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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
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 7 EFTA00079009 Case 9:08-cv-
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
ty in his sentence until the [review by writ] is concluded ...."' LAFAVE ET AL., CRIMINAL Procedure § 26.7(b) (Nov. 2010) (quoting United States v. DiFrancesco, 449 U.S. 117, 146 (1980)). 40 EFTA00079032 Case 9:08-cv-80736-KAM Document 48 Entered on FLSD Docket 03/21/2011 Page 41 of 42 DATED: March 21,2
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
ality in his sentence until the [review by writ] is concluded ...."' LAFAVE ET AL., CRIMINAL Procedure § 26.7(b) (Nov. 2010) (quoting United States DiFrancesco, 449 U.S. 117, 146 (1980)). 39 EFTA00235789 reason, it makes sense for the Court to bifurcate the process and determine, first, the extent of the
orized release; Material Severable; Redaction; No Assertion by Victims Box #2 P-008517 Thru P-008535 6/25/2007 Letter from Gerald Lefcourt to Jeffrey Sloman and Andrew Lourie [pursuant to Court's Order, not being withheld as privileged — will be produced to opposing counsel upon lift of stay by 11th C
onship; Claims Against Public Prosecutor; Overriding Need; Attorney Conduct at Issue Suppl. Box #3 P-013334 Thru File folder entitled "11/13/07 Sloman to Leflcowitz (was this sent?)" containing draft 11/13/07 letter from J. Sloman Attorney-Client Privilege Inadequate Log; No Factual Underpinning
rom Stake Center and other victims, and pleaded guilty to one count of tax evasion and three counts of wire fraud. Pursuant to her plea agreement, DiFrancesco agreed to make restitution to Stake ' Stake Center previously petitioned this court for mandamus, and we denied this petition as premature. See Sta
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
y in his sentence until the [review by writ] is concluded ...."' LAFAvs El' AL., CRIMINAL Procedure § 26.7(b) (Nov. 2010) (quoting United States v. DiFrancesco, 449 U.S. 117, 146 (1980)). 40 EFTA00208413 Case 9:08-cv-80736-KAM Document 48 Entered on FLSD Docket 03/21/2011 Page 41 of 42 DATED: March 21.
Entities connected to both Jeffrey Sloman and DiFrancesco

Jeffrey Epstein
PERSON
A. Marie Villafana
PERSON
Alexander Acosta
PERSON
Jay Lefkowitz
PERSON
Kenneth Marra
PERSONJack Goldberger
PERSONJane Doe
PERSON
United States
LOCATION
Department of Justice
ORGANIZATION
Bradley Edwards
PERSON
Prince Andrew
PERSON
George W. Bush
PERSONthe Southern District
LOCATION
Alan Dershowitz
PERSONRolando Garcia
PERSONGarcia
PERSON
Podhurst
PERSONMaria Farmer
PERSONFBI
ORGANIZATION
Palm Beach County
LOCATION