EFTA00013666.pdf

440 KB

Extraction Summary

7
People
3
Organizations
2
Locations
2
Events
3
Relationships
4
Quotes

Document Information

Type: Legal correspondence / facsimile
File Size: 440 KB
Summary

This document is a letter dated July 17, 2008, from the U.S. Department of Justice (Southern District of Florida) to Jeffrey Epstein's attorney, Michael R. Tein. The U.S. Attorney's Office disputes the defense's claim that the federal criminal action is 'pending,' stating that under the Non-Prosecution Agreement (NPA), the investigation is suspended and motions to quash subpoenas should have been withdrawn. The letter warns that if Epstein claims the federal action is pending to stay civil proceedings, the DOJ will resume the motion to quash and analyze seized computer equipment.

People (7)

Name Role Context
Jeffrey Epstein Subject / Defendant
Subject of the federal investigation and Non-Prosecution Agreement.
R. Alexander Acosta United States Attorney
Signatory of the letter representing the Southern District of Florida.
Michael R. Tein Defense Attorney
Recipient of the letter; attorney at Lewis Tein, P.L.
Jack Alan Goldberger Defense Attorney
Copied (cc) on the letter; recipient of fax.
Lilly Ann Sanchez Attorney
Referenced in a citation regarding a December 19, 2007 letter.
[Redacted] Assistant United States Attorney
Author/Sender of the letter (signature and name block redacted).
Jane Does Victims
Referenced as minor victims of offenses under Title 18 USC Section 2255.

Organizations (3)

Name Type Context
U.S. Department of Justice
Southern District of Florida, issuing agency.
Lewis Tein, P.L.
Law firm representing Jeffrey Epstein.
State of Florida
Referenced jurisdiction for prosecution under the NPA.

Timeline (2 events)

2007-12-19
Previous letter from US Attorney to Lilly Ann Sanchez referenced.
N/A
Lilly Ann Sanchez US Attorney
2008-07-17
DOJ sends letter to Epstein's counsel regarding the status of the federal investigation and the Motion to Quash.
West Palm Beach, FL
Michael R. Tein Assistant U.S. Attorney

Locations (2)

Location Context
Address of the U.S. Attorney's Office.
Address of Lewis Tein, P.L.

Relationships (3)

Jeffrey Epstein Client/Attorney Michael R. Tein
Letter addressed to Tein regarding his client Epstein.
Jeffrey Epstein Client/Attorney Jack Goldberger
Goldberger copied on legal correspondence regarding Epstein.
R. Alexander Acosta Prosecutor/Defendant Jeffrey Epstein
Acosta is the US Attorney signing the letter regarding Epstein's case.

Key Quotes (4)

"The Office has reviewed your 'Notice of Continued Pendency of Federal Criminal Action,' and we feel that it misrepresents the posture of the federal investigation."
Source
EFTA00013666.pdf
Quote #1
"Pursuant to the Non-Prosecution Agreement, that motion was supposed to have been withdrawn several months ago, and, therefore, is not 'pending' in our estimation."
Source
EFTA00013666.pdf
Quote #2
"One of those conditions is Epstein's agreement that the subject Jane Does, while minors, were victims of a violation of an offense enumerated in Title 18, United States Code Section 2255..."
Source
EFTA00013666.pdf
Quote #3
"If, instead, Mr. Epstein intends to fully abide by the Non-Prosecution Agreement, then the 'federal Grand Jury investigation will remain suspended...'"
Source
EFTA00013666.pdf
Quote #4

Full Extracted Text

Complete text extracted from the document (4,645 characters)

U.S. Department of Justice
United States Attorney
Southern District of Florida
500 South Australian Ave., Suite 400
West Palm Beach, FL 33401
(561) 820-8711
Facsimile: (561) 820-8777
July 17, 2008
VIA FACSIMILE
Michael R. Tein, Esq.
Lewis Tein, P.L.
3059 Grand Avenue, Suite 340
Coconut Grove, FL 33133
Re: Jeffrey Epstein
Dear Mr. Tein:
The Office has reviewed your "Notice of Continued Pendency of Federal Criminal Action," and we feel that it misrepresents the posture of the federal investigation. For example, you cite to In re Grand Jury, No. FGJ 07-103 (WPB), as evidence that the federal criminal action remains pending. That is a citation to Mr. Epstein's Motion to Quash a subpoena for computer equipment removed from Mr. Epstein's home after he and his attorneys were aware of the existence of the state investigation. Pursuant to the Non-Prosecution Agreement, that motion was supposed to have been withdrawn several months ago, and, therefore, is not "pending" in our estimation.
The Non-Prosecution Agreement calls for deferment of federal prosecution "in favor of prosecution by the State of Florida, provided that Epstein abides by the [enumerated] conditions and the requirements of th[e] Agreement . . ." (Non-Prosecution Agreement, p. 2 (emphasis added).) One of those conditions is Epstein's agreement that the subject Jane Does, while minors, were victims of a violation of an offense enumerated in Title 18, United States Code Section 2255, and that they "will have the same rights to proceed under Section 2255 as [they] would have had if Mr. Epstein had been tried and convicted of an enumerated offense." (United States Attorney's December 19, 2007 letter to Lilly Ann Sanchez.)
If, in fact, your position is that the federal criminal action is still pending such that the Court must stay the civil proceedings, then the Office proposes that we seek the prompt resolution of the Motion to Quash, so that the computer equipment can be analyzed and the
EFTA00013666
MICHAEL TEIN, ESQ.
JULY 17, 2008
PAGE 2
federal investigation can continue. If, instead, Mr. Epstein intends to fully abide by the Non-Prosecution Agreement, then the "federal Grand Jury investigation will remain suspended, and all pending federal Grand Jury subpoenas will be held in abeyance unless and until [Epstein] violates any term of [the Non-Prosecution Agreement]." (Non-Prosecution Agreement, page 5.)
Please advise whether you intend to correct the representations to the Court regarding the status of the federal investigation.
Sincerely,
R. Alexander Acosta
United States Attorney
By: [Redacted Signature]
Assistant United States Attorney
cc: Jack Goldberger, Esq.
[Redacted], Esq.
EFTA00013667
U.S. Department of Justice
United States Attorney
Southern District of Florida
500 S. Australian Ave, 4th Floor
West Palm Beach, Florida 33401
(561) 820-8711
Facsimile (561) 820-8777
FACSIMILE COVER SHEET
TO: Michael R. Tein
FAX NO. 305-442-6744
PHONE NO. [Redacted]
TO: Jack Alan Goldberger
FAX NO. 561-835-8691
PHONE NO. [Redacted]
DATE: July 17, 2008
# OF PAGES: 3
RE: Jeffrey Epstein
FROM: [Redacted], Assistant U.S. Attorney
PHONE NO. [Redacted]
COMMENTS:
EFTA00013668
07/17/08 18:17 FAX 15616594526 USAO WEST PALM 001
*********************
*** TX REPORT ***
*********************
TRANSMISSION OK
TX/RX NO 3957
CONNECTION TEL 8358691
SUBADDRESS
CONNECTION ID
ST. TIME 07/17 18:16
USAGE T 00'42
PGS. SENT 3
RESULT OK
U.S. Department of Justice
United States Attorney
Southern District of Florida
500 S. Australian Ave, 4th Floor
West Palm Beach, Florida 33401
(561) 820-8711
Facsimile (561) 820-8777
FACSIMILE COVER SHEET
TO: Michael R. Tein
FAX NO. 305-442-6744
PHONE NO. [Redacted]
TO: Jack Alan Goldberger
FAX NO. 561-835-8691
PHONE NO. [Redacted]
DATE: July 17, 2008
# OF PAGES: 3
RE: Jeffrey Epstein
FROM: [Redacted], Assistant U.S. Attorney
PHONE NO. [Redacted]
EFTA00013669
07/17/08 18:18 FAX 15616594526 USAO WEST PALM 001
*********************
*** TX REPORT ***
*********************
TRANSMISSION OK
TX/RX NO 3958
CONNECTION TEL 13054426744
SUBADDRESS
CONNECTION ID
ST. TIME 07/17 18:17
USAGE T 01'04
PGS. SENT 3
RESULT OK
U.S. Department of Justice
United States Attorney
Southern District of Florida
500 S. Australian Ave, 4th Floor
West Palm Beach, Florida 33401
(561) 820-8711
Facsimile (561) 820-8777
FACSIMILE COVER SHEET
TO: Michael R. Tein
FAX NO. 305-442-6744
PHONE NO. [Redacted]
TO: Jack Alan Goldberger
FAX NO. 561-835-8691
PHONE NO. [Redacted]
DATE: July 17, 2008
# OF PAGES: 3
RE: Jeffrey Epstein
FROM: [Redacted], Assistant U.S. Attorney
PHONE NO. [Redacted]
EFTA00013670

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