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acy to commit an assault on a plane. I just want to make sure that we have something that is factually accurate. Just trying to plan ahead" (id). At Jay Lefkowitz's request, MAUSA Lourie and I scheduled a conference call with him for early on the morning of September 14, 2007 (id. at 25). Mr. Lourie did not att
Villafana letter to Lclkowitz, Black, and Goldberger regarding history of Epstein's performance under the NPA 89 6/17(2009 Villafaila letter to Lelkowitz regarding monitoring future performance under the NPA 90 9/1/2009 Black letter to Montan seeking approval for Epstein to transfer community contr
draft Plea Agreement 9/18/2007 1:37pm draft Information 9/18/2007 Garcia, Villafaiia Lourie Email stating new terms that Louric negotiated with Lefkowitz 9/19/2007 A. Laurie, R. Garcia, K. A. Marie Villafana Email re negotiating strategy with attached correspondence l6 9/19/2007 A. A. Marie Vi
Criminal Chief Matt Menchel contacted SLC Schultz about moving me to Appeals after I pointed out actions that I considered to be in violation of the Ashcroft memo and victims' rights legislation. I also understand that SLC Schultz may have knowledge of USA Acosta providing my prosecution memorandum to Cr
cy to commit an assault on I plane. I just want to make sure that we have something that is factually accurate. Just trying to plan ahead" (id.). At Jay Lefkowitz's request, MAUSA and I scheduled conference call with him for early on the morning of September 14, 2007 (id. at 25). Mr. did not attend the confere
After correspondence with Roy Black and I telephone conference with Mr. Black and Jay Leflcowitz, we were advised that USA Acosta had informed Mr. Lefkowitz31 that Epstein could be considered for any Erogram that was available to other prisoners. At that point, I was unable to press forward with I breach,
o understand that Criminal Chief contacted SLC about moving me to Appeals after I pointed out actions that I considered to be in violation of the Ashcroft memo and victims' rights legislation. I also understand that SLC ma have knowled e of USA Acosta providing my prosecution memorandum to Main Jus
the authority, and his consent, to make any determination it deems appropriate regarding this matter, including to decline federal prosecution. 2 Jay Lefkowitz has personally reviewed the reporter's contemporaneous notes. EFTA00310840 KIRKLAND & ELLIS LLP Honorable ■ May 14, 2008 Page 4 As you know, I
ncluding to decline federal prosecution. 2 Jay Lefkowitz has personally reviewed the reporter's contempora
o 7. at 6; and January 2004, Vol. 1, No. 1, at I, 3 (reflecting the positions of President Bush, Attorney General Gonzalez, former Attorney General Ashcroft, and former Assistant Attorney General for the Civil Rights Division Acosta that human trafficking involves force, fraud and coercion, and is a for
f Justice Washington, D.C. 20530 June 23, 2008 Jay Lefkowitz„ Esq. Kenneth Starr, Esq. Kirkland and Ellis LL
stice Washington, D.C. 20530 June 23, 2008 Jay Lefkowitz„ Esq. Kenneth Starr, Esq. Kirkland and Ellis LL
de clear that "Twombly expounded the pleading standard for 'all civil actions' and not just pleadings made in the context of an antitrust dispute," Ashcroft'. Iqbal No. 07-1015 (U.S. May 18, 2009) (slip op. at 20) (quoting Fed. R. Civ. P. 1), the need to enforce these pleading requirements is especially
victim elected to proceed exclusively under § 2255, as opposed to a civil damages action). 6 As the Agreement was being signed, Epstein's attorney Jay Lefkowitz e-mailed AUSA Villafana, requesting: "Marie - Please do whatever you can to keep this [Agreement] from becoming public." (emphasis added). AUSA Vil
illafana, requesting: "Marie - Please do whatever you can to keep this [Agreement] from becoming public." (emphasis added). AUSA Villafafia assured Lefkowitz that the Agreement would be kept confidential. 7 For example, in a December 6, 2007 letter, AUSA Villafana informed Lefkowitz that "fsjection 3771
guage of the statute, and we are required to enforce that plain meaning even if the proper interpretation raises policy concerns. See ?" Eldred v. Ashcroft, 537 U.S. 186, 222, 123 S.Ct. 769, 154 L.Ed.2d 683 (2003). "The wisdom of Congress' action ... is not within our province to second guess." ? a Id.
zgaiirkiend.coi cc Subject RE: Meeting A. Marie Villcialla Assistant U.S. Attorney — Ori From: \(USAFLS\)" Sent: 09/19/2007 11:51 AM AST To: Jay Leflcowitz Subject: Meeting Barry is available Monday morning. Our most flexible West Palm Beach magistrate is on duty on Monday, so, assuming we have signe
ey Epstein - con I ential (USAFLS) Dear Mr. Jay Lefkowitz [[email protected]] (USAFLS) I write to
thy balance of power between the States and the Fede I Government will reduce the risk of tyranny and abuse from either front.") (quoting Gregory'. Ashcroft, 501 U.S. 452, 458 (1997)). Thus, Congress's power to legislate in this area is constrained by the Commerce Clause. As Lopez demonstrates, the 08-8
e ...............................60 3. September 7, 2007: Acosta, Other USAO Attorneys, and FBI Supervisors Meet with Epstein Attorneys Starr, Lefkowitz, and Sanchez ...............................................................................................62 VI. SEPTEMBER 2007: THE PLEA NEGO
t, in the interest of full disclosure, I did not believe that Mr. Epstein would be eligible because he will not be in Zone A or B.117 This morning Jay Lefkowitz called and said that I was correct but, if we could get Mr. Epstein down to 14 months, then he thought he would be eligible. My response: have hi
u know is completely unacceptable to the FBI, ICE [Immigration and Customs Enforcement], the victims, and me. These plea negotiations violate the Ashcroft memo, the U.S. Attorney[s’] Manual, and all of the various iterations of the victims’ rights legislation. Strategically, you have started the plea
ng down, we just want to get a final blessing.” Negotiations continued throughout the day on Wednesday, September 19, 2007, with Villafaña and Lefkowitz exchanging emails regarding the factual proffer for a plea and the scheduling of a meeting to finalize the plea agreement’s terms. During that exc
deputy and with whom he had socialized. Later, when Epstein was seeking Acosta’s personal involvement in the case, Epstein hired Kenneth Starr and Jay Lefkowitz, prominent attorneys from Kirkland & Ellis with whom Acosta was acquainted from his previous employment with that firm. Villafaña told OPR that s
he prosecutor harbors a good faith doubt, based on either the law or the evidence, as to the government’s ability to prove the charge at trial. The Ashcroft Memo explains that the “basic policy” “requires federal prosecutors to charge and pursue all charges that are determined to be readily provable” an
Granting Motion for Limited Appearance of Jay P. Lefkowitz) (Critton, Robert) (Entered: 05/21/2009) 05/21/
ion that all the allegations in the complaint are true (even if doubtful in fact)." Id. The United States Supreme Court very recently made clear in Ashcroft v. lubal No. 07-1015 (U.S. May 18, EFTA00175268 Case 9:09-cv-80469-KAM Document 31 Entered on FLSD Docket 06/01/2009 Page 3 of 11 Jane Doe II
ing the state to do a little bit more. 21 Q MM-hmm. All right. Did you have any discussions 22 about whether this disposition comported with the Ashcroft 23 memo in that you were hunting to the state for a minor 24 charge, for a fairly minor charge, what you -- your office 25 had already understo
Page: EFTA00009016 →ing the state to do a little bit more. 21 Q MM-hmm. All right. Did you have any discussions 22 about whether this disposition comported with the Ashcroft 23 memo in that you were hunting to the state for a minor 24 charge, for a fairly minor charge, what you -- your office 25 had already understo
Page: EFTA00009016 →ing the state to do a little bit more. 21 Q MM-hmm. All right. Did you have any discussions 22 about whether this disposition comported with the Ashcroft 23 memo in that you were hunting to the state for a minor 24 charge, for a fairly minor charge, what you -- your office 25 had already understo
Page: EFTA00009016 →y wanted to argue -- they, being defense 13 counsel, wanted to argue why we should not pursue this case. 14 Q And in this case, it was Starr and Lefkowitz from 15 Kirkland & Ellis, and Lilly Ann Sanchez, I believe who met 16 with you. 17 A Fair. I remember it was Starr and Lefkowitz. I 18 don't
Page: EFTA00009055 →y wanted to argue -- they, being defense 13 counsel, wanted to argue why we should not pursue this case. 14 Q And in this case, it was Starr and Lefkowitz from 15 Kirkland & Ellis, and Lilly Ann Sanchez, I believe who met 16 with you. 17 A Fair. I remember it was Starr and Lefkowitz. I 18 don't
Page: EFTA00009055 →y wanted to argue -- they, being defense 13 counsel, wanted to argue why we should not pursue this case. 14 Q And in this case, it was Starr and Lefkowitz from 15 Kirkland & Ellis, and Lilly Ann Sanchez, I believe who met 16 with you. 17 A Fair. I remember it was Starr and Lefkowitz. I 18 don't
Page: EFTA00009055 →ty that was going through to come up 9 with a federal plea, but eventually she and the defense 10 attorney who is most actively working on this, Jay Lefkowitz, 11 turn back to the NPA, and if you look at 17d, just to make 12 the sort of staffing clear, you know, of course 13 has left, is going on vac
Page: EFTA00009083 →ty that was going through to come up 9 with a federal plea, but eventually she and the defense 10 attorney who is most actively working on this, Jay Lefkowitz, 11 turn back to the NPA, and if you look at 17d, just to make 12 the sort of staffing clear, you know, of course 13 has left, is going on vac
Page: EFTA00009083 →ty that was going through to come up 9 with a federal plea, but eventually she and the defense 10 attorney who is most actively working on this, Jay Lefkowitz, 11 turn back to the NPA, and if you look at 17d, just to make 12 the sort of staffing clear, you know, of course 13 has left, is going on vac
Page: EFTA00009083 →Entities connected to both Jay Lefkowitz and Ashcroft

Jeffrey Epstein
PERSON
Alexander Acosta
PERSONKirkland & Ellis LLP
ORGANIZATIONLeon 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
Ken Starr
PERSONthe Southern District
LOCATION
Bradley Edwards
PERSON
Alan Dershowitz
PERSON
George W. Bush
PERSON
Prince Andrew
PERSONRobert C. Josefsberg
PERSON