EFTA00189407¶
Villafana, Ann Marie C. (USAFLS)¶
| From: |
| Sent: |
| To: |
| Subject: |
| Sloman, Jeff (USAFLS) |
| Friday, May 02, 2008 11:02 AM |
| Villafana, Ann Marie C. (USAFLS) |
| RE: One other thing |
Thanks. Here’s the revised final. Let me know if you spot anything else. BTW, I preserved your grammatical honor.¶
| EpsteinNoticeLtr |
|---|
| 0408.wpd |
| From: | Villafana, Ann Marie C. (USAFLS) |
| Sent: | Wednesday, April 30, 2008 11:24 AM |
| To: | Sloman, Jeff (USAFLS) |
| Subject: | RE: One other thing |
Hi Jeff – I like it, especially all of the quotes of their language. I just changed a few spacing issues, but I wanted to leave the substantive edits up to you.¶
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In your listing of attorneys, I didn’t know if you wanted to add Mr. Starr’s name up there (I know it is mentioned later), as well as adding “former U.S. Attorney Guy Lewis, and noted criminal defense attorneys Roy Black and Marty Weinberg (I need to check on his name)”
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Under “The Negotiation Phase,” you say that one of the options Epstein was presented with was a Rule 11 plea to a federal charge, but that isn’t correct. At that time, Alex was unwilling to do a Rule 11 plea, so we were left with trying to find federal charges that he could plead to that resulted in the agreed imprisonment term. Maybe write: “In order to achieve this result, the parties considered two alternatives, a plea to federal charges that limited Epstein’s sentencing exposure, or, as suggested by you, a plea to state charges encompassing Epstein’s conduct.” [Much later, Alex changed his mind, but by that time, Epstein’s crew was on the “he didn’t do anything wrong” bandwagon.]
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Under “Delay,” you may want to quote the language of the agreement, which clearly DID NOT contemplate a staggered plea and sentencing. [The true reason why they didn’t plead on the November date was because the judge would have remanded him on that date, rather than let him stay out until January. Quite simply, this was not our problem, we have always maintained that the state court judge should do her own thing, so it wasn’t a legitimate reason for further delay, but it essentially would have eliminated Epstein’s plan to never spend a day in jail.]
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In your conclusion, you may want to make one specific term explicit: “Therefore, as I proposed in my email to you on February 25, 2008, you shall have until ___, to comply with all of the terms and conditions of the Agreement, including plea, sentence, and incarceration, as modified by the USA’s December 19th letter to Ms. Sanchez.”
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Not substantive, but I feel the need to defend my “grammar honor” so — I know that you, Andy, and Alex (as well as defense counsel) all think that I have made up the word “registrable,” but, according to The Oxford American Dictionary, the adjective form of “register” is “registrable.”
Thank you!¶
A. Marie Villafaña¶
1077¶
P-014889¶
08-80736-CV-MARRA¶