Epstein Secrets

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

ified that they would counsel their friends to lie about their ages as well. Ms. Miller stated the following: "I would tell my girlfriends just like Carolyn approached me. Make sure you tell hint you're. 18. Well, these girls that I brought, i know that they were 18 or 19 or 20. And the girls that !didn

in similarly abusive circumstances at the time of trial, and who gave dishonest answers regarding that subject at voir dire, was impliedly biased); United States v. Eubanks, 591 F.2d 513, 517 (9th Cir. 1979) (per curiam) (implying bias where, in a trial for participation in a heroin distribution conspiracy, a

ere and there is no legal basis for Juror No. 50 to intervene in this matter. This is not a request by a journalist to intervene for public access. See United States v. Aref, 533 F.3d 72, 81 (2d Cir. 2008) (motion to intervene to assert the public's First Amendment right of access to criminal proceedings is prop

juror who had been the victim of [sexual assault and sexual abuse] to harbor bias against a defendant accused of such a crime." See id. Like Jane, Carolyn, Kate, an' Juror No. 50 claims to be a victim of child sexual abuse. Like Jane, Carolyn, Kate, and Juror No. 50 delayed disclosing the abuse he s

d and common objectives. Both Counts Three and Five are charged under the same statute, 18 U.S.C. § 371, for conspiracy to commit an offense against the United States. But going beyond this "general level" of similarity, the statutory objectives of the two counts differ. Macchia, 35 F.3d at 669. Count Three is a c

peculation, with the apparent presumption that absent evidence would necessarily favor the Defendant, is insufficient to establish actual prejudice. See United States v. Long, 697 F. Supp. 651, 657 (S.D.N.Y. 1988) (no prejudice where there is "no way of knowing what [an absent witness's] testimony would have been

again and again and again."), 2901 ("Four women have testified at this trial about Maxwell. They all describe the same woman, the same playbook."). Carolyn was the only witness who testified regarding Count Five. The Government argued that her testimony "was corroborated by what Annie an old [the jury

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 revie

stein testified that they would counsel their friends to lie about their ages as well. stated the following: '1 would tell my girlfriends just like Carolyn approached me. Make sure you tell him you're 18. Well, these girls that I brought, I know that they were 18 or 19 or 20. And the girls that I didn'

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

ified that they would counsel their friends to lie shout their ages as well. Ms. Miller stated the following: "I would tell my girlfriends just like Carolyn approached me. Make sure you tall hiin you're IR. Well, these girls that I brought, I know that they were IS or 19 or 20. And the girls that I didn

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

rage friends to Mr. Epstein counseled them to lie about their ages as well. Ms. Miller stated the following: "I would tell my girlfriends just like Carolyn approached me. Make sure you tell him you're 18. Well, these girls that I brought, I know that they were 18 or 19 or 20. And the girls that I didn't

t of Florida and elsewhere, the defendant, SCOTT W. ROTHSTEIN, did knowingly conspire, confederate, and agree with persons known and unknown to the United States Attorney, to commit offenses against the United States in violation of Title 18, United States Code, Sections 1956 and 1957, that is: i. to knowing

8 - FBI). Yet at her September, 2009 deposition now represented by EDWARDS and RRA, L.M. told a very different story: Q: My question was what did Carolyn tell you to tell Mr. Epstein about your age? A: She said it didn't matter. Q: That's your recollection about what she said? A: Yes, she said — I

had become the leading voice for human rights in the Soviet Union. Sharansky was arrested by the Soviet KGB in 2003 [check] on charges of spying for the United States—a charge that carried the death penalty. I had previously represented two Jewish Refusenicks who had tried to steal a small airplane in which to esca

ed us to join them for dinner at the Savoir Faire Restaurant in Edgartown. We had already eaten before the service, but we readily accepted. My wife, Carolyn, my son Elon and I dined with the Clintons. We were later joined for dessert by Vernon Jordan and his wife, Anne. The dinner was relaxed. The Presid

t page? Q. Page 19. You were asked: "I'm wondering, have you spoken to Jeffrey Epstein about this since these allegations came out in this suit in the United States? Have conversations happened there?" Oo On KH MP WN BP PRR PP Pe RH to OW HU PWN REO communication with Jeffrey Epstein, correct? A. I disclosed

xhibits as well, That will save us some time. MR. SCOTT: What is this? MR. SCAROLA: Her calendar, his calendar. MR. SCOTT: Who's calendar is this, Carolyn's? MR. SCAROLA: Okay. This is Number 10. MR. SCOTT: Carolyn's calendar. (Thereupon, marked as Plaintiff Exhibit 10.) MR. SCAROLA: This is Number

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

e. he thought I was 18... (Miller Sworn Statement at 13) • Instructed Others to Lic About Their Ages A: . . . I would tell my girlfriends just like Carolyn approached me. Make sure you tell him you're III. Well, these girls that I brought. f know that they were IR or 19 or 20. And the girls that I didn