EFTA00013811.pdf
2.97 MB
Extraction Summary
10
People
8
Organizations
4
Locations
4
Events
2
Relationships
6
Quotes
Document Information
Type:
Legal submission / memorandum
File Size:
2.97 MB
Summary
This document is a legal submission by Kirkland & Ellis LLP to the Deputy Attorney General arguing against federal prosecution of Jeffrey Epstein in circa 2008. The defense argues that Epstein's conduct amounts to state-level solicitation of prostitution rather than federal sex trafficking or sex tourism, citing recent Supreme Court decisions to advocate for a narrow interpretation of federal statutes. The text asserts that Epstein did not target minors, did not use interstate commerce to lure victims, and that any underage women lied about their age.
People (10)
| Name | Role | Context |
|---|---|---|
| Jeffrey E. Epstein | Subject |
Described as a successful businessman and philanthropist with no prior criminal record; accused of solicitation but d...
|
| Justice Scalia | Supreme Court Justice |
Authored opinion in United States v. Santos (2008) referenced for the rule of lenity.
|
| Justice Thomas | Supreme Court Justice |
Authored opinion in Cuellar v. United States (2008) referenced for narrow statutory interpretation.
|
| Brian Benczkowski | Principal Deputy Assistant Attorney General |
Author of a Nov 9, 2007 letter to the House Judiciary Committee regarding state vs federal jurisdiction in prostituti...
|
| Barry Kutun | Former North Miami City Attorney |
Cited as a comparable case where federal prosecutors declined to prosecute despite egregious conduct.
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| Walter Dellinger | Assistant Attorney General |
Author of a 1994 memo on Presidential Authority to Decline to Execute Unconstitutional Statutes.
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| Abner J. Mikva | Counsel to the President |
Recipient of the Dellinger memo.
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| Justice Alito | Supreme Court Justice |
Referenced for his concurring opinion in Cuellar regarding the 'purpose' requirement.
|
| Epstein's Mother | Family |
Died in April 2004; Epstein visited her frequently in the hospital in Florida.
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| [Redacted] | Witnesses/Masseuses |
Various women whose names are redacted, cited in deposition transcripts regarding their interactions with Epstein.
|
Organizations (8)
| Name | Type | Context |
|---|---|---|
| Kirkland & Ellis LLP |
Law firm representing Jeffrey Epstein, authors of the submission.
|
|
| Office of the Deputy Attorney General |
Recipient of the legal submission.
|
|
| CEOS |
Child Exploitation and Obscenity Section (DOJ); conducted a limited review of Epstein.
|
|
| State Attorney's Office (SAO) |
Florida prosecution office that investigated Epstein for 15 months.
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|
| U.S. Attorney's Office |
Southern District of Florida; currently investigating/prosecuting the federal case.
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| FBI |
Federal Bureau of Investigation; mentioned as attempting to persuade a witness she was a victim.
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| Supreme Court |
U.S. Supreme Court; decisions cited extensively as legal precedent.
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| FAA |
Federal Aviation Administration; conducts periodic inspections of Epstein's aircraft in Florida.
|
Timeline (4 events)
2007-05-18
Barry Kutun pleaded guilty to sex with underage prostitutes.
Miami-Dade County courtroom
Locations (4)
| Location | Context |
|---|---|
|
Epstein's home for 20 years, location of the alleged conduct.
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Travel origin/destination for Epstein.
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Travel origin/destination for Epstein.
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Location of the Barry Kutun case.
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Relationships (2)
Jeffrey Epstein
→
Client/Service Provider (alleged)
→
[Redacted] Masseuses
Document describes them providing massages, sometimes topless, sometimes involving self-masturbation by Epstein.
Jeffrey Epstein
→
Employer/Employee
→
Epstein's Assistants
Assistants made the phone calls to schedule appointments.
Key Quotes (6)
"Mr. Epstein's conduct—including his misconduct—falls within the heartland of historic state police and prosecutorial powers."Source
EFTA00013811.pdf
Quote #1
"He was an ordinary 'John,' not a pimp."Source
EFTA00013811.pdf
Quote #2
"Mr. Epstein specifically requested that each masseuse be at least 18 years old."Source
EFTA00013811.pdf
Quote #3
"The majority of the massages were just that and nothing else."Source
EFTA00013811.pdf
Quote #4
"Mr. Epstein lived in Palm Beach, and his interstate travel was merely to go home."Source
EFTA00013811.pdf
Quote #5
"There is not a shred of evidence that Mr. Epstein (or his assistants) did any such thing, and he cannot be prosecuted under this statute."Source
EFTA00013811.pdf
Quote #6
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