Epstein Secrets

8-cv-80736-KAM Document 417 Entered on FLSD Docket 08/11/2017 Page 5 of 33 On about September 24, 2007, the U.S. Attorney's Office sent an e-mail to Jay Lefkowitz, one of Epstein's attorneys, stating that the Government and Epstein's counsel would negotiate about what information would be disclosed to the vict

the outcome to anyone. Id. at 20, 1 52 (citing Ex. 66) (emphases added). And further, on September 25, 2007, the line prosecutor sent an e-mail to Lefkowitz stating: "And can we have a conference call to discuss what I may disclose to . . . the girls regarding the agreement." Id. at 20, 1 53 (citing Ex.

eement" so that the Government would know exactly what needed to be produced to the victims in this CVRA case. Id. at 43,1 142. On August 18, 2008, Letkowitz wrote the line prosecutor that Epstein objected to disclosure of the terms of the NPA, but that Epstein would "cooperate with the government to rea

equires that there be no disputed issues that are genuine or material for the moving party to be entitled to judgment as a matter of law. See, e.g., Joseph v. Napolitano, 839 F. Supp. 2d 1324, 1333 (E. Fla. 2012). If the evidence offered by the nonmoving party is 17 EFTA00597334 Case 9:08-cv-80736-KAM Document 41

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

quires that there be no disputed issues that are genuine or material for the moving party to be entitled to judgment as a matter of law. See, e.g., Joseph v. Napolitano, 839 F. Supp. 2d 1324, 1333 (S.D. Fla. 2012). The undisputed facts "3 See Exhibit 88. 174 Exhibit 26; Exhibit 27; Exhibit 62; Exhibit 63 at 4-6, 18

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

quires that there be no disputed issues that are genuine or material for the moving party to be entitled to judgment as a matter of law. See, e.g., Joseph v. Napolitano, 839 F. Supp. 2d 1324, 1333 (S.D. Fla. 2012). The undisputed facts "3 See Exhibit 88. 174 Exhibit 26; Exhibit 27; Exhibit 62; Exhibit 63 at 4-6, 18

that arises out of the ongoing federal investigation as described above."41 29. 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

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

quires that there be no disputed issues that are genuine or material for the moving party to be entitled to judgment as a matter of law. See, e.g., Joseph v. Napolitano, 839 F. Supp. 2d 1324, 1333 (S.D. Fla. 2012). The undisputed facts " 3 See Exhibit 88. IM Exhibit 26; Exhibit 27; Exhibit 62; Exhibit 63 at 4-6, 18