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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
judgment is proper. See Sainz v. Cabarceno Enterprises, Inc., No. 14-20608-CIV, 2015 WL 12551061, at *1 (■. Fla. 2015) (citing Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 255 (1986)). The undisputed facts recited above plainly establish that the Government—with the knowledge of, and at the urging of Ep
I (a)(5) is significant 3 Jane Doe No. 2's exculpatory statements regarding Epstein were not lost on his attorneys. A December 21, 2007 letter from Jay Leflcowitz, one of Epstein's attorneys, to U.S. Attorney Acosta, devoted two pages examining Jane Doe No. 2's interview testimony on April 24, 2007. Ex. D at
hts associated with the agreement entered into by the United States and Mr. Epstein in a timely fashion." Ex. N, Nov. 27, 2007 email from Sloman to Lefkowitz. Epstein's attorneys responded by citing to the Attorney General's Guidelines provision stating that there must be a charge filed in a Federal distr
rdict for that party. If the evidence is merely colorable, or is not significantly probative, summary judgment may be granted." Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 250, 106 S. Ct. 2505, 2511 (1986) (internal citations omitted). 3 EFTA00799827 Case 9:08-cv-80736-KAM Document 408 Entered on FLS
71(a)(5) is significant 3 Jane Doe No. 2's exculpatory statements regarding Epstein were not lost on his attorneys. A December 21, 2007 letter from Jay Lefkowitz, one of Epstein's attorneys, to U.S. Attorney Acosta, devoted two pages examining Jane Doe No. 2's interview testimony on April 24, 2007. Ex. D at
hts associated with the agreement entered into by the United States and Mr. Epstein in a timely fashion." Ex. N, Nov. 27, 2007 email from Sloman to Lefkowitz. Epstein's attorneys responded by citing to the Attorney General's Guidelines provision stating that there must be a charge filed in a Federal distr
rdict for that party. If the evidence is merely colorable, or is not significantly probative, summary judgment may be granted." Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 250, 106 S. Ct. 2505, 2511 (1986) (internal citations omitted). 3 EFTA00591464 Case 9:08-cv-80736-KAM Document 401-2 Entered on F
Entities connected to both Jay Lefkowitz and Lobby, Inc.

Jeffrey Epstein
PERSON
Alexander Acosta
PERSONLeon Black
PERSON
A. Marie Villafana
PERSON
Kenneth Marra
PERSON
United States
LOCATION
Jeffrey Sloman
PERSON
Department of Justice
ORGANIZATIONJane Doe
PERSON
Ken Starr
PERSON
Bradley Edwards
PERSONthe Southern District
LOCATION
George W. Bush
PERSON
Prince Andrew
PERSON
Paul Cassell
PERSONMaria Farmer
PERSON
Scarlett Johansson
PERSON
Dexter Lee
PERSON
the United States District Court
ORGANIZATION
Bill Clinton
PERSON