This is an FBI investigation document from the Epstein Files collection (FBI VOL00009). Text has been machine-extracted from the original PDF file. Search more documents →
FBI VOL00009
EFTA00227071
154 pages
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From: Sent: To: Cc: Subject: oy Electronic Copy of my Fax PM lay Here is a scanned version of the fax, in case you have already left. Lefkowitz 080813008.pdf Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach FL 33401 Phone Fax 561 820-8777 259 EFTA00227171
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From: Sent: To: Are you reachable? Thanks — Jay Wednesday. August 13. 2008 4:40 PM The information contained in this communication is confidential, may be attorney-client privileged, may constitute inside information, and is intended only for the use of the addressee. It is the property of Kirkland & Ellis LLP or Kirkland & Ellis International LLP. Unauthorized use, disclosure or copying of this communication or any part thereof is strictly prohibited and may be unlawful. If you have received this communication in error, please notify us immediately by return e-mail or by e-mail to postmasterakirkland.com, and destroy this communication and all copies thereof, including all attachments. 266 EFTA00227172
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From: Sent: To: Cc: Subject: Dear Roy - e nes ay, i l l ist 1 : PM Roy BLACK Jeffrey Epstein Judge Marra has set us for a status conference tomorrow afternoon in Jane Doe v. United States. Given Judge Marra's past rulings, I anticipate that he may order us to turn over the agreement, so we need to get this issue resolved today, if at all possible. Thank you, NNW Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 Phone Ulla Fax 561 820-8777 Tracking: 267 EFTA00227173
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From: Sent: es ay, ugt. ...I.P.It To: Roy BLACK Cc: IIIIIIIIIIIPPIPIIIIIIIMIIIIINIS) Subject: Full Agreement Hi Roy — This is what I have provided to Lanna as representing the full agreement and it is what I have described in my Declaration with the Court. Epstein Agrmt001.pdf Thank you. PR IPPRIey 500 S. Australian Ave, Suite 400 West Palm Reach, FL 33401 Phone Fax 561 820-8777 272 EFTA00227174
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From: Sent: To: Subject: Roy BLACK [RBLACK©royblack coml Re Call Ok. I will call at 4:15 your time. Original Message From: To: Roy < LA < roy ac .com> Sent: 8/12/2008 3:42:04 PM Subject: Call Hi Roy tied up until 4:15. Can we call you then? Or would you like to call us? Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 Phone 561 209-1047 Fax 561 820-8777 275 EFTA00227175
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miallopmemillumpamileu From: MillaMilininin Sent: Tuesday, August 12, 2008 3:42 PM To: Roy BLACK Subject Call Hi Roy — Karen is tied up until 4:15. Can we call you then? Or would you like to call us? memonnume Assistant U.S. Attorney 500 S. Australian Aye, Suite 400 West Palm Beach, FL 33401 Phon. Fax 561 820-8777 276 EFTA00227176
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Sent: Tuesday, August 12, 2008 12:07 PM To: Roy BLACK Subject: RE: Jeffrey Epstein Hi Roy -- Can you give me a call? We need to discuss something. Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West P lm Be h F 33401 Phone Fax 561 820-8777 Original Message From: Roy BLACK [mailto:[email protected]] Sent: Monda , Au ust 11, 2008 11:40 PM To: Subject: Jeffrey Epstein Marie: I have conferred with the lawyers on the team. They all thank you for agreeing to oppose any disclosure of the 9/24/07 agreement. We firmly believe this document is not discoverable in the civil cases. However if the court rules against you on this we request that you further ask that any disclosure be subject to a strong protective order prohibiting dissemination to anyone except counsel to the petitioners. We are particularly concerned because civil lawyers are more apt to publicize something like this than those of us who litigate on the criminal side of the docket. You may recall one lawyer standing on the bridge to palm beach railing over his misconceptions of the case. This is the typical vehicle they use to get more plaintiffs. You had also asked what documents were disclosed in the state court. As part of counsels obligation to fully disclose any promises or inducements which led to the plea agreement, the 9/24/07 agreement was filed with the court. It was filed under seal. Once again I want to re-assure you that Mr. Epstein and his counsel intend to stand by their agreements. If you or anyone in the USAO have any concern about a possible breach please call or email me again so we can discuss any dispute or misunderstanding and allay any concerns. Thanks again. Roy 279 EFTA00227177
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From: Sent: Tuesday, August 12, 200811:12 AM To: Lanna Belohlavek Subject: Epstein Hi Lanna — Sorry to be a bother, but we need to file our response with the Court this week, so I really need a copy of what was filed in your case and also the procedures to obtain the transcript of the change of plea hearing. Thank you. Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 Phone Fax 56 282 EFTA00227178
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From: Sent: Tuesday, August 12: 2008 9:08 AM To: Roy BLACK Subject: RE: Jeffrey Epstein Roy, thank you for your response and your assistance. I will forward your request to Dexter Lee, who is representing the United States in the civil suit. Can you please ask Jack Goldberger to send me an exact copy of what was filed under seal in the state court? I want to insure that all of us are presenting the same packet of documents as the final agreement. Regards, Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Pal B 33401 Phone Fax 561 820-8777 Original Message From: Roy BLACK [mailto:[email protected]] Sent:aididissaiSPM To: Subject: Jeffrey Epstein I have conferred with the lawyers on the team. They all thank you for agreeing to oppose any disclosure of the 9/24/07 agreement. We firmly believe this document is not discoverable in the civil cases. However if the court rules against you on this we request that you further ask that any disclosure be subject to a strong protective order prohibiting dissemination to anyone except counsel to the petitioners. We are particularly concerned because civil lawyers are more apt to publicize something like this than those of us who litigate on the criminal side of the docket. You may recall one lawyer standing on the bridge to palm beach railing over his misconceptions of the case. This is the typical vehicle they use to get more plaintiffs. You had also asked what documents were disclosed in the state court. As part of counsels obligation to fully disclose any promises or inducements which led to the plea agreement, the 9/24/07 agreement was filed with the court. It was filed under seal. Once again I want to re-assure you that Mr. Epstein and his counsel intend to stand by their agreements. If you or anyone in the USAO have any concern about a possible breach please call or email me again so we can discuss any dispute or misunderstanding and allay any concerns. Thanks again. Roy Tracking: 283 EFTA00227179
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From: Sent: To: Subject: Roy BLACK [[email protected]) Monda A Jeffrey Epstein I have conferred with the lawyers on the team. They all thank you for agreeing to oppose any disclosure of the 9/24/07 agreement. We firmly believe this document is not discoverable in the civil cases. However if the court rules against you on this we request that you further ask that any disclosure be subject to a strong protective order prohibiting dissemination to anyone except counsel to the petitioners. We are particularly concerned because civil lawyers are more apt to publicize something like this than those of us who litigate on the criminal side of the docket. You may recall one lawyer standing on the bridge to palm beach railing over his misconceptions of the case. This is the typical vehicle they use to get more plaintiffs. You had also asked what documents were disclosed in the state court. As part of counsels obligation to fully disclose any promises or inducements which led to the plea agreement, the 9/24/07 agreement was filed with the court. It was filed under seal. Once again I want to re-assure you that Mr. Epstein and his counsel intend to stand by their agreements. If you or anyone in the USAO have any concern about a possible breach please call or email me again so we can discuss any dispute or misunderstanding and allay any concerns. Thanks again. Roy 285 EFTA00227180
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From: Sent: To: Cc: Subject: "day, ugt .ist( :)WIll RE: messages Thank you, Lanna. I think we are going to have to produce a copy of the agreement in a suit pending in the federal court, and 1 want to make sure that we are using the same document in both courthouses. Thank you again, and have a good weekend. 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 Phone Fax 561 820-8777 From: Lanna Belohlavek [mailto Sent: Friday, August 08, 2008 5:13 PM To: Villafana, Ann Marie C. (USAFLS) Subject: messages Have gotten your messages but have been swamped and am just getting out of court. I will get with you on Monday. Have a good weekend. Lanna Tracking: 269 EFTA00227181
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(USAFLS) From: Sent: To: Subject: Roy BLACK RE: Notification of Possible Compelled Disclosure of theNon-Prosecution Agreement Thank you, Roy. Your help is greatly appreciated. Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West P 33401 Phone Fax 561 820-8777 Original Message From: Roy BLACK [mailto:[email protected]] Sent: Thursday, August 07, 2008 4:34 PM To: Subject: Re: Notification of Possible Compelled Disclosure of theNon-Prosecution Agreement I am working on this and will get back to you. • • From: To: Roy Cc: Cc: roy. ac .com> Sent: 8/7/2008 3:57:52 PM Subject: Notification of Possible Compelled Disclosure of the Non-Prosecution Agreement Dear Roy: In accordance with paragraph 13 of the Non-Prosecution Agreement, I am providing notice of possible compulsory process commanding the disclosure of the Agreement. As I'm sure you know, two of Mr. Epstein's victims have filed suit against the United States alleging that the government violated their rights as victims by not consulting them prior to entering into the Non-Prosecution Agreement. As part of their response to one of the government's filings, the victims asked the Court to order the production of the Non-Prosecution Agreement. The deadline for the government to respond is August 15th and we intend to oppose the motion based upon the confidentiality provision. I have attached a copy of the victims' pleading for your review. In connection with this, we want to make certain that we are making consistent representations to the judiciary regarding the contents of the Agreement. I know 291 EFTA00227182
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that Jack Goldberger filed the Agreement under seal in the state court in accordance with the state judge's order. Can you provide us with a copy of what Jack filed, so that, if we are ordered by the federal court to disclose the agreement, it is exactly the same as what has been filed in the state court? Thank you again for your assistance. Regards, Mismegml «DE19_080801_Victims' Resp to Notice.pdf» Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach FL 33401 Phon Fax 561 820-8777 Tracking: 292 EFTA00227183
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From: Sent: To: Subject: Roy BLACK [RBLACK©royblack.com] Thursday, August 07, 2008 4.34 PM Iled Disclosure of theNon-Prosecution Agreement I am working on this and will get back to you. ri:inal Messa:e From: To: Roy BLACK <[email protected]> Cc: Cc: Sent: 8/7/2008 3:57:52 PM Subject: Notification of Possible Compelled Disclosure of the Non-Prosecution Agreement Dear Roy: In accordance with paragraph 13 of the Non-Prosecution Agreement, I am providing notice of possible compulsory process commanding the disclosure of the Agreement. As I'm sure you know, two of Mr. Epstein's victims have filed suit against the United States alleging that the government violated their rights as victims by not consulting them prior to entering into the Non-Prosecution Agreement. As part of their response to one of the government's filings, the victims asked the Court to order the production of the Non-Prosecution Agreement. The deadline for the government to respond is August 15th and we intend to oppose the motion based upon the confidentiality provision. I have attached a copy of the victims' pleading for your review. In connection with this, we want to make certain that we are making consistent representations to the judiciary regarding the contents of the Agreement. I know that Jack Goldberger filed the Agreement under seal in the state court in accordance with the state judge's order. Can you provide us with a copy of what Jack filed, so that, if we are ordered by the federal court to disclose the agreement, it is exactly the same as what has been filed in the state court? Thank you again for your assistance. Regards, «DE19_080801_Victims' Resp to Notice.pdf» Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 294 EFTA00227184
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Phone Fax 561 820-8777 295 EFTA00227185
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From: Sent: To: Cc: Subject: Dear Roy: Thursday, August 07, 2008 3:58 PM Roy BLACK Notification of Possible Compelled Disclosure of the Non-Prosecution Agreement In accordance with paragraph 13 of the Non-Prosecution Agreement, lam providing notice of possible compulsory process commanding the disclosure of the Agreement. As I'm sure you know, two of Mr. Epstein's victims have filed suit against the United States alleging that the government violated their rights as victims by not consulting them prior to entering into the Non-Prosecution Agreement. As part of their response to one of the government's filings, the victims asked the Court to order the production of the Non-Prosecution Agreement. The deadline for the government to respond is August 15th and we intend to oppose the motion based upon the confidentiality provision. I have attached a copy of the victims' pleading for your review. In connection with this, we want to make certain that we are making consistent representations to the judiciary regarding the contents of the Agreement. I know that Jack Goldberger filed the Agreement under seal in the state court in accordance with the state judge's order. Can you provide us with a copy of what Jack filed, so that, if we are ordered by the federal court to disclose the agreement, it is exactly the same as what has been filed in the state court? Thank you again for your assistance. assds DE19 .080801._yi aims' Rasp to N.. ssisar iMilirney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 Phone Fax 561 820-8777 Tracking: 296 EFTA00227186
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From: Roy BLACK [RBLACK@royblack corn) Sent: Wednesda Au ust 06, 2008 1:49 PM To: Subject: Re: Follow-up on last week's call Ok. Will do. 0 From: To: Roy BLACK <[email protected]> Cc: Sent: 8/6/2008 1:38:23 PM Subject: RE: Follow-up on last week's call Hi Roy -- Hope your trip is going well. Are you available today at 4:30 Eastern (1:30 Pacific)? If so, please call my office at the number below, and Karen and I can both be reached there. Thank you. Assistant . . Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 Phone 561 209-1047 Fax 561 820-8777 Original Message From: Roy BLACK [mailto:[email protected]] Sent: Tuesda Au us 2 To: Cc: Subject: Re: Follow-up on last week's call Marie I just got back to my computer. Sorry it took awhile to respond. I am available tomorrow to call you. Let me know what time to call. Remember I am 3 hours behind you so email me the time in the am and I will call. Thanks Roy >> > 08/ : >>> Hi Roy - Are you available late this afternoon to do a follow-up on last week's call? If today does not work, can you let us know about your availability tomorrow, as well? Thank you. 306 EFTA00227187
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Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 Phone IMINIIIIIMIIIIIM Fax 561 820-8777 307 EFTA00227188
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From: Sent: To: Cc: Subject: Roy BLACK (RBLACK@royblack corn] e: o ow-up on as wee 's call Marie I just got back to my computer. Sorry it took awhile to respond. I am available tomorrow to call you. Let me know what time to call. Remember I am 3 hours behind you so email me the time in the am and I will call. Thanks Roy >> > 08/05/08 1:01 PM >>> Hi Roy - Are you available late this afternoon to do a follow-up on last week's call? If today does not work, can you let us know about your availability tomorrow, as well? Thank you. Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 Phone Fax 561 820-8777 313 EFTA00227189
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From: Sent: Tuesday, August 05, 2008 3:29 PM To: Lanna Belohlavek Subject: Question re Epstein Hi Lanna — Sorry to bother you, but a question has come up over here. I know that you filed the Non- Prosecution Agreement with the United States. Did you file the version that I emailed to you (the three-part agreement) or a different version? Thank you. Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West PM1103401 Phone Fax 561 820-8777 318 EFTA00227190