Epstein Secrets

statements, their credibility and the foundations. il' any. for claiming personal istiory. Also. Mr. Epstein would have received, pursuant to either Brady or Jencks. material in the Ponta of prior inconsistent statements made by these women before they learned of any financial benefit that may be avai

epartment of Justice United States Attorney Southern District of Florida It ALEXANDER ACOSTA UNITED STATES A7TORNEY DELIVERY BY FACSIMILE Lilly Ann Sanchez Fowler White Burnett, PA 1395 Brickell Ave, 14th Floor Miami, FL 33131 Re: Jeffrey Epstein Dear Ms. Sanchez: 99 N E 4 Sure, Moat FL 3O31 O03

it has identified. Because the information provided by these women goes directly to the question of Mr. Epstein's guilt or innocence, it is classic Brady information. We understand that the U.S. Attorney might not want to disclose impeachment information about their witnesses prior to a charge or dur

your cooperation in this matter. If you have any questions, please do not hesitate to call. IACK A. GOLDBERGER CC: Gerald B. Lefcourt, Esq. Lilly Ann Sanchez, Esq. 2 08-80736-CV-MARRA RFP WPB 001693 EFTA00209872 i4a1 IA fit hIANUFACTLIPSER PAO 1.4AAL/FAC71REIVS OESVNATK)N Cc ARCRAF7 BOEING 72 7-

ed to provide the draft indictmatt. We understand that we have no statutory right to a FRI 302 that inculpates Mr. Epstein (although we believe that Brady principles would encourage the disclosure of P131 302 reports that exonerate him). We are Lammed that there is information that could be rebutted i

S FOWLER WHITE 13URNETT IAMI, • LAMM 3 3 - 2 FAX TriANSMITICAL Faxeshe ex costa NUMBER OF PAGES: 3 (Excluding itansmitial page) FROM: Lilly Ann Sanchez FAX NUMBER: - MATTER NO: 71200 REMARKS: please see attached. TELEPHONE NUMBER: Original documents will K will not K follow by mail. TIME OF TRAN

reasonableness."); / Kyles v. Whitley, 514 U.S. 419, 432-33, 115 S. Ct. 1555, 1565, 131 L.Ed.2d 490 (1995) (under the Due Process Clause and 11 Brady v. Maryland, 373 U.S. 83, 83 S. Ct. 1194, 10 L.Ed.2d 215 (1963), prosecutors must disclose all evidence, upon request, that is favorable to the def

Y; (2) Roy Black, Black Srebnick Komspan & Stumpf, Miami, FL; (3) Gerald B. Lefcourt, Law Office of Gerald B. Lefcourt, P.C., New York, NY (4) Lilly Ann Sanchez, Fowler White Burnett, Miami, FL; (5) Jack A. Goldberger, Goldberger & Weiss, West Palm Beach, FL; and (6) Joe D. Whitley, Alston & Bird, Washingto

e attorneys representing criminals, the Office would promptly turn over all information in its possession that was helpful to these criminals under Brady v. Maryland, 373 U.S. 83 (1963), and related decisions. Victims' counsel asked the Office to extend to the victims the same assistance that it would

Epstein (including, but not limited to, Roy Black, Jay Lefkowitz, Jack Goldberger, Martin Weinberg, Gerald Lefcourt, Michael Tien, Guy Lewis, Lilly Ann Sanchez, Ken Starr, Alan Dershowitz) and agents acting in support of Epstein (including, but not limited to former President Bill Clinton and Andrew Albert

s representing criminals, your Office would promptly turn over to us all information in its possession that was helpful to these criminals under the Brady and Giglio decisions. We asked your Office to extend to the victims the same assistance that it would provide to criminals — i.e., we asked and t

vision of your Office. It has been our understanding for quite some time that he frequently corresponded with Epstein's attorneys, especially Lily Ann Sanchez, during the plea discussions, and it is our understanding that he left your Office around the time the non-prosecution agreement was signed. Our pr

npersuaded by the letter and the presentation, but I agreed that I should carefully review transcripts of the recorded statements given to PBPD for Brady issues." Since witness credibility was clearly at the fore, I undertook efforts " The requested documents and items were never provided. 15 As the

rming them of FBI investigation 7 7/26/2006 South Florida Sun-Sentinel Article Regarding Chief Reiter's referral of case to FBI 8 8/2/2007 Lilly Ann Sanchez email to Matt Menchel with attached letter containing counter- proposal for plea to two years of 'supenised custody.' 9 8/24/2006- 10/24/2006 Entai

r statements, their credibility and the foundations, if any, for claiming personal injury. Also, Mr. Epstein would have received, pursuant to either Brady or Jencks, material in the form of prior inconsistent statements made by these women before they learned of any financial benefit that may be avail

Y Dated: By: Dated: va,_ Dated: Dated: A. MARIE VILLAFARA ASSISTANT U.S. ATTORNEY GERALD LEFCOURT, ESQ. COUNSEL TO JEFFREY EPSTEIN LILLY ANN SANCHEZ, ESQ. ATTORNEY FOR JEFFREY EPSTEIN Page 7 of 7 EFTA00234582 By signing this agreement Epstein asserts and certifies that the above has been read

r statements, their credibility and the foundations, if any, for claiming personal injury. Also, Mr. Epstein would have received, pursuant to either Brady or Jencks, material in the form of prior inconsistent statements made by these women before they learned of any financial benefit that may be avail

R ACOSTA UNITED STATES ATTORNEY Dated: By: Dated: va,_ Dated: Dated: ASSIST RNEY GERALD LEFCOURT, ESQ. COUNSEL TO JEFFREY EPSTEIN LILLY ANN SANCHEZ, ESQ. ATTORNEY FOR JEFFREY EPSTEIN Page 7 of 7 EFTA00213060 By signing this agreement Epstein asserts and certifies that the above has been read