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

1 KIRKLAND & ELLIS LLP To the extent there is a similar, but more egregious, local Florida case on the books, it is that of Barry Kutun, a former North Miami city attorney accused of having sex with underage prostitutes and videotaping the sessions. Mr. Kutun pleaded guilty on May 18, 2007 in a Miami- Dad

ction 2422(b) expressly requires that the crime be committed "knowingly," and that requisite mental element applies as to each element of the crime. United Slates v, XCitement Video, Inc., 513 U.S. 64, 68.69 (1994); United States v. Meek, 366 F.3d 705, 718 (9lh Cir. 2004); United States v. Root, 296 F.3d 1222,

imited to sex trafficking that involves children or is accomplished by force, fraud, or coercion." United States v. Evans 476 F.3d at 1179 n. 1. Sec aho United States v, Sims, 171 Fed. 3505-019 Page 19 of 63 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00003291 EFTA00157673 ALLEN GUTHR

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

ically underscore these principles and help to highlight why federal prosecution in this case would be improper as a matter of both law and policy. See United States v. Santos, No. 06-1005 (June 2, 2008); Cuellar v. United States, No. 06-1456 (June 2, 2008). Though they both address the interpretation and applica

13 KIRKLAND & ELLIS LLP To the extent them is a similar, but more egregious, local Florida case on the books, it is that of Barry Kutun, a former North Miami city attorney accused of having sex with underage prostitutes and videotaping the sessions. Mr. Kutun pleaded guilty on May 18, 2007 in a Miami- Dad

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

en so does every other sentence handed out by the State on similar facts. Indeed, the conduct here can be compared to that of Barry Kutun, a former North Miami city attorney accused of having sex with underage prostitutes and videotaping the sessions. Mr. Kutun pleaded guilty on May 18, 2007 in a Miami- Dad

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

, that amounts to solicitation under State law. After all, prostitution, even when the allegations involve minors, is fundamentally a State concern, United States v. Evans, 476 F.3d 1176, n.1 (11th Cir. 2007) (noting that federal law "does not criminalize all acts of prostitution (a vice traditionally governed

ically underscore these principles and help to highlight why federal prosecution in this case would be improper as a matter of both law and policy. See United States v. Santos, No. 06-1005 (June 2, 2008); Cuellar v. United States, No. 06-1456 (June 2, 2008). Though they both address the interpretation and applica

6 KIRKLAND & ELLIS LLP To the extent there is a similar, but more egregious, local Florida case on the books, it is that of Barry Kutun, a former North Miami city attorney accused of having sex with underage prostitutes and videotaping the sessions. Mr. Kutun pleaded guilty on May 18, 2007 in a Miami- Dad

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12(c). FURTHER YOUR AFFIANT SAYETH NAUGHT. C FEDERAL BUREAU OF S Sworn to and subscribed before me this / day of December, 2009. R. JOHNSO UNITED STATE GISTRATE JUDGE 5 ATION Atr :YR O C i E ENT EFTA00728199 cpsQ 9:08-Cv-80119-KAM Document 469-3 Entered on FLSD Docket 02/17/2010 Page 7 of

OF AMERICA vs. ALFREDO RODRIGUEZ, Defendant. CRIMINAL COVER SHEET 1. Did this matter originate from a matter pending in the Northern Region of the United States Attorney's Office prior to October 14, 2003? Yes X No 2. Did this matter originate from a matter pending in the Central Region of the United St

ORIDA CASE NO. 502038CA037319)C0C048 AB 2/3 6 Plaintiff, 7 Vs. 9 JEHREY EPSTEIN. Defendant 10 11 17 1031 Ives Dairy Road 13 Suite 228 North Miami, Eland,' 14 August 7, 2009 1:15 p.m. to 5:30 p.m. 15 16 CONTINUED 17 VIDEOTAPED 18 DEPOSITION 19 CC 20 ALFREDO RODRIGUEZ 21 22 taken

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iminal statutes, including those enacted to protect important federal interests. In cases involving the federalization of activity that is within the States’ historic police power, Congress must speak with particular clarity. See, e.g., Will v. Michigan Dep’t of State Police, 491 U.S. 58, 65 (1989). 12

a KIRKLAND & ELLIS LLP \ To the extent there is a similar, but more egregious, local Florida case on the books, it is . that of Barry Kutun, a former North Miami city attorney accused of having sex with underage prostitutes and videotaping the sessions. Mr. Kutun pleaded guilty on May 18, 2007 in a Miami- Dade

tter points out (CEOS letter at p. 3), I was a member of CEOS. In fact, I served as a federal prosecutor for twelve years; five years as an Assistant United States Attorney for the Southern District of West Virginia, and seven years at CEOS. I began working as a trial attorney for CEOS in 1999, and was pr