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ng) that they had already negotiated a non-prosecution agreement with Epstein. 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 08-80736-CV-MARRA 000687
s of the CVRA and, indeed, pressured the U.S. Attorney's Office to commit those 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
ation, but it later appeared that would be an illegal sentence in this case, and thus only adequate remedy is to allow defendant to withdraw plea); Craig'. People, 986 P.2d 951, 959-60 (Cob. 1999) (because "neither the prosecutor nor the trial court have authority to modify or waive the mandatory paro
ome sort of objection from defendant Epstein. The U.S. Attorney's Office, however, rejected those objections In a letter on about December 6, 2007, Jeffrey H. Sloman, First Assistant U.S. Attorney again sent a letter to Jay Lefkowitz, reiterating the U.S. Attorney's Office's legal obligations to keep victims 31
ic proceeding in the district court involving ... plea ...." Exhibit "C." Similarly, on about November 27, 2007, then First Assistant U.S. Attorney Jeff Sloman sent an e-mail to Jay Lefkowitz, defense counsel for Epstein stating: "The United States has a statutory obligation (Justice for All Act of 2004) to
ation, but it later appeared that would be an illegal sentence in this case, and thus only adequate remedy is to allow defendant to withdraw plea); Craig'. People, 986 P.2d 951, 959-60 (Colo. 1999) (because "neither the prosecutor nor the trial court have authority to modify or waive the mandatory par
he FBI commenced its own investigation, then-U.S. Attorney for the Southern District ofFlorida, Alexander Acosta, asked First Assistant U.S. Attorney Jeffrey Sloman whether it was “appropriate to approach [State Attorney Krischer] and give him a heads up re where we might go?” Sloman replied, “No for fear that it
nd (ix) the _additional need for maintaining secrecy in the particular yase in question. Kut/er, 800 F. Supp. 2d at 47-48 (quotingJn re Petition of Craig, 131 F.3d 99, 106 (1997)). 6 103. The v~st majority of these fact.ors support disclosure in this case. First? the party seeking disclosure does so
the defense claim that this case "was, at heart, a local sex abuse case." Epstein Remedies Br. at 15 (quoting former First Assistant U.S. Attorney Jeffrey Sloman). Indeed, one of the experts that Intervenor Epstein hired represented to the Justice Department during discussions about the NPA that "[t]his is a
Page: EFTA00021449 →terpreting plea agreements. Indeed, numerous cases hold that such agreements are unenforceable when they deviate from legal requirements. See, e.g., Craig v. People, 986 P.2d 951, 959-60 (Colo. 1999) (court cannot enforce a plea agreement that waives the mandatory parole period); State v. Garcia, 582
Page: EFTA00021500 →the defense claim that this case "was, at heart, a local sex abuse case." Epstein Remedies Br. at 15 (quoting former First Assistant U.S. Attorney Jeffrey Sloman). Indeed, one of the experts that Intervenor Epstein hired represented to the Justice Department during discussions about the NPA that "[t]his is a
Page: EFTA00022553 →terpreting plea agreements. Indeed, numerous cases hold that such agreements are unenforceable when they deviate from legal requirements. See, e.g., Craig v. People, 986 P.2d 951, 959-60 (Colo. 1999) (court cannot enforce a plea agreement that waives the mandatory parole period); State v. Garcia, 582
Page: EFTA00022604 →Entities connected to both Jeffrey Sloman and Craig Martin

Jeffrey Epstein
PERSON
A. Marie Villafana
PERSON
Alexander Acosta
PERSONKaren
PERSON
Jay Lefkowitz
PERSONLeon Black
PERSON
Kenneth Marra
PERSONJack Goldberger
PERSONRoy Black
PERSON
Lesley Groff
PERSON
Marc Rich
PERSON
United States
LOCATIONJane Doe
PERSON
Department of Justice
ORGANIZATION
Prince Andrew
PERSON
Bradley Edwards
PERSON
George W. Bush
PERSON
Bill Richardson
PERSON
Ken Starr
PERSON
Alan Dershowitz
PERSON