Epstein Secrets

ce e-mails attached Suppl. Box 3 P-013847 Thru P-013849 E-mail to and September 18, 2007, 11:43 , RE: Draft Agreements?, with e-mail from Jay Leflcowitz (September 18, 2007, 11:09 M. attached Atty work-product Suppl. Box 3 P-013850 E-mail, to Alex Acosta and September 18, 2007, 9:31 RE: Epste

torney handwritten notes Attorney-Client Privilege Work Product Suppl. Box #3 P-013334 Thru P-013337 File folder entitled "11/13/07 Sloman to Lefkowitz (was this sent?" containing draft 11/13/07 letter from responding to J. Lefkowitz's letter Attorney-Client Privilege Work Product Page 2 of 14

P-013334 Thru P-013337 File folder entitled "11/13/07 Sloman to Lefkowitz (was this sent?" containing draft 11/13/07 letter from responding to J. Lefkowitz's letter Attorney-Client Privilege Work Product Page 2 of 14 EFTA00185415 Case 9:08-cv-80736-KAM Document 216-1 Entered on FLSD Docket 07/27/20

o make a statement under oath at the state sentencing.s44 81. On November 28, 2007, Lefkowitz sent an email to U.S. Attorney Acosta (with a copy to AUSA Sloman) objecting to victim notifications: We do, however, strongly and emphatically object to your sending a letter to the alleged victims. Finally, we d

orney's Office has not produced any emails sent to or from any home e-mail addresses of its prosecutors. 30. On September 17, 2007, defense counsel Jay Leflcowitz responded: "[D]o you have another obstruction proffer I can review that you have drafted? Also, if we go that route, would you intend to make the d

tempted to notify or confer with the victims about the existence of the NPA. 35. On September 23, 2007, the U.S. Attorney's Office sent an email to Lefkowitz stating: "It is factually accurate that the list we are going to give you are persons we have identified as victims. If we did not think they were

o make a statement under oath at the state sentencing."' 81. On November 28, 2007, Lefkowitz sent an email to U.S. Attorney Acosta (with a copy to AUSA Sloman) objecting to victim notifications: We do, however, strongly and emphatically object to your sending a letter to the alleged victims. Finally, we d

tion not only to Epstein, but also to certain co-conspirators. (DE 407 at ¶ 28.) On September 17, 2007, the line prosecutor wrote to defense counsel Jay Lefkowitz: "Please send [a document] to my home e-mail address — [redacted] and give me a call on my cell [redacted] so I can be ready for some discussions t

ss — [redacted] and give me a call on my cell [redacted] so I can be ready for some discussions tomorrow." (DE 407 at ¶ 29.) On September 17, 2007, Lefkowitz responded: "[D]o you have another obstruction proffer I can review that you have drafted? Also, if we go that route, would you intend to make the de

ng the procedures for the third-party representative for the victims under the NPA's compensation provisions. (DE 407 at ¶ 64.) On October 25, 2007, AUSA Sloman sent a letter to Retired Judge Davis about selecting an attorney to represent the victims under the 11 EFTA00794132 Case 9:08-cv-80736-KAM Docum

oman. Each of Mr. Epstein's attorneys, including Roy Black, Gerald Lefcourt, Alan Dershowitz, Alan Dershowitz's brother, Nat Dershowitz, Ken Starr, Jay Lefkowitz, Lilly Sanchez, Jack Goldberger, Bruce Lyons, Martin Weinberg, Stephanie Thacker, Guy Lewis, Mike Tein, Joe Whitley and Herb Rosen, have expressed

howitz's brother, Nat Dershowitz, Ken Starr, Jay Lefkowitz, Lilly Sanchez, Jack Goldberger, Bruce Lyons, Ma

ll, engaged the attorney representative, Mr. Josefsberg, to obtain a settlement payment from Mr. Epstein under the NPA. On October 31, 2007, First AUSA Sloman emailed Mr. Epstein's counsel, confirming that "I understand that the plea and sentence will occur on or before the January 4th [2008] date." See O

orney's Office has not produced any emails sent to or from any home e-mail addresses of its prosecutors. 30. On September 17, 2007, defense counsel Jay Leflcowitz responded: "[D]o you have another obstruction proffer I can review that you have drafted? Also, if we go that route, would you intend to make the d

tempted to notify or confer with the victims about the existence of the NPA. 35. On September 23, 2007, the U.S. Attorney's Office sent an email to Lefkowitz stating: "It is factually accurate that the list we are going to give you are persons we have identified as victims. If we did not think they were

o make a statement under oath at the state sentencing."' 81. On November 28, 2007, Lefkowitz sent an email to U.S. Attorney Acosta (with a copy to AUSA Sloman) objecting to victim notifications: We do, however, strongly and emphatically object to your sending a letter to the alleged victims. Finally, we d

tion not only to Epstein, but also to certain co-conspirators. (DE 407 at ¶ 28.) On September 17, 2007, the line prosecutor wrote to defense counsel Jay Lefkowitz: "Please send [a document] to my home e-mail address — [redacted] and give me a call on my cell [redacted] so I can be ready for some discussions t

ss — [redacted] and give me a call on my cell [redacted] so I can be ready for some discussions tomorrow." (DE 407 at ¶ 29.) On September 17, 2007, Lefkowitz responded: "[D]o you have another obstruction proffer I can review that you have drafted? Also, if we go that route, would you intend to make the de

ng the procedures for the third-party representative for the victims under the NPA's compensation provisions. (DE 407 at ¶ 64.) On October 25, 2007, AUSA Sloman sent a letter to Retired Judge Davis about selecting an attorney to represent the victims under the 11 EFTA00081343 Case 9:08-cv-80736-KAM Docum

tion not only to Epstein, but also to certain co-conspirators. (DE 407 at ¶ 28.) On September 17, 2007, the line prosecutor wrote to defense counsel Jay Lefkowitz: "Please send [a document] to my home e-mail address — [redacted] and give me a call on my cell [redacted] so I can be ready for some discussions t

ss — [redacted] and give me a call on my cell [redacted] so I can be ready for some discussions tomorrow." (DE 407 at ¶ 29.) On September 17, 2007, Lefkowitz responded: "[D]o you have another obstruction proffer I can review that you have drafted? Also, if we go that route, would you intend to make the de

ictims. (DE 407 at ¶ 76.) After these meetings with three victims, Epstein's defense team complained. (DE 407 at ¶ 77.) On about November 27, 2007, AUSA Sloman sent an e-mail to Lefkowitz, (with a copy to U.S. Attorney Acosta) stating that the Office had a statutory obligation to notify the victims about E

tion not only to Epstein, but also to certain co-conspirators. (DE 407 at ¶ 28.) On September 17, 2007, the line prosecutor wrote to defense counsel Jay Lefkowitz: "Please send [a document] to my home e-mail address — [redacted] and give me a call on my cell [redacted] so I can be ready for some discussions t

ss — [redacted] and give me a call on my cell [redacted] so I can be ready for some discussions tomorrow." (DE 407 at ¶ 29.) On September 17, 2007, Lefkowitz responded: "[D]o you have another obstruction proffer I can review that you have drafted? Also, if we go that route, would you intend to make the de

ictims. (DE 407 at ¶ 76.) After these meetings with three victims, Epstein's defense team complained. (DE 407 at ¶ 77.) On about November 27, 2007, AUSA Sloman sent an e-mail to Lefkowitz, (with a copy to U.S. Attorney Acosta) stating that the Office had a statutory obligation to notify the victims about E