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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
filed a detailed affidavit from the victims' attorney, Bradley J. Edwards, about the nature of the calls that he had with the line prosecutor. See Edwards Aff. of Aug. II, 2017, at IN 11.25. If the Government fails to dispute that affidavit, of course that affidavit would provide additional evidence suppor
ly leading to a federal prosecution. Edwards Declaration at xxxxxx. 22. On about November 27, 2007, Assistant U.S. Attorney isle sent an e-mail to Jay Lefkowitz, defense counsel for Epstein. The e-mail stated: The United States has a statutory obligation (Justice for All Act of 2004) to notify the victims o
n would ultimately plead to only two misdemeanor offenses and would serve only jail time. Many of the negotiations are reflected in e-mails between Lefkowitz and Copies of the correspondence are attached as Exhibit 2 to the Edwards Declaration accompanying this filing (hereinafter cited as "U.S. Attorney
U.S. Attorney's Office for the Southern District of Florida regarding the plea agreement that had been negotiated between them. See Attachment 1 to Edwards Aff. These e-mail disclosed for the first time the steps that had been taken by the U.S. Attorney's Office to avoid having the victims in the case lear
ding to a federal prosecution. Edwards Declaration at xxxxxx. 22. On about November 27, 2007, Assistant U.S. Attorney Jeff Sloman sent an e-mail to Jay Lefkowitz, defense counsel for Epstein. The e-mail stated: The United States has a statutory obligation (Justice for All Act of 2004) to notify the victims o
n would ultimately plead to only two misdemeanor offenses and would serve only jail time. Many of the negotiations are reflected in e-mails between Lefkowitz and Copies of the correspondence are attached as Exhibit 2 to the Edwards Declaration accompanying this filing (hereinafter cited as "U.S. Attorney
U.S. Attorney's Office for the Southern District of Florida regarding the plea agreement that had been negotiated between them. See Attachment 1 to Edwards Aff. These e-mail disclosed for the first time the steps that had been taken by the U.S. Attorney's Office to avoid having the victims in the case lear
Entities connected to both Jay Lefkowitz and Edwards Aff

Jeffrey Epstein
PERSON
Alexander Acosta
PERSONLeon Black
PERSON
A. Marie Villafana
PERSONJack Goldberger
PERSON
Kenneth Marra
PERSON
United States
LOCATION
Department of Justice
ORGANIZATIONJane Doe
PERSON
Bradley Edwards
PERSONthe Southern District
LOCATION
George W. Bush
PERSON
Paul Cassell
PERSON
Lesley Groff
PERSONFBI
ORGANIZATIONMarie
PERSON
Podhurst
PERSONMaria Farmer
PERSON
Dexter Lee
PERSON
Palm Beach Police Department
ORGANIZATION