Epstein Secrets

tate. The travel must be for the purpose of engaging in the unlawful sexual act. See s2 liftmen HufT, 291 U.S. 559, 562-63 (1934) and Mortensen'. United Stales. 322 U.S. 369, 374 (1944) ("An intention that the women or girls shall engage in the conduct outlawed by Section 2 must be found to exist before th

nduct, with any person, regardless of that person's age. Rather, it criminalizes travel for the purpose of engaging in unlawful sexual activities. United State;'. Hayward 359 F.3d 631, 638 (3d Cir. 2004). See also United States'. Tykarsky 446 F.3d 458, 471 (3d Cir. 2006): EFTA00221344 12/07/07 FRI 15:39

e," United States Cagithli. 49 F.3d 1079, 1083 (56 Cif( 1995), or "at least one of the defendant's motivations for taking trip in the first place," United Statist I EU& 935 F.2d 365, 389 (In Cir. 1991). Swain }Widow', 224 Fed. Appx. 923 (1 I s Cu. 2007) (unpublished). EFTA00221345 12/07/07 FRI 15:40 FAX 1

d to offer my views regarding the case of Jeffrey Epstein ("Mr. Epstein"), who entered into a Deferred Prosecution Agreement ("the Agreement") with the United State's Attorney's Office for the Southern District of Florida ("USAO") to resolve state and federal criminal investigations relating to his actions involvi

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

germent via the Internet. EFTA00221337 12/07/07 FRI 15:36 FAX I KIRKLAND&ELLIS LLP [ib014 Alan Dershowitz, Esq. December 7, 2007 Page 7 See United Sates 1. Searcy 418 F.3d 1193, 1197 (11th Cir. 2005) (citing H.R. Rep. No. 104.458, at 193 (1996) (Conf.Rep.)). ace ast K. Seto, Note- How S_hould Legislati

s, have essentially involved a standard fact pattern where an undercover agent pretends to be a young teenager on-line, and is directly solicitated. See United States'. Farner 251 F.3d 510 (5th Cir. 2001). See also Cagifitatest Root 296 F.3d 1222, 1227- 28 (11th Cir. 2002); United States I. Sims, 428 F.3d 945, 959

. Alexander Acosta dated October 10, 2007; Jay Lefkowitz's letter to R. Alcor Acosta dated October 23, 2007; R. Alexander Acosta's letter to Judge Edward B. dated October 25, 2007; Jay telkowitz's letter to Jeffrey Sloman dated November 8, 2007; Judge Kenneth Starr's letter to Alice Fisher dated Novemb

k that physical force against the person . . . or another may be used in t the course of committing the offense." 18 U.S.C. § 16(b). Post-Johnson v. United Sta , U.S. 135 S. Ct. 2551 (2015), a court might decide differently. See, e.g., Menendez Whitaker, 908 F.3d 467 (9'b Cir. 2018). Even if not a crime

considered for work release. At some point after the NPA was signed, USA Acosta was recused from the Epstein matter. AUSA John McMillan (still at USA0): Early in the investigation, I asked AUSA McMillan if he would serve as co-counsel on the case. Before I joined the West Palm Beach Office, AUSA M

rate contact with Epstein. (See Exhibit A-1.) One of the subpoenaed victims was Individual #28, who is referred to as Jane Doe #2 in the Jane Doe' United Stales litigation. When approached for an interview, Individual #28 refused to speak with the agents, and I remember S/A Kuyrkendall telling me that she fe

GRAND JURY PROCEEDINGS SEALED ORDER GRANTING APPLICATION FOR PERMISSION TO DISCLOSE GRAND JURY MATERIAL THIS MATTER has come before the Court on the United States' Sealed Application for Permission to Disclose Grand Jury Material and for Entry of a Protective Order. The Court has considered the Motion and find

page draft letter to Judge , attached 10/25/2007 Lefkowitz Cyndee Campos Email - 1 page with letter to Judge attached 10/25/2007 The Hon. Edward B. Jeffrey Sloman Background information to Special Master to appoint attorney for victims 10/29/2007 Deadline date for Epstein's plea and sentencing a

this procedure because. as I mentIona I think It to probably in their best WOWS. In terms of plea agreement language. let me suggest the following: Thu United Slates agrees to make a minion seeking the appointment of a Guardian ad titan to mpresent the identified victims, Following the appointment of such Guardia

mber I I, 2007 Page 4 The final agreement was very similar to what was proposed by Ms. Villotbna in her initial draft agreement on July 31. 2007: The United Stoles shall provide l3poein's anomey's with u list of individuals whom ii fins identified as victims, as defined in IR U.S.C. § 2255. alter Epstein has si

hich point they were eliminated by your Office: IT APPEARING, idler an invizligation of the offenses and Epstcin's background, thin the interest or the United Stales pursuant to the Petite policy will be served by the Following procedure ... Epstein understands that the United Stales Attorney has no authority to

s attorneys to select the attorney representative. Ms. Villafana continued to lobby for Mr. Ocariz's appointment. On October 19. 2007, retired Judge Edward B. who was appointed by the parties to select the attorney representative. informed Mr. Epstein' that he received a telephone call from Mr. Ocariz di

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

ve. As a result, on October 29, 2007, the parties executed an Addendum wherein it was mutually agreed that former United States District Court Judge Edward B. would serve as the independent third-party. Judge Davis selected the venerable law firm of Podhurs and Josefsberg to represent the approximately 3

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 Slates, Epstein's signature on this agreement is not to be construed as an admission of any criminal or civil liability other than that contained in 18 U.

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

21002 99 ME. 4.4 Street Miami, F133132 Telephone: (305) 961-9299 Facsimile: (305) 530-6444 October 25, 2007 DELIVERY BY FAGS lyilLE The Hon. Edward B. (Ret.) Akerman Senterfitt One Southeast Third Avenue, 25th Floor Miami, Florida 33131 Re: Service as a Special Master. Dear Judge Thank you for

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

HAEL L. SCHEVE DEAN T. XENICK DAVID A. YAREMA IFUDRIDA BOARD CERTIFIED CIVIL TRIAL LAWYER 2ADMITTE0 TO PRACTICE IN FLORIDA AND COLOMDO Honorable Edward B. Akerman Senterfitt One SE Third Avenue Floor 28 Miami, FL 33131-1715 Re: Jeffrey Epstein Dear Judge BURMAN, CRITTON LUTTIER &COLEMAN, LLP YOUR

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

entative. As a result, on October 29, 2007, the parties executed an A um wherein it was mutually agreed that former ' States District Court Judge Edward B. would serve as the independent third-party. Judge selected the venerable law firm of Podhurst and Josefsberg to represent the approximately 34 al

dations 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

ve. As a result, on October 29, 2007, the parties executed an Addendum wherein it was mutually agreed that former United States District Court Judge Edward B. would serve as the independent third-party. Judge selected the venerable law firm of Podhurst and Josefsberg to represent the approximately 34 al

following language regarding the 2255 provision: "Any person, who while a minor, was a victim of a violation of an offense enumerated in Title 18, United States Code, § 2255, will have the same rights to proceed under § 2255 as she would have had, if Mr. Epstein been tried federally and convicted of an enume

rty. A copy of the October 29, 2007 Addendum is attached hereto as Tab E. The parties subsequently agreed that retired Federal District Court Judge Edward B. should be that independent third-party/special master. Ultimately, Judge selected Robert C. Josefsberg of the law firm of Podhurst, Orseck, Josef

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

entative. As a result, on October 29, 2007, the parties executed an Addendum wherein it was mutually agreed that former States District Court Judge Edward B. would serve as the independent third-party. Judge selected the venerable law firm of Podh r nd Josefsberg to represent the approximately 34 a eg