Epstein Secrets

US DeP•Mlilla I tr4 tram Race.” Fodor& AulaSciti Attailnistratien 08-80736-CV-MARRA RFP WPB 001697 EFTA00209876 U.S. Department of Justice United Slates Attorney Southern District of Florida 500 South Australian Ave., Suite 400 West Palm Beach, FL 3340! (361)820-8711 Facsimile: (561)820-8777 May

ta United States Att A. Marie Assistant United States Attorney 08-80736-CV-MARRA RFP WPB 001698 EFTA00209877 05/15/2007 16:57 FAX 5618021787 USA0 WPB FL gaol TX REPORT IX#i TRANSMISSION OK Sals *****Atii************* TX/RX NO 4676 CONNECTION TEL 8358691 SUBADDRESS CONNECTION ID ST.

a result of the federal investigation], or acquittal on the merits shall be a bar to any subsequent federal prosecution for the same act or acts." U.S.A.M. § 9-2.031A (emphasis added). Consistent with that principle, and of particular relevance to this case, the Department itself just recently observed

inding that the defendant had an intent to persuade or to attempt to persuade.' United States I Murrell 368 F.3d 1283, 1287 (11th Cir. 2004) (citing United States'. Bailey, 228 F.3d 637, 638-39 (6th Cir.2000)). Thus, the targeted criminal conduct must occur through the interstate facility, not thereafter, and

pstein about their age. See Tab 4 r. at 38-39; Tab 5, Tr. at 16; Tab 6, 2 08-80736-CV-MARRA REP WPB 001671 EFTA00209850 KIRKLAND & ELLIS LLP Miller Tr. at 6 8, 22, 45; Tab 7, 13; Tab 8 Tr. at 8; Tab 9, Tr. at 5; and Tab 10, Tr. at 14-15 (excerpts from these transcripts are included below). Furt

n in county jail; (3) a methodology to compensate the victims identified by the United States; (4) entry EFTA00225699 U.S. Department of Justice United Slates Attorney Southern District of Florida First As,ramt US Attorney DELIVERY BY FACSIMILE Jay P. Lefkowitz, Esq. Kirkland & Ellis LLP Cifigroup Ce

or calls unless AUSA Villafana and/or her supervisors advise him otherwise. Furthermore, you make reference to "our July 8 deadline." Respectfully, the United States Attorney's Office for the Southern District of Florida ("SDFL") has never agreed to any such deadline. Should you decide to provide the SDFL with an

ations which ultimately resulted in United States Attorney R. Alexander Acosta's' December 19, 2007 letter to Lilly Ann Sanchez. In that letter, the United States Attorney tried to eliminate all concerns which, quite frankly, the SDFL was not obligated to address, let alone consider. He proposed the following

were 18 or 19 or 20. And the girls that !didn't !mow and I don't know if they were lying or not, 1 would say make sure that you tell him you're 18." Miller Tr. at 22. Third, there was no routine or habit of improper cotrununication expressing an intent to transfomi a massage into an illegal sexual act. In

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

ere IS or 19 or 20. And the girls that I didn't know and I don't know if they were lying or not, 1 would say make sure that you tell him you're 18." Miller Tr. at 22. Third, there was no tontine or habit of improper communication expressing an intent to transform a massage into an illegal sexual act. In f

ough such misconduct was, as we contend it is, inextricably intenwined 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 revie

ere IS or 19 or 20. And the girls that I didn't know and I don't know if they were lying or not, I would say make sure that you tell him you're 18." Miller Tr. at 22. Third, there was no routine or habit of improper communication expressing an intent to transfonn a massage into an illegal sexual act. In f

pond to your e-mail or calls unle /or her supervisors advise him otherwise. Furthermore, you make reference to "our July 8 deadline." Respectfully, the United States Attorney's Office for the Southern District of Florida ("SDFL") has never agreed to any such deadline. Should you decide to provide the SD v additi

re 18 or 19 or 20. And the girls that I didn't know and I don't know if they were lying or not, I would say make sure that you tell him you're 18." Miller Tr. at 22. Third, there was no routine or habit suggesting an intent to transform a massage into an illegal sexual act. For instance, Ms. Laduke stated

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

ere 18 or 19 or 20. And the girls that I didn't know and 1 don't know if they were lying in not, 1 would say make sure that you tell him you're 18." Miller Tr. at 22. Third, there was no routine or habit of improper communication expressing an intent to transfomt a massage into an illegal sexual act, Iii