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minimize Epstein's civil exposure. For example, on October 3, 2007, Assistant U.S. Attorney Marie sent an email (attached hereto as Exhibit "D") to Jay Lefkowitz, counsel for Epstein, with attached proposed letter to special master regarding handling numerous expected civil claims against Epstein. The letter
Attorney's Office prepared negotiated plea agreements containing these charges. For example, in a September 18, 2007, email from AUSA Villafaila to Lefkowitz (attached hereto as Exhibit "H"), she attached the proposed plea agreement describing Epstein's witness tampering as follows: "UNITED STATES vs. JE
Epstein became a convicted sex offender, he was not to have contact with any of his victims. During the course of his guilty pleas on June 30, 2008, Palm Beach Circuit Court Judge Deborah Dale Pucillo ordered Epstein "not to have any contact, direct or indirect" with any victims. She also expressly stated that her no-co
ice" in § 3771(a)(5) is 3 Jane Doe No. 2's exculpatory statements regarding Epstein were not lost on his attorneys. A December 21, 2007 letter from Jay Lefkowitz, one of Epstein's attorneys, to U.S. Attorney Acosta, devoted two pages examining Jane Doe No. 2's interview testimony on April 24, 2007. Ex. D at
by Epstein's attorneys to the Deputy Attorney General. Ex... On June 23, 2008, John Roth, Senior Associate Deputy Attorney General wrote to Messrs. Lefkowitz and Stair, advising them that "federal prosecution of this case is appropriate." Ex. I. Mr. Roth also told Epstein's attorneys that their allegation
represented Jane Doe No. 1 and Jane Doe No. 2. (a) This placed both petitioners on notice that Epstein would be pleading guilty on June 30, 2008, in Palm Beach Circuit Court. I. THE GOVERNMENT DID NOT VIOLATE PETITIONERS' § 3771(a)(2) RIGHT TO REASONABLE, ACCURATE, AND TIMELY NOTICE Supreme Court has repeatedly emphas
I (a)(5) is significant 3 Jane Doe No. 2's exculpatory statements regarding Epstein were not lost on his attorneys. A December 21, 2007 letter from Jay Leflcowitz, one of Epstein's attorneys, to U.S. Attorney Acosta, devoted two pages examining Jane Doe No. 2's interview testimony on April 24, 2007. Ex. D at
hts associated with the agreement entered into by the United States and Mr. Epstein in a timely fashion." Ex. N, Nov. 27, 2007 email from Sloman to Lefkowitz. Epstein's attorneys responded by citing to the Attorney General's Guidelines provision stating that there must be a charge filed in a Federal distr
presented Jane Doe No. 1 and Jane Doe No. 2. (Id.) This placed both petitioners on notice that Epstein would be pleading guilty on June 30, 2008, in Palm Beach Circuit Court. Petitioners' arguments and the record in this case simply do not establish that there was any violation of the petitioners' right to confer. See a
71(a)(5) is significant 3 Jane Doe No. 2's exculpatory statements regarding Epstein were not lost on his attorneys. A December 21, 2007 letter from Jay Lefkowitz, one of Epstein's attorneys, to U.S. Attorney Acosta, devoted two pages examining Jane Doe No. 2's interview testimony on April 24, 2007. Ex. D at
hts associated with the agreement entered into by the United States and Mr. Epstein in a timely fashion." Ex. N, Nov. 27, 2007 email from Sloman to Lefkowitz. Epstein's attorneys responded by citing to the Attorney General's Guidelines provision stating that there must be a charge filed in a Federal distr
epresented Jane Doe No. 1 and Jane Doe No. 2. (ti) This placed both petitioners on notice that Epstein would be pleading guilty on June 30, 2008, in Palm Beach Circuit Court. Petitioners' arguments and the record in this case simply do not establish that there was any violation of the petitioners' right to confer. See a
pstein's civil exposure. For example, on October 3, 2007, Assistant U.S. Attorney Marie Villafafia sent an email (attached hereto as Exhibit "D") to Jay Lefkowitz, counsel for Epstein, with attached proposed letter to special master regarding handling numerous expected civil claims against Epstein. The letter
Attorney's Office prepared negotiated plea agreements containing these charges. For example, in a September 18, 2007, email from AUSA Villafafia to Lefkowitz (attached hereto as Exhibit "H"), she attached the proposed plea agreement describing Epstein's witness tampering as follows: "UNITED STATES vs. JE
Epstein became a convicted sex offender, he was not to have contact with any of his victims. During the course of his guilty pleas on June 30, 2008, Palm Beach Circuit Court Judge Deborah Dale Pucillo ordered Epstein "not to have any contact, direct or indirect" with any victims. She also expressly stated that her no-co
system: 500 S. Australian Ave., Suite 400 inis ma West Palm Beach, FL 33401 Attorneys for the Government Roy Black, Esq. Jackie Perczek Es . • Jay P. Lefkowitz Kirkland & Eli P Martin G. Weinberg. P.C. Criminal Defense Counsel for Jeffrey Epstein /s/ Bradley J. Edwards 4 EFTA00188816 Case 9:08-cv-80
Attorney's Office prepared negotiated plea agreements containing these charges. For example, in a September 18, 2007, email from AUSA Villafafia to Lefkowitz (attached hereto as Exhibit "H"), she attached the proposed plea agreement describing Epstein's witness tampering as follows: "UNITED STATES vs. JE
Epstein became a convicted sex offender, he was not to have contact with any of his victims. During the course of his guilty pleas on June 30, 2008, Palm Beach Circuit Court Judge Deborah Dale Pucillo ordered Epstein "not to have any contact, direct or indirect" with any victims. She also expressly stated that her no-co
al mseimien-ef-that-investigatienr Edwards-Deelaratien-at--11-147 33. On about February 25, 2008, Assistant U.S. Attorney Sloman sent an e-mail to Jay Leflcowitz„ a copy of which is attached hereto as Exhibit _.Bpsteinls—eriminal—defense eeunselr explaining that the Justice Department's Child Exploitation Obsc
ter Relantionulso-is-felling-Chief Reiier-not4O-diselose the-eufeente-fe-anyene 4-2, On about September 25, 2007, AUSA Villafafia sent an e-mail to Lefkowitz, a copy of which is attached hereto as Exhibit stating.-11And-ean-we-itaye-a-eenferenee-edi-te-disesss what-I-may-diselese-to,the-gek-regarding-th
2005. Plea bargain The appellate case stems from a decision by federal prosecutors not to charge Epstein if he pleaded guilty to state charges in Palm Beach Circuit Court for soliciting an underage girl for prostitution. He was sentenced to 18 months in jail and house arrest. Epstein moved back to New York City from
Entities connected to both Jay Lefkowitz and Palm Beach Circuit Court

Jeffrey Epstein
PERSON
Alexander Acosta
PERSONLeon Black
PERSONJack Goldberger
PERSONRoy Black
PERSON
Kenneth Marra
PERSON
A. Marie Villafana
PERSON
United States
LOCATIONJane Doe
PERSON
Department of Justice
ORGANIZATION
Jeffrey Sloman
PERSON
Ken Starr
PERSONMartin Weinberg
PERSON
Bradley Edwards
PERSONthe Southern District
LOCATION
Alan Dershowitz
PERSON
George W. Bush
PERSONRobert C. Josefsberg
PERSONGerald Lefcourt
PERSON
Prince Andrew
PERSON