| --- |
| title: "House Oversight: Estate Documents (Nov 12) (HOUSE_OVERSIGHT_012143)" |
| source: "House Oversight: Estate Documents (Nov 12)" |
| sourceUrl: "https://www.justice.gov/epstein" |
| date: "2026-01-01" |
| category: "House Oversight" |
| eftaNumber: "HOUSE_OVERSIGHT_012143" |
| ocrPages: 1 |
| ocrChars: 3206 |
| ocrElapsed: 0.0 |
| parseTier: "external-legacy" |
| engine: "engine undisclosed (ep-nov-12.greg.technology mirror)" |
| externalSource: "greg-ep-nov-12" |
| externalLicense: "not granted" |
| externalCredit: "ep-nov-12.greg.technology" |
| externalUrl: "https://ep-nov-12.greg.technology" |
| --- |
| |
| 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. |
| 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, |
| 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 em |
| • Tr. at 38-39; Tab 5, |
| Tr. at 16; Tab 6, |
| 2 |
| HOUSE_OVERSIGHT_012143 |
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