Epstein Secrets

urt sentence would also mean that the federal government was not proceeding.” There is no evidence, however, that he verified this understanding with Sloman or Villafana, let alone the State Attorney. OPR found no indication that Acosta ever communicated, or directed Sloman or Villafana to communicate, hi

tojthe victims regarding the upcoming change of plea, but the Office decided dial victim notification could only come from a state investigator, and Jeff Sloman asked PBPD Cliief Reiter to assist.” On Saturday, June 28,2008, VillafanajemailedSloman to inform him tliat PBPD Cliief Reiter “is going to notify vi

ision to resolve the case through the NPA or in the negotiations leading to the agreement: former U.S. Attorney R. Alexander Acosta, and former AUSAs Jeffrey H. Sloman, Matthew I. Menchel, Andrew C. Lourie, and Ann Marie C. Villafana. Each subject submitted written responses detailing their involvement in the federa

n the CVRA litigation; Outlook data collected to respond to production requests in that case; a set ofEpstein case documents maintained by Acosta and Sloman; computer files regarding the Epstein case collected by Sloman; Villafafia’s Outlook data; Acosta’s hard drive; and the permanently retained official

tely three weeks abroad. Extensive international travel of this nature further demonstrates a significant risk of flight. See, e.g., United States v. Anderson, 384 F. Supp. 2d 32, 36 (D.D.C. 2005). There can be no assurance that, upon release, the defendant would suddenly lack access to such means of travel

s of the CVRA and, indeed, pressured the U.S. Attorney's Office to commit these violations. Tr. July 11, 2008, at 9. 26. On about December 6, 2007, Jeffrey H. Sloman, First Assistant U.S. Attorney sent a letter to Jay Lefkowitz, noting the U.S. Attorney's Office's legal obligations to keep victims informed of th

move forward towards possible prosecution. Tr. July 11, 2008, at 4-6, 18-19, 22-23, 28-29. 23. On about November 27, 2007, Assistant U.S. Attorney Jeff Sloman sent an e-mail to Jay Lefkowitz, defense counsel for Epstein. The e-mail stated that the U.S. Attorney's Office had an obligation to notify the vic

ing) that they had already negotiated a non-prosecution agreement withtpstein. Exhibit "H." 38. On about February 25, 2008, Assistant U.S. Attorney Sloman sent an e-mail to Jay Lefkowitz, Epstein's criminal defense counsel, explaining that the Justice Department's Child 17 EFTA00177025 Case 9:08-cv

disputes. Construing the CVRA in the way that d'See 18 U.S.C. § 113 (assault within territorial jurisdiction of the United States): United States I Anderson, 528 F.2d 590, 591 (5th Cir. 1976) (in prosecution for assault with intent to commit murder within territorial jurisdiction of United States, distri

-Justiee-Deparnnent-emitast-any-vistimsr including fer-example-Jane-Dee44-r abeut-their-views-en4he-nen-preseeutiem 26. On about December 6, 2007, Jeffrey H. Sloman, First Assistant U.S. Attorney sent a letter to Jay Lefkowitz, a copy of which is attached hereto as Exhibit neting-the ttemeyie EpsteM-Ple-lette

ation would continue, possibly leading to a federal prosecution. Edwards Declaration at ¶ 8. a On about November 27, 2007, Assistant U.S. Attorney Jeff Sloman sent an e-mail to Jay Lefkowitz, defense counsel for Epstein, a copy of which is attached hereto as Exhibit The e-mail-statedt—that-the-1478,Atiem

overnment reached any final mseimien-ef-that-investigatienr Edwards-Deelaratien-at--11-147 33. On about February 25, 2008, Assistant U.S. Attorney Sloman sent an e-mail to Jay Leflcowitz„ a copy of which is attached hereto as Exhibit _.Bpsteinls—eriminal—defense eeunselr explaining that the Justice D

e process because the litigants and the courts assume that the sole purpose of discovery is to assist trial preparation.") (quoting United States'. Anderson, 799 F.2d 1438, 1441(11'h Cir. 1986; emphasis in original). See also Anderson, 799 F.2d at 1441 ("Historically, discovery materials were not availa

d their rights 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

her the victims should be notified, despite the absence of a federal charge being filed. Indeed, on November 27, 2007, First Assistant U.S. Attorney Jeff Sloman advised Jay Lefkowitz by email that the Justice for All Act of 2004 obligated the United States to "notify the victims of the anticipated upcoming

jury to return a verdict 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 Docu

d their rights 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

her the victims should be notified, despite the absence of a federal charge being filed. Indeed, on November 27, 2007, First Assistant U.S. Attorney Jeff Sloman advised Jay Lefkowitz by email that the Justice for All Act of 2004 obligated the United States to "notify the victims of the anticipated upcoming

jury to return a verdict 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 Docu

proof beyond a reasonable doubt that each of them was a victim of an enumerated offense." (emphasis added). First Assistant United States Attorney Jeffrey Sloman used similar language in tying the names of the "victims" to the basis for a potential indictment, see December 6, 2007 letter from Mr. Sloman to M

frey Sloman used similar language in tying the names of the "victims" to the basis for a potential indictment, see December 6, 2007 letter from Mr. Sloman to Mr. Lefkowitz at 2, 3; see also your email to Mr. Lefkowitz and Mr. Black on August 14, 2008 at 3:27 p.m., where you state that the list contains

1501310 EFTA00180364 Case 9:08-cv-80804-KAM Document 1 Entered on FLSD Docket 07/21/2008 Page 17 of 100 omitted) (emphasis added); Turner v. Anderson, 704 So. 2d 748, (Ha. 4th DCA 1998) ("[N]o public policy should allow appellant to recover damages as a result of engaging in criminal conduct such

te Burnett F OWL E RWH I T E All'otiNgTS AT LAW B URNETT 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

statute. I would note that the United States provided the draft letter to defense ns a courtesy. in addition, First Assistant United States Attorney Sloman already incorporated in the letter several edits that had been requested by defense counsel. I agree that Section 3771 applies to notice of proceed

apply not only to references to unindicted co-conspirators in indictments and factual proffers, but also to motion papers. See, e.g., United States. Anderson, 55 F. Supp. 2d 1163, 1168 (D. Kan. 1999) ("After carefully reviewing the government's moving papers on the conflict of interest issue, the court c

No, sir. 8 Q. How many women and how many men came to 9 your house? 10 A. I want to say two ladies and two guys. 11 Q. Did someone named Jeffrey Sloman come to 12 your house? 13 A. I don't know names, sir. 14 Q. Do you know who Jeffrey Sloman is? 15 A. No, sir. 16 Q. Do you know who Jef

16 316 EFTA00180422 Case 9:08-cv-80804-KAM Document 1 Entered on FLSD Docket 07/21/2008 Page 17 of 100 omitted) (emphasis added); Turner v. Anderson, 704 So. 2d 748, (Fla. 4th DCA 1998) ("[N]o public policy should allow appellant to recover damages as a result of engaging in criminal conduct suc

Villafana, Ann Marie C. (USAFLS) From: Vi°Mena. Ann Mane C. (USAFLS) Sent: Tuesday. July 31, 2007 1:37 PM To: Sloman, Jeff (USAFLS); Menchel, Matthew (USAFLS); Lourie. Andrew (USAFLS) Subject: Emailing: Conf Plea Negotiations.wpd Attachments: Conf Plea Negotiati

porting its version of the material facts or to refute the moving party's contention that the facts entitle it to judgment as a matter of law. See Anderson, 477 U.S. at 256-257, 106 S.Ct. 2505. The Court need not accept mere conclu- sory allegations, whether they are made in the complaint or a sworn s