Epstein Secrets

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

rc "merely a statement of assertion or concession made for some independent purpose," and may be controverted or explained by the party who made it. Martinez I Bally's Louisiana, Inc., 244 F.3d 474, 476-77 (51° Cir. 2001), citing McNamara v. Miller, 269 F.2d 511, 515 (D.C. Cir. 1959). In contrast, a judi

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

suffers personal injury as a result of such violation." "18 U.S.C. §2255 gives victims of sexual conduct who are minors a private right of action." Martinez'. White, 492 P.Supp.2d 1186, 1188 (N.D. Cal. 2007). 18 U.S.C.A. §2255 "merely provides a cause of action for damages in `any appropriate United Stat

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

who suffers personal injury as a result of such violation." "18 . §2255 gives victims of sexual conduct who are minors a private right of action." Martinez'. White, 492 F.Supp.2d 1186, 1188 (N.D. Cal. 2007). 18 §2255 "merely provides a cause of action for damages in `any appropriate United States Distr

Villafana, Ann Marie C. (USAFLS) From: Sloman. Jeff (USAFLS) Sent: Monday, October 22, 2007 5:26 PM To: Villafana, Ann Marie C. (USAFLS); Acosta, Alex (USAFLS) Subject: Fw: Epstein Fyi Se

bpoena to Paul A. Lavery (return date 5/29/07) 59 5/22/2007 Andrew Cootie Gerald B. Lefcourt Letter requesting to meet with Matthew Menchel and Jeffrey Sloman and \ lc\ Acosta prior to an indictment being filed 28 5/22/2007 Matthew Menchel and Jeff Sloman; cc: A. Marie Villafalia Andrew Laurie Email

/2008 VilLiana letter to Capt. Sleeth, Palm Beach Sheriffs Office, mganling Epstein's work release application 85 6/9/2009 Vadatla Memorandum to Sloman, Senior, Garcia, awl Atkinson seeking permission to declare breach with attachments awl proposal breach letter 86 6/9/2009 Signed indictment packa

e Dalton School (return date 9/29/09) 9/26/2006 Acosta, Mulvihill, Sloman, Noto, Waters, L°urie' Stefin, Atkinson, Garcia, Brown, Boscovich, Martinez Villafaila Memo regarding changes to Child Explotation Statutes in Tide 18 16 10/19/2006 Subpoena to Individual #28 (return date 10/27/06) 10/2

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

Q. 6 "A judicial admission is a formal concession in the pleadings or stipulations by a party or counsel that is binding on the party making them." Martinez v. Bally's Louisiana. Inc. 244 F.3d 474, 476-77 (5th Cir. 2001). 23 EFTA00799847 Case 9:08-cv-80736-KAM Document 408 Entered on FLSD Docket 06/0

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

Q. 6 "A judicial admission is a formal concession in the pleadings or stipulations by a party or counsel that is binding on the party making them." Martinez v. Bally's Louisiana. Inc. 244 F.3d 474, 476-77 (5th Cir. 2001). 23 EFTA00591484 Case 9:08-cv-80736-KAM Document 401-2 Entered on FLSD Docket 06

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

suffers personal injury as a result of such violation." "18 U.S.C. §2255 gives victims of sexual conduct who are minors a private right of action." Martinez v. White 492 F.Supp.2d 1186, 1188 (N.D. Cal. 2007). 18 U.S.C.A. §2255 "merely provides a cause of action for damages in `any appropriate United Stat

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

suffers personal injury as a result of such violation." "18 U.S.C. §2255 gives victims of sexual conduct who are minors a private right of action." Martinez v. White 492 F.Supp.2d 1186, 1188 (N.D. Cal. 2007). 18 U.S.C.A. §2255 "merely provides a cause of action for damages in `any appropriate United Stat

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

conveniens. The dismissal will be stayed for 30 days to give plaintiffs the opportunity to file suit in Mexico. IT IS SO ORDERED. N.D.CaI.,2007. Martinez White F.Supp.2d ----, 2007 WL 1813773 (N.D.Cal.) END OF DOCUMENT O 2007 Thomson/West. No Claim to Orig. U.S. Govt. Works. s wows air m• • 19.