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1.01 MB
Extraction Summary
7
People
3
Organizations
1
Locations
5
Events
4
Relationships
8
Quotes
Document Information
Type:
Legal document
File Size:
1.01 MB
Summary
This legal document details the contentious communications in late November and early December 2007 between federal prosecutors (Acosta, Sloman, Villafaña) and Jeffrey Epstein's defense team (Lefkowitz, Starr). The core conflict revolved around the timing, content, and legal necessity of notifying victims about Epstein's upcoming state plea hearing, with the defense arguing for delay and review, and the prosecution asserting its obligations and threatening to void the plea agreement. The dispute involved a series of letters and instructions, highlighting the friction in executing the terms of the Non-Prosecution Agreement (NPA).
People (7)
| Name | Role | Context |
|---|---|---|
| Epstein | Defendant |
Mentioned in relation to his agreement to plead guilty to state charges, serve jail time, and potential monetary dama...
|
| Sloman |
Exchanged edits on a draft victim notification letter with Villafaña, informed Lefkowitz of the government's intent t...
|
|
| Villafaña |
Exchanged edits with Sloman, provided a draft notification letter to Lefkowitz, was informed by a lead case agent abo...
|
|
| Lefkowitz | Defense Counsel (implied) |
Objected to the government's plan to notify victims, argued on behalf of the defense, and sent letters to Acosta.
|
| Acosta |
Received and replied to letters from Lefkowitz, accused the defense team of delaying the NPA, and directed prosecutor...
|
|
| Starr | Defense Counsel |
Informed by Acosta via letter about a deadline for victim notifications and co-sent a letter with Lefkowitz to Acosta.
|
| Fisher | Assistant Attorney General |
Received a copy of a letter sent by Starr and Lefkowitz to Acosta.
|
Organizations (3)
| Name | Type | Context |
|---|---|---|
| State Attorney’s Office | government agency |
Mentioned as the office where victims could file a written statement for the state court hearing.
|
| FBI | government agency |
Mentioned as one of the agencies from which victims had received notification letters.
|
| USAO | government agency |
Mentioned as one of the agencies from which victims had received notification letters.
|
Timeline (5 events)
Locations (1)
| Location | Context |
|---|---|
|
Mentioned as the place where Epstein would serve 18 months as part of his agreement.
|
Relationships (4)
They exchanged edits on a draft victim notification letter and communicated about its contents and distribution, indicating they were colleagues working on the same task.
They exchanged letters arguing over the legal obligations and procedures for notifying victims under Epstein's NPA. Acosta accused Lefkowitz's team of delaying tactics, while Lefkowitz objected strongly to Acosta's team's proposed actions.
They are both identified as part of Epstein's defense team and co-authored a letter to Acosta on December 5, 2007.
Key Quotes (8)
"[t]here are a few girls who didn’t receive the original letters, so I will need to modify the introductory portion of the letter for those."Source
— Villafaña
(Informing Sloman about the need to edit the draft victim notification letter.)
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Quote #1
"incendiary and inappropriate"Source
— Lefkowitz
(Describing his objection to the proposal to notify victims before Epstein's plea.)
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Quote #2
"should have a right to review and make objections to that submission prior to it being sent to any alleged victims."Source
— Lefkowitz
(Arguing for the defense's right to review the victim notification letter.)
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Quote #3
"we stand ready to unwind the Agreement"Source
— Acosta
(In a reply letter to Lefkowitz, asserting the government's position if Epstein was dissatisfied with the NPA.)
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Quote #4
"not to issue victim notification letters until this Friday [December 7] at 5 p.m., to provide you with time to review these options with your client."Source
— Acosta
(In a letter to defense counsel Starr, directing prosecutors to hold the letters.)
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Quote #5
"the victims were not told of the availability of Section 2255 relief during the investigation phase of this matter."Source
— Acosta
(Refuting defense allegations that Villafaña had acted improperly.)
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Quote #6
"still holding many of the original V/W letters addressed to victims from the USAO."Source
— lead case agent
(Reporting to Villafaña on the status of victim notification letters on December 6, 2007.)
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Quote #7
"[I]f the matter is set for the 14th, please let me know so I can include that in my victim notifications."Source
— Villafaña
(In an email to state prosecutors seeking confirmation of the court date.)
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Quote #8
Full Extracted Text
Complete text extracted from the document (4,041 characters)
Case 22-1426, Document 77, 06/29/2023, 3536038, Page241 of 258
SA-239
Case 1:20-cr-00330-AJN Document 204-3 Filed 04/16/21 Page 239 of 348
SA-239
Case 1:20-cr-00330-AJN Document 204-3 Filed 04/16/21 Page 239 of 348
she would inform victims of the terms of the resolution of the federal case, including Epstein’s
agreement to plead guilty to state charges and serve 18 months in county jail, and the victims’
ability to seek monetary damages against Epstein. The letter also would invite victims to appear
at the state court hearing and make a statement under oath or provide a written statement to be
filed by the State Attorney’s Office. Sloman and Villafaña exchanged edits on the draft victim
notification letter, and Villafaña also informed Sloman that “[t]here are a few girls who didn’t
receive the original letters, so I will need to modify the introductory portion of the letter for
those.”³¹²
agreement to plead guilty to state charges and serve 18 months in county jail, and the victims’
ability to seek monetary damages against Epstein. The letter also would invite victims to appear
at the state court hearing and make a statement under oath or provide a written statement to be
filed by the State Attorney’s Office. Sloman and Villafaña exchanged edits on the draft victim
notification letter, and Villafaña also informed Sloman that “[t]here are a few girls who didn’t
receive the original letters, so I will need to modify the introductory portion of the letter for
those.”³¹²
Sloman informed Lefkowitz of the government’s need to meet its “statutory obligation
(Justice for All Act of 2004) to notify the victims of the anticipated upcoming events and their
rights associated with the agreement” and his intent to “notify the victims by letter after COB
Thursday, November 29.” Lefkowitz objected to the proposal to notify the victims, asserting that
it was “incendiary and inappropriate” and not warranted under the Justice for All Act of 2004. He
argued that the defense “should have a right to review and make objections to that submission
prior to it being sent to any alleged victims.” He also insisted that if any notification letters were
sent to “victims, who still have not been identified to us, it should happen only after Mr. Epstein
has entered his plea” and that the letter should come from the attorney representative rather than
the government. On November 28, 2007, at Sloman’s instruction, Villafaña provided Lefkowitz
with the draft victim notification letter, which would advise victims that the state court plea was
to occur on December 14, 2007.³¹³
(Justice for All Act of 2004) to notify the victims of the anticipated upcoming events and their
rights associated with the agreement” and his intent to “notify the victims by letter after COB
Thursday, November 29.” Lefkowitz objected to the proposal to notify the victims, asserting that
it was “incendiary and inappropriate” and not warranted under the Justice for All Act of 2004. He
argued that the defense “should have a right to review and make objections to that submission
prior to it being sent to any alleged victims.” He also insisted that if any notification letters were
sent to “victims, who still have not been identified to us, it should happen only after Mr. Epstein
has entered his plea” and that the letter should come from the attorney representative rather than
the government. On November 28, 2007, at Sloman’s instruction, Villafaña provided Lefkowitz
with the draft victim notification letter, which would advise victims that the state court plea was
to occur on December 14, 2007.³¹³
In a November 29, 2007 letter to Acosta, Lefkowitz strongly objected to the proposed draft
notification letter, arguing that the government was not obligated to send any letter to victims until
after Epstein’s plea and sentencing. Lefkowitz also contended that the victims had no right to
appear at Epstein’s state plea hearing and sentencing or to provide a written statement for such a
proceeding. In a November 30, 2007 reply letter to Lefkowitz, Acosta did not address the
substance of Lefkowitz’s arguments, but accused the defense team of “in essence presenting
collateral challenges” delaying effectuation of the NPA, and asserted that if Epstein was
dissatisfied with the NPA, “we stand ready to unwind the Agreement” and proceed to trial. Shortly
thereafter, Acosta informed defense counsel Starr by letter that he had directed prosecutors “not to
issue victim notification letters until this Friday [December 7] at 5 p.m., to provide you with time
to review these options with your client.” In the letter, Acosta also refuted defense allegations that
Villafaña had acted improperly by informing the victims of the potential for receiving monetary
damages, stating that “the victims were not told of the availability of Section 2255 relief during
the investigation phase of this matter.”
notification letter, arguing that the government was not obligated to send any letter to victims until
after Epstein’s plea and sentencing. Lefkowitz also contended that the victims had no right to
appear at Epstein’s state plea hearing and sentencing or to provide a written statement for such a
proceeding. In a November 30, 2007 reply letter to Lefkowitz, Acosta did not address the
substance of Lefkowitz’s arguments, but accused the defense team of “in essence presenting
collateral challenges” delaying effectuation of the NPA, and asserted that if Epstein was
dissatisfied with the NPA, “we stand ready to unwind the Agreement” and proceed to trial. Shortly
thereafter, Acosta informed defense counsel Starr by letter that he had directed prosecutors “not to
issue victim notification letters until this Friday [December 7] at 5 p.m., to provide you with time
to review these options with your client.” In the letter, Acosta also refuted defense allegations that
Villafaña had acted improperly by informing the victims of the potential for receiving monetary
damages, stating that “the victims were not told of the availability of Section 2255 relief during
the investigation phase of this matter.”
On December 5, 2007, Starr and Lefkowitz sent a letter to Acosta, with copies to Sloman
and Assistant Attorney General Fisher, “reaffirm[ing]” the NPA, but taking “serious issue” with
and Assistant Attorney General Fisher, “reaffirm[ing]” the NPA, but taking “serious issue” with
³¹² On November 28, 2007, two months after the NPA was signed, the lead case agent informed Villafaña that
only 15 of the then-known victims had received victim notification letters from either the FBI or the USAO. On
December 6, 2007, the lead case agent reported to Villafaña that she was “still holding many of the original V/W
letters addressed to victims from the USAO.”
only 15 of the then-known victims had received victim notification letters from either the FBI or the USAO. On
December 6, 2007, the lead case agent reported to Villafaña that she was “still holding many of the original V/W
letters addressed to victims from the USAO.”
³¹³ Villafaña understood the state prosecutors had set the December 14, 2007 date, and emailed them for
confirmation, stating, “[I]f the matter is set for the 14th, please let me know so I can include that in my victim
notifications.”
confirmation, stating, “[I]f the matter is set for the 14th, please let me know so I can include that in my victim
notifications.”
213
DOJ-OGR-00021413
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