Epstein Secrets

ification letter, and draft correspondence to Jay Lefkowitz." Here again, the materials at issue go to the h

. Black, Srebnick, Kornspan & Stumpf, P.A. 201 South Biscayne Boulevard, Suite 1300 Miami, FL 33131 Email: [email protected] (305) 37106421 Jay P. Lefkowitz Kirkland & Ellis, LLP 601 Lexington Avenue New York, NY 10022 Email: [email protected] (212) 446-4970 Martin G. Weinberg, P.C. 20 Park Pl

entry reads: "File folder entitled '12/05/07 Stan• to Acosta' containing drafts of 11/30/07 letters from A. Acosta to K. Starr and from J. Sloman to J. Lefkowitz re performance and victim notification with handwritten notes and edits by A. Marie Villafafla." Again, these materials are central to the dispute i

d.6 As a fourth and final illustration, the victims requested information about why the U.S. Attorney's Office for the Southern District of Florida (USAO-SDFL) was "conflicted out" of considering issues relating to the Epstein matter, as well as any information that developed about that conflict after the

ail: E-mail: Attorneys for the Government Roy Black, Esq. Jackie Perczek, Esq. Black Srebnick Korns . an & Stum.f P.A. Miami, FL 33131 Email: Jay P. Lefkowitz Kirkland & Ellis, LLP New York NY 10022 Email: Martin G. Weinberg, P.C. Boston MA 02116 Email: Criminal Defense Counsel for Jeffrey Epstein /

an & Stum.f P.A. Miami, FL 33131 Email: Jay P. Lefkowitz Kirkland & Ellis, LLP New York NY 10022 Email:

.' As a fourth and final illustration, the victims requested information about why the U.S. Attorney's Office for the Southern District of Florida (USAO-SDFL) was "conflicted out" of considering issues relating to the Epstein matter, as well as any information that developed about that conflict after the

Government." See supra at 1-3. II. Denied. 12. The Respondent admits that, after receiving a request (RFP MIA 000281) from Epstein defense counsel Jay Lefkowitz on September 24, 2007, to "[p]lease do whatever you can to keep this from becoming public," the USAO-SDFL did take some steps to keep the non-prose

RFP MIA 000281) from Epstein defense counsel Jay Lefkowitz on September 24, 2007, to "[p]lease do whatever

to the instant matter. This litigation involves petitioners' claims that the United States Attorney's Office for the Southern District of Florida (USAO-SDFL) violated the petitioners' rights under the Crime Victims Rights Act (CVRA) when the USAO-SDFL entered into a non-prosecution agreement with Jeffrey

Discovery has revealed that during these negotiations, several drafts of the NPA were exchanged. See, e.g., Exh. C (9/17/07 email from Villafana to Lefkowitz attaching draft NPA); Exh. D (9/21/07 email from Villafana to Lefkowitz attaching draft NPA). In addition, the parties exchanged several drafts of

squarely refutes the government's position. The co-conspirator immunity provision does not prohibit merely prosecutions by the USAO for the SDFL ("USAO-SDFL"), but by "the United States." This broad prohibition was intentional, as demonstrated by the express references elsewhere in the NPA to the United

Discovery has revealed that during these negotiations, several drafts of the NPA were exchanged. See, e.g., Exh. C (9/17/07 email from Villafana to Lefkowitz attaching draft NPA); Exh. D (9/21/07 email from Villafana to Lefkowitz attaching draft NPA). In addition, the parties exchanged several drafts of

squarely refutes the government's position. The co-conspirator immunity provision does not prohibit merely prosecutions by the USAO for the SDFL ("USAO-SDFL"), but by "the United States." This broad prohibition was intentional, as demonstrated by the express references elsewhere in the NPA to the United

ision in the NPA is intended to refer only to the USAO-SDFL, it does so explicitly. See Mem. at 8-9 (citing examples of NPA's explicit references to USAO-SDFL). While the government is correct that the use of the term "the United States" in a plea agreement, without snore, is insufficient under Annabi and

submitted an affidavit from Epstein's counsel, defense counsel notes that it has made several unsuccessful attempts to obtain information from Jay Lelkowitz, the attorney who was principally involved in negotiating the language of the NPA on Epstein's behalf. 17 EFTA00028900 --- PAGE BREAK --- CONCLU