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ppropriate. Eighth, it is both unreasonable and unjustifiable to hold Mr. Epstein responsible—never mind declare him in breach—with regard to Judge McSorley's nunc pro tune order. Exhibit 1, June 15, 2009 Letter at 3. Neither Mr. Epstein nor defense counsel had anything to do with and certainly no prior
nder the NPA. As you know from past experience, and as Mr. Acostuaviously acknowledged in letters to my partner Ken Starr (on December 4, 2007) and Lilly Sanchez (on December 19, 2007), the language of 18 is "far from simple," and, in certain respects, subject to significant ambiguity. I believe it
ortant and must be fully vetted irrespective of timeliness concerns." See Exhibit 6, December 19, 2007 Letter from U.S. Attorney Acosta to Attorney Lilly Sanchez at 3. He also stated that he had spoken with AAG Fisher to ask that she review this matter and to expedite the process. Id. • In the beg
ctim notifications (and, later, I Declaration in the Jane Doe litigation) based upon this understanding. When Epstein entered his guilty plea, Judge McSorley required him to file his federal Non-Prosecution Agreement with the Court since that formed part of the consideration for the state plea. I wanted
those changes. Criminal Chief participated in numerous meetings on the case, and had private conversations regarding resolution of the matter with Lilly counsel to Mr. Epstein. Ms. had formerly served as Deputy Chief in the Major Crimes Section at the USAO while Mr. was Chief of Major Crimes. As
the Mare to set a timely plea and sentencing date. At that time, you assured me that the scheduling delay was caused by the unavailability of Judge McSorley. You promised that a date would be set promptly. On November 15M, Rotondo Garcia met with Barry Krisher on another Matta, and was told by Mr. ICriab
were detailed and time-consuming. Mr. Epstein's defense team, including yourself, Professor Dershowitz, former United States Attorney Guy Lewis, Ms. Lilly Ann Sanchez and Messrs. Roy Black, Jack Goldberger, Gerry Lefcourt and Jay Lefkowitz had the opportunity to review and raise objections to the term
ess in Livingston, New Jersey. EFTA00232796 CAPTAIN DAVID SLEETH DECEMBER 11, 2008 PAGE 5 application for work release. I understand that Judge McSorley's standing order states that she "takes no position with respect to the eligibility of any inmate sentenced in this Division unless specifically st
between his attorneys and your office, Epstein secretly withheld correspondence by several of his mostii ral owered attorneys — namely Ken Starr and Lilly. Sanchez. Epstein settled the case wit within days after this limited production, and we did not realize the absence of what must have been critic
ctim notifications (and, later, a Declaration in the Jane Doe litigation) based upon this understanding. When Epstein entered his guilty plea, Judge McSorley required him to file his federal Non-Prosecution Agreement with the Court since that formed part of the consideration for the state plea. I wanted
in child exploitation cases was an issue of growing concern, so I was mindful that this plea mechanism that Criminal Chief Menchel had devised with Lilly Ann Sanchez would extinguish, the victims' right to restitution. That was one of the reasons why, on July 4, 2007, I wrote to Mr. Menchel that I be
s Office about legal repercussions if he was not admitted to the program. I also discovered—again, not from Mr. Epstein or his attorneys—that Judge McSorley had modified Mr. Epstein's judgment motc pro tune to an "Order of Community Control I," which directly contradicted the terms of the Non- Prosecutio
were detailed and time-consuming. Mr. Epstein's defense team, including yourself, Professor Dershowitz, former United States Attorney Guy Lewis, Ms. Lilly Ann Sanchez and Messrs. Roy Black, Jack Goldberger, Gerry Lefeourt and Jay Lefkowitz had the opportunity to review and raise objections to the term
s Office about legal repercussions if he was not admitted to the program. I also discovered—again, not from Mr. Epstein or his attorneys—that Judge McSorley had modified Mr. Epstein's judgment motc pro tune to an "Order of Community Control I," which directly contradicted the terms of the Non- Prosecutio
were detailed and time-consuming. Mr. Epstein's defense team, including yourself, Professor Dershowitz, former United States Attorney Guy Lewis, Ms. Lilly Ann Sanchez and Messrs. Roy Black, Jack Goldberger, Gerry Lefcourt and Jay Lefkowitz had the opportunity to review and raise objections to the term
Entities connected to both Sandra K. McSorley and Lilly

Jeffrey Epstein
PERSONJack Goldberger
PERSONAnn Sanchez
PERSON
Alexander Acosta
PERSON
Department of Justice
ORGANIZATIONDarren Indyke
PERSONLeon Black
PERSON
Lesley Groff
PERSONRoy Black
PERSON
United States
LOCATION
Joe Biden
PERSON
Jay Lefkowitz
PERSON
Palm Beach County
LOCATIONthe Southern District
LOCATION
Kenneth Marra
PERSON
Ken Starr
PERSONGerald Lefcourt
PERSONRobert C. Josefsberg
PERSONSouthern District
LOCATION
A. Marie Villafana
PERSON