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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
gment based on the undisputed factual record that has since been developed in this case. 111 /// /// 30 EFTA00211747 Respectfully submitted, BENJAMIN G. GREENBERG ACTING UNITED STATES ATTORNEY By: Attorneys for the Government CERTIFICATE OF SERVICE I HEREBY CERTIFY that on June 2, 2017, the foregoing Respo
icials and Epstein's attorneys, in which Epstein sought to have the NPA overturned. See Ex. H at 1. 23. On May 15, 2008, the Chief of the CEOS sent Jay Lefkowitz, Esq., a five-page letter, explaining the inquiry it conducted of the federal criminal investigation of Epstein. Ex. H. The letter concluded that "
d additional letter briefs to the Deputy Attorney General. Ex. V. 25. On June 23, 2008 Senior Associate Deputy Attorney General, wrote to Messrs. Lefkowitz and Starr, advising them that "federal prosecution of this case is appropriate." Ex. I. Mr. Roth also told Epstein's attorneys that their allegation
Attorney Edwards informed AUSA /// /// 111 that someone would be present for him at the hearing. M. 8 EFTA00211714 Respectfully submitted, BENJAMIN G. GREENBERG ACTING UNITED STATES ATTORNEY By: Assistant United States Attorney Miami Florida 33132 Tel E-mat Assistant United States Attorney Fla Bar No
icials and Epstein's attorneys, in which Epstein sought to have the NPA overturned. See Ex. H at 1. 23. On May 15, 2008, the Chief of the CEOS sent Jay Lefkowitz, Esq., a five-page letter, explaining the inquiry it conducted of the federal criminal investigation of Epstein. Ex. H. The letter concluded that "
l letter briefs to the Deputy Attorney General. Ex. V. 25. On June 23, 2008, John Roth, Senior Associate Deputy Attorney General, wrote to Messrs. Lefkowitz and Starr, advising them that "federal prosecution of this case is appropriate." Ex. I. Mr. Roth also told Epstein's attorneys that their allegation
Id. / / / I/I I/I 8 EFTA00799602 Case 9:08-cv-80736-KAM Document 402 Entered on FLSD Docket 06/02/2017 Page 9 of 10 Respectfully submitted, BENJAMIN G. GREENBERG ACTING UNITED STATES ATTORNEY By: Is/Dexter A. Lee Dexter A. Lee Assistant United States Attorney Fla Bar No. 0936693 99 N.E. 4th Street, Suite
. 53. Admitted. 54. The Government admits that paragraph 54 accurately quotes from an email dated September 25, 2007 from AUSA Marie Villafafia to Jay Lefkowitz, but denies that the email "tr[ied] to set up an arrangement whereby Epstein's victims would not be represented by various 7 EFTA00799809 Case 9
6/2/2017 Villafafia Decl. at ¶ 38. 60. Admitted. 61. Admitted. (citation is incorrect). 62. Denied. The Thursday, October 18, 2007 email from Mr. Lefkowitz expresses thanks to U.S. Attorney Acosta for meeting on Friday. 63. Admitted. 64. Admitted. 65. Admitted. 66. The government admits that the NPA
-13. /// /// /// 20 EFTA00799822 Case 9:08-cv-80736-KAM Document 407 Entered on FLSD Docket 06/06/2017 Page 21 of 22 Respectfully submitted, BENJAMIN G. GREENBERG ACTING UNITED STATES ATTORNEY By: /s/ Dexter A. Lee Dexter A. Lee Assistant United States Attorney Fla Bar No. 0936693 99 N.E. 4th Street, Suit
. 53. Admitted. 54. The Government admits that paragraph 54 accurately quotes from an email dated September 25, 2007 from AUSA Marie Villafafia to Jay Lefkowitz, but denies that the email "tr[ied] to set up an arrangement whereby Epstein's victims would not be represented by various 7 EFTA00799787 Case 9
6/2/2017 Villafafia Decl. at ¶ 38. 60. Admitted. 61. Admitted. (citation is incorrect). 62. Denied. The Thursday, October 18, 2007 email from Mr. Lefkowitz expresses thanks to U.S. Attorney Acosta for meeting on Friday. 63. Admitted. 64. Admitted. 65. Admitted. 66. The government admits that the NPA
-13. /// /// /// 20 EFTA00799800 Case 9:08-cv-80736-KAM Document 407 Entered on FLSD Docket 06/06/2017 Page 21 of 22 Respectfully submitted, BENJAMIN G. GREENBERG ACTING UNITED STATES ATTORNEY By: /s/ Dexter A. Lee Dexter A. Lee Assistant United States Attorney Fla Bar No. 0936693 99 N.E. 4'h Street, Suit
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
e. / / / I/I I/I 30 EFTA00799854 Case 9:08-cv-80736-KAM Document 408 Entered on FLSD Docket 06/06/2017 Page 31 of 32 Respectfully submitted, BENJAMIN G. GREENBERG ACTING UNITED STATES ATTORNEY By: Is/Dexter A. Lee Dexter A. Lee Assistant United States Attorney Fla Bar No. 0936693 99 N.E. 4th Street, Suite
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
/ / / / / / / 30 EFTA00591491 Case 9:08-cv-80736-KAM Document 401-2 Entered on FLSD Docket 06/02/2017 Page 32 of 33 Respectfully submitted, BENJAMIN G. GREENBERG ACTING UNITED STATES ATTORNEY By: Is/Dexter A. Lee Dexter A. Lee Assistant United States Attorney Fla Bar No. 0936693 99 N.E. 4'h Street, Suite
led "Rsrch re Crime Victims Rights" containing attorney research, handwritten notes, draft victim notification letter, and draft correspondence to Jay Lefkowitz (Also contains a November 28 2007 letter from Kenneth Starr to , and a November 29, 2007 letter from Jay Lefkowitz to R. Alexander Acosta (P-010
Thru P-009125 12/6/2007 Letter from to Jay P. Lefkowitz re Jeffrey Epstein (victim notification) [pursua
States respectfully requests that the Application and any Order related to the Application be sealed. Dated: May 30, 2017 Respectfully submitted, BENJAMIN G. GREENBERG ASSISTANT U.S. ATTORNEY Florida Bar No. 500 South Australian Ave, Suite 400 West Palm Beach. Florida 33401 Tel: EFTA00086375 UNITED STATES DI
Entities connected to both Jay Lefkowitz and BENJAMIN G. GREENBERG

Jeffrey Epstein
PERSON
Alexander Acosta
PERSONLeon Black
PERSON
A. Marie Villafana
PERSON
Kenneth Marra
PERSON
United States
LOCATION
Department of Justice
ORGANIZATIONJane Doe
PERSON
Jeffrey Sloman
PERSON
Ken Starr
PERSON
Bradley Edwards
PERSONthe Southern District
LOCATIONRobert C. Josefsberg
PERSON
George W. Bush
PERSON
Paul Cassell
PERSONSanchez
PERSONMaria Farmer
PERSON
Dexter Lee
PERSON
the United States District Court
ORGANIZATION
Virginia Giuffre
PERSON