WEBVTT
1
00:00:00.200 --> 00:00:03.160
What's up everyone and welcome to another episode of the
2
00:00:03.259 --> 00:00:06.419
Epstein Chronicles. In this episode, we're going to dive right
3
00:00:06.459 --> 00:00:12.189
back into the letter sent by Epstein's lawyers to Alex Acosta. B.
4
00:00:12.849 --> 00:00:18.589
Redacted prompted an unduly invasive investigation of Mr. Epstein. Redacted's
5
00:00:18.649 --> 00:00:22.609
investigation of Mr. Epstein raises serious questions, despite the fact
6
00:00:23.019 --> 00:00:25.879
that she was made aware of the inaccuracies in the
7
00:00:25.920 --> 00:00:30.839
PBPD's probable cause affidavit She chose to include the affidavit
8
00:00:31.219 --> 00:00:33.679
in the document file with the court knowing that the
9
00:00:33.719 --> 00:00:38.009
public could access it. Then Redacted issued letters requesting documents
10
00:00:38.049 --> 00:00:43.170
whose subject matter have no relation to the allegations against Mr. Epstein. Notably,
11
00:00:43.289 --> 00:00:46.689
after we objected to these overly broad and intrusive requests,
12
00:00:47.130 --> 00:00:51.509
Deputy Chief Redacted denied knowledge of Redacted's actions, and Redacted
13
00:00:51.850 --> 00:00:56.219
commendably sought to significantly narrow the list of documents requested.
14
00:00:57.109 --> 00:00:59.990
In a subsequent court filing, Redacted referred to our agreement
15
00:01:00.229 --> 00:01:03.409
to remove these items from her demand list as evidence
16
00:01:03.429 --> 00:01:08.239
of Mr. Epstein's non-cooperation. This was only the beginning. Redacted
17
00:01:08.420 --> 00:01:12.040
also subpoenaed the agent of Roy Black without following the
18
00:01:12.060 --> 00:01:16.019
guidelines provided in the U.S. Attorney's Manual that require prior
19
00:01:16.060 --> 00:01:20.439
notification to Washington necessary to seek lawyers' records. We once
20
00:01:20.500 --> 00:01:24.299
more requested Mr. Lurie to intervene. Despite these efforts, Redacted
21
00:01:24.359 --> 00:01:27.670
followed up with a subpoena of for Mr. Epstein's confidential
22
00:01:27.790 --> 00:01:32.150
medical records served directly on his chiropractor, with no notice
23
00:01:32.170 --> 00:01:35.879
to Mr. Epstein. Redacted also made the unusual request of
24
00:01:36.000 --> 00:01:38.579
asking the state attorney's office for some of the grand
25
00:01:38.599 --> 00:01:42.319
jury material. She threatened to subpoena the state when she
26
00:01:42.359 --> 00:01:44.980
was informed that it was in violation of Florida law
27
00:01:45.319 --> 00:01:49.319
to release this information. After compiling this evidence, Redacted stated
28
00:01:49.359 --> 00:01:52.319
that she would be initiating an investigation into a purported
29
00:01:52.359 --> 00:01:57.590
violation of U.S. Code 18, Section 7, 1591, again without
30
00:01:57.650 --> 00:02:02.599
required prior DOJ notification. Redacted then broadened the scope of
31
00:02:02.620 --> 00:02:06.040
the investigation without any foundation for doing so by adding
32
00:02:06.060 --> 00:02:09.800
charges of money laundering and violations of a money transmitting
33
00:02:09.840 --> 00:02:14.219
business to the investigation. Mr. Epstein's counsel explained that there
34
00:02:14.259 --> 00:02:17.490
could be no basis for these charges since Mr. Epstein
35
00:02:17.509 --> 00:02:21.210
did not commit any prerequisite act for a money laundering
36
00:02:21.250 --> 00:02:26.240
charge and has never even engaged in a money transmitting business. Ms.
37
00:02:26.280 --> 00:02:29.479
Redacted responded that Mr. Epstein could be charged under these
38
00:02:29.520 --> 00:02:33.689
statutes because he funded illegal activities. To suggest that Mr.
39
00:02:33.789 --> 00:02:37.409
Epstein could violate these statutes simply by spending his legally
40
00:02:37.469 --> 00:02:41.930
earned money on prostitutes is manifestly an erroneous interpretation of
41
00:02:41.969 --> 00:02:45.479
the law. To our relief, after briefing Redacted at a
42
00:02:45.520 --> 00:02:49.780
meeting regarding the spurious application of these statuses, we were
43
00:02:49.819 --> 00:02:53.800
told to ignore the laundry list and that defense counsel
44
00:02:53.919 --> 00:02:58.599
should focus on be turned to U.S. Code 18, Section 2422B.
45
00:02:59.240 --> 00:03:02.460
Once Mr. Epstein's counsel submitted and presented the reasons why
46
00:03:02.500 --> 00:03:06.039
a federal case would require stretching the relevant federal statutes
47
00:03:06.340 --> 00:03:10.180
beyond recognition, and that federal involvement in this matter should
48
00:03:10.259 --> 00:03:13.889
be precluded based on the federalism concerns, the petite policy,
49
00:03:14.270 --> 00:03:19.289
and general principles of prosecutorial discretion, the parties commenced discussions
50
00:03:19.349 --> 00:03:22.750
of a possible plea agreement. Around this time, we received
51
00:03:22.789 --> 00:03:25.849
an email from Redacted suggesting that that she wanted to
52
00:03:25.909 --> 00:03:29.530
discuss the possibility of a concurrent federal and state resolution.
53
00:03:30.229 --> 00:03:33.210
We were immediately informed by your office that Redacted did
54
00:03:33.250 --> 00:03:35.849
not have the authority to make any such plea proposals
55
00:03:36.210 --> 00:03:38.830
and would not be involved in any further negotiations of
56
00:03:38.889 --> 00:03:43.090
a plea. Despite this commitment, Redacted was the principal negotiator
57
00:03:43.129 --> 00:03:47.159
of the agreement. At our meeting on September 7th, she
58
00:03:47.189 --> 00:03:50.860
made reference to an allegation against Mr. Epstein involving a
59
00:03:50.879 --> 00:03:55.289
12-year-old individual. This allegation is without merit, and without foundation.
60
00:03:55.909 --> 00:03:59.740
Though your last letter suggests that there waxed or was
61
00:03:59.789 --> 00:04:03.120
no contact between individuals in your office and the press,
62
00:04:03.699 --> 00:04:06.740
we were previously told by Redacted that the FBI was
63
00:04:06.780 --> 00:04:10.960
receiving information specifically from Connolly, a Vanity Fair reporter, and
64
00:04:11.000 --> 00:04:17.000
not vice versa. C. Redacted included unfair terms in the agreement.
65
00:04:17.680 --> 00:04:21.430
Redacted took positions in negotiating this matter that stray from
66
00:04:21.459 --> 00:04:25.769
both stated policy and established law. First, redacted insisted that
67
00:04:25.829 --> 00:04:28.720
as part of the federal plea agreement, the state attorney's office,
68
00:04:28.759 --> 00:04:32.680
without being shown new evidence, should be convinced to charge Mr.
69
00:04:32.759 --> 00:04:36.240
Epstein with violations of law and recommend a sentence that
70
00:04:36.300 --> 00:04:40.410
are significantly harsher than what the state deemed appropriate. In fact,
71
00:04:40.430 --> 00:04:43.870
the state attorneys viewed this matter as a straightforward prostitution
72
00:04:43.889 --> 00:04:46.750
case and believed that a term of probation was and
73
00:04:46.889 --> 00:04:52.209
is the appropriate sentence. At redacted's insistence, however, Mr. Epstein
74
00:04:52.250 --> 00:04:56.050
was forced to undertake the highly unusual and unprecedented action
75
00:04:56.529 --> 00:04:59.689
of directing his defense team to contract the state prosecutors
76
00:04:59.730 --> 00:05:03.259
themselves and ask for an upward departure in both his
77
00:05:03.300 --> 00:05:06.779
indictment and sentence. There was no effort by the state
78
00:05:06.819 --> 00:05:10.920
and federal prosecutors to coordinate the prosecutions, a practice which
79
00:05:11.000 --> 00:05:14.759
is against the tenets of the Petit policy. In our view,
80
00:05:15.180 --> 00:05:19.439
it's unprecedented to micromanage Each and every term of Mr.
81
00:05:19.519 --> 00:05:23.060
Epstein's state plea, including the exact state charges to which Mr.
82
00:05:23.160 --> 00:05:26.899
Epstein pled guilty, the time frame within Mr. Epstein must
83
00:05:27.000 --> 00:05:30.019
enter the state plea and surrender to state officials and
84
00:05:30.040 --> 00:05:32.560
the amount of time he must spend in county jail.
85
00:05:33.300 --> 00:05:37.160
This is particularly true where the state attorney's office has
86
00:05:37.220 --> 00:05:39.660
a different view of the case and there has been
87
00:05:39.699 --> 00:05:44.279
no coordination with state authorities. In addition, redacted require that Mr.
88
00:05:44.379 --> 00:05:49.110
Epstein's sentence include a registerable offense. As you know, requiring
89
00:05:49.170 --> 00:05:53.329
sex offender registration will have significant impact both immediately and
90
00:05:53.379 --> 00:05:56.480
forever after. This harsh term, which is said to be
91
00:05:56.540 --> 00:05:59.560
suggested by the FBI, was added despite the fact that
92
00:05:59.600 --> 00:06:02.740
the state believed that Mr. Epstein's conduct did not warrant
93
00:06:03.160 --> 00:06:07.009
any such registration. As you know, state officials have special
94
00:06:07.069 --> 00:06:12.009
expertise in deciding which offenders pose a threat to their community. Moreover,
95
00:06:12.089 --> 00:06:16.000
this demand placed the state's prosecutors' credibility at issue and
96
00:06:16.040 --> 00:06:19.100
diminishes the force of sexual registration when it's applied to
97
00:06:19.160 --> 00:06:22.759
offenders who state prosecutors do not believe are dangerous or
98
00:06:22.819 --> 00:06:27.579
require registration. Redacted's decision not to permit the state attorney
99
00:06:27.639 --> 00:06:31.360
to determine a matter uniquely within its province was unwarranted.
100
00:06:32.779 --> 00:06:36.000
What is more, when negotiating the settlement portion of the agreement,
101
00:06:36.360 --> 00:06:39.680
Redacted insisted that a civil settlement provision be included in
102
00:06:39.699 --> 00:06:45.019
the agreement, namely the inclusion of U.S. Code 18, Section 2255.
103
00:06:45.209 --> 00:06:48.970
a negotiating term which is unprecedented in nature. While we
104
00:06:48.990 --> 00:06:51.850
were reluctant and cautious about a plea agreement in which
105
00:06:51.889 --> 00:06:55.410
a criminal defendant gives up certain rights to contest liability
106
00:06:55.449 --> 00:07:00.269
for a civil settlement, redacted's ultimatums required that we acquiesce
107
00:07:00.310 --> 00:07:04.529
to these unprecedented terms. For instance, when plea discussion stalled
108
00:07:04.829 --> 00:07:08.290
as a result of redacted's demands, Mr. Epstein's counsel received
109
00:07:08.329 --> 00:07:11.110
a letter from her stating, as it now appears you
110
00:07:11.129 --> 00:07:15.079
will not settle. At this point, redacted expressed, her intention
111
00:07:15.120 --> 00:07:20.620
to relaunch the government's previously set-aside money laundering investigation. She
112
00:07:20.699 --> 00:07:23.610
also issued a rush of subpoenas and sent target letters
113
00:07:23.629 --> 00:07:27.449
to Mr. Epstein's employees, adding new federal charges including obstruction
114
00:07:27.470 --> 00:07:31.550
of justice. She then personally called Mr. Epstein's largest and
115
00:07:31.589 --> 00:07:34.709
most valued business client without any basis to inform him
116
00:07:35.230 --> 00:07:39.579
of the investigation. In an attempt to prevent further persecution
117
00:07:40.240 --> 00:07:44.740
and intimidation, We proposed that Mr. Epstein establish a restitution
118
00:07:44.769 --> 00:07:48.519
fund specifically for the settlement of the identified individual's civil
119
00:07:48.579 --> 00:07:52.980
claims and that an impartial independent representative be appointed to
120
00:07:53.040 --> 00:07:56.540
administer that fund. There was no dollar amount limit discussed
121
00:07:56.579 --> 00:08:00.410
for the fund, but the idea was still rejected. We
122
00:08:00.470 --> 00:08:03.250
then pointed out the state's charges to which Mr. Epstein
123
00:08:03.310 --> 00:08:06.250
was to plead guilty carried with it a state restitution
124
00:08:06.290 --> 00:08:10.970
provision that would allow victims to recover damages. Misredacted, however...
125
00:08:11.029 --> 00:08:15.269
rejected this idea and suggested requiring a guardian ad litium
126
00:08:15.689 --> 00:08:19.050
implying that the alleged victims in question were currently minors
127
00:08:19.389 --> 00:08:23.189
and needed special representation. We later learned that the government's
128
00:08:23.250 --> 00:08:27.100
list of individuals included a woman as old as 24,
129
00:08:27.100 --> 00:08:30.300
which flies in the face of prior representations. It should
130
00:08:30.319 --> 00:08:33.159
be noted that any person who is currently 24 years
131
00:08:33.179 --> 00:08:35.840
or older could not have been a victim under U.S.
132
00:08:35.860 --> 00:08:40.039
Code Section 2255, even if the conduct occurred in 2001.
133
00:08:41.379 --> 00:08:45.080
At Redacted's insistence, the parties ultimately agreed to the appointment
134
00:08:45.120 --> 00:08:48.779
of an attorney representative. But Redacted then took the position
135
00:08:49.110 --> 00:08:52.049
that Mr. Epstein should pay for the representative's fees, which
136
00:08:52.090 --> 00:08:54.970
effectively meant that Mr. Epstein must pay to sue himself.
137
00:08:55.850 --> 00:08:59.990
Redacted also proposed wholly irrelevant charges, such as making obscene
138
00:09:00.029 --> 00:09:04.049
phone calls and violations of child privacy laws. When Redacted
139
00:09:04.090 --> 00:09:07.090
learned of these proposed charges, he asked Mr. Epstein's defense
140
00:09:07.110 --> 00:09:11.470
team to ignore them, as they would embarrass the office. d.
141
00:09:12.529 --> 00:09:16.820
Redacted continually and purposefully misinterpreted the critical terms of the agreement.
142
00:09:17.620 --> 00:09:21.159
Since the execution of the agreement redacted as repeatedly and misconstrued,
143
00:09:21.480 --> 00:09:25.059
the terms contained therein. As you know, several facets of
144
00:09:25.100 --> 00:09:28.450
this matter have been highly contested by both parties. We
145
00:09:28.500 --> 00:09:32.090
sometimes have obtained two competing views as to your willingness
146
00:09:32.389 --> 00:09:35.450
to compromise on specific issues that we have raised with
147
00:09:35.470 --> 00:09:38.730
your office. In particular, there are times when we receive
148
00:09:38.769 --> 00:09:42.100
verbal agreement from you or your staff and sometimes from
149
00:09:42.120 --> 00:09:46.399
misredacted herself, on a particular issue, only to subsequently receive
150
00:09:46.440 --> 00:09:51.649
a contradictory interpretation from misredacted that negates our prior common understanding.
151
00:09:53.610 --> 00:09:57.110
Her misrepresentations appear to be attempts to effectively change the
152
00:09:57.149 --> 00:10:02.149
spirit and the meaning of the non-prosecution agreement. We offer
153
00:10:02.230 --> 00:10:08.080
several examples of significant misrepresentations. First, despite the fact that
154
00:10:08.100 --> 00:10:10.740
we received several commitments from your office that it would
155
00:10:10.779 --> 00:10:13.960
monitor Mr. Epstein's state sentencing but not interfere with it
156
00:10:14.000 --> 00:10:17.750
in any way, Ms. Redacted sought to do just that. Ms.
157
00:10:17.789 --> 00:10:21.179
Redacted's decision to utilize a civil remedy statute in the
158
00:10:21.220 --> 00:10:24.679
place of a restitution fund for the alleged victims eliminates
159
00:10:24.740 --> 00:10:29.159
a notification requirement under the Justice for All Act in 2004,
160
00:10:29.159 --> 00:10:32.500
a federal law that requires federal authorities to notify victims
161
00:10:32.879 --> 00:10:36.769
as to any available restitution, not of any potential civil remedies,
162
00:10:37.470 --> 00:10:40.789
to which they're entitled. Despite this fact, Ms. Redacted proposed
163
00:10:40.850 --> 00:10:43.629
a victim's notification letter to be sent to the alleged
164
00:10:43.669 --> 00:10:47.620
federal victims. Ms. Redacted has gone even further. alleging that
165
00:10:47.639 --> 00:10:50.899
the victims may take written statements or testify against Mr.
166
00:10:51.000 --> 00:10:54.029
Epstein at the sentencing. We find no basis in law
167
00:10:54.450 --> 00:10:57.970
or the agreement that provides the identified individuals with either
168
00:10:58.049 --> 00:11:01.009
a right to appear at Mr. Epstein's plea and sentence
169
00:11:01.370 --> 00:11:03.559
or to submit a written statement to be filed by
170
00:11:03.580 --> 00:11:06.940
the state attorney. Here, Mr. Epstein is pleading guilty to
171
00:11:07.000 --> 00:11:10.159
and being sentenced for state offenses, not the federal offenses
172
00:11:10.240 --> 00:11:14.710
under which the government has unilaterally recognized these identified individuals
173
00:11:14.830 --> 00:11:18.419
as victims. The notion that individuals whose names are not
174
00:11:18.480 --> 00:11:21.769
even known to the charging prosecutor in a state actually
175
00:11:21.789 --> 00:11:26.450
should somehow be allowed to speak at a proceeding is unjustifiable. Furthermore,
176
00:11:26.809 --> 00:11:30.309
only after obtaining the executed agreement did Ms. Redacted begin
177
00:11:30.350 --> 00:11:34.379
insisting that the selected representative's duties go beyond settlement and
178
00:11:34.409 --> 00:11:40.039
include litigating claims for individuals. In Ms. Redacted's victim's notification letter,
179
00:11:40.320 --> 00:11:43.779
she states that Mr. Potthurst and Ms. Josephsburg, the selected
180
00:11:43.799 --> 00:11:48.779
of attorneys' representatives, may present the identified individuals. This language
181
00:11:48.840 --> 00:11:53.080
assumes the selected representatives will agree to serve in the
182
00:11:53.120 --> 00:11:57.299
capacity envisioned by Ms. Redacted, which is patently incorrect. Yet
183
00:11:57.360 --> 00:12:01.200
neglecting the spirit of principle of ethic with respects to conflict, Ms.
184
00:12:01.250 --> 00:12:05.909
Redacted continues to improperly emphasize that the chosen attorney representative
185
00:12:06.190 --> 00:12:09.490
should be able to litigate the claims of individuals. In
186
00:12:09.509 --> 00:12:12.809
a similar fashion, Ms. Redacted has overstated the scope of Mr.
187
00:12:12.889 --> 00:12:17.279
Epstein's waiver of of liability pursuant to the agreement. Misredacted
188
00:12:17.320 --> 00:12:20.919
began asserting that Mr. Epstein has waived liability even when
189
00:12:20.980 --> 00:12:24.440
claims with identified individuals are not settled just after the
190
00:12:24.500 --> 00:12:28.350
execution of the agreement. Despite the fact that at this
191
00:12:28.389 --> 00:12:31.549
time we obtained an agreement from you that Mr. Epstein's
192
00:12:31.590 --> 00:12:36.090
waiver would not stretch past settlement, misredacted continues to espouse
193
00:12:36.490 --> 00:12:41.610
this erroneous interpretation. F. Misredacted in the settlement process. We're
194
00:12:41.629 --> 00:12:44.769
concerned that Ms. Redacted has repeatedly attempted to manipulate the
195
00:12:44.789 --> 00:12:49.309
process under which Mr. Epstein has agreed to settle civil claims. First,
196
00:12:49.350 --> 00:12:54.789
she inappropriately attempted to nominate Humbert Burt Ocariz for attorney
197
00:12:54.830 --> 00:12:59.129
representative despite the fact that Mr. Ocariz has a long-standing
198
00:12:59.169 --> 00:13:02.990
relationship with Ms. Redacted. Mr. Ocariz turns out to be
199
00:13:03.029 --> 00:13:05.980
a very good personal friend and law school classmate of Ms.
200
00:13:06.000 --> 00:13:10.220
Redacted's boyfriend, a fact she assiduously kept hidden from counsel.
201
00:13:11.009 --> 00:13:13.639
We also learned that Ms. Redacted that she shared the
202
00:13:13.840 --> 00:13:16.860
Ocariz the summary of the charges the government was considering
203
00:13:17.220 --> 00:13:20.720
against Epstein, even after your office conceded that it was
204
00:13:20.759 --> 00:13:25.370
inappropriate for its attorneys to select an attorney representative. Ms.
205
00:13:25.399 --> 00:13:31.110
Redacted continued to lobby for Mr. Ocariz's appointment. On October 19, 2007,
206
00:13:31.110 --> 00:13:34.049
retired Judge Edward B. Davis, who was appointed by the
207
00:13:34.110 --> 00:13:38.129
parties to select the attorney representative, informed Mr. Epstein's counsel
208
00:13:38.629 --> 00:13:42.120
that he received a telephone call from Mr. Okeriz, directly
209
00:13:42.200 --> 00:13:45.659
requesting that Judge Davis appoint him as the attorney representative
210
00:13:45.700 --> 00:13:49.610
in the matter. Furthermore, federal interference continues to plague the
211
00:13:49.659 --> 00:13:53.809
integrity of the implementation of the agreement. We recently learned
212
00:13:53.850 --> 00:13:56.789
that despite the fact that there was no communication between
213
00:13:56.830 --> 00:14:00.190
state and federal authorities as to the investigation of Mr. Epstein,
214
00:14:00.509 --> 00:14:03.250
the FBI visited the state attorney's office two weeks ago
215
00:14:03.269 --> 00:14:07.879
to request Mr. Epstein be disqualified to participate in work release,
216
00:14:08.299 --> 00:14:11.220
even though the agreement mandates that Mr. Epstein be treated
217
00:14:11.600 --> 00:14:15.139
as any other inmate. 3. Conclusion In sum, we request
218
00:14:15.159 --> 00:14:18.600
that you review the evidence supporting the prosecution of Mr. Epstein.
219
00:14:19.059 --> 00:14:21.960
Such a review would serve to address similar concerns as
220
00:14:22.000 --> 00:14:25.480
those raised in Brady v. Maryland, which mandate the disclosure
221
00:14:25.500 --> 00:14:28.929
of evidence material to guilt or innocence, even after the
222
00:14:28.990 --> 00:14:31.490
execution of an agreement, to enter a plea of guilty.
223
00:14:32.549 --> 00:14:35.450
We believe that the prosecution team was informed by its witnesses,
224
00:14:35.830 --> 00:14:39.090
including persons other than redacted and redacted, who were discussed
225
00:14:39.149 --> 00:14:41.980
at length above, that Mr. Epstein's practice was to seek
226
00:14:42.059 --> 00:14:46.549
women older than 18 rather than targeting those under 18.
227
00:14:46.549 --> 00:14:49.269
We would expect, for instance, that redacted a key witness
228
00:14:49.590 --> 00:14:52.649
whose interview with the FBI was recorded would have provided
229
00:14:52.730 --> 00:14:56.409
such exonerating information as well as many others. We would
230
00:14:56.450 --> 00:14:59.809
also expect the review to uncover clear evidence that demonstrates
231
00:14:59.830 --> 00:15:02.450
that Mr. Epstein did not travel to Florida for the
232
00:15:02.490 --> 00:15:05.929
purpose of having illegal underage sex, nor that he induced
233
00:15:05.980 --> 00:15:10.490
underage women by using the internet or phones. Furthermore, we
234
00:15:10.590 --> 00:15:13.629
ask you to consider whether there's reliable evidence, not just
235
00:15:13.649 --> 00:15:17.570
that Mr. Epstein had sexual contact with witnesses who are
236
00:15:17.610 --> 00:15:21.120
in fact underage, but whether the allegations are based on
237
00:15:21.159 --> 00:15:24.899
trustworthy and corroborated evidence that Mr. Epstein knew that the
238
00:15:24.960 --> 00:15:27.940
females in question were under 18 at the time of
239
00:15:27.980 --> 00:15:31.340
sexual contact to Mr. Epstein traveled to his home in
240
00:15:31.379 --> 00:15:34.450
Palm Beach for the purpose of having such sexual contact
241
00:15:34.470 --> 00:15:37.909
to the extent the allegation charges a violation of of U.S.
242
00:15:37.929 --> 00:15:42.850
Code 18 Section 2423B and C. And Mr. Epstein induced
243
00:15:42.889 --> 00:15:47.370
such sexual contact by using an instrumentality of interstate commerce
244
00:15:47.409 --> 00:15:51.129
to the extent the allegations charge a violation of 18 U.S.
245
00:15:51.169 --> 00:15:56.879
Code Section 2422B. There's no evidence of internal solicitation, which
246
00:15:56.940 --> 00:16:00.320
is the norm upon which federal jurisdiction is usually modeled
247
00:16:00.440 --> 00:16:03.649
under the statutes. We believe that the information we provide
248
00:16:03.690 --> 00:16:06.850
to you in this submission will be informative and spark
249
00:16:06.870 --> 00:16:10.029
a motivation to gain more information with respect to the
250
00:16:10.070 --> 00:16:13.909
investigation of the matter. Again, we're not seeking to unwind
251
00:16:13.950 --> 00:16:16.789
the agreement. We're only seeking for you to exercise your
252
00:16:16.840 --> 00:16:20.320
discretion in directing that an impartial and respected member of
253
00:16:20.340 --> 00:16:23.500
your office test the evidence upon which the draft federal
254
00:16:23.539 --> 00:16:27.419
indictment was based against, the best evidence, including the transcripts
255
00:16:27.779 --> 00:16:31.769
of the tape-recorded pre-federal involvement interviews. Finally, I'd like to
256
00:16:31.870 --> 00:16:35.629
reiterate our appreciation for the opportunity to have provided to
257
00:16:35.669 --> 00:16:38.710
review some of our issues and concerns. I look forward
258
00:16:38.730 --> 00:16:42.250
to speaking with you shortly. This was signed by Jay Lefkowitz.
259
00:16:43.669 --> 00:16:46.110
All the information that goes with this episode can be
260
00:16:46.149 --> 00:16:48.100
found in the description box.
1
00:00:00.200 --> 00:00:03.160
What's up everyone and welcome to another episode of the
2
00:00:03.259 --> 00:00:06.419
Epstein Chronicles. In this episode, we're going to dive right
3
00:00:06.459 --> 00:00:12.189
back into the letter sent by Epstein's lawyers to Alex Acosta. B.
4
00:00:12.849 --> 00:00:18.589
Redacted prompted an unduly invasive investigation of Mr. Epstein. Redacted's
5
00:00:18.649 --> 00:00:22.609
investigation of Mr. Epstein raises serious questions, despite the fact
6
00:00:23.019 --> 00:00:25.879
that she was made aware of the inaccuracies in the
7
00:00:25.920 --> 00:00:30.839
PBPD's probable cause affidavit She chose to include the affidavit
8
00:00:31.219 --> 00:00:33.679
in the document file with the court knowing that the
9
00:00:33.719 --> 00:00:38.009
public could access it. Then Redacted issued letters requesting documents
10
00:00:38.049 --> 00:00:43.170
whose subject matter have no relation to the allegations against Mr. Epstein. Notably,
11
00:00:43.289 --> 00:00:46.689
after we objected to these overly broad and intrusive requests,
12
00:00:47.130 --> 00:00:51.509
Deputy Chief Redacted denied knowledge of Redacted's actions, and Redacted
13
00:00:51.850 --> 00:00:56.219
commendably sought to significantly narrow the list of documents requested.
14
00:00:57.109 --> 00:00:59.990
In a subsequent court filing, Redacted referred to our agreement
15
00:01:00.229 --> 00:01:03.409
to remove these items from her demand list as evidence
16
00:01:03.429 --> 00:01:08.239
of Mr. Epstein's non-cooperation. This was only the beginning. Redacted
17
00:01:08.420 --> 00:01:12.040
also subpoenaed the agent of Roy Black without following the
18
00:01:12.060 --> 00:01:16.019
guidelines provided in the U.S. Attorney's Manual that require prior
19
00:01:16.060 --> 00:01:20.439
notification to Washington necessary to seek lawyers' records. We once
20
00:01:20.500 --> 00:01:24.299
more requested Mr. Lurie to intervene. Despite these efforts, Redacted
21
00:01:24.359 --> 00:01:27.670
followed up with a subpoena of for Mr. Epstein's confidential
22
00:01:27.790 --> 00:01:32.150
medical records served directly on his chiropractor, with no notice
23
00:01:32.170 --> 00:01:35.879
to Mr. Epstein. Redacted also made the unusual request of
24
00:01:36.000 --> 00:01:38.579
asking the state attorney's office for some of the grand
25
00:01:38.599 --> 00:01:42.319
jury material. She threatened to subpoena the state when she
26
00:01:42.359 --> 00:01:44.980
was informed that it was in violation of Florida law
27
00:01:45.319 --> 00:01:49.319
to release this information. After compiling this evidence, Redacted stated
28
00:01:49.359 --> 00:01:52.319
that she would be initiating an investigation into a purported
29
00:01:52.359 --> 00:01:57.590
violation of U.S. Code 18, Section 7, 1591, again without
30
00:01:57.650 --> 00:02:02.599
required prior DOJ notification. Redacted then broadened the scope of
31
00:02:02.620 --> 00:02:06.040
the investigation without any foundation for doing so by adding
32
00:02:06.060 --> 00:02:09.800
charges of money laundering and violations of a money transmitting
33
00:02:09.840 --> 00:02:14.219
business to the investigation. Mr. Epstein's counsel explained that there
34
00:02:14.259 --> 00:02:17.490
could be no basis for these charges since Mr. Epstein
35
00:02:17.509 --> 00:02:21.210
did not commit any prerequisite act for a money laundering
36
00:02:21.250 --> 00:02:26.240
charge and has never even engaged in a money transmitting business. Ms.
37
00:02:26.280 --> 00:02:29.479
Redacted responded that Mr. Epstein could be charged under these
38
00:02:29.520 --> 00:02:33.689
statutes because he funded illegal activities. To suggest that Mr.
39
00:02:33.789 --> 00:02:37.409
Epstein could violate these statutes simply by spending his legally
40
00:02:37.469 --> 00:02:41.930
earned money on prostitutes is manifestly an erroneous interpretation of
41
00:02:41.969 --> 00:02:45.479
the law. To our relief, after briefing Redacted at a
42
00:02:45.520 --> 00:02:49.780
meeting regarding the spurious application of these statuses, we were
43
00:02:49.819 --> 00:02:53.800
told to ignore the laundry list and that defense counsel
44
00:02:53.919 --> 00:02:58.599
should focus on be turned to U.S. Code 18, Section 2422B.
45
00:02:59.240 --> 00:03:02.460
Once Mr. Epstein's counsel submitted and presented the reasons why
46
00:03:02.500 --> 00:03:06.039
a federal case would require stretching the relevant federal statutes
47
00:03:06.340 --> 00:03:10.180
beyond recognition, and that federal involvement in this matter should
48
00:03:10.259 --> 00:03:13.889
be precluded based on the federalism concerns, the petite policy,
49
00:03:14.270 --> 00:03:19.289
and general principles of prosecutorial discretion, the parties commenced discussions
50
00:03:19.349 --> 00:03:22.750
of a possible plea agreement. Around this time, we received
51
00:03:22.789 --> 00:03:25.849
an email from Redacted suggesting that that she wanted to
52
00:03:25.909 --> 00:03:29.530
discuss the possibility of a concurrent federal and state resolution.
53
00:03:30.229 --> 00:03:33.210
We were immediately informed by your office that Redacted did
54
00:03:33.250 --> 00:03:35.849
not have the authority to make any such plea proposals
55
00:03:36.210 --> 00:03:38.830
and would not be involved in any further negotiations of
56
00:03:38.889 --> 00:03:43.090
a plea. Despite this commitment, Redacted was the principal negotiator
57
00:03:43.129 --> 00:03:47.159
of the agreement. At our meeting on September 7th, she
58
00:03:47.189 --> 00:03:50.860
made reference to an allegation against Mr. Epstein involving a
59
00:03:50.879 --> 00:03:55.289
12-year-old individual. This allegation is without merit, and without foundation.
60
00:03:55.909 --> 00:03:59.740
Though your last letter suggests that there waxed or was
61
00:03:59.789 --> 00:04:03.120
no contact between individuals in your office and the press,
62
00:04:03.699 --> 00:04:06.740
we were previously told by Redacted that the FBI was
63
00:04:06.780 --> 00:04:10.960
receiving information specifically from Connolly, a Vanity Fair reporter, and
64
00:04:11.000 --> 00:04:17.000
not vice versa. C. Redacted included unfair terms in the agreement.
65
00:04:17.680 --> 00:04:21.430
Redacted took positions in negotiating this matter that stray from
66
00:04:21.459 --> 00:04:25.769
both stated policy and established law. First, redacted insisted that
67
00:04:25.829 --> 00:04:28.720
as part of the federal plea agreement, the state attorney's office,
68
00:04:28.759 --> 00:04:32.680
without being shown new evidence, should be convinced to charge Mr.
69
00:04:32.759 --> 00:04:36.240
Epstein with violations of law and recommend a sentence that
70
00:04:36.300 --> 00:04:40.410
are significantly harsher than what the state deemed appropriate. In fact,
71
00:04:40.430 --> 00:04:43.870
the state attorneys viewed this matter as a straightforward prostitution
72
00:04:43.889 --> 00:04:46.750
case and believed that a term of probation was and
73
00:04:46.889 --> 00:04:52.209
is the appropriate sentence. At redacted's insistence, however, Mr. Epstein
74
00:04:52.250 --> 00:04:56.050
was forced to undertake the highly unusual and unprecedented action
75
00:04:56.529 --> 00:04:59.689
of directing his defense team to contract the state prosecutors
76
00:04:59.730 --> 00:05:03.259
themselves and ask for an upward departure in both his
77
00:05:03.300 --> 00:05:06.779
indictment and sentence. There was no effort by the state
78
00:05:06.819 --> 00:05:10.920
and federal prosecutors to coordinate the prosecutions, a practice which
79
00:05:11.000 --> 00:05:14.759
is against the tenets of the Petit policy. In our view,
80
00:05:15.180 --> 00:05:19.439
it's unprecedented to micromanage Each and every term of Mr.
81
00:05:19.519 --> 00:05:23.060
Epstein's state plea, including the exact state charges to which Mr.
82
00:05:23.160 --> 00:05:26.899
Epstein pled guilty, the time frame within Mr. Epstein must
83
00:05:27.000 --> 00:05:30.019
enter the state plea and surrender to state officials and
84
00:05:30.040 --> 00:05:32.560
the amount of time he must spend in county jail.
85
00:05:33.300 --> 00:05:37.160
This is particularly true where the state attorney's office has
86
00:05:37.220 --> 00:05:39.660
a different view of the case and there has been
87
00:05:39.699 --> 00:05:44.279
no coordination with state authorities. In addition, redacted require that Mr.
88
00:05:44.379 --> 00:05:49.110
Epstein's sentence include a registerable offense. As you know, requiring
89
00:05:49.170 --> 00:05:53.329
sex offender registration will have significant impact both immediately and
90
00:05:53.379 --> 00:05:56.480
forever after. This harsh term, which is said to be
91
00:05:56.540 --> 00:05:59.560
suggested by the FBI, was added despite the fact that
92
00:05:59.600 --> 00:06:02.740
the state believed that Mr. Epstein's conduct did not warrant
93
00:06:03.160 --> 00:06:07.009
any such registration. As you know, state officials have special
94
00:06:07.069 --> 00:06:12.009
expertise in deciding which offenders pose a threat to their community. Moreover,
95
00:06:12.089 --> 00:06:16.000
this demand placed the state's prosecutors' credibility at issue and
96
00:06:16.040 --> 00:06:19.100
diminishes the force of sexual registration when it's applied to
97
00:06:19.160 --> 00:06:22.759
offenders who state prosecutors do not believe are dangerous or
98
00:06:22.819 --> 00:06:27.579
require registration. Redacted's decision not to permit the state attorney
99
00:06:27.639 --> 00:06:31.360
to determine a matter uniquely within its province was unwarranted.
100
00:06:32.779 --> 00:06:36.000
What is more, when negotiating the settlement portion of the agreement,
101
00:06:36.360 --> 00:06:39.680
Redacted insisted that a civil settlement provision be included in
102
00:06:39.699 --> 00:06:45.019
the agreement, namely the inclusion of U.S. Code 18, Section 2255.
103
00:06:45.209 --> 00:06:48.970
a negotiating term which is unprecedented in nature. While we
104
00:06:48.990 --> 00:06:51.850
were reluctant and cautious about a plea agreement in which
105
00:06:51.889 --> 00:06:55.410
a criminal defendant gives up certain rights to contest liability
106
00:06:55.449 --> 00:07:00.269
for a civil settlement, redacted's ultimatums required that we acquiesce
107
00:07:00.310 --> 00:07:04.529
to these unprecedented terms. For instance, when plea discussion stalled
108
00:07:04.829 --> 00:07:08.290
as a result of redacted's demands, Mr. Epstein's counsel received
109
00:07:08.329 --> 00:07:11.110
a letter from her stating, as it now appears you
110
00:07:11.129 --> 00:07:15.079
will not settle. At this point, redacted expressed, her intention
111
00:07:15.120 --> 00:07:20.620
to relaunch the government's previously set-aside money laundering investigation. She
112
00:07:20.699 --> 00:07:23.610
also issued a rush of subpoenas and sent target letters
113
00:07:23.629 --> 00:07:27.449
to Mr. Epstein's employees, adding new federal charges including obstruction
114
00:07:27.470 --> 00:07:31.550
of justice. She then personally called Mr. Epstein's largest and
115
00:07:31.589 --> 00:07:34.709
most valued business client without any basis to inform him
116
00:07:35.230 --> 00:07:39.579
of the investigation. In an attempt to prevent further persecution
117
00:07:40.240 --> 00:07:44.740
and intimidation, We proposed that Mr. Epstein establish a restitution
118
00:07:44.769 --> 00:07:48.519
fund specifically for the settlement of the identified individual's civil
119
00:07:48.579 --> 00:07:52.980
claims and that an impartial independent representative be appointed to
120
00:07:53.040 --> 00:07:56.540
administer that fund. There was no dollar amount limit discussed
121
00:07:56.579 --> 00:08:00.410
for the fund, but the idea was still rejected. We
122
00:08:00.470 --> 00:08:03.250
then pointed out the state's charges to which Mr. Epstein
123
00:08:03.310 --> 00:08:06.250
was to plead guilty carried with it a state restitution
124
00:08:06.290 --> 00:08:10.970
provision that would allow victims to recover damages. Misredacted, however...
125
00:08:11.029 --> 00:08:15.269
rejected this idea and suggested requiring a guardian ad litium
126
00:08:15.689 --> 00:08:19.050
implying that the alleged victims in question were currently minors
127
00:08:19.389 --> 00:08:23.189
and needed special representation. We later learned that the government's
128
00:08:23.250 --> 00:08:27.100
list of individuals included a woman as old as 24,
129
00:08:27.100 --> 00:08:30.300
which flies in the face of prior representations. It should
130
00:08:30.319 --> 00:08:33.159
be noted that any person who is currently 24 years
131
00:08:33.179 --> 00:08:35.840
or older could not have been a victim under U.S.
132
00:08:35.860 --> 00:08:40.039
Code Section 2255, even if the conduct occurred in 2001.
133
00:08:41.379 --> 00:08:45.080
At Redacted's insistence, the parties ultimately agreed to the appointment
134
00:08:45.120 --> 00:08:48.779
of an attorney representative. But Redacted then took the position
135
00:08:49.110 --> 00:08:52.049
that Mr. Epstein should pay for the representative's fees, which
136
00:08:52.090 --> 00:08:54.970
effectively meant that Mr. Epstein must pay to sue himself.
137
00:08:55.850 --> 00:08:59.990
Redacted also proposed wholly irrelevant charges, such as making obscene
138
00:09:00.029 --> 00:09:04.049
phone calls and violations of child privacy laws. When Redacted
139
00:09:04.090 --> 00:09:07.090
learned of these proposed charges, he asked Mr. Epstein's defense
140
00:09:07.110 --> 00:09:11.470
team to ignore them, as they would embarrass the office. d.
141
00:09:12.529 --> 00:09:16.820
Redacted continually and purposefully misinterpreted the critical terms of the agreement.
142
00:09:17.620 --> 00:09:21.159
Since the execution of the agreement redacted as repeatedly and misconstrued,
143
00:09:21.480 --> 00:09:25.059
the terms contained therein. As you know, several facets of
144
00:09:25.100 --> 00:09:28.450
this matter have been highly contested by both parties. We
145
00:09:28.500 --> 00:09:32.090
sometimes have obtained two competing views as to your willingness
146
00:09:32.389 --> 00:09:35.450
to compromise on specific issues that we have raised with
147
00:09:35.470 --> 00:09:38.730
your office. In particular, there are times when we receive
148
00:09:38.769 --> 00:09:42.100
verbal agreement from you or your staff and sometimes from
149
00:09:42.120 --> 00:09:46.399
misredacted herself, on a particular issue, only to subsequently receive
150
00:09:46.440 --> 00:09:51.649
a contradictory interpretation from misredacted that negates our prior common understanding.
151
00:09:53.610 --> 00:09:57.110
Her misrepresentations appear to be attempts to effectively change the
152
00:09:57.149 --> 00:10:02.149
spirit and the meaning of the non-prosecution agreement. We offer
153
00:10:02.230 --> 00:10:08.080
several examples of significant misrepresentations. First, despite the fact that
154
00:10:08.100 --> 00:10:10.740
we received several commitments from your office that it would
155
00:10:10.779 --> 00:10:13.960
monitor Mr. Epstein's state sentencing but not interfere with it
156
00:10:14.000 --> 00:10:17.750
in any way, Ms. Redacted sought to do just that. Ms.
157
00:10:17.789 --> 00:10:21.179
Redacted's decision to utilize a civil remedy statute in the
158
00:10:21.220 --> 00:10:24.679
place of a restitution fund for the alleged victims eliminates
159
00:10:24.740 --> 00:10:29.159
a notification requirement under the Justice for All Act in 2004,
160
00:10:29.159 --> 00:10:32.500
a federal law that requires federal authorities to notify victims
161
00:10:32.879 --> 00:10:36.769
as to any available restitution, not of any potential civil remedies,
162
00:10:37.470 --> 00:10:40.789
to which they're entitled. Despite this fact, Ms. Redacted proposed
163
00:10:40.850 --> 00:10:43.629
a victim's notification letter to be sent to the alleged
164
00:10:43.669 --> 00:10:47.620
federal victims. Ms. Redacted has gone even further. alleging that
165
00:10:47.639 --> 00:10:50.899
the victims may take written statements or testify against Mr.
166
00:10:51.000 --> 00:10:54.029
Epstein at the sentencing. We find no basis in law
167
00:10:54.450 --> 00:10:57.970
or the agreement that provides the identified individuals with either
168
00:10:58.049 --> 00:11:01.009
a right to appear at Mr. Epstein's plea and sentence
169
00:11:01.370 --> 00:11:03.559
or to submit a written statement to be filed by
170
00:11:03.580 --> 00:11:06.940
the state attorney. Here, Mr. Epstein is pleading guilty to
171
00:11:07.000 --> 00:11:10.159
and being sentenced for state offenses, not the federal offenses
172
00:11:10.240 --> 00:11:14.710
under which the government has unilaterally recognized these identified individuals
173
00:11:14.830 --> 00:11:18.419
as victims. The notion that individuals whose names are not
174
00:11:18.480 --> 00:11:21.769
even known to the charging prosecutor in a state actually
175
00:11:21.789 --> 00:11:26.450
should somehow be allowed to speak at a proceeding is unjustifiable. Furthermore,
176
00:11:26.809 --> 00:11:30.309
only after obtaining the executed agreement did Ms. Redacted begin
177
00:11:30.350 --> 00:11:34.379
insisting that the selected representative's duties go beyond settlement and
178
00:11:34.409 --> 00:11:40.039
include litigating claims for individuals. In Ms. Redacted's victim's notification letter,
179
00:11:40.320 --> 00:11:43.779
she states that Mr. Potthurst and Ms. Josephsburg, the selected
180
00:11:43.799 --> 00:11:48.779
of attorneys' representatives, may present the identified individuals. This language
181
00:11:48.840 --> 00:11:53.080
assumes the selected representatives will agree to serve in the
182
00:11:53.120 --> 00:11:57.299
capacity envisioned by Ms. Redacted, which is patently incorrect. Yet
183
00:11:57.360 --> 00:12:01.200
neglecting the spirit of principle of ethic with respects to conflict, Ms.
184
00:12:01.250 --> 00:12:05.909
Redacted continues to improperly emphasize that the chosen attorney representative
185
00:12:06.190 --> 00:12:09.490
should be able to litigate the claims of individuals. In
186
00:12:09.509 --> 00:12:12.809
a similar fashion, Ms. Redacted has overstated the scope of Mr.
187
00:12:12.889 --> 00:12:17.279
Epstein's waiver of of liability pursuant to the agreement. Misredacted
188
00:12:17.320 --> 00:12:20.919
began asserting that Mr. Epstein has waived liability even when
189
00:12:20.980 --> 00:12:24.440
claims with identified individuals are not settled just after the
190
00:12:24.500 --> 00:12:28.350
execution of the agreement. Despite the fact that at this
191
00:12:28.389 --> 00:12:31.549
time we obtained an agreement from you that Mr. Epstein's
192
00:12:31.590 --> 00:12:36.090
waiver would not stretch past settlement, misredacted continues to espouse
193
00:12:36.490 --> 00:12:41.610
this erroneous interpretation. F. Misredacted in the settlement process. We're
194
00:12:41.629 --> 00:12:44.769
concerned that Ms. Redacted has repeatedly attempted to manipulate the
195
00:12:44.789 --> 00:12:49.309
process under which Mr. Epstein has agreed to settle civil claims. First,
196
00:12:49.350 --> 00:12:54.789
she inappropriately attempted to nominate Humbert Burt Ocariz for attorney
197
00:12:54.830 --> 00:12:59.129
representative despite the fact that Mr. Ocariz has a long-standing
198
00:12:59.169 --> 00:13:02.990
relationship with Ms. Redacted. Mr. Ocariz turns out to be
199
00:13:03.029 --> 00:13:05.980
a very good personal friend and law school classmate of Ms.
200
00:13:06.000 --> 00:13:10.220
Redacted's boyfriend, a fact she assiduously kept hidden from counsel.
201
00:13:11.009 --> 00:13:13.639
We also learned that Ms. Redacted that she shared the
202
00:13:13.840 --> 00:13:16.860
Ocariz the summary of the charges the government was considering
203
00:13:17.220 --> 00:13:20.720
against Epstein, even after your office conceded that it was
204
00:13:20.759 --> 00:13:25.370
inappropriate for its attorneys to select an attorney representative. Ms.
205
00:13:25.399 --> 00:13:31.110
Redacted continued to lobby for Mr. Ocariz's appointment. On October 19, 2007,
206
00:13:31.110 --> 00:13:34.049
retired Judge Edward B. Davis, who was appointed by the
207
00:13:34.110 --> 00:13:38.129
parties to select the attorney representative, informed Mr. Epstein's counsel
208
00:13:38.629 --> 00:13:42.120
that he received a telephone call from Mr. Okeriz, directly
209
00:13:42.200 --> 00:13:45.659
requesting that Judge Davis appoint him as the attorney representative
210
00:13:45.700 --> 00:13:49.610
in the matter. Furthermore, federal interference continues to plague the
211
00:13:49.659 --> 00:13:53.809
integrity of the implementation of the agreement. We recently learned
212
00:13:53.850 --> 00:13:56.789
that despite the fact that there was no communication between
213
00:13:56.830 --> 00:14:00.190
state and federal authorities as to the investigation of Mr. Epstein,
214
00:14:00.509 --> 00:14:03.250
the FBI visited the state attorney's office two weeks ago
215
00:14:03.269 --> 00:14:07.879
to request Mr. Epstein be disqualified to participate in work release,
216
00:14:08.299 --> 00:14:11.220
even though the agreement mandates that Mr. Epstein be treated
217
00:14:11.600 --> 00:14:15.139
as any other inmate. 3. Conclusion In sum, we request
218
00:14:15.159 --> 00:14:18.600
that you review the evidence supporting the prosecution of Mr. Epstein.
219
00:14:19.059 --> 00:14:21.960
Such a review would serve to address similar concerns as
220
00:14:22.000 --> 00:14:25.480
those raised in Brady v. Maryland, which mandate the disclosure
221
00:14:25.500 --> 00:14:28.929
of evidence material to guilt or innocence, even after the
222
00:14:28.990 --> 00:14:31.490
execution of an agreement, to enter a plea of guilty.
223
00:14:32.549 --> 00:14:35.450
We believe that the prosecution team was informed by its witnesses,
224
00:14:35.830 --> 00:14:39.090
including persons other than redacted and redacted, who were discussed
225
00:14:39.149 --> 00:14:41.980
at length above, that Mr. Epstein's practice was to seek
226
00:14:42.059 --> 00:14:46.549
women older than 18 rather than targeting those under 18.
227
00:14:46.549 --> 00:14:49.269
We would expect, for instance, that redacted a key witness
228
00:14:49.590 --> 00:14:52.649
whose interview with the FBI was recorded would have provided
229
00:14:52.730 --> 00:14:56.409
such exonerating information as well as many others. We would
230
00:14:56.450 --> 00:14:59.809
also expect the review to uncover clear evidence that demonstrates
231
00:14:59.830 --> 00:15:02.450
that Mr. Epstein did not travel to Florida for the
232
00:15:02.490 --> 00:15:05.929
purpose of having illegal underage sex, nor that he induced
233
00:15:05.980 --> 00:15:10.490
underage women by using the internet or phones. Furthermore, we
234
00:15:10.590 --> 00:15:13.629
ask you to consider whether there's reliable evidence, not just
235
00:15:13.649 --> 00:15:17.570
that Mr. Epstein had sexual contact with witnesses who are
236
00:15:17.610 --> 00:15:21.120
in fact underage, but whether the allegations are based on
237
00:15:21.159 --> 00:15:24.899
trustworthy and corroborated evidence that Mr. Epstein knew that the
238
00:15:24.960 --> 00:15:27.940
females in question were under 18 at the time of
239
00:15:27.980 --> 00:15:31.340
sexual contact to Mr. Epstein traveled to his home in
240
00:15:31.379 --> 00:15:34.450
Palm Beach for the purpose of having such sexual contact
241
00:15:34.470 --> 00:15:37.909
to the extent the allegation charges a violation of of U.S.
242
00:15:37.929 --> 00:15:42.850
Code 18 Section 2423B and C. And Mr. Epstein induced
243
00:15:42.889 --> 00:15:47.370
such sexual contact by using an instrumentality of interstate commerce
244
00:15:47.409 --> 00:15:51.129
to the extent the allegations charge a violation of 18 U.S.
245
00:15:51.169 --> 00:15:56.879
Code Section 2422B. There's no evidence of internal solicitation, which
246
00:15:56.940 --> 00:16:00.320
is the norm upon which federal jurisdiction is usually modeled
247
00:16:00.440 --> 00:16:03.649
under the statutes. We believe that the information we provide
248
00:16:03.690 --> 00:16:06.850
to you in this submission will be informative and spark
249
00:16:06.870 --> 00:16:10.029
a motivation to gain more information with respect to the
250
00:16:10.070 --> 00:16:13.909
investigation of the matter. Again, we're not seeking to unwind
251
00:16:13.950 --> 00:16:16.789
the agreement. We're only seeking for you to exercise your
252
00:16:16.840 --> 00:16:20.320
discretion in directing that an impartial and respected member of
253
00:16:20.340 --> 00:16:23.500
your office test the evidence upon which the draft federal
254
00:16:23.539 --> 00:16:27.419
indictment was based against, the best evidence, including the transcripts
255
00:16:27.779 --> 00:16:31.769
of the tape-recorded pre-federal involvement interviews. Finally, I'd like to
256
00:16:31.870 --> 00:16:35.629
reiterate our appreciation for the opportunity to have provided to
257
00:16:35.669 --> 00:16:38.710
review some of our issues and concerns. I look forward
258
00:16:38.730 --> 00:16:42.250
to speaking with you shortly. This was signed by Jay Lefkowitz.
259
00:16:43.669 --> 00:16:46.110
All the information that goes with this episode can be
260
00:16:46.149 --> 00:16:48.100
found in the description box.