Epstein Secrets

: 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

On or about July 15, 2004, DefendantIMEMS placed one or niorii telephone calls to a telephone used by Jane Doe #9. (67) On or about July 16, 2004, Defendan caused Jane Doe #9 to make one or more telephone calls to a telephone used by Jane Doe #10. (68) On or about July 17, 2004, Defendant telephone c

lculation of the offense levels under United States Sentencing Guidelines Manual (USSG) §§ 2G2.I and 2G2.2 (1998).FNI I FNI I. The 1998 edition of the United States Sentencing Guidelines Manual was applied in this case due to concerns about possible ex post facto problems that might arise from subsequent amend

prft—H... 12/18/2007 EFTA00191996 Page 13 of 13 77 Fed.Appx. 371 77 Fed.Appx. 371, 2003 WL 22331999 (C.A.6 (Ohio)) (Cite as: 77 Fed.Appx. 371) United States' Lyckman, 235 F.3d 234, 237-40 (5th Cir.2000). The term "sadism," which is the most relevant to this case, is defined as the " infliction of pain u

ent when it is based on consent from a third party whom the agents reasonably believed (even if erroneously) to have common rt.over the premises. United Stater 979 F.2)77, 79 (6th Cir.1992) (quoting Illinois Rodriguez, 497 U.S. 177, 110 S.Ct. 93, III L.Ed.2d 148 (1990)). B. Attempted Enticement of A M

14. The district court observed that "the lessee's consent to the instant search of the spare bedroom provides an independent g reason to deny the Defendan ' . n to suppress. See United Stain 979 1 i 2c1 77, 79 (6th Cir.1992); unite tales Clutter, 914 F.2d 775, 777 (6th r.1990), cert. denied,499 U

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

lephone call to a telephone used by Jane Doe #15. (147) On or about April 1, 2005, one of Defendant JEFFREY EPSTEIN's employees prepared a note for Defendan FFREY EPSTEIN's review that read: "10:30 [Jane Doe #15]/[Jane Doe #10] on Fri around 2'Oclock". (148) In or around June 2005, Defendant JEFFREY EP

JEFFREY EPSTEIN LILLY A ANCHEZ, ESQ ATTORNEY FOR JEFFREY EPSTEIN Case No. 08-80736-CV-MARRA P-013446 EFTA00230351 U.S. Department of Justice United Slates Attorney Southern District of Florida R ALEXANDER ACOSTA UNITEDSTATES ATTORNEY DELIVERY BY FACSIMILE Fowler White Burnett, PA 1395 Brickell Ave

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

In or around 2003, Defendant JEFFREY EPSTEIN made a payment of $200 to Jane Doe #2, who was then a sixteen-year-old girl. (16) In or around 2003, Defendan placed a telephone call to a telephone used by Jane Doe #2 to make an appointment for Jane Doe #2 to travel to 358 El Brillo Way. (17) On or abou

t the victim is a minor, regardless of what the victim says or how the victim appears. Id. (emphasis added; additional internal citations omitted). Cl United States v. Wild, 143 7 EFTA02857530 Fed. Appx. 938, 942 (4th Cir. 2005) (the parties agreed that, to prove a violation of § 2423(a), the United States h

05, even though Jane Doe #2 never went to EPSTEIN's house because at the time of his travel, EPSTEIN intended for Jane Doe #2 to come to the house. See United States v. Han, 230 F.3d 560 (2d Cir. 2000) (defendant could be convicted of violating Section 2423(b) even though no sexual activity occurred and "minor"

he masturbated. 8 EFTA02857682 (5) In or around 2001, Defendant JEFFREY EPSTEIN made a payment of $300 to Jane Doe #2. (6) In or around 2001, Defendan placed a telephone call to a telephone used by Jane Doe #2 to make an appointment for Jane Doe #2 to travel to 358 El Brillo Way. (7) In or arou