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y Mr. Epstein at least as early as 2001, so all of the victims were minors at the time of the offense."101 87. On December 7, 2007, defense attorney Lilly Ann Sanchez sent a letter to AUSA Sloman, requesting "that the Office hold off on sending any victim notification letters." The Government complied.102 88. Whi
the following using the Court's CM/ECF system: Dexter Lee A. Marie Villafafia 500 S. Australian Ave., Sui
otification would not be required by 18 USC §3771. Your office has come to a similar conclusion, see AUSA Alex Acosta's December 19, 2007 letter to Lilly Sanchez, pg 2. We are sensitive, however, to the adversarial litigation previously filed regarding other §3771 issues. Accordingly, we propose the followin
gust 15, 2008 11:42 AM To: Acosta, Alex (USAFLS); Sloman, Jeff (USAFLS); (USAFLS) Subject: New proposed response to Jay Dear Jay: (USAFLS); Lee, Dexter (USAFLS); Atkinson, Karen Thank you for your response. Our communications with Roy Black and later with you were solely to determine what Mr. Epste
nce of a September 2007 Non-Prosecution Agreement, an October 2007 Addendum and a letter dated December 19, 2007 from the U.S. Attorney to Attorney Lilly Ann Sanchez , Counsel to Jeffrey Epstein (DE 35 at ¶3).' I I assume those involved in the above-referenced litigation, have copies of the relevant court filin
nd the USAO-SDFLA and counsel for the Jane Does, on numerous matters related to Jeffrey Epstein, including contacts with AUSAs "Marie Villafana and Dexter Lee." DE 41 at 3. The Government's filings frame the issue before the Court as to whether the "Government was obligated, under 18 U.S.C. § 3771(a)(5),
nce of a September 2007 Non-Prosecution Agreement. an October 2007 Addendum and a letter dated December 19, 2007 from the U.S. Attorney to Attorney Lilly Ann Sanchez , Counsel to Jeffrey Epstein (DE 35 at ¶3).r I assume those involved in the above-referenced litigation, have copies of the relevant court filings,
nt" and the USAO-SDFLA and counsel for the s, on numerous matters related to Jeffrey Epstein, including contacts with Jane ii AUSAs "Marie and Dexter Lee." DE 41 at 3. The Government's filings frame the issue before the Court as to whether the "Government was obligated, under 18 U.S.C. § 377I(a)(5),
nce of a September 2007 Non-Prosecution Agreement, an October 2007 Addendum and a letter dated December 19, 2007 from the U.S. Attorney to Attorney Lilly Ann Sanchez , Counsel to Jeffrey Epstein (DE 35 at ¶3).' I I assume those involved in the above-referenced litigation, have copies of the relevant court filin
d the USAO-SDFLA and counsel for the Jane Does, on numerous matters related to Jeffrey Epstein, including contacts with AUSAs "Marie Villafafia and Dexter Lee." DE 41 at 3. The Government's filings frame the issue before the Court as to whether the "Government was obligated, under 18 U.S.C. § 3771(a)(5),
y Mr. Epstein at least as early as 2001, so all of the victims were minors at the time of the offense."101 87. On December 7, 2007, defense attorney Lilly Ann Sanchez sent a letter to AUSA Sloman, requesting "that the Office hold off on sending any victim notification letters." The Government complied.102 88. Whi
the following using the Court's CM/ECF system: Dexter Lee A. Marie Villafafia 500 S. Australian Ave., Sui
y Mr. Epstein at least as early as 2001, so all of the victims were minors at the time of the offense.s101 87. On December 7, 2007, defense attorney Lilly Ann Sanchez sent a letter to AUSA requesting "that the Office hold off on sending any victim notification letters." The Government complied.102 88. While discu
the following using the Court's CMIECF system: Dexter Lee Fax: E-mail: E-mail: Attorneys for the Govern
orney's Office and Epstein was subsequently modified by an October 2007 Addendum and a December 19, 2007, letter from the U.S. Attorney to Attorney Lilly Ann Sanchez. See Supplemental Declaration of A. Marie Villafafia, doe. #35, at 1; U.S. Attorney's Correspondence at 234-37. The—‘65,4atemeyss—Offiee-414--rtet-
STIPULATED TO, THIS DAY OF DECEMBER, 2010. A-deems-it By: BRADLEY J. EDWARDS COUNSEL FOR PLAINTIFFS WIFREDO A. FERRER UNITED STATES ATTORNEY DEXTER LEE ASSISTANT U.S. ATI'ORNEY EFTA00191284 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 08-80736-Civ-Marra/Johnson JANE DOES #1
torney's Office and Epstein was subsequently modified by an October 2007 Addendum and a December 19, 2007, letter from the U.S. Attorney to Attorney Lilly Ann Sanchez. The US. Attorney's Office did not confer with any of the victims about these modifiCations of the agreement (or even notify them of the existence
nt to Local Rule 7.1(a)(3), undersigned counsel contacted counsel for Plaintiffs and counsel for the United States. Assistant United States Attorney Dexter Lee reported that the United States does not oppose the Motion to Intervene. Bradley Edwards, Esq., counsel for Plaintiffs reported that they oppose th
torney's Office and Epstein was subsequently modified by an October 2007 Addendum and a December 19, 2007, letter from the U.S. Attorney to Attorney Lilly Ann Sanchez. The US. Attorney's Office did not confer with any of the victims about these modifiCations of the agreement (or even notify them of the existence
nt to Local Rule 7.1(a)(3), undersigned counsel contacted counsel for Plaintiffs and counsel for the United States. Assistant United States Attorney Dexter Lee reported that the United States does not oppose the Motion to Intervene. Bradley Edwards, Esq., counsel for Plaintiffs reported that they oppose th
Entities connected to both Lilly Ann Sanchez and Dexter Lee

Jeffrey Epstein
PERSON
A. Marie Villafana
PERSON
Alexander Acosta
PERSON
Bradley Edwards
PERSON
Jeffrey Sloman
PERSON
Kenneth Marra
PERSONJane Doe
PERSONKaren
PERSON
Karen Atkinson
PERSONMarie
PERSON
Paul Cassell
PERSONJack Goldberger
PERSONLeon Black
PERSON
United States
LOCATION
Jay Lefkowitz
PERSONRoy Black
PERSON
George W. Bush
PERSONMaria Farmer
PERSON
Department of Justice
ORGANIZATIONthe Southern District
LOCATION