Epstein Secrets

inappropriate. The money laundering statute was designed to be used and has been construed as a "concealment" statute, not a spending statute. See United Stales v. Shepard, 396 F.3d 1116 (10th Cir.), cert. denied, 545 U.S. 1110 (2005); United States v. Hall, 434 F.3d 42 (1st Cir. 2006) (money laundering sta

d terrorism. The type of business contemplated by Congress is one which, for a fee, accepts funds for transfer within or outside the United States. See United States v. Talebnejad 460 F.3d 563, 565 (4th Cir. 2006); United States v. Velastegui, 199 F.3d 590 (2d Cir. 1999). Once the money transmitter receives the

tes v. Holland, 381 F.3d 80 (2d Cir. 2004) (woman running prostitution business convicted for recruiting and transport of prostitutes under § 2421); United States v. Footman, 215 F.3d 145 (1s1 Cir. 2000) (pimp who ran a prostitution ring convicted of violating § 2421). Likewise, in keeping with its purpose and

prostituting underage persons, either by force, fraud, or coercion. These cases bear no relationshijo to the circumstance at issue here. See, e.g., United Slates v. Norris, 188 Fed. Appx. 822 (11 Cir. 2006) (unpublished)(prosecution of several men for conspiracy to hold young women in peonage, and to traffi

sterday. 'write to you now to supplement our discussion. As you know, I feel strongly that the involvement of the federal government—culminating in the Deferred Prosecution Agreement—runs afoul of fundamental principles of federalism, the well-established Petite Policy, and issues of paramount importance with respect to the admi

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

fallen into this manifest legal error.22 In addition, federal prosecutors insisted that they dictate every detail of the State sentence pursuant to the Deferred Prosecution Agreement. Once again, this was done without any coordination with the State. Federal prosecutors went so far as to demand a restriction on the judge not to

ERROR, PLEASE NOTIFY S IMMEDIATELY AT: To: Company: Fax #: Direct #: linked Stales Attorney's Office CC: Company: Fax #: Direct #: t Inited States Attorney's Office From: Date: PageswIcover. Fax #: Direct #: Jay P. Leitowitz August 22, 2008 3 Message: EFTA00183577 "PM91-11,111 04 Ari

osta United States Attorney By Assistant United United States Attorney cc: Chief, Northern Division EFTA00183564 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: August 22, 2008

Re: Jeffrey Epstein Dear Marie: Fauzintikt: I write in response to your letter dated August 15. 2008 regarding the civil restitution portion of the Deferred Prosecution Agreement (the "Agreement"). Thank you for confirming our position that the December modification proposal is not part of the Agreement. As expressed by U.S.

dance with Paragraph 7B, please provide me with a proposed written submission to the Special Master by Monday afternoon. Finally, as you are aware, yhe United States has been ordered to produce the Non-Prosecution Agreement. In accordance with that Order, we will produce the September Agreement with the October A

rey Epstein Dear Marie: a rcsmokt: )14$.4900 1 write in response to your letter dated August 15. 2008 regarding the civil restitution portion of the Deferred Prosecution Agreement (the "Agreement"). Thank you for confirming our position that the December modification proposal is not part of the Agreement. As expressed by U.S.

SE NOIMANDIATELY AT: To: A. Villarana CC: Company: tinned States Attorney's °Dice Company: Fax #: Fax Direct Direct Si: Karen Atkinson ' United Slates Attorney's Oniee. From: Date: . Pagestmeover. Fax Direct #: Jay V. Letkowilz August 18.2008 3 Message: 08-80736-CV-MARRA RFP WPB 000581 E

008 Re: deity Epstein nestrtolu: ) 4A13.4900 I write in response to your letter dated August 15. 2008 regarding the civil restitution portion of the Deferred Prosecution Agreement (the "Agreement"). Thank you for tumlIrmIng our position that ember modification proposal is not port of the Agreement. As expressed by U.S. Attor

is no evidence that the phone was used to induce the young women to do anything other than provide EFTA00225884 • • • Page 25 (1995) (quoting United States' Enmons, 410 U.S. 3%, 411-12 (1973)). In Enmons, the Court refused to accept the Government's "broad concept" of the Hobbs Act, because it would have

ion of the Petite Policy, and an appendix, which includes significant documentary evidence including testimony by witnesses that was obtained after the Deferred Prosecution Agreement was signed. For the reasons we discuss in the submission, we do not believe this is an appropriate case for federal prosecution. I want to call you