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ound September 2007. plea discussions took place between Jeffrey Epstein, represented by numerous attorneys (including lead criminal defense counsel Jay Leflcowitz), and the U.S. Attorney's Office for the Southern District of Florida, represented by Assistant U.S. Attorneyed others. The plea discussions gener
Lefkowitz stain . SIMIMMISIO U.S. Attorney's Correspondence at 156. 15. On about September 26, 2007, the U.S. Attorney's Office sent an e-mail to Lefkowitz in which she stated• arnale EFTA00229924 Case 9:O8-cv-80736-KAM Document 48 Entered on FLSD Docket 03/21/2011 Page 9 of 42 Apparently the ' gree
possible prosecution. Tr. July 11, 2008, at 4-6, 18-19, 22-23, 28-29. 23. On about November 27, 2007, Assistant U.S. AttorneMM sent an e-mail to Jay Leikowitz, defense counsel for Epstein. The e-mail stated that the U.S. Attorney's Office had an obligation to notify the victims S 12 EFTA00229928 7.7
tein's counsel U.S. Attorney's Correspondence at 153 (emphases added). 14. On about September 25, 2007, the U.S. Attorney's Office sent an email to Lefkowitz stain . SIMIMMISIO U.S. Attorney's Correspondence at 156. 15. On about September 26, 2007, the U.S. Attorney's Office sent an e-mail to Lefkowitz
ould apply. Since the earliest days of our nation, it has been settled law that "where there is a legal right, there is also a legal remedy . . .." Marbury v. Madison, 5 U.S. 137, 163 (1803) (internal quotation omitted). Moreover, "[i]f the right is created by a federal statute, the federal courts have
ly to reach the;Palm Beach area. U.S. Attorney's Correspondence at 29. 13. On about September 24, 2007, the U.S. Attorney's Office sent an e-mail to Jay Lefkowitz, criminal defense counsel for Epstein, regarding the agreement. The e-mail stated that the Government and Epstein's counsel U.S. Attorney's Corresp
LSD Docket 03/21/2011 Page 7 of 42 felony offenses and would serve only county jail time. Many of the negotiations are reflected in e-mails between Lefkowitz and the U.S. Attorney's Office. See generally Exhibit "A." 10. The evidence supporting these charges was overwhelming, including the interlocking
ld apply. Since the earliest days of our nation, it has been settled law that "where there is a legal right, there is also a legal remedy . . . .." Marbury-v. Madison, 5 U.S. 137, 163 (1803) (internal quotation omitted). Moreover, "[i]f the right is created by a federal statute, the federal courts have
rs" within the meaning of Rule 6(e), then it likewise violated grand jury secrecy for government attorneys to make such disclosures to (for example) Jay Lefkowitz. Disclosures of confidential grand jury matters can only be made upon court order. See Fed. R. Crim. P. 6(c)(3)(E). Everything the victims are disc
eys to make such disclosures to (for example) Jay Lefkowitz. Disclosures of confidential grand jury matters
This argument contradicts fundamental American jurisprudence, which holds that "where there is a legal right, there is also a legal remedy . .." Marbury v. Madison, 5 U.S. 137, 163 (1803) (internal quotation omitted). 'I'he victims have deferred full briefing on the remedy issue because they understa
o a mere two state prostitution-solicitation charges and agree to an 18-month sentence in the county jail. On September 16, 2007, Epstein's counsel Jay Lefkowitz sent the U.S. Attorney's Office a proposed written agreement, wherein the Office would extend immunity from federal prosecution to Epstein and cer
federal immunity. The co-conspirators did not sign the NPA and were not listed as parties to it. 7 As the NPA was being signed. Epstein's attorney Lefkowitz e-mailed AUSA Villafana, requesting: "Marie— Please do whatever you can to keep this (NPA) from becoming public." AUSA Villafana assured Lefkowitz that
opriate equitable remedy"). Furthermore, it has long been an "indisputable rule, that where there is a legal right, there is also a legal remedy." Marbury v. Madison, 5 U.S. 1 Cranch 137, 163, 2 L.Ed. 60 (1803) (quoting 3 William Blackstone, Commentaries *23). For that reason, "[w]here legal rights ha
ly to reach the'Palm Beach area. U.S. Attorney's Correspondence at 29. 13. On about September 24, 2007, the U.S. Attorney's Office sent an e-mail to Jay Lefkowitz, criminal defense counsel for Epstein, regarding the agreement. The e-mail stated that the Government and Epstein's counsel U.S. Attorney's Corresp
LSD Docket 03/21/2011 Page 7 of 42 felony offenses and would serve only county jail time. Many of the negotiations are reflected in e-mails between Lefkowitz and the U.S. Attorney's Office. See generally Exhibit "A." 10. The evidence supporting these charges was overwhelming, including the interlocking
ld apply. Since the earliest days of our nation, it has been settled law that "where there is a legal right, there is also a legal remedy . . . .." Marbury v. Madison, 5 U.S. 137, 163 (1803) (internal quotation omitted). Moreover, "[l]t' the right is created by a federal statute, the federal courts hav
Entities connected to both Jay Lefkowitz and Marbury

Jeffrey Epstein
PERSON
Alexander Acosta
PERSONLeon Black
PERSONRoy Black
PERSON
A. Marie Villafana
PERSONJack Goldberger
PERSON
Kenneth Marra
PERSON
United States
LOCATION
Department of Justice
ORGANIZATIONJane Doe
PERSON
Jeffrey Sloman
PERSONMartin Weinberg
PERSON
Bradley Edwards
PERSONthe Southern District
LOCATION
Alan Dershowitz
PERSON
George W. Bush
PERSONGerald Lefcourt
PERSON
Prince Andrew
PERSON
Paul Cassell
PERSON
Lesley Groff
PERSON