Epstein Secrets

tivity for which a person can be charged with a criminal offense, that is a violation of Florida Statutes Section 794.05; in violation of Title 18, United StateW bode, Sections 2422(b) and 2. COUNT 22 (Enticement of a Minor: 18 U.S.C. § 2422(b)) 55. Paragraphs 1 through 25 of this Indictment are re-alleged

rtment could bring charges, it should decline as a matter of prosecutorial discretion. The relevant factors are set forth in Section 9-27.230 of the United States Attorney's Manual, and those factors counsel against prosecution. Mr. Epstein has no criminal history of any kind. Given the unique nature of any pr

il litigation against him. They further demanded that Mr. Epstein waive EFTA00225865 • Page 44 case involving the murder of a federal official." U.S.A.M. § 9-2.031D. To put it mildly, that egregious example is a far cry from the situation at hand. Instead, the federal prosecutors' disagreement with t

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." Id. However, after Mr. Epstein's counsel conveyed to the prosecutors the fact that they had appeared to ig

federal prosecutors were taking in order to circumvent its restrictions. Mr. Menchel's articulation of the purported federal interest misrepresents the Petite Policy on two grounds. First, Mr. Menchel's position that the federal interest could not be vindicated in the absence of a jail term for Mr. Epstein is co

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

ing the relevant federal statutes beyond recognition, and that federal involvement in this matter should be precluded based on federalism concerns. the Petite Policy, and general principles or prosecutorial discretion. the parties commenced discussions an possible pica agreement. Around this time, we received an

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

hing the relevant federal statutes beyond recognition, and that federal involvement in this mutter should be precluded butt on federalism concerns, the Petite Policy, and general principles of prosecutorial disattion, the panics corn • discussions of a possible plea agreement. Around this time, we received an e

S L LP Jay P I otternWs, P C. loP 11Wr r ly blk Orland can VIA FACSIMILE (303) SM1-4444 Honorable R. Alexander Acosta united States Attorney United Slates Attorney's ()filet Southern District of Florida 99 NE itlh Street Miami. Fla 33132 Dear Alex: nap MIn IARD 'Armen-. Cinarmap Conte, 153 Emit

to undertake discussion with the Slate Attorney's 011ie,: to ensure compliance with these procedures. which compliance will he necessary to satisfy the United Status' interest. pursuant In the Poise policy. We reiterate that this ease was at heart a local matter that was being fully addressed by the state crimin

ng the relevant federal statutes beyond recognition, and that federal involvement in this matter should he precluded basest on federalism concerns, the Petite Policy, and general principles of prosecutorial discretion. the parties commenced discussions of a possible plea agreement. Around this time. we received a

L. Rev. 23, 29 (1997) ("Why have these policies been adopted? The epithet `soft on crime' is the contemporary equivalent of `soft on Communism.' In the United States, politicians have learned that to win you need to convince the public that you are tough on crime."); Greg Holton, After the Federalization Binge: A

cutors violated the authority of state and local governments, overthrowing principles of comity, contravening the "clear statement rule" as well as the Petite Policy, and undermining a comprehensive state investigation and resolution of the case. As a result of the unwarranted interference of federal prosecutors

L. Rev. 23, 29 (1997) ("Why have these policies been adopted? The epithet `soft on crime' is the contemporary equivalent of `soft on Communism.' In the United States, politicians have learned that to win you need to convince the public that you are tough on crime."); Greg Holton, After the Federalization Binge: A

cutors violated the authority of state and local governments, overthrowing principles of comity, contravening the "clear statement rule" as well as the Petite Policy, and undermining a comprehensive state investigation and resolution of the case. As a result of the unwarranted interference of federal prosecutors