Epstein Secrets

ound September 2007. plea discussions took place between Jeffrey Epstein, represented by numerous attorneys (including lead criminal defense counsel Jay Leflcowitz), and the U.S. Attorney's Office for the Southern District of Florida, represented by Assistant U.S. Attorneyed others. The plea discussions gener

Lefkowitz stain . SIMIMMISIO 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 she stated• arnale EFTA00229924 Case 9:O8-cv-80736-KAM Document 48 Entered on FLSD Docket 03/21/2011 Page 9 of 42 Apparently the ' gree

possible prosecution. Tr. July 11, 2008, at 4-6, 18-19, 22-23, 28-29. 23. On about November 27, 2007, Assistant U.S. AttorneMM sent an e-mail to Jay Leikowitz, defense counsel for Epstein. The e-mail stated that the U.S. Attorney's Office had an obligation to notify the victims S 12 EFTA00229928 7.7

tein'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 email to Lefkowitz stain . SIMIMMISIO 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

Submitted, s/ Bradley I. Edwards Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L. and Paul G. Cassell Pro MX Vice Quinney College of Law at the University of Utah Attorneys for Jane Due 01 and Jane Doe 02 41 EFTA00229957 Case 9:08-cv-80736-KAM Document 48 Entered on FLSD Docket 0

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

& LEHRMAN, P.L. 425 North Andrews Avenue, Suite 2 Fort Lauderdale Florida 33301 Telephone Facsimile E-mail: And Paul G. Cassell Pro Hac Vice Quinney College of Law at the University of Utah' 332 S. 1400 E. Salt Lake Cit 4112 Telephone: Facsimile: 'This daytime business address is provided for identificati

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

& LEHRMAN, P.L. 425 North Andrews Avenue, Suite 2 Fort Lauderdale Florida 33301 Telephone Facsimile E-mail: And Paul G. Cassell Pro Hac Vice Quinney College of Law at the University of Utah' 332 S. 1400 E. Salt Lake Cit 4112 Telephone: Facsimile: 'This daytime business address is provided for identificati

ers" within the meaning of Rule 6(e), then it likewise violated grand jury secrecy for your attorneys to make such disclosures to (for example) lay Lefkowitz. Disclosures of confidential grand jury matters can only be made upon court order. See Fed. R. Crim. P. 6(e)(3)(E). To our knowledge, there is no s

ry secrecy requirements. Sincerely, Paul Cassell Co-Counsel for Jane Doe Paul G. Cassell Ronald N. Boyce Presidential Professor of Criminal Law Quinney College of Law at the University of Utah CONFIDENTIAL: This electronic message - along with any/all attachments - is confidential. This message is intended only f