Epstein Secrets

that Mr. Epstein will act in good faith and comply with the letter and spirit of the NPA. As to the third item, we have reviewed your letter to Mr. Sloman of February 8, 2010. While Mr. Acosta did state in his letter of December 19, 2007, that he did not believe that the Office was EFTA00194762 ROY

st merely of a notification and will neither encourage nor discourage attendance or submission of materials related to the application. Sincerely, Jeffrey H. Sloman United States Attorney By: s/A. Marie Villafafia A. Marie Villafafia Assistant United States Attorney cc: Jeffrey H. Sloman, U.S. Attorney Ro

consider 201 S. Biscayne Boulevard, Suite 1300 • Miami, Florida 33131 • Phone: 305-371.6421 • Fax: 305-358-2006. wiinv.Royelack.com EFTA00194766 Jeff Sloman, Esq. Bob Senior, Esq. Marie Villafana, Esq. March 5, 2010 Page 2 responsive motions that relate to the scope of waiver of liability that is me

, and the rule of lenity applied in construing a statute, Defendant's position as to the meaning of the statute would prevail. See United States'. Santos 128 S.Ct. 2020, 2025 (2008). As summarized by the United States Supreme Court in Santos, supra, at 2025: 5 See argument in sections (2) and (3) t

meaning of the statute would prevail. See United States'. Santos 128 S.Ct. 2020, 2025 (2008). As summarized by the United States Supreme Court in Santos, supra, at 2025: 5 See argument in sections (2) and (3) that follow which represent the predicate for the rule of lenity issue discussed in B. 9

that Mr. Epstein will act in good faith and comply with the letter and spirit of the NPA. As to the third item, we have reviewed your letter to Mr. Sloman of February 8, 2010. While Mr. Acosta did state in his letter of December 19, 2007, that he did not believe that the Office was EFTA00183808 ROY

st merely of a notification and will neither encourage nor discourage attendance or submission of materials related to the application. Sincerely, Jeffrey H. Sloman United States Attorney By: s/A. Villa afia A. Assistant United States Attorney cc: Jeffrey H. Sloman, U.S. Attorney Robert K. Senior, Acting

consider 201 S. Biscayne Boulevard, Suite 1300 • Miami. Florida 33131 • Phone: 30S-371.6421 • Fax: 305-358-2006 • suww.RoyBlack.com EFTA00183812 Jeff Sloman, Esq. Esq. , Esq. March 5, 2010 Page 2 responsive motions that relate to the scope of waiver of liability that is memorialized in the NPA. Add

of inertia upon the party that can best induce Congress to speak more clearly and keeps courts from making criminal law in Congress's stead. ... In Santos. the Court was faced with the interpretation of the term "proceeds" in the federal money laundering statute, 18 . §1956. "The federal money-launder

aning of the statute would prevail. See United Statcs I. Santos, 128 S.Ct. 2020, 2025 (2008). As summarized by the United States Supreme Court in Santos, supra, at 2025: See argument in sections (2) and (3) that follow which represent the predicate for the rule of lenity issue discussed in B. 9 EF

ROY BIACK HOWARD M. SREBNICK SCOTT A. KORNSPAN LARRY A. srumpt. MARIA NEYRA JACKIE PERCZEK MARK A.J. SHAPIRO JARED LOPEZ Jeff Sloman, Esq. United States Attorney 99 N.E. 4th Street Miami, FL 33132 BLACK SREBNICK KORNSPAN STUMPF - P.A. March 29, 2010 Assistant United Stat

and the rule of lenity applied in construing a statute, Defendant's position as to the meaning of the statute would prevail. See United States v. Santos 128 S.Ct. 2020, 2025 (2008). As summarized by the United States Supreme Court in Santos, supra, at 2025: 5 See argument in sections (2) and (3) t

eaning of the statute would prevail. See United States v. Santos 128 S.Ct. 2020, 2025 (2008). As summarized by the United States Supreme Court in Santos, supra, at 2025: 5 See argument in sections (2) and (3) that follow which represent the predicate for the rule of lenity issue discussed in B. 9

ROY BIACK HOWARD M. SREBNICK Scott A. KORNSPAN LARRY A. STUMPF MARIA NEYRA JACKIE PERCZEK MARK A.J. SHAPIRO JARED LOPEZ Jeff Sloman, Esq. United States Attorney 99 N.E. 4th Street Miami, FL 33132 BLACK SREBNICK KORNSPAN STUMPF P.A. JESSICA FONSECA-NADER KAntutEn P. RIILU

and the rule of lenity applied in construing a statute, Defendant's position as to the meaning of the statute would prevail. See United States v. Santos 128 S.Ct. 2020, 2025 (2008). As summarized by the United States Supreme Court in Santos, supra, at 2025: 5 See argument in sections (2) and (3) t

eaning of the statute would prevail. See United States v. Santos 128 S.Ct. 2020, 2025 (2008). As summarized by the United States Supreme Court in Santos, supra, at 2025: 5 See argument in sections (2) and (3) that follow which represent the predicate for the rule of lenity issue discussed in B. 9

t responds to CEOS’s assessment of its limited review of Mr. Epstein’s case; and a point-by- point rebuttal to First Assistant United States Attorney Jeffrey Sloman’s recent letter which we believe contains factual inaccuracies typical of our correspondence from the United States Attorney’s Office in Miami (the “

secution is to the facts in this case. Importantly, we note that the CEOS review was conducted prior to the Supreme Court’s very recent decisions in Santos and Cuellar, which we believe—illuminating as they do the Court’s interpretive methodology when it comes to federal criminal law—powerfully demonstra

t responds to CEOS’s assessment of its limited review of Mr. Epstein’s case; and a point-by- point rebuttal to First Assistant United States Attorney Jeffrey Sloman’s recent letter which we believe contains factual inaccuracies typical of our correspondence from the United States Attorney’s Office in Miami (the “

secution is to the facts in this case. Importantly, we note that the CEOS review was conducted prior to the Supreme Court’s very recent decisions in Santos and Cuellar, which we believe—illuminating as they do the Court’s interpretive methodology when it comes to federal criminal law—powerfully demonstra