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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
Pages 101–120 / 154
Page 101 / 154
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
Page 102 / 154
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
Page 103 / 154
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
Page 104 / 154
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
Page 105 / 154
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
Page 106 / 154
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
Page 107 / 154
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:RBLACK@royblack.com] 
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
Page 108 / 154
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
Page 109 / 154
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:RBLACK@royblack.com] 
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
Page 110 / 154
From: 
Sent: 
To: 
Subject: 
Roy BLACK [RBLACK@royblack.com) 
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
Page 111 / 154
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
Page 112 / 154
(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:RBLACK@royblack.com] 
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
Page 113 / 154
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
Page 114 / 154
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 <RBLACK@royblack.com> 
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
Page 115 / 154
Phone 
Fax 561 820-8777 
295 
EFTA00227185
Page 116 / 154
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
Page 117 / 154
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 <RBLACK@royblack.com> 
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:RBLACK@royblack.com] 
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
Page 118 / 154
Assistant U.S. Attorney 
500 S. Australian Ave, Suite 400 
West Palm Beach, FL 33401 
Phone IMINIIIIIMIIIIIM 
Fax 561 820-8777 
307 
EFTA00227188
Page 119 / 154
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
Page 120 / 154
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
Pages 101–120 / 154