Epstein Secrets

Memorandum SubjectDate Re: Operation Leap Year March 15, 2007 ToFrom R. Alexander Acosta, United States Attorney Jeff Sloman, First Assistant United States Attorney M, Chief, Criminal Division MAUSA, Northern Region Chief, Northern Region 1. Introduction This memoran

unpersuaded: The calls were not accidentally or incidentally placed, but rather were made knowingly to further a scheme. . . . Accordingly, whether Drury knew or intended that they would travel across state lines is immaterial. Id. at 1313. In Drury , the Eleventh Circuit did not address whether the

hone call was between states) or purely intrastate in nature ( i.e. , the telephone call was made to another telephone within the same state)."). In Drury , the defendant used his land-line telephone to call an undercover agent's cellular telephone. Although both the defendant and the agent were in Ge

Memorandum SubjectDate Re: Operation Leap Year April 17, 2007 ToFrom R. Alexander Acosta, United States Attorney Jeff Sloman. First Assistant United States Attorney W , Chief, Criminal Division , MAUSA, Northern Region Chief, Northern Region 1. Introduction This memo

unpersuaded: The calls were not accidentally or incidentally placed, but rather were made knowingly to further a scheme. . . . Accordingly, whether Drury knew or intended that they would travel across state lines is immaterial. Id. at 1313. In Drury , the Eleventh Circuit did not address whether the

hone call was between states) or purely intrastate in nature ( i.e. , the telephone call was made to another telephone within the same state)."). In Drury , the defendant used his land-line telephone to call an undercover agent's cellular telephone. Although both the defendant and the agent were in Ge

Memorandum SubjectDate Re: Operation Leap Year January 31, 2007 ToFrom R. Alexander Acosta, United States Attorney Jeff Sloman. First Assistant United States Attorney er Chief, Criminal Division , MAUSA, Northern Region Chief, Northern Region I. Introduction This memoran

unpersuaded: The calls were not accidentally or incidentally placed, but rather were made knowingly to further a scheme. . . . Accordingly, whether Drury knew or intended that they would travel across state lines is immaterial. Id. at 1313. In Drury , the Eleventh Circuit did not address whether the

hone call was between states) or purely intrastate in nature ( i.e. , the telephone call was made to another telephone within the same state)."). In Drury , the defendant used his land-line telephone to call an undercover agent's cellular telephone. Although both the defendant and the agent were in Ge

Memorandum SubjectDate Re: Operation Leap Year April 30, 2007 ToFrom R. Alexander Acosta, United States Attorney Jeff Sloman. First Assistant United States Attorney M a, Chief, Criminal Division MAUSA, Northern Region , Chief, Northern Region 1. Introduction This memor

unpersuaded: The calls were not accidentally or incidentally placed, but rather were made knowingly to further a scheme. . . . Accordingly, whether Drury knew or intended that they would travel across state lines is immaterial. Id. at 1313. In Drury , the Eleventh Circuit did not address whether the

hone call was between states) or purely intrastate in nature ( i.e. , the telephone call was made to another telephone within the same state)."). In Drury , the defendant used his land-line telephone to call an undercover agent's cellular telephone. Although both the defendant and the agent were in Ge

do not fit within any proper construction of any of the federal criminal statutes under consideration. • 4 First Assistant United States Attorney Jeffrey Sloman sought to preclude Mr. Epstein or his agents from communicating with the alleged "victims." See November 5, 2007 Letter from J. Sloman, Exhibit I. D

due to a procedure available under state law, and following the wave of recent lawsuits that have been filed against Mr. Epstein (ironically by Mr. Sloman's former law partner), we have been able to engage in discovery and take sworn statements from several of the alleged victims. These statements, wh

if it intends to pre-empt the historic powers of the itates') (quoting Rice' Santa Fe Elevator Corp., 331 U.S. 218 (1947)); see also United States Drury, 344 F.3d 1089, 1101 (11th Cir. 2003) (recognizing that in the absence of "unmistakably clear" language signaling Congress's intent to alter the fe

unpersuaded: The calls were not accidentally or incidentally placed, but rather were made knowingly to further a scheme. . . . Accordingly, whether Drury knew or intended that they would travel across state lines is immaterial. Id. at 1313. In Drury, the Eleventh Circuit did not address whether the d

d Addendum to Prosecution Memorandum USAO No. 2006R01181 September 13, 2007 Atworuktok Zit //002 To R. Alexander Acosta United States Attorney Jeffrey Sloman First Assistant U.S. Attorney Deputy Chief, Criminal Division, West Palm Beach Chief Chief, Criminal Section I, Northern Division, WPB From AUS