Epstein Secrets

ictim of a violation of lenumemtod $04)(1011x of Title l8) and who suffers personal injury as a m utt of such violation ...may sue In any oppropioto United Stales 011trint Court and shall recover the actual damages such person sustains and the cost of the suit, includingii reasonable attorney's fee." toot U

litigant. to contest allegations made against him seem to contradict the principles of justice and fairness that fire embedded in the tenets of the United Slates Attorney's Office. I also assert that on both a principled and practical level. the mere involvement of your Office in the matter with respect to

NETT MIAMI • F00 LAUDERDALE • WraT PALM UfA01 • 5T. PETER5OLMO 3067800201 December 7, 2007 Jeffrey Sloman First Assisiam United States Attorney United Stales Attorney's Office Southern District of Florida Re: Jeffrey Epstein Dear Jeff: 1-(466 P.002/004 F-016 Callnac) 5810 FIALA FouNi0arni nowt 130

d victims. This letter is meant to assist you in performing your duties by providing you with background information regarding the agreement between the United States and Jeffrey Epstein and the duties that the attorney representative will have to perform. The Federal Bureau of Investigation and the U.S. Attorney

e Petitioners have not been attempting to negotiate with the government for more than 30 months. As set forth in the Procedural I Iistory Section of the United States' Opposition to Jane Doe #1 and Jane Doe #2's Motion for Finding of Violations of the Crime Victim Rights Act ("CVRA"), at the last hearing on the Pet

fendant gives up certain rights to contest liability for a chill mettle specifically. Ms. • ' not believe there wits room for contention given the IJSAO's, and ultimatums that required that we acquiesce to these unprecedented terns. Concerns Iteaardinu Section 2253 Mr Epstein unconditionally re-as

December I I. 2007 Page 4 the final agreement was very similar to what was proposed by Ms. in her initial draft agreement on July 31. 2007: the United Stales shall provide F.pstein's attorney's with a list of individuals whom it has identified as victims, as defined in IS U.S.C. f 2255. alter Epsicin has

oth offenses. Additionally, for the sake of fairness and candor, we believe the same language contained in your letter to Judge Davis, stating that Itibe United States takes no position as to the validity of any such claim under this statute," should be included in any proposed letter. Sixth, your letter states th

of an enumerated federal crime. This requires Mr. Epstein to in essence admit guilt, though he believes he did not commit the requisite offense. The United States Attorney Manual ("USAM") 9-27.440, Principles of Federal Prosecution, sets forth' clear r,:quirement when' defendant tenders' pica of guilty but sub

d. Needless to say. we were elisi alarmed that Ms. would attempt to influence the settlement process on such improper grounds. And even alter the IJSAO conceded that it was inappropriate for its attorneys to select the attorney representative. Ms. Villafana continued to improperly lobby for Mr. Ocar

this procedure because. as I mentIona I think It to probably in their best WOWS. In terms of plea agreement language. let me suggest the following: Thu United Slates agrees to make a minion seeking the appointment of a Guardian ad titan to mpresent the identified victims, Following the appointment of such Guardia

mber I I, 2007 Page 4 The final agreement was very similar to what was proposed by Ms. Villotbna in her initial draft agreement on July 31. 2007: The United Stoles shall provide l3poein's anomey's with u list of individuals whom ii fins identified as victims, as defined in IR U.S.C. § 2255. alter Epstein has si

hich point they were eliminated by your Office: IT APPEARING, idler an invizligation of the offenses and Epstcin's background, thin the interest or the United Stales pursuant to the Petite policy will be served by the Following procedure ... Epstein understands that the United Stales Attorney has no authority to

but based on the belief that a guardian ad litem would not be appropriate lbr adults that are capable of making their own decisions. Ilowever. the IJSAO included into the Agreement that we pay Ibr the attorney representative -- when originally Ms. Villafana stated that the representative could he paid

erson can be charged with a criminal 39 EFTA01718615 . offense, that is a violation of Florida Statutes Section 794.05; in violation of Title 18, United States Code, Sections 2422(b) and 2. COUNT 14 (Enticement of a Minor: 18 U.S.C. § 2422(b)) 49. Paragraphs 1 through 19 of this Indictment are re-alleged

ity or process of the prior prosecution. not the sentencing outcome. Second, the state plea agreement offered was not "manifestly inadequate" tinder U.S.A.M. § 9- 2.03ID. indeed, the only real difference hews= the state and federal plea proposals was whether Mr. Epstein served his sentence in jail or comm

n to undertake discussion with the $tate Attorney's Office In ensure compliance with these procedures, which compliance will be necessary to satisfy the United States' interest. pursuant to the Perire policy. We reiterate that this case was at heart a local matter that was being fully addressed by the state crimi

utgrowth of the fact that civil settlement. as opposed to restitution. is considered in the Agreement, A. Rule of the Attorney Representative The IJSAO has improperly emphasised that the chosen Bonney representative should be able to litigate the claims of individuals, which violates the terms, and

S L LP Jay P I otternWs, P C. loP 11Wr r ly blk Orland can VIA FACSIMILE (303) SM1-4444 Honorable R. Alexander Acosta united States Attorney United Slates Attorney's ()filet Southern District of Florida 99 NE itlh Street Miami. Fla 33132 Dear Alex: nap MIn IARD 'Armen-. Cinarmap Conte, 153 Emit

to undertake discussion with the Slate Attorney's 011ie,: to ensure compliance with these procedures. which compliance will he necessary to satisfy the United Status' interest. pursuant In the Poise policy. We reiterate that this ease was at heart a local matter that was being fully addressed by the state crimin

tified individuals, raises cause Ibr concern as to the nature of all conununications that are made to the 'victims.' You previously stated that the IJSAO's main objective with respect to the Section 2255 component of the Agreement was to -place the victims in the same position as they would have been

the United States, advised that her January 2001 record was the return from her London, England trip 'The April 2001 CBP record was her return to the United States' ould not recall her travel from advised that her United States March and May 2001 CPB records! Passport was Australia. turned over to the United

d jury than to protect from delay the progress of the trial after an indictment has been found." Id. at 327, 60 S. Cr. at 542; see also Di Bella v. United States. 369 U.S. 121, 124, 82 S.O. 654, 656-57, 7 L.Pd.2d 614 (1962) ("This insistence on finality and prohibition of piecemeal review discourage undue l

vestigation into allegations of improper sti 2006 Thomson/West. No Claim to Orig. U.S. Govt. Works. EFTA01699660 09/06/2006 20:43 FAX 5618021787 IJSAO ¶VFB FL tN06 832 F.2d 554 (Cite as: 832 F.2d 554, 955) influence peddling by certain public officials of the City of Jacksonville. Witnesses ap

he sake of confidentiality, we will not produce the relevant documents. -One such communication, however, was made in a December 6, 2007 letter from United States Attorney Acosta to myselt in which he stated that tithe Office has no intention to take any position in any civil litigation arising between Mr. Eps

k of suppo Mt. E ein's offer of $50,000 to resolve claims that are not time-barred (as we believe claim to be), without any On several occasions, IJSAO representatives have asserted that the government takes no position as to the claims of the individuals identified as alleged victims. For the sake

ough such misconduct was, as we contend it is, inextricably intenwined with the credibility of the accusations being made against Mr. Epstein by the United States Attorney's Office in Miami ("USAO"). Moreover, CEOS did not assess the terms of the Deferred Prosecution Agreement now in effect, nor did CEOS revie

ports to prohibit any further cantata between Mr. lipskirrk defense learn and U.S. Attorney Acosta. and instead requires us to communicate with the IJSAO only though Mr. Sloman's subordinatcx. While it pains us to say this, this misguided proscouion lion, the ukase! gives (he appearance that il may h