Epstein Secrets

oenas. See Tab 2], September 24, 2007 Non Prosecution A ement. It alsoguarantees that persons identified in the Grand Jury subpoena such as , and Leslie Groff and others will not be prosecuted. The new Grand Jury subpoena clearly violates the Non- Prosecution Agreement. Although Mr. Epstein has exercised

in the Grand Jury subpoena such as , and Leslie Groff and others will not be prosecuted. The new Grand

it is not in accord with the principles of justice. Indeed, as noted, just a few weeks ago, the Supreme Court underscored this point in Santos and Cuellar. The Court made clear that prosecutorial discretion does not provide the USAO cart blanche to expand criminal statutes as they seek to do here with

upreme Court decisions addressing that element. See Hansen v. Huff, 291 U.S. 559 (1934); Mortensen v. United States, 322 U.S. 369 (1944). Santos and Cuellar speak loudly and clearly against prosecutors seeing such elasticity in federal criminal statutes, including those enacted to protect important fede

See Tab 21, September 24, 2007 Non Prosecution A reernenThiso_auarantees that persons identified in the Grand Jury subpoena such as Sarah , and Leslie Groff and others will not be prosecuted. The new Grand Jury subpoena clearly violates the Non- Prosecution Agreement. Although Mr. Epstein has exercised

ruction charges, many of the facts I included in that first proffer were hypothesized based upon our discussions and the agents' observations of Ms. Groff. We will need to interview her to confirm the accuracy of those facts. On a second count, we could rely on the incident where Mr. Epstein's private

A00209852 KIRKLAND & ELLIS LLP Congress to speak more clearly and keeps courts from making criminal law in Congress's stead." Slip op. at 6.I In Cuellar, the Court examined the link between the money-laundering statute's mens rea requirement and the underlying elements of the offense. After a careful

o Suprems Court decisions addressing that element. See Hansen'. Huff, 291 U.S. 559 (1934); Mortensen. United States, 322 U.S. 369 (1944). Santos and Cuellar speak loudly and clearly against prosecutors seeing such elasticity in federal criminal statutes, including those enacted to protect important fede

to the facts in this case. Importantly, we note that the CEOS review was conducted prior to the Supreme Court’s very recent decisions in Santos and Cuellar, which we believe—illuminating as they do the Court’s interpretive methodology when it comes to federal criminal law—powerfully demonstrate the subst

subpoenas. See Tab 21, September 24, 2007 Non Prosecution Agreement. It also guarantees that persons identified in the Grand Jury subpoena such and Leslie Groff and others will not be prosecuted. The new Grand Jury subpoena clearly violates the Non- Prosecution Agreement. Although Mr. Epstein has exercised hi

tified in the Grand Jury subpoena such and Leslie Groff and others will not be prosecuted. The new Grand

to the facts in this case. Importantly, we note that the CEOS review was conducted prior to the Supreme Court’s very recent decisions in Santos and Cuellar, which we believe—illuminating as they do the Court’s interpretive methodology when it comes to federal criminal law—powerfully demonstrate the subst

oenas. See Tab 21, September 24, 2007 Non Prosecution Agreement. It also guarantees that persons identified in the Grand Jury subpoena such i. | and Leslie Groff and others will not be prosecuted. The new Grand Jury subpoena clearly violates the Non- Prosecution Agreement. Although Mr. Epstein has exercised hi

d in the Grand Jury subpoena such i. | and Leslie Groff and others will not be prosecuted. The new Grand