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August 4, 2009 VIA ELECTRONIC MAIL Spencer T. Kuvin, Esq. Leopold—Kuvin, P.A. 2925 PGA Boulevard Suite 200 Palm Beach Gardens, FL 33410 Re: Jeffrey Epstein/B.B. — Requested Disclosure of Non-Prosecution Agreement Dear Mr. Kuvin: Thank you for your letter regarding the disclosure of the Non-Prosecution Agree
ter giving notice of breach. I respectfully submit that the Motion to Dismiss that is referenced therein did not constitute a willful breach of Mr. Epstein's obligations under the non-prosecution agreement. Mr. Epstein's counsel unanimously determined that the filing of this Motion to Dismiss was not a
tatement [DE 29] dated May 26, 2009. Counsel for Defendant EPSTEIN Certificate of Service I HEREBY CERTIFY that a
, Suite 400 West Palm Beach, Florida 33401 Re: Jeffrey Epstein Dear Ms. Villafana, M www.kirkland.com
d therein did not constitute a willful breach of Mr. Epstein's obligations under the non-prosecution agreement
tion against Jeffrey Epstein styled B.B.I. Jeffi-ey Epstein, case no.: 502008CA037319 MB AB. We are hereby r
reviewed this very matter with you and other individuals in your Office in November 2008. At that time, Mr. Roy Black met with you, Karen Atkinson, Bob Senior, and Jeffrey Sloman in Miami to review the work release issue. Among other significant documents shown to you, we presented you with your own email
tion of Jeffrey Epstein to Intervene and to Quash Grand Jury Subpoenas 6(e) Box #3 P-012089 Thru P-012129 United States' Response to Motion of Jeffrey Epstein to Intervene and to Quash Grand Jury Subpoenas and Cross-Motion to Compel 6(e) Box #3 P-012130 Thru P-012150 Declaration of Joseph Recarey 6(
admits that the FBI and the U.S. Attorney's Office for the Southern District of Florida ("USAO") conducted an investigation into Jeffrey Epstein ("Epstein") and developed evidence and information in contemplation of a potential federal prosecution against Epstein for many federal sex offenses. Except
of 23 EFTA00191231 Bates Range Description Privilege(s) Asserted Box #3 P-011923 Thru P-011966 Folder entitled "Responses to Arguments from JE Counsel" containing: ■ 7/13/2007 letter from Lilly Ann Sanchez to Andrew Lourie with handwritten attorney (Lourie) notes; ■ 6/25/2007 letter fro
Florida ("USAO") conducted an investigation into Jeffrey Epstein ("Epstein") and developed evidence and i
ation of Jeffrey Epstein has been completed, and Mr. Epstein and the U.S. Attorney's Office have reached an ag
llafafia regarding letter received from Lilly Ann Sanchez Work Product Deliberative Process 49 3/19/2008-3/27/2008 emails between Jeff Sloman, Bob Senior, Karen Atkinson, Rolando Garcia, Nesbitt Kurykendall, and Jason Richards regarding waiting for DC's decision regarding Epstein's challenges to NP
ana, Esq. United States Attorney's Office Southern District of Florida 500 South Australian Avenue, Suite 400 West Palm Beach, Florida 33401 Re: Jeffrey Epstein Dear Marie: Wel write prepared this answer in response to your letter dated June 15, 2009. At this point, as you are well aware it has been well
nt first intervened in what was originally a matter investigated and charged by state prosecutorial authorities. It has been almost a year since Mr. Epstein pleaded guilty in state court and began serving his sentence in county jail, pursuant to the terms and as a direct result of the federal Non-Prosec
e, Suite 400 West Palm Beach, Florida 33401 Re: Jeffrey Epstein Dear Marie: Wel write prepared this ans
rial authorities. It has been almost a year since Mr. Epstein pleaded guilty in state court and began serving
nd Mr. Goldberger who failed to approved of—ethe victim notification letter that contained incorrect information .eereeivking infematieri-thatailfr Epsteicr-and-I-eentendeel-is-ineerveet, See June 15 letter at 2. Thate incorrect information eenteineel-in the letter was a proposed unilateral modification
eviewed this very matter with you and other individuals in your office in November 2008. At that time, Mr. Roy Black met with you, Karen Atkinson, Bob Senior, and Jeffrey Sloman in Miami to review the work release issue. Among other significant documents, we presented you with your EFTA00731119 Ms. A.
nt first intervened in what was originally a matter investigated and charged by state prosecutorial authorities. It has been almost a year since Mr. Epstein pleaded guilty in state court and began serving his sentence in county jail, pursuant to the terms and as a direct result of the federal Non-Prosec
Dear Marie: vvwkirkland.com June 19, 2009 Re: Jeffrey Epstein Facsimile: We prepared this answer in response
Dear Marie: vvwkirkland.com June 19, 2009 Re: Jeffrey Epstein Facsimile: We prepared this answer in r
rial authorities. It has been almost a year since Mr. Epstein pleaded guilty in state court and began serving
reviewed this very matter with you and other individuals in your Office in November 2008. At that time, Mr. Roy Black met with you, Karen Atkinson, Bob Senior, and Jeffrey Sloman in Miami to review the work release issue. Among other significant documents shown to you, we presented you with your own email
ange of plea on June 30, 2008 but did not have any contact with any member of the SAO that day. Later, when the issue arose regarding whether or not Epstein was taking the position that the NPA included USA Acosta's December 2007 letter, I contacted Ms. Behlolavek and SA Krischer to obtain a copy of wha
pstein would be pleading guilty on June 30, 2008, I would not release the witness (id). I formally withdrew the subpoena on June 30, 2008, following Jeffrey Epstein's entry of his guilty plea in state court (Exhibit B-135). These activities took us up to the time of Jeffrey Epstein's June 30, 2008 guilty plea. Fro
IA FACSIMILE Brad Edwards, Esq. The Law Offices of Brad Edwards & Associates, LLC 2028 Harrison Street, Suite 202 Hollywood, Florida 33020. Re: Jeffrey EpsteinMIM NOTIFICATION OF IDENTIFIED VICTIM Dear Mr. Edwards: By virtue of this letter, the United States Attorney's Office for the Southern Dis
prosecution of any potential co-conspirators of Mr. Epstein, including unidentified co-conspirators. I do n
line to enter his guilty plea would be extended again, and we continued preparing for indictment (Exhibits B-34 through B-37). So, on May 27, 2008, Bob Senior, who took Matt Menchel's place as Criminal Chief, Jeff Sloman, who had taken over for USA Acosta due to his recusal from the Epstein matter, Karen
mail from Andy Lourie to Man Menchel and Jeff Sloman (cc: Marie Villafaila) re letter received from Gerald Lefcourt discussing a meeting to discuss Epstein investigation Work Product Deliberative Process P-013982 5/23/2007 email from Jason Richards to Marie Villafaiia re extradition research Work P
estions Work Product 6(e) Deliberative Process Investigative Privilege P-014781 thru P-014800 3/19/2008-3/27/2008 emails between Jeff Sloman, Bob Senior, Karen Atkinson, Rolando Garcia, Nesbitt Kurykendall, and Jason Richards regarding waiting for DC's decision regarding Epstein's challenges to NPA
mail from Andy Lourie to Man Menchel and Jeff Sloman (cc: Marie Villafaila) re letter received from Gerald Lefcourt discussing a meeting to discuss Epstein investigation Work Product Deliberative Process P-013982 5/23/2007 email from Jason Richards to Marie Villafaiia re extradition research Work P
estions Work Product 6(e) Deliberative Process Investigative Privilege P-014781 thru P-014800 3/19/2008-3/27/2008 emails between Jeff Sloman, Bob Senior, Karen Atkinson, Rolando Garcia, Nesbitt Kurykendall, and Jason Richards regarding waiting for DC's decision regarding Epstein's challenges to NPA
ail from Andy Lourie to Matt Menchel and Jeff Sloman (cc: Marie Villafafia) re letter received from Gerald Lefcourt discussing a meeting to discuss Epstein investigation Work Product Deliberative Process P-013982 5/23/2007 email from Jason Richards to Marie Villafafia re extradition research Work P
estions Work Product 6(e) Deliberative Process Investigative Privilege P-014781 thru P-014800 3/19/2008-3/27/2008 emails between Jeff Sloman, Bob Senior, Karen Atkinson, Rolando Garcia, Nesbitt Kurykendall, and Jason Richards regarding waiting for DC's decision regarding Epstein's challenges to NPA
ail from Andy Laurie to Matt Menchel and Jeff Sloman (cc: Marie Villafatia) re letter received from Gerald Lefcourt discussing a meeting to discuss Epstein investigation Work Product Deliberative Process P-013982 5/23/2007 email from Jason Richards to Marie Villafaila re extradition research Work P
Page: EFTA00020711 →estions Work Product 6(e) Deliberative Process Investigative Privilege P-014781 thru P-014800 3/19/2008-3/27/2008 emails between Jeff Sloman, Bob Senior, Karen Atkinson, Rolando Garcia, Nesbitt Kurykendall, and Jason Richards regarding waiting for DC's decision regarding Epstein's challenges to NPA
Page: EFTA00020726 →Entities connected to both Jeffrey Epstein and Bob Senior
Leon Black
PERSON
Prince Andrew
PERSON
Alan Dershowitz
PERSON
George W. Bush
PERSON
Bradley Edwards
PERSON
United States
LOCATIONJack Goldberger
PERSONSouthern District
LOCATIONJane Doe
PERSON
Department of Justice
ORGANIZATIONMaria Farmer
PERSONMartin Weinberg
PERSON
Kenneth Marra
PERSON
Alexander Acosta
PERSONthe Southern District
LOCATION
Paul Cassell
PERSON
A. Marie Villafana
PERSON
Virginia Giuffre
PERSON
Jay Lefkowitz
PERSONRoy Black
PERSON