EFTA00183457¶
| Phone Number | |
|---|---|
| 5161.959.8300 | f5161.835.8691 |
| One Clearlake Centre, Suite I400 | 250 Australian Avenue South | West Palm Beach, FL 33401 |
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(b) Any notification be effectuated by a separate mailing to each individual without the inclusion of any language that appeared on the second page of your June 30, 2008 memorandum; i.e. rather than including in each notification a large section listing “identified individuals” with redactions other than the name of the recipient (which we contend would be a clear and impermissible signal to any individual that the notification is a broad notification to numerous other alleged victims). Rather, a simple one page notification directed only to the recipient, and limited to the information currently on the first page of your draft memorandum would suffice.¶
for civil litigation;¶
(a) Any notification be sent to any individual by mail (or served upon their attorney, to the extent known), and we respectfully object to any service by hand, a method of service which carries the concomitant risk of conversations regarding the notification that potentially would place the federal authorities in a position of being advocates¶
First, please note that we have several requests concerning any such notification. Specifically, we¶
request that:¶
address a few related issues.¶
Thank you for your letter to me dated July 8, 2008 and the draft document dated, e-mailed and faxed to me at my office on June 30, 2008, styled “Notification of Identified Victims.” I would like to¶
Dear Ms.¶
Re: Jeffrey E. Epstein¶
SENT VIA E-MAIL & FACSIMILE¶
Assistant United States Attorney¶
United States Attorney’s Office¶
500 South Australian Avenue¶
4th Floor, Suite 400¶
West Palm Beach, Florida 33401¶
*Board Certified Criminal Trial Attorney † Member of New Jersey & Florida Bars¶
July 9, 2008¶
JASON S.WEISS¶
- JOSEPH R. ATTERBURY
† JACK A. GOLDBERGER¶
EFTA00183458¶
Jeffrey Epstein¶
cc:¶
very truly yours,¶
Jack A. Goldberger¶
I look forward to your response. Until then, I remain.¶
agreement.¶
Finally, please know that it is Mr. Epstein’s firm intent to fulfill strictly each term and condition of his Non-Prosecution Agreement with the Government. Nothing in this letter should be construed, however, as waiving any defense that may be available to Mr. Epstein under the parties’ written¶
Third, I would respectfully request that you provide me with the names of the “pro bono lawyers” who, you indicated to me at our June 30 meeting at my office, were intending to represent certain persons identified on your June 30 draft notification, as well as any knowledge that the Government has as to how they were selected, and what communications the Government has had with them to¶
date.¶
Our understanding of the Non-Prosecution Agreement is that it does not require Mr. Epstein to “acknowledge” anything not already contained within the four corners of the written agreement. The agreement certainly contains no written term obligating that he “waive any evidentiary challenge to the introduction of a copy” of any “Notification of Identified Victims” in “any judicial proceeding between any identified individual” and Mr. Epstein, as your memorandum currently requests. Further, please note that your June 30 stipulation, as drafted, is not limited to Section 2255 proceedings. Rather, your June 30 draft requires Mr. Epstein to waive evidentiary challenges in “any judicial proceeding” - which clearly exceeds the bounds of the parties’ written agreement.¶
Second, please note also that we do not understand your request that Mr. Epstein and his attorneys execute the rider / acknowledgment contained within your June 30 hand-delivered draft. Specifically, we do not believe that the Non-Prosecution Agreement requires Mr. Epstein’s execution of any such additional stipulation. Because we want to ensure that Mr. Epstein continues to strictly comply with the letter of the parties’ agreement, we respectfully ask that you explain why you believe that the Non-Prosecution Agreement requires execution of your stipulation.¶
(d) You supplement the notification with the Government’s previously made representation that it is not vouching for the veracity of any claim by any identified individual. See Letter from J. Sloman to E. (10/25/07).¶
(c) You eliminate from any notification any language that is currently contained in the “acknowledgment” section of the June 30, 2008 memorandum; and¶