I don’t think we have an issue with staleness because the memory cards are fixed (they haven’t changed since the original search warrant).¶
Assistant U.S. Attorney¶
500 S. Australian Ave, Suite 400¶
West Palm Beach, FL 33401¶
Phone¶
-----Original Message-----¶
From: Kuyrkendall, E N.¶
Subject: Re: Epstein update¶
I like your style! Unsure what communication btw Jeff and Jay is about?? Also do we have staleness issues with SW?¶
Hi all - I wanted to update you on a couple of new developments in the Epstein case. First, Jeff Herman is supposed to give a press conference today announcing the filing of a third lawsuit against Epstein. That case also involves a victim whom we are no longer referring to in the indictment [Drew - please do not tell that to the defense.] Herman seems to have latched onto the group which, as discussed in my third addendum to the pros memo, we have already decided to forego for the most part.¶
Drew - Since I am not certain of the scope of your meeting, I do not know how critical it is for you to see the new facts developed in the supplemental pros memos (you reviewed the initial pros memo from May of last year). If you would like the supplements, please let me know. The legal theories have remained the same.¶
1455¶
08-80736-CV-MARRA¶
P-014656¶
EFTA00189352¶
I also wanted to call to everyone’s attention the three-year statute of limitations in Florida for the state solicitation offenses. The statute will run for all the victims this summer. Once it runs we cannot insist on a state court plea to a new charge. It also means that the state cannot charge the crimes related to the victims discovered after the initial investigation. We have asked the Palm Beach Police Department to forego presenting those charges for state prosecution in deference to our prosecution. If we do not intend to go forward, it is imperative that we communicate that to the Police Department as soon as possible so they can present those victims for state prosecution.¶
I have reserved time with the grand jury on the 18th. I had hoped to present the indictment at that time, but in light of Jeff’s communication with Jay, I will push it off until the 25th. I would still like to start the presentation on the 18th so we aren’t accused of rushing the grand jury. So,’ I hope that the final indictment packet will be approved by that date.¶
Thank you.¶
1456¶
08-80736-CV-MARRA¶
P-014657¶