Epstein Secrets

ri • 33401 IA LDBERGER, ESQUIRE Fl Bar No. co: The Honorable Sandra MeSorley EFTA00221324 12/07/07 FRI 15:31 FAX 1 KIRKLAND&ELLIS LLP Z001 KIRKLAND & ELLIS LLP Fax Transmittal 777 South Figueroa Street Los Angela 017 Phone Fax Please notify us Immediately If any pages are not received. THE INFORMATIO

nder state law. Confining the statute's reach to such situations is precisely what eliminates what would otherwise be First Amendment problems. See Bailey 228 F.3d at 639 ("Defendant simply does not EFTA00221341 12/07/07 FRI 15:38 FAX 1 K I RKLAND&ELLI S LLP o1s Alan Dershowitz, Esq. December 7,

ny sex act himself, he would nevertheless violate §2422(b)." United States'. Murrell, 368 F.3d 1283, 1286 (11th Cir. 2004). See also United States Bailey, 228 F.3d 637, 639 (02' Cu. 2000) ("Congress has made a clear choice to criminalize persuasion and the attempt to persuade, not the performance of

in effect, nor did CEOS review the federal prosecutors' inappropriate efforts to implement those tenns. We detail this point below. EFTA00208771 KIRKLAND & ELLIS LLP SUBMISSION TO THE OFFICE OF THE DEPUTY ATTORNEY GENERAL IN THE MATTER OF JEFFREY E. EPSTEIN Jeffrey Epstein, a successful businessman and noted ph

a, I was a part of the prosecution team that prosecuted the first case in the country under the federal Violence Against Women Act. United States v. Bailey, 112 F.3d 758 (4th Cir.), cert denied, 522 U.S. 896 (1997). The case went to trial and the defendant was sentenced to life in prison. l also spearh

KIRKLAND & ELLIS LLP make an independent decision not adversely affected by conclusions that over and over have proven, witness by witness, allegation by allegation, to

the communication itself—not the resulting act. The Court of Appeals for the Eleventh Circuit, in Murrell, underscores the point: The defendant in Bailey contended that attempt under § 2422(6) 'requires the specific intent to commit illegal sexual acts rather than just the intent to persuade or solic

KIRKLAND & ELLIS LLP SUBMISSION TO THE OFFICE OF THE DEPUTY ATTORNEY GENERAL IN THE MATTER OF JEFFREY E. EPSTEIN Jeffrey Epstein, a successful businessman and noted ph

the communication itself—not the resulting act. The Court of Appeals for the Eleventh Circuit, in Murrell, underscores the point: The defendant in Bailey contended that attempt under § 2422(b) `requires the specific intent to commit illegal sexual acts rather than just the intent to persuade or solic

ER, ESQUIRE Fl Bar No. 262013 co: The Honorable Sandra McSorley EFTA00214705 12/07/07 FRI 15:31 FAX 1 213 680 8500 KIRRLAND&ELLIS LLP I& 001 KIRKLAND & ELLIS LLP Fax Transmittal 777 South Figueroa Street Los Angeles, California 90017 Phone. (213) 680-8400 Fax: (213) 680-8500 Please notify us Immediately

sex act himself, he would nevertheless violate §2422(b)." United States v. Murrell, 368 F.3d 1283, 1286 (11th Cir. 2004). See also United States v. Bailey 228 F.3d 637, 639 (02' Cu. 2000) ("Congress has made a clear choice to criminalize persuasion and the attempt to persuade, not the performance of t

(213) 680-8500 (213) 680-8440 Fax 0: Direct II: Message: EFTA00176206 12/07/07 FRI 15:31 FAX 1 213 680 8500 K I RKLAND&ELLI S LLP WI Oo2 KIRKLAND & ELLIS LLP AND Affillaltb Kw not)) W. Starr To Call Wrier Directly: (213)88044440 kstarakirkland.com VIA FACSIMILE (305) 530-6444 Honorable R. Alexander

sex act himself, he would nevertheless violate §2422(b)." United States'. Murrell, 368 F.3d 1283, 1286 (1 I th Cir. 2004). See also United States'. Bailey 228 F.3d 637, 639 (61° Cir. 2000) ("Congress has made a clear choice to criminalize persuasion and the attempt to persuade, not the performance of t

y, Moskowitz, = Abdus-Salaam, JJ. 6081 30129/10 (*Wile People of the State of New York, Respondent, I Jeffrey E. Epstein, Defendant-Appellant. Kirkland & Ellis LLP, New York (Jay P. Lefkowitz of EFTA00184585 Case 9:08-cv-80736-KAM Document 361-38 Entered on FLSD Docket 02/10/2016 Page 3 of 5 counsel), for ap

York and in Florida. Estes stated they travel with Epstein everywhere he goes. I interviewed Zara Bailey of 35 Riverside Jersey City, New Jersey. Bailey stated she just arrived from Scotland and has worked with Zeff for only one month. She stated she has never met Epstein and has not seen him. The i

CONFIDENTIAL SUBMISSION TO THE OFFICE OF THE DEPUTY ATTORNEY GENERAL RE J. EPSTEIN HOUSE_OVERSIGHT_012135 --- PAGE BREAK --- KIRKLAND & ELLIS LLP AND AFFILIATED PARTNERSHIPS 777 South Figueroa Street Los Angeles, California 90017 Kenneth W. Starr : To Call Writer Directly: FP Facsimile: www

s the communication itself—not the resulting act. The Court of Appeals for the Eleventh Circuit, in Murrell, underscores the point: The defendant in Bailey contended that attempt under § 2422(b) ‘requires the specific intent to commit illegal sexual acts rather than just the intent to persuade or solicit

KIRKLAND & ELLIS LLP SUBMISSION TO THE OFFICE OF THE DEPUTY ATTORNEY GENERAL IN THE MATTER OF JEFFREY E. EPSTEIN Jeffrey Epstein, a successful businessman and noted ph

the communication itself—not the resulting act. The Court of Appeals for the Eleventh Circuit, in Murrell, underscores the point: The defendant in Bailey contended that attempt under § 2422(b) `requires the specific intent to commit illegal sexual acts rather than just the intent to persuade or solic