EFTA00013811.pdf

"SUBMISSION TO THE OFFICE OF THE DEPUTY ATTORNEY GENERAL"

"We have reviewed every reported case under 18 U.S.C. 1591, 2422(b), and 2423(b), and cannot find a single one that resulted in a conviction on facts a"

"November 9, 2007 Letter from Justice Department Principal Deputy Assistant Attorney General Brian Benczkowski to the House Committee on the Judiciary"

"November 2, 1994 Memorandum from Assistant Attorney General Walter Dellinger to the Hon. Abner J. Mikva, Counsel To The President"

"The prosecution has never represented to counsel that they have evidence that would prove that the inducement or enticement to engage in illegal sexua"

"the phone calls were made by his assistants in the course of setting up many other appointments"

"prosecutors have signaled that they intend to offer a purely circumstantial case if this matter proceeds to trial"

"several individuals who were contacted by phone visited Mr. Epstein's house"

"his travels to Palm Beach were merely trips returning often to his home of twenty years"

"Mr. Epstein did not travel to Palm Beach for the purpose of engaging in sexual activity with a minor"

"the FBI attempted to persuade her that she was in fact a victim of federal crimes when she herself repeatedly confirmed that she was not."

"Mr. Epstein spent at least 100 days a year in Palm Beach for family purposes, business purposes, and social purposes, and to maintain a home."

"regularly saw his mother who was hospitalized and then convalesced in south Florida."

"KIRKLAND & ELLIS LLP... There is simply no basis for the federal prosecutors' disparate treatment of Mr. Epstein."

"Mr. Epstein's conduct does not satisfy the elements of 2422(b). Each element must be individually stretched, and then conflated in a tenuous chain to "

"several individuals who were contacted by phone visited Mr. Epstein's house and did not perform a massage at all"

"Well, these girls that I brought, I know that they were 18 or 19 or 20. And the girls that I didn't know... I would say make sure that you tell him yo"

"she was informed that she was going to Mr. Epstein's house to give him a massage and nothing else"

"direct the U.S. Attorney's Office for the Southern District of Florida to discontinue its involvement in this matter"

"The SAO, therefore, sought and obtained an indictment charging Mr. Epstein"

"The conflict between the Santos and Cuellar decisions and CEOS's grant of effectively unlimited discretionary authority to the USAO to take federal la"

"several individuals who were contacted by phone visited Mr. Epstein's house"

"The text is a legal memorandum prepared by Kirkland & Ellis LLP arguing on behalf of Mr. Epstein regarding federal prosecution elements."

"he cannot be guilty of an offense under 2422(b)"

"prosecuting him under this statute would expand the law far beyond its scope"

"Mr. Epstein's assistant"

"Mr. Epstein (or his assistants) did any such thing"

"to visit his sick and dying mother in the hospital for months on end"

"she first met Mr. Epstein when her friend, [REDACTED-003], introduced her to him."

"necessary for a conviction under § 1591... confirming that further federal involvement in this matter would be inappropriate."

"Jeffrey Epstein... should not be prosecuted federally for conduct that amounts to, the solicitation of prostitution."

"KIRKLAND & ELLIS LLP ... We have not been able to find a single federal prosecution based on facts like these"

"Nor can the cause requirement be proved simply by the fact that Mr. Epstein compensated the women."

"the fact that Mr. Epstein later may have persuaded any particular masseuse to engage in unlawful activity during the massage"

"many of the women phoned Mr. Epstein's assistant themselves in order to determine whether he wanted a massage"

"return responsibility for this case to the State of Florida"

"there is no evidence that Palm Beach County authorities and Florida prosecutors cannot effectively prosecute and punish the conduct."

"Under Florida law, prostitution entails... Absent proof... he cannot be guilty of an offense under 2422(b)."

"As Justice Alito stated in his concurring opinion... Cuellar v. United States, supra"

"In Boehm, the defendant was charged with conspiracy to distribute cocaine and cocaine base to minors"

"Mr. Kutun pleaded guilty on May 18, 2007 in a Miami-Dade County courtroom as part of an agreement with State prosecutors and he received five years pr"