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PAUL G. CASSELL Ronald N. Boyce Presidential Professor of Criminal Law S.J. Quinney College of Law at the University of Utah 383 S. University St. Salt Lake City, UT 84112 Telephone:¶
January 20, 2016¶
Dear U.S. Attorney Rodriguez-Velez:¶
I have been trying to reach the appropriate person in your Office about the above-captioned matter for six weeks. I write on behalf of Jane Doe No.1 and Jane Doe No.2, the victims of false statement, to inquire into the matter and to exercise their right to confer, 18 U.S.C. §3771(a)(5). My repeated phone calls have not been returned, so I am writing directly to you. Because this is an important matter that has been “conflicted out” to your Office, I hope that you will have someone return my call.¶
By way of background, during the extended federal criminal investigation in Florida of Jeffrey Epstein for numerous sex offenses, was a senior Assistant U.S. Attorney in the U.S. Attorney’s Office for the Southern District of Florida. Within months after a non-prosecution agreement was signed between the Office and Epstein, left the Office and immediately went into private practice as a white collar criminal defense attorney. Coincidentally, his office happened to be not only in the same building (and on the same floor) as Epstein’s lead criminal defense counsel, Jack Goldberger, but it was actually located right next door to the Florida Science Foundation – an Epstein-owned and -run company where Epstein spent his “work release.”¶
While working in this Office adjacent to Epstein’s, Reinhart undertook the representation of numerous Epstein employees and pilots during the civil cases filed against Epstein by the victims – cases that involved the exact same crimes and same evidence being reviewed by the U.S. Attorney’s office when he was employed¶
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there. Specifically, he represented (Epstein’s number one co-conspirator who was actually named as such in the NPA), his housekeeper (Louella Ruboyo), and his pilots Larry Morrison, Larry Visoski, David Rogers, William Hammond and Robert Roxburgh. (Hammond and Roxburgh were not deposed, but the others were.) See depositions of these individuals in various Epstein civil cases. On information and belief, representation of these individuals was paid, directly or indirectly, by Epstein.¶
representations were in contravention of Justice Department regulations and Florida bar rules. Such representations also give, at least, the improper appearance that may have attempted to curry with Epstein and then reap his reward through favorable employment. But of particular relevance to the matter that has been assigned to your Office, filed a sworn declaration (in the case of Jane Doe No. 1 and Jane Doe No. 2 vs. United States, 9:08-cv-80736) stating under oath that “I never learned any confidential, non-public information about the Epstein matter.” Id., DE 79-1. The U.S. Attorney’s Office for the Southern District of Florida has since admitted, in answers to our request for admissions in the Jane Doe matter, that sworn statement is false. The circumstances surrounding making his false statement make it apparent that this could not have been an accident. I believe that Dexter Lee and other prosecutors within the U.S. Attorney’s Office in the Southern District of Florida can provide you further information showing how declaration was clearly false.¶
Jane Doe No. 1 and Jane Doe No. 2 have been harmed by his false statement and are, accordingly, “victims” of his federal crime of perjury. As their attorney (along with co-counsel ), I would like to confer with you about how your Office intends to handle this issue. See 18 U.S.C. 3771(a)(5) (victim’s right to confer). I understand that the matter was referred to your Office because of the conflict of interest that the U.S. Attorney’s Office for the Southern District of Florida might have investigating perjury by one of its former prosecutors.¶
Last summer, I tried to reach your Office repeatedly to learn the status of the referral. I had been told by the U.S. Attorney’s Office for the Southern District of Florida that AUSA was handling the matter. I later learned that had left your Office and the matter had been reassigned to AUSA After repeated calls, I ultimately made contact with who then told me he would contact to see about the case. After further inquiries, I was told that the matter had been further reassigned to AUSA In about October, my co-counsel and I were able to speak to about the case, and we were¶
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assured that appropriate investigation was moving forward and that Mr. would stay in touch.¶
Having not heard back from Mr. for a while, on December 5, 2015, I sent him an email to inquire about the status of the case. I received a “bounceback” email indicating that he was apparently no longer with your Office. I then made a series of phone calls to who I was told was handling the reassignment of cases that had previously been handled by AUSA After several weeks of telephone calls, I was able to talk to She told me that the matter was on the desk of the First Assistant and was pending reassignment. I was told to call for further information.¶
I have left phone messages for Ms. I on December 28, January 5, January 14, and yesterday – none of which have been returned. Accordingly, I am writing to you.¶
I hope you can see why Mr. and I may be concerned about whether the case is being expeditiously handled. It appears that it is about to be reassigned to the fourth AUSA in in the last six months and no one is responding to my repeated calls about conferring on the case. The case presents very important issues about the integrity of the judicial process and the fair treatment of crime victims. I hope that someone in your Office will call me about the case soon.¶
I can be reached through the contact information above. Thanks in advance for your consideration of this issue. (Note: the views expressed in this letter are my own, and are not an institutional position of the University of Utah.)¶
Sincerely,¶
Cc:¶
Paul G. Cassell¶
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