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941 KB
Extraction Summary
9
People
3
Organizations
2
Locations
2
Events
4
Relationships
8
Quotes
Document Information
Type:
Legal document
File Size:
941 KB
Summary
This legal document details a dispute between the prosecution (represented by Sloman, Villafaña, and Acosta) and Jeffrey Epstein's defense team (Starr and Lefkowitz) regarding the government's obligation to notify victims under the VRRA. The prosecution argues for the necessity of informing victims about Epstein's Non-Prosecution Agreement and his upcoming state plea deal, scheduled for December 14, 2007, while the defense objects strongly. The document includes excerpts from letters exchanged between the two sides, outlining their legal positions and the specifics of the proposed plea agreement.
People (9)
| Name | Role | Context |
|---|---|---|
| Starr |
Co-author of a letter to the USAO on behalf of the defense, asserting it was 'wholly inappropriate' to send a victim ...
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|
| Lefkowitz |
Co-author of a letter to the USAO and recipient of letters from Sloman, representing the defense in the Epstein case.
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|
| Acosta |
Recipient of a copy of a letter from Sloman. Urged by the defense to withhold a notification letter. Mentioned in a f...
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|
| Assistant Attorney General Fisher | Assistant Attorney General |
Mentioned as the person with whom the defense wanted to discuss the victim notification matter.
|
| Sloman | Attorney |
Sent letters to Lefkowitz on behalf of the government, arguing for the necessity of victim notification under the VRR...
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| Villafaña | Attorney |
Recipient of a copy of a letter from Sloman. Identified as a contact person for victims. Described in a footnote as t...
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| Mr. Epstein | Defendant |
Subject of a federal investigation and a Non-Prosecution Agreement, who agreed to plead to a state offense.
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| Jeffrey Epstein | Defendant |
Subject of a federal investigation mentioned in a revised draft victim notification letter.
|
| Judge Sandra K. McSorley | Judge |
The judge scheduled to preside over Mr. Epstein's change of plea and sentencing.
|
Organizations (3)
| Name | Type | Context |
|---|---|---|
| USAO | government agency |
Referenced as the U.S. Attorney's Office, whose interpretation of an agreement was disputed by the defense and which ...
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| FBI | government agency |
Mentioned in the context of the 'FBI case agent' whom victims could contact with questions.
|
| OPR | government agency |
Mentioned in footnote 315 as the Office of Professional Responsibility, which was informed by Villafaña about the aut...
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Timeline (2 events)
2007-12-14
Mr. Epstein's change of plea and sentencing hearing.
state court
Locations (2)
| Location | Context |
|---|---|
|
Mentioned as a type of venue for proceedings.
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|
Mentioned as the venue where Epstein would plead guilty.
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Relationships (4)
Sloman (representing the government) and Lefkowitz (representing the defense) were on opposing sides of a legal matter, communicating via letters regarding victim notification in the Epstein case.
They co-authored a letter to the USAO, indicating they were colleagues working together on the defense team.
They were colleagues on the prosecution team. Footnote 315 details their collaborative process, stating Villafaña was the primary author of a document that Sloman approved and signed, and that they, along with Acosta, reviewed and edited correspondence together.
Key Quotes (8)
"wholly inappropriate"Source
— Starr and Lefkowitz letter
(Describing the USAO's plan to send a proposed victim notification letter.)
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Quote #1
"strongly urg[ed]"Source
— Starr and Lefkowitz letter
(Urging Acosta to withhold the notification letter.)
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Quote #2
"to discuss this matter with Assistant Attorney General Fisher."Source
— Starr and Lefkowitz letter
(Stating a condition for potentially proceeding with victim notification.)
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Quote #3
"the earliest possible"Source
— Sloman
(Regarding the notice the government was obligated to provide victims about the status of the investigation and plea.)
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Quote #4
"Again, federal law requires that victims have the ‘reasonable right to confer with the attorney for the Government in this case.’"Source
— Sloman
(Addressing the defense objection to advising victims to contact government attorneys.)
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Quote #5
"The three victims who were notified prior to your objection had questions directed to Mr. Epstein’s punishment, not the civil litigation. Those questions are appropriately directed to law enforcement."Source
— Sloman
(Advising the defense about the nature of questions from already-notified victims.)
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Quote #6
"the federal investigation of Jeffrey Epstein has been completed,"Source
— Revised draft victim notification letter
(A statement from a draft letter forwarded by Sloman to Lefkowitz.)
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Quote #7
"As I mentioned above, as part of the resolution of the federal investigation, Mr. Epstein has agreed to plead guilty to state charges. Mr. Epstein’s change of plea and sentencing will occur on December 14, 2007, at ___ a.m., before Judge Sandra K. McSorley,"Source
— Revised draft victim notification letter
(An excerpt from a draft letter providing specific information about the upcoming plea hearing.)
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Quote #8
Full Extracted Text
Complete text extracted from the document (3,546 characters)
Case 22-1426, Document 77, 06/29/2023, 3536038, Page242 of 258
SA-240
Case 1:20-cr-00330-AJN Document 204-3 Filed 04/16/21 Page 240 of 348
SA-240
Case 1:20-cr-00330-AJN Document 204-3 Filed 04/16/21 Page 240 of 348
the USAO’s interpretation of the agreement and “the use of Section 2255.” The Starr and Lefkowitz letter asserted it was “wholly inappropriate” for the USAO to send the proposed victim notification letter “under any circumstances,” and “strongly urg[ed]” Acosta to withhold the notification letter until after the defense was able “to discuss this matter with Assistant Attorney General Fisher.”
The following day, Sloman sent a letter to Lefkowitz, with copies to Acosta and Villafaña, asserting that the VRRA obligated the government to notify victims of the 18 U.S.C. § 2255 proceedings as “other relief” to which they were entitled. Sloman also stated that the VRRA obligated the government to provide the victims with information concerning restitution to which they may be entitled and “the earliest possible” notice of the status of the investigation, the filing of charges, and the acceptance of a plea.314 (Emphasis in original). Sloman added:
Just as in 18 U.S.C. § 3771 [the CVRA], these sections are not limited to proceedings in a federal district court. Our Non-Prosecution Agreement resolves the federal investigation by allowing Mr. Epstein to plead to a state offense. The victims identified through the federal investigation should be appropriately informed, and our Non-Prosecution Agreement does not require the U.S. Attorney’s Office to forego [sic] its legal obligations.315
Sloman also addressed the defense objection to advising the victims to contact Villafaña or the FBI case agent with questions or concerns: “Again, federal law requires that victims have the ‘reasonable right to confer with the attorney for the Government in this case.’” Sloman advised the defense: “The three victims who were notified prior to your objection had questions directed to Mr. Epstein’s punishment, not the civil litigation. Those questions are appropriately directed to law enforcement.”
Along with this letter, Sloman forwarded to Lefkowitz for comment a revised draft victim notification letter that was substantially similar to the prior draft provided to the defense. The letter stated that “the federal investigation of Jeffrey Epstein has been completed,” Epstein would plead guilty in state court, the parties would recommend 18 months of imprisonment at sentencing, and Epstein would compensate victims for damage claims brought under 18 U.S.C. § 2255. The letter provided specific information concerning the upcoming change of plea hearing:
As I mentioned above, as part of the resolution of the federal investigation, Mr. Epstein has agreed to plead guilty to state charges. Mr. Epstein’s change of plea and sentencing will occur on December 14, 2007, at ___ a.m., before Judge Sandra K. McSorley,
314 See 42 U.S.C. § 10607(c)(1)(B) and (c)(3).
315 Emphasis in original. Sloman also stated that the USAO did not seek to “federalize” a state plea, but “is simply informing the victims of their rights.” Villafaña informed OPR that Sloman approved and signed the letter, but she was the primary author of the document. OPR notes that Villafaña was the principal author of most correspondence in the Epstein case, and that following the signing of the NPA, regardless of whether the letter went out with her, Sloman’s, or Acosta’s signature, the three attorneys reviewed and edited drafts of most correspondence before a final version was sent to the defense.
315 Emphasis in original. Sloman also stated that the USAO did not seek to “federalize” a state plea, but “is simply informing the victims of their rights.” Villafaña informed OPR that Sloman approved and signed the letter, but she was the primary author of the document. OPR notes that Villafaña was the principal author of most correspondence in the Epstein case, and that following the signing of the NPA, regardless of whether the letter went out with her, Sloman’s, or Acosta’s signature, the three attorneys reviewed and edited drafts of most correspondence before a final version was sent to the defense.
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