LAW OFFICES ALLEN GUTHRIE MCHUGH & THOMAS, PLLC
P.O. BOX 3394 ‘ORGE G. RI r Gepraoe ST ERE CHARLESTON, WEST VIRGINIA 25333-3304 REBECCA A. BETTS oehiae 500 LEE STREET, EAST, SUITE 800 JAMES 8, ARNOLD CHARLESTON, WEST VIRGINIA 25301
DAVID J. HARDY : WM. SCOTT WICKLINE oa PAMELA L, ‘CAMPBELL
PAMELA C. DEEM FACSIMILE!
PHILIP J. COMBS STEPHANIE D. TRACKER
BRYANT J. SPANN — WRITER'S DIRECT DIAL TERESA K. THOMPSON DEBRA C. PRICE e-mails
CHRISTOPHER S. ARNOLD
CHRISTOPHER D. PENCE
PETER G, MARKHAM
ZACKARY B. MAZEY June 19, 2008
OF COUNSEL THOMAS E. McHUGH
Mr. John Roth
Senior Associate Deputy Attorney General Office of the Deputy Attorney General United States Department of Justice
950 Pennsylvania Avenue, N.W. Washington, D.C. 20530
Dear Mr. Roth:
I write to offer my reaction to the May 15, 2008 correspondence from the United States Department of Justice Child Exploitation and Obscenity Section (“CEOS”) regarding the federal investigation of Jeffrey Epstein by the United States Attorney’s Office for the Southern District of
Florida (“(USAO”).’ I will refrain from recounting Mr. Epstein’s arguments in detail here, but, rather, will highlight salient points responsive to the CEOS letter.
In particular, I write from a background well familiar with child exploitation cases and victim/witness issues. As the CEOS letter points out (CEOS letter at p. 3), I was a member of CEOS. In fact, I served as a federal prosecutor for twelve years; five years as an Assistant United States Attorney for the Southern District of West Virginia, and seven years at CEOS. I began working as a trial attorney for CEOS in 1999, and was promoted to Deputy Chief for Litigation in 2002, and ultimately to Principal Deputy Chief for the Section in 2004,
As those who have worked with me know, [have a history of working diligently on behalf of victims of crime. While at the United States Attorney’s Office for the Southern District of West Virginia, I was a part of the prosecution team that prosecuted the first case in the country under the federal Violence Against Women Act. United States v. Bailey, 112 F.3d 758 (4" Cir.), cert denied, 522 U.S. 896 (1997). The case went to trial and the defendant was sentenced to life in prison. I also spearheaded the domestic violence and federal criminal child support prosecution efforts for that office, prosecuting some of the first cases in the country under the federal Child Support Recovery
1 Citations to the May 15, 2008 correspondence will be referenced herein as “CEOS letter at p. __.”
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