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2.46 MB
Extraction Summary
5
People
5
Organizations
1
Locations
1
Events
2
Relationships
6
Quotes
Document Information
Type:
Legal memorandum / defense submission
File Size:
2.46 MB
Summary
This document is a page from a legal submission by Kirkland & Ellis LLP to the Office of the Deputy Attorney General, arguing against federal prosecution of Jeffrey Epstein. The text asserts that federal statutes are being impermissibly stretched and requests that the case be handled by the State of Florida. In the 'Summary of Facts,' the defense claims Epstein did not personally schedule massages, that sexual activity was limited primarily to self-masturbation, and that underage women systematically lied to Epstein about their age.
People (5)
| Name | Role | Context |
|---|---|---|
| Jeffrey Epstein | Subject/Defendant |
Described as maintaining a home in Palm Beach, receiving massages, and allegedly requesting masseuses be 18+.
|
| Epstein's Mother | Family |
Epstein reportedly helped care for her at his Palm Beach home.
|
| Personal Assistants | Staff |
Allegedly scheduled appointments including massages; Epstein claims he did not schedule them personally.
|
| Masseuses | Service Providers/Victims |
Women visiting Epstein's home; defense claims they often contacted assistants first and lied about age.
|
| Deputy Attorney General | Government Official |
Recipient of the request to end federal involvement.
|
Organizations (5)
| Name | Type | Context |
|---|---|---|
| Kirkland & Ellis LLP |
Author of the document defending Epstein.
|
|
| CEOS |
Child Exploitation and Obscenity Section (DOJ); referenced regarding 'novel' interpretive expansions.
|
|
| Office of the Deputy Attorney General |
Entity being petitioned to stop federal investigation.
|
|
| Supreme Court |
Referenced regarding decisions in Santos and Cuellar.
|
|
| State of Florida |
Preferred jurisdiction for the case according to the defense.
|
Timeline (1 events)
Various (Past 20 years)
Locations (1)
| Location | Context |
|---|---|
Relationships (2)
Text states personal assistants scheduled appointments for him.
Women visited home to perform massages; sexual activity admitted by defense.
Key Quotes (6)
"The statute has never been applied to a “John,” and only a highly and impermissibly selective prosecution could stretch § 1591 to reach conduct like that at issue in this case."Source
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Quote #1
"request that the Office of the Deputy Attorney General end federal involvement in this matter so that the State of Florida may resolve this case appropriately."Source
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Quote #2
"The majority of the massages were just that and nothing else."Source
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Quote #3
"At times, the masseuses would be topless, and some sexual activity might occur—primarily self-masturbation on the part of Mr. Epstein."Source
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Quote #4
"Mr. Epstein specifically requested that each masseuse be at least 18 years old."Source
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Quote #5
"most of the women who have testified that they were actually under 18 have specifically admitted to systematically lying to Mr. Epstein about their age."Source
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Quote #6
Full Extracted Text
Complete text extracted from the document (3,296 characters)
KIRKLAND & ELLIS LLP
sexual trafficking. The statute has never been applied to a “John,” and only a highly and impermissibly selective prosecution could stretch § 1591 to reach conduct like that at issue in this case.
In short, without “novel” interpretive expansions—a description used by CEOS itself—it cannot be shown that Mr. Epstein violated any of the three federal statutes identified by prosecutors. As the Supreme Court’s recent decisions in Santos and Cuellar make clear, federal law may not be stretched in that manner, and the current federal investigation relies, as its foundation, on impermissibly elastic stretches of each statute beyond any reported precedent; beyond the essential elements of each statute; well outside the ordinary construction of each statute’s limitations; and on a selective, extraordinary, and unwarranted expansion of federal law to cover conduct that has always been exclusively within the core of state powers.
At this point in time, the need for Departmental oversight is critical. We appreciate this opportunity to submit our assessment of the key facts in this case and review of the pertinent federal statutes, and respectfully request that the Office of the Deputy Attorney General end federal involvement in this matter so that the State of Florida may resolve this case appropriately.
Summary of the Facts
Mr. Epstein has maintained a home in Palm Beach, Florida for the past 20 years. While there, he routinely conducted business, received medical attention, socialized with friends, and helped care for his elderly mother. Mr. Epstein also had various women visit his home to perform massages. He did not personally schedule the massage appointments or communicate with the women over the phone or the Internet. Rather, Mr. Epstein’s personal assistants scheduled many types of appointments, personal trainers, chiropractors, business meetings and massages. The phone message pad taken from his house and in the possession of the government confirmed that in many cases, the women themselves contacted Mr. Epstein’s assistants to inquire about his availability—rather than vice versa.
The majority of the massages were just that and nothing else. Mr. Epstein often would be on the telephone conducting business while he received his massage. At times, the masseuses would be topless, and some sexual activity might occur—primarily self-masturbation on the part of Mr. Epstein. On other occasions, no sexual activity would occur at all. There was no pattern or practice regarding which masseuse would be scheduled on a particular day—if one would be scheduled at all—or whether any sexual activity might occur. Indeed, Mr. Epstein almost never knew which masseuse his assistants had scheduled until she arrived. See Tab 3, [REDACTED] Toll Records.
Mr. Epstein specifically requested that each masseuse be at least 18 years old. The vast majority of the masseuses were in fact in their twenties, many accompanied to Mr. Epstein’s home by friends or even other family members. Furthermore, most of the women who have testified that they were actually under 18 have specifically admitted to systematically lying to Mr. Epstein about their age. See Tab 4 [REDACTED] Tr. at 38-39; Tab 5, [REDACTED] Tr. at 16; Tab 6,
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