Epstein Secrets

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

"encompass the entire criminal investigatory process," but rather "at the very least requires the initiation of legal proceedings." P M()Chavez it Martinez, 538 U.S. 760, 766, 123 S.Ct. 1994, 155 L.Ed.2d 984 (2003). Notably, in so holding, the Court drew on longstanding tradition, citing its now nearl

n legal parlance the judicial-case connotation is undoubtedly primary." Maj. Op. at 1207. As to the term "case," even the Majority cites Chavez v. Martinez, 538 U.S. 760, 766, 123 S. Ct. 1994, 2000-01, 155 L.Ed.2d 984 (2003), which supports my conclusion that the CVRA's conferral right attaches pre- cha

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

ein'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 e-mail to Lefkowitz stating: 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

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 Lcfkowitz and the U.S. Attorney's Office. See generally Exhibit "A." 10. The evidence supporting these charges was overwhelming, including the interlocking

rc "merely a statement of assertion or concession made for some independent purpose," and may be controverted or explained by the party who made it. Martinez I Bally's Louisiana, Inc., 244 F.3d 474, 476-77 (51° Cir. 2001), citing McNamara v. Miller, 269 F.2d 511, 515 (D.C. Cir. 1959). In contrast, a judi

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

e Dalton School (return date 9/29/09) 9/26/2006 Acosta, Mulvihill, Sloman, Noto, Waters, L°urie' Stefin, Atkinson, Garcia, Brown, Boscovich, Martinez Villafaila Memo regarding changes to Child Explotation Statutes in Tide 18 16 10/19/2006 Subpoena to Individual #28 (return date 10/27/06) 10/2

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

Q. 6 "A judicial admission is a formal concession in the pleadings or stipulations by a party or counsel that is binding on the party making them." Martinez v. Bally's Louisiana. Inc. 244 F.3d 474, 476-77 (5th Cir. 2001). 23 EFTA00799847 Case 9:08-cv-80736-KAM Document 408 Entered on FLSD Docket 06/0

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

Q. 6 "A judicial admission is a formal concession in the pleadings or stipulations by a party or counsel that is binding on the party making them." Martinez v. Bally's Louisiana. Inc. 244 F.3d 474, 476-77 (5th Cir. 2001). 23 EFTA00591484 Case 9:08-cv-80736-KAM Document 401-2 Entered on FLSD Docket 06

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

nal problems, the other should prevail—whether or not those constitutional problems pertain to the particular litigant before the Court." °Clad< v. Martinez. 543 U.S. 371. 380-81. 125 S. Ct. 716. 724. 160 L.Ed.2d 734 (2005). It is thus no answer to say that the separation of powers problems might not ap

ve of the $526,466 already paid by Mr. Epstein - meet the criteria set forth by the NPA. We assure you that both Mr. Epstein's prior civil counsel, Jay Lefkowitz, who, with you, was a primary negotiator of the NPA language, and Mr. Critton, each strongly believe that significant amounts of the fees and costs

that both Mr. Epstein's prior civil counsel, Jay Lefkowitz, who, with you, was a primary negotiator of the N

suffers personal injury as a result of such violation." "18 U.S.C. §2255 gives victims of sexual conduct who are minors a private right of action." Martinez'. White, 492 P.Supp.2d 1186, 1188 (N.D. Cal. 2007). 18 U.S.C.A. §2255 "merely provides a cause of action for damages in `any appropriate United Stat

for itself." That the provisions of ¶8 are "far from simple" is illustrated in the construction of those paragraphs by Mr. Epstein's prior counsel, Jay Lefkovvitz, who repeatedly advised Mr. Acosta, by letter, that he considered the waiver of liability to be limited to those who agreed to damages, and was ina

that both Mr. Epstein's prior civil counsel, Jay Lefkowitz, who, with you, was a primary negotiator of the N

who suffers personal injury as a result of such violation." "18 . §2255 gives victims of sexual conduct who are minors a private right of action." Martinez'. White, 492 F.Supp.2d 1186, 1188 (N.D. Cal. 2007). 18 §2255 "merely provides a cause of action for damages in `any appropriate United States Distr

Granting Motion for Limited Appearance of Jay P. Lefkowitz) (Critton, Robert) (Entered: 05/21/2009) 05/21/

er of EFTA00175292 Case 9:09-cv-80469-KAM Document 13 Entered on FLSD Docket 05/06/2009 Page 19 of 29 Jane Doe II v. Epstein, et al. Page 19 Martinez v. White, 492 F.Supp.2d 1186, 1188 (N.D. Cal. 2007), (emphasis added). 18 U.S.C.A. §2255 "merely provides a cause of action for damages in 'any appr