LAW OFFICES ALLEN GUTHRIE MCHUGH & THOMAS, PLLC Rip G. WHINE B. ALLEN REBECCA k BETTS R. lERRANCE ROOMERS DAVID 8. THOMAS JAMES S. ARNOLD DAVID J. HARDY WM SCOTT WICKLINE PAMELA L. CAMPBELL PAMELA C DEEM PHILIP J. CO/ABS STEPHANE D. THICKER BRYANT J. SPANN TERESA K. THO/APSON DEBRA C. PRICE CHRISTOPHER S. ARNOLD CHRISTOPHER D. PENCE PETER G. MAIVOLIM ZACKARV B. LLISEY OF COUNSEL THOMAS E. McHUGH P. 0. BOX 3301 CHARLESTON, WEST VIRGINIA 25333-3394 500 LEE STREET. EAST. SMITE 800 CHARLESTON. WEST VIRGINIA 25301 June 19, 2008 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: TELEPHONE FACSWIL.MMI WRITER'S DIRECT OK e•fiella 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 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, I 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