 (1987) (itself quoting Russell° I. United States 464 U.S. 16, 23 (1983))). There is no basis for departing from that rule. Given the strong evidence that Congress did not intend retroactively to ap

phrase. See, e.g., United States'. Garcia-M, 234 F.3d 217, 220 n.3 (5th Cir. 2000); United States I. Yang, 128 F.3d 1065, 1069-70 (7th Cir. 1997); United Statosi. Ellis 935 F.2d 385, 389-90 (1st Cir. 1991); see also United States'. Hoschouer, 224 Fed. Appx. 923, 926-27 (11th Cir. 2007) (unpublished opinion);

er Defendant Epstein's defense of the civil actions filed against him violates the non-prosecution agreement between Epstein and the United States. The United States' position in this matter would be very helpful to the Court and, accordingly, the Court requests that the United States appear at the hearing. Base

tion apaisai him h irntinned for any offense that usis the 'objecter0e grandjuria inwangation, il may be by way of anInfonnwion sIgned and filai by the United States Anone); end hereby nives Ma rie to be Indktcd by e gnnd jury as ha any aie offense, lit tyy lff hie 6of 7 Case No. 08-80736-CV-MARRA P-011809 EFTA0

leventh Circuit recently noted that federal law "does not criminalize all acts of prostitution (a vice traditionally governed by state regulation)." United States,. Evans, 476 F.3d 1176, n.1 (11th Cir. 2007); see also Offense Instruction 80, Eleventh -22- Case No. 08-80736-CV-MARRA P-011863 EFTA00192909 Ca

A P-011819 EFTA00192865 U.S. Department of Justice Washington, D.C. 20530 June 23, 2008 Jay Lefkowitz„ Esq. Kenneth Starr, Esq. Kirkland and Ellis LLP 777 South Figueroa Street Los Angeles, CA 90017 Gentlemen: This Office has completed a thorough review of the U.S. Attorney's handling of the mat

erson can be charged with a criminal 39 EFTA01718615 . offense, that is a violation of Florida Statutes Section 794.05; in violation of Title 18, United States Code, Sections 2422(b) and 2. COUNT 14 (Enticement of a Minor: 18 U.S.C. § 2422(b)) 49. Paragraphs 1 through 19 of this Indictment are re-alleged

ity or process of the prior prosecution. not the sentencing outcome. Second, the state plea agreement offered was not "manifestly inadequate" tinder U.S.A.M. § 9- 2.03ID. indeed, the only real difference hews= the state and federal plea proposals was whether Mr. Epstein served his sentence in jail or comm

n to undertake discussion with the $tate Attorney's Office In ensure compliance with these procedures, which compliance will be necessary to satisfy the United States' interest. pursuant to the Perire policy. We reiterate that this case was at heart a local matter that was being fully addressed by the state crimi

U.S. Department of.Justiee United States Attorney Southern District of Florida DELIVERY BY ELECTRONIC MAIL Jay P. Leflcowitz, Esq. Kirkland 8c Ellis LLP New York, New York 10022-4675 Re: Jeffrey Epstein Dear Jay: West Palm Beach, FL 3 acsuni e: December 13, 2007 I am writing not to respond to

n been convicted at trial. No more; no less." Initials of Jeffrey Epstein Initials of Jack Goldberger EFTA00225601 U.S. Department of Justice United Stales Attorney Southern District of Florida 500 South Australian Ave., Suite 400 West Palm Beach, FL 33401 (561) 820-8711 Facsimile: (561) 820-8777 J

m Beach, FL 33401 (561) 820-8711 Facsimile: (561) 820-8777 June 30, 2008 NOTIFICATION OF IDENTIFIED VICTIMS NOTICE: IN ACCORDANCE WITH TITLE 18, UNITED STATES CODE, SECTION 3509(d) AND FLORIDA LAW, THE ATTACHED DOCUMENT IS TO BE TREATED AS CONFIDENTIAL AND SHALL NOT BE DISCLOSED EXCEPT IN CONNECTION WIT

enied that one of these victims is entitled to proceed under 18 U.S.C. § 2255, that will be considered a breach of the Non-Prosecution Agreement and the United States will proceed accordingly. Sincerely, It. Alexander Acosta United States Attorney I ly : A. Marie Villafafia Assistant United States Attorney c

XHIBIT B-55 EFTA00225611 U.S. Department of Justice Washington, D.C. 20530 June 23, 2008 Jay Lefkowitz, Esq. Kenneth Starr, Esq. Kirkland and Ellis LLP 777 South Figueroa Street Los Angeles, CA 90017 Gentlemen: This Office has completed a thorough review of the U.S. Attorney's handling of the mat

te commerce for the purpose of engaging in illicit sexual conduct, as defined in 18 U.S.C. § 2423(1), with minor females, in violation of Title 18, United States Cod; Section 2423(b); all in violation of Title 18, United States Code, Section 2423(e); (3) using a facility or means of interstate or foreign commer

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

U.S. Department of Justice Washington, D.C. 20530 June 23, 2008 Jay Lefkowitz, Esq. Kenneth Starr, Esq. Kirkland and Ellis LLP Gentlemen: This Office has completed a thorough review of the U.S. Attorney's handling of the matter involving your client, Jeffrey Epstein. We ha

ober 08, 2008 2:40 PM To: Villafana, Ann Marie C. (USAFLS); Roy Black Cc: Atkinson, Karen (USAFLS); Lee, Dexter (USAFLS) Subject: Re: Jane Does I. United States Thank you for sending this. Jay From: "Villafana, Ann Marie C. (USAFLS)" [[email protected]] Sent: 10/08/2008 02:37 PM AST To: <RB

FLS)" <[email protected]>; "Lee, Dexter (USAFLS)" <[email protected]> Subject: Jane Does. United States Dear Roy and Jay: I am attaching the United States' Response to the Petitioners' Motion to Unseal the Non-Prosecution Agreement, which was filed in the victims' rights suit filed against the United St

attorney-client privileged, may constitute inside information, and is intended only for the use of the addressee. It is the property of Kirkland a Ellis LLP or Kirkland s Ellis International LLP. Unauthorized use, disclosure or copying of this 472 EFTA00190404 communication or any part thereof is str

tates Attorney should determine, based on information he deems reliable, that Epstein has violated any of the conditions of this Agreement, then the United States Attorney may at any time initiate prosecution against Epstein for any offense. In this case, the United States Attorney will furnish Epstein with ti

n to undertake discussion with the State Attorney's Office to ensure compliance with these procedures, which compliance will be necessary to satisfy the United States' interest, pursuant to the Petite policy. In consideration of Epstein's agreement to plead guilty and to provide compensation in the manner describe

ttorney-client privileged, may constitute inside information, and is intended only for the use of the addressee. It is the property of Kirkland a Ellis LLP or Kirkland i Ellis International LLP. US_Atty_Cor_00117 EFTA00235443 Unauthorized use, disclosure or copying of this communication or any part

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 C'USAO"). Moreover. CEOS did not assess the terms of the Defened Prosecution Agreement now in effect, nor did CEOS review

U.S. Department of Justice Washington, D.C. 2053U June 23, 2008 Jay Lefkowitz, Esq. Kenneth Starr, Esq. Kirkland and Ellis LLP Gentlemen: This Office has completed a thorough review of the U.S. Attorney's handling of the matter involving your client, Jeffrey Epstein. We ha