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construed as an admission of civil or criminal liability in regards to any of those who seek compensation from the Trust. See draft proposal from Jay Lelkowitz to Andrew l.nurie dated September 15. 2007. In response, Ms. • nded that the Agreement contain language considering the inclusion of guardian ad M
ch. I did this in an attempt to avoid what I foresaw would likely be 'litigious seleaion process. It was only after I proposed this change that Mr. Lelkowitz raised with me his enumerated concerns. 2 Section 2255 provides that: "[tiny person who, while' minor, was' victim of violation of [enumerated secti
dentified victims and Epstein's counsel may contort the identified victims through that counsel. Sere draft non-pmsecutio agreement nailed from to Lelkowitz dated September 17. 20117. The inclusion of I guardian ad litem. however. only served to complicate mailers. We continued to reiterate our objectio
nsensual: she lied to Mr.. Epstein about her age: she instructed others to lie about their ages: there was no sexual contact between herself and Mr. Lipstein at any lime; and there was never any inducement over the telephone, computer or through any other means of interstate commerce We ask that you cons
ent and has been sentenced. Upon the execution of this agreement. the United States. in consultation with und subject to the good faith approval of Lipstein's counsel. shall .elect an attorney representative for these persons. who shall be paid fin by Ipsteiti. tostein's counsel may contact the identifie
Watt Alex (USAFLSr <AlexAcostaeusdoi.g ow. 1121200711:44 AM To "Jay Lefkowite <[email protected]> cc bcc Subject RE: I'm on my way to a mtg outside the office. Unlikely to be before 3pm. That said, III/ is around i
g outside the office. Unlikely to be before 3pm. That said, III/ is around if you want to talk with him re the 2255. -----Original Message From: Jay Letkowitz Sent: Wednesday, November 21, 2007 11:38 AM To: Acosta, Alex (USAFLS) Subject: The information contained in this communication is confidential,
ex (USAFLS)" <1.c.gos a bcc SubOct Correspondence Dear Jay: Please review the enclosed. I look forward to seeing you tomorrow. «071213 a Ltr to Lefkowitz finaipdf'> Assistant U.S. Attorney West Palm Beach, FL 33401 071213 Viafana Ltr to Lefkabitz rmat pdf US_Atty_Cor_00266 EFTA00235592 a U.S. De
f US_Atty_Cor_00266 EFTA00235592 a U.S. Department of Justice United States Attorney Southern District of Florida DELIVERY BY ELECTRONIC MAIL Jay P. Lefkowitz, Esq. • Kirkland & Ellis LLP Citigroup Center 153 East 53rd Street New York, New York 10022-4675 Re: Jeffrey Epstein Dear Jay: 500 S. Austral
elements of this offense. His assertion raises for me substantial concerns. This Off= will not, and cannot, be a party to an agreement in which, Mr. Lipstein pleads guilty to an offense that he believes he did not commit. We are considering how best to proceed. 2 X1003 US_Atty_Cor_00273 EFTA00235599
AFLS) Subject: Re: Follow up - Thanks. Jeff, are we all set? Jay Original Message From: " , (USAFLS)" Sent: 10/18/2007 12:15 PM AST To: Jay Lefkowitz Cc: " , Jeff (USAFLS)" Subject: RE: Follow up Jeff -- Can you see any issues with this? If not, please confirm with Jay. Original Message From: J
d by the FBI to confirm whether they were 17 or 18 at the time of their activity with Mr. Epstein." See Tab 26, September 24, 2007 Email from M. to J. Lefkowitz (emphasis added). This statement indicated that, at least the "six others" (and, as it turns out, all those identified except two) had reached the a
to confer with your co-counsel regarding this matter. Although the language of Paragraph 8 could be so construed, our First Assistant informed Mr. Lefkowitz some weeks ago that this was not our position. As Mr. Lefkowitz has noted, were Mr. Epstein convicted at trial, the plaintiff-victims in a subsequen
comnsual; she lied to Mr.. Epstein about her age: she instructed others to lie about their ages: there was no sexual contact between herself and Mr. Lipstein at any lime; and there was never any inducement over the telephone, computer or through any other means of interstate commerce We ask that you cons
ct that Bert Ocariz is a friend of my boyfriend and that I have a "longstanding relationship" with Mr. Ocariz. RFP MIA 000464 EFTA00208945 • • JAY P. LEFKOWITZ, ESQ. DECEMBER 13, 2007 PAGE 2 OF 5 I informed you that I selected Mr. Ocariz because he was a friend and classmate of two people whom I respecte
es." See Tab 37, February 27, 2008 Email from J. Again, that claim was utterly false; Mr. Thomas's contemporaneous hand-written notes, reviewed by Jay Lefkowitz, confirm that the USAO had violated settled Department policy and ethical rules by providing case-specific information about the Department's legal
ch and every term of Mr. Epstein's State plea, including the exact state charges to which Mr. Epstein plead guilty; the time-frame within which Mr. Lipstein must enter that state pica and surrender to state olficials; and the amount of time he must spend in county jail. This is particularly true where th
pay for the attorney representative — when originally stated that the n:presrmative could he paid for by us or the federal court. Sec c-mail frona Lelkowitz dated September 23. 2007. EFTA00214315 12/11/2007 11:45 FAX t 027/099 KIRKLAND & ELLIS Lir R. Alexander Acosta I)cecmhcr I I. 2007 l'age 4 t
dentified victims and Epstein's counsel may contact Ow identified victims through that counsel. See draft non-pmsecution agreement e-mailed fro to Lelkowitz dated September I?. 2007. the inclusion of a guardian ad 'them, however. on y served to complicate matters. We continued to reiterate our objection
list of persons who seek reimbursement and make a good faith showing to the Tomei: that they suffered injury as a result of the conduct of Epstein. Lipstein waives his right to contest liability ur damages up to an amount agreed to by Ilse panics for any settlements entered into by the Trustee. Eivaenrs
rued as an admission or civil or criminal liability in regards to any of those who seek I. pensalion from the Trust. See draft proposal sent from Jay Lerkowitz to Andrew I.ourie doted September 15. 2007." In response, Ms. Villarana demanded that the Agreement contain language considering the inclusion of a
t of Florida DELIVERY BY ELECTRONIC MAIL Jay P. Lefkowitz, Esq. Kirkland & Ellis LLP ew York, New York 10
and that ease has since been distinguished as well. B. Ms. Prompted An Unduh• Invasive lInvestiention Of Mr. Epstein. Ms. s investigation of Mr. Lipstein raises serious questions. Despite the fact that she was mac aware of the inaccuracies in the P131'lis Probable Cause Affidavit, she chose to includ
ered to join the trial team and provide additional support from CEOS. On September 7, 2007, U.S. Attorney Acosta met with Kirkland & Ellis partners Jay Lefkowitz and former Solicitor General Ken Starr and Ms. Sanchez, along with Chief Oosterbahn and AUSAs» John McMillan, and FAUSA Sloman, Messrs. Starr and L
mber 20. So we will plan to proceed on one that date." October 18, 2007 email from Jay Lefkowitz to USA It. Alexander Acosta. On the same day, Mr. Lefkowitz confirmed with First Assistant Jeffrey H. Sloman that this postponement " will not affect when Epstein begins serving his sentence." 2 Corresponden
nsensual: she lied to Mr.. Epstein about her age; she instructed others to lie about their ages: there was no sexual contact between herself and Mr. Lipstein at any time; and them was never any inducement over the telephone, computer or through any other means of interstate commerce We ask that you consi
atutes that have been identified by prosecurors-18 U.S.C. e 1591. 2422(b), and 2423(h). Onu of the other members of Mr. Epstein's defense team, lay Letkowitz, has personally reviewed the reporter's contemporaneoua notes. Although some of the women alleged to be involved were 16 and 17 years of age, sever
CW. CEOS made clear that it did not do so. indeed. est.:C.)5 declined to es:Amine several of the more troubling aspects ne dic investigation of Mr. Lipstein. in,:ladiar the deliberate kick to the 1V,',r York Times of numennts highly contidemial aspects u' Ilse inn:Sligatitin Iler.011:111011:: heitcec
Entities connected to both Jay Lefkowitz and Lipstein

Jeffrey Epstein
PERSON
Alexander Acosta
PERSONKirkland & Ellis LLP
ORGANIZATIONLeon Black
PERSONRoy Black
PERSON
A. Marie Villafana
PERSONJack Goldberger
PERSON
Kenneth Marra
PERSON
United States
LOCATION
Jeffrey Sloman
PERSON
Department of Justice
ORGANIZATIONJane Doe
PERSON
Ken Starr
PERSONthe Southern District
LOCATION
Alan Dershowitz
PERSONRobert C. Josefsberg
PERSON
George W. Bush
PERSONGerald Lefcourt
PERSON
Prince Andrew
PERSONSouthern District
LOCATION