Epstein Secrets

/JOHNSON JANE DOE I and JANE DOE 2, Plaintiffs, v. UNITED STATES OF AMERICA, Defendant. MOTION TO INTERVENE OF ROY BLACK, MARTIN WEINBERC, AND JAY LEFKOWITZ This is a motion pursuant to Federal Rule of Civil Procedure 24(a) by attorneys Roy Black, Martin Weinberg, and Jay Lefkowitz, to intervene for the

INTERVENE OF ROY BLACK, MARTIN WEINBERC, AND JAY LEFKOWITZ This is a motion pursuant to Federal Rule of Civ

omcyJ ay Lefkowitz within the next few days, as soon as a certificate of good standing from the New York Bar arrives. Attorneys Black, Weinberg and Lcfkowitz do not seek intervention to litigate whether the Crime Victims' Rights Act was violated and if so, against whom a remedy is appropriate. Instead, t

llowed those other victims to participate while maintaining some semblance of privacy. Petitioners also reiterate baseless allegations made against AUSA Villafaila regarding the choice of the attorney-representative for the victims, despite knowing that: (1) the issue of the attorney-representative arose after

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

t the United States 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

to confer with your co-counsel regarding this matter. Although the language of Paragraph 8 could be so construed, our First Assistant informed Mr. Lefkowitz some weeks ago that this was not our position. As Mr. Lefkowitz has noted, were Mr. Epstein convicted at trial, the plaintiff-victims in a subsequen

ourself, Professor Dershowitz, former United States Attorney Guy Lewis, Ms. Lilly Ann Sanchez and Messrs. Roy Black, Goldberger, Geny Lefcourt and Jay Lefkowitz had the opportunity to review and raise objections to the terms of the Agreement. Again, no one raised objections to the Section 2255 language. Si

ion 2255 provision issue was first discussed at a July 31, 2007, meeting between FAUSA Sloman, Criminal Chief Menchel, West Palm Beach Chief Lourie, AUSA Villafaila, and two FBI agents who met with Roy Black, Gerald Lefcourt, and Lilly Ann Sanchez. On that date, the prosecutors presented a written, four-bullet-

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

e a lengthy process and we request your continued patience while we conduct a thorough investigation." Further, on January 31, 2008, Wild met with AUSA Villafaila, FBI agents, and another federal prosecutor, provided additional details of Epstein's sexual abuse of her, and expressed her hope that Epstein woul

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

ie Villafana secured pro bono counsel to represent Jane Doe #1. Pro bono counsel was able to assist Jane Doe #1 in avoiding the improper deposition. AUSA Villafaila secured pro bono counsel by contacting Meg Garvin, Esq. of the the National Crime Victims' Law Center in Portland, Oregon, which is based in the Le

fered to join the trial team and provide additional support from CEOS. On September 7, 2007, U.S. Attorney Acosta met with Kirkland & Ellis partners Jay Lefkowitz and former Solicitor General Ken Starr and Ms. Sanchez, along with Chief Oosterbahn and AUSAs Villafana, John McMillan, and FAUSA Sloman.6 Messrs. S

r Solicitor General Ken Starr and Ms. Sanchez, along with Chief Oosterbahn and AUSAs Villafana, John McMillan, and FAUSA Sloman.6 Messrs. Starr and Lefkowitz presented arguments regarding the sufficiency of the federal interest in the case and other legal and factual issues. We discussed those legal argum

e S. Fisher, as well as the Criminal Division's Appellate Section and the Office of Enforcement Operations regarding the petit policy. By May 2007, AUSA Villafaila began seeking approval from her supervisors to indict Epstein. Her immediate supervisor was Andrew Lourie. Mr. Lourie had served as the Chief of the

East Broward Boulevard. 7th Floor Fort Lauderdale, FL 33394 (954) 660-5946 Facsimile. (954) 356-7230 June 15, 2009 DELIVERY BY ELECTRONIC MAIL Jay P. Lefkowitz, Esq. Kirkland & Ellis LLP Citigroup Center 153 East 53rd Street New York, New York 10022-4675 Roy Black, Esq. Black Srebnick Kornspan & Stumpf

Goldberger & Weiss, P.A. One Clearlake Centre, Suite 1400 250 Australian Ave S. West Palm Beach, FL 33401-5015 Re' Jeffrey Epstein Dear Messrs. Lefkowitz, Goldberger, and Black: I write to confirm my conversation with Mr. Lefkowitz of June 12, 2009. As I mentioned during that conversation and during

. Next, you assert that our letter miscb aractetizes Mr. Epstein's obligation to pay damages to the victims. To avoid that suggestion, I have asked AUSA Villafaila to simply quote the terms of the Agreement directly into the Notification Letter. We also have no objection to referring to Mr. Epstein as a "sexua