EFTA00013785.pdf

"I write to offer my reaction to the May 15, 2008 correspondence from the United States Department of Justice Child Exploitation and Obscenity Section"

"topless massages to him at his Palm Beach home"

"ultimately to Principal Deputy Chief for the Section in 2004"

"ALLEN GUTHRIE MCHUGH & THOMAS, PLLC ... DAVID B. THOMAS"

"federal investigation of Jeffrey Epstein by the United States Attorney's Office for the Southern District of Florida"

"ALLEN GUTHRIE MCHUGH & THOMAS, PLLC Mr. John Roth June 19, 2008"

"the USAO has indicated its intent to prosecute Mr. Epstein for purported violations of 18 U.S.C. §§ 2422, 2423, and 1591"

"we conclude that U.S. Attorney Acosta could properly use his discretion to authorize prosecution in this case"

"In his recent letter to Jay Lelkowitz, First Assistant United States Attorney ("FAUSA") Sloman letter at p. 5"

"we have been able to show are misleading and inaccurate... unfairly prejudice Mr. Epstein to the financial benefit of the friends and colleagues of th"

"First Assistant United States Attorney ("FAUSA") confirmed our understanding that the USAO was to have facilitated"

"Mr. Epstein was indicted by a State grand jury on a single felony count of solicitation of prostitution."

"Lana Belohlavek... Chief of the SAO Sex Crimes Division"

"The federal prosecution of Mr. Epstein has been a moving target from the inception."

"Following an extensive 15-month State investigation, Mr. Epstein was indicted by a State grand jury"

"Mr. filed a $50million lawsuit purportedly on behalf of his daughter without her authority or knowledge."

"Given that each has brought a civil lawsuit against Mr. Epstein, with Ms. and her family seeking $50 million from Mr. Epstein"

"the complaint of an alleged victim, but, rather, upon the complaint father"

"Mr. John Roth June 19, 2008"

"ALLEN GUTHRIE MCHUGH & THOMAS, PLLC Mr. John Roth June 19, 2008"

"she went to Mr. Epstein's house (she went there only once)"

"ALLEN GUTHRIE MCHUGH & THOMAS, PLLC... Mr. John Roth June 19, 2008... The investigation and testimony in this case makes clear that Mr. Epstein did no"

"Mr. Epstein was returning to one of his residences when he traveled to Florida"

"Mr. Epstein visited his mother nearly every weekend in Palm Beach until she passed away in April, 2004."

"I will refrain from recounting Mr. Epstein's arguments in detail here, but, rather, will highlight salient points responsive to the CEOS letter."

"Ms. , for instance, has testified that Ms. =, who introduced her to Mr. Epstein, expressly told her to lie to Mr. Epstein about her age."

"Ms. =, who introduced her to Mr. Epstein, expressly told her to lie to Mr. Epstein about her age."

"the women he permitted entry to his residence."

"the dominant purpose for his traveling to Palm Beach was not to engage in illegal sexual activity, but to simply return to one of his residences."

"the USAO should not be permitted to pursue an unfounded federal criminal case against Mr. Epstein under the guise of prosecutorial discretion"

"Mr. Epstein masturbated, engaged in some sexual touching, and a small number of alleged acts of penetration... relative to the government's primary, a"

"The fact that CEOS had to evaluate its own decision with respect to some of the allegations against Mr. Epstein prevents its subsequent review and opi"

"the State of Florida and Palm Beach County are effectively prosecuting and punishing that conduct"

"we have found that the allegations have been misrepresented... submitted in this regard, while acknowledging that the theories are 'novel,' and that o"

"Mr. Acosta could rightfully conclude that this federal issue is best resolved by a jury"

"told Mr. Epstein that she was 18 years old, and confirmed this fact with Palm Beach Police."

"In particular, § 2422(b) requires that the defendant specifically intended to target a minor."

"was clear on this point at her deposition during which she repeatedly testified that nobody—not Mr. Epstein or any of his assistants—ever used the Int"

"CEOS explicitly stated it fully understand[s] our argument (CEOS letter at p.2) that Mr. Epstein should not be charged under 2423(b)"

"our request that Mr. Epstein should not be prosecuted federally would not permit him to go completely unpunished"

"In sum, to accord discretion to the USAO, albeit without benefit of the requested full de novo review"

"Mr. Epstein paid individuals to find friends and acquaintances, certain of whom were under the age of 18, to provide topless massages to him at his Pa"

"Lana Belohlavek not only met with and interviewed these witnesses during the course of the 15-month state investigation"

"The investigation and testimony in this case makes clear that Mr. Epstein did not use any facility of interstate commerce to commit any act forbidden "

"As to the purported violation of 18 U.S.C. 2423 for allegedly traveling in interstate commerce for the purpose of engaging in illicit sexual activity"

"were § 1591 not limited in this fashion... the USAO has not met its burden for any victim for any of the crimes alleged."