Epstein Data Wiki

Jay Lefkowitz

Properties2
tagsperson, attorney, kirkland-ellis, usao-sdfl, department-of-justice, non-prosecution-agreement, sora, cvra, legal-fees, press, 2007, 2008, 2010, 2011
aliasesJay P. Lefkowitz, Jay P. Lefkowitz, P.C.

81 min read

Firm and role in the record”Jay P. Lefkowitz, P.C.”, Kirkland & Ellis LLP, New York; counsel to Jeffrey Epstein12
Described by the Department’s own reviewers as”a litigation partner who had served in high-level positions in the administrations of” two Presidents, who with Kenneth Starr “contacted the USAO on Epstein’s behalf” in August 20072
What this page is aboutThe written campaign he ran between August 2007 and June 2008 to move Epstein’s case out of the hands of the line prosecutors in West Palm Beach and up through the Department of Justice, and the answers the government sent back; and the work that followed it, from the 2010-11 New York sex-offender proceeding to the press letters of 2010-11, the fees, and an engagement the record still shows in 2018345678
The correspondence fileA 52-page run in the release holds the exchange with the U.S. Attorney’s Office from 10 October to 26 December 2007: his letters of 10 October, 29 November, 11 December, 21 December and 26 December, a 5 December letter signed by Kenneth Starr and by him, and the office’s replies191011121314
How the office recorded himIts own file folders were titled by his name — “11/8/07 Lefkowitz to Sloman”, “11/13/07 Sloman to Lefkowitz (was this sent?)”, “12/21/07 Lefkowitz to Acosta”, “Draft ltr from Sloman to Lefkowitz re termination” — and were withheld from the victims in 2013 as privileged1516
The ladder, as the defence later described itAssistant Attorney General, Criminal Division (28 November 2007); the Child Exploitation and Obscenity Section (January – 15 May 2008); the Office of the Deputy Attorney General (May – June 2008)45
The government’s answer23 June 2008, by email to him: “the Deputy Attorney General has completed his review of the Epstein matter and has determined that federal prosecution of Mr. Epstein’s case is appropriate”, with a deadline of 30 June for the guilty plea17
After the federal caseCounsel of record for Epstein at the New York sex-offender hearing of 18 January 2011 and on the appeal from it; a limited intervenor in his own name in the victims’ CVRA case from 2011; the addressee of Kirkland’s invoices, of the victims’ attorney representative’s invoices, and of a crisis-communications firm’s1819202122
What the firm charged$895.00 an hour in 2009 and $995.00 in 2011; one Kirkland invoice for the period ending 31 May 2011 comes to $172,620.00. Asked under oath in March 2010 what he had paid Lefkowitz, Epstein answered “More than a hundred thousand dollars”232024
Not established hereAnything he said in any meeting or telephone call except as another party’s letter records it; the contents of the material the government withheld as privileged; whether the drafts the office filed under his name were ever sent

Jay P. Lefkowitz is a Kirkland & Ellis partner who acted for Jeffrey Epstein from 2007. The Justice Department’s Office of Professional Responsibility records that in August 2007, “immediately after the USAO offered the terms that ultimately led to the NPA, two attorneys from the firm of Kirkland & Ellis, one of the largest law firms in the country, contacted the USAO on Epstein’s behalf: Kenneth Starr… and Jay Lefkowitz, a litigation partner who had served in high-level positions in the administrations of Presidents [redacted] H.W. Bush and [redacted] W. Bush.”2 What follows is that approach as the paper records it: who wrote to whom, on what date, and at what level of the Department. It then follows the engagement past the federal case, into a New York registration proceeding, a fee file, a press campaign and a set of court papers he filed in his own name.

The non-prosecution agreement itself, the June 2008 submission to the Office of the Deputy Attorney General and the U.S. Attorney’s own conduct are held on other pages and are not retold here. This page is the correspondence, from the defence side, and what the same lawyer did for the same client afterwards.

Nothing set out below is a finding of wrongdoing. Lefkowitz was defence counsel, and the letters are advocacy for a client; where the record holds the government’s answer to something he wrote, the answer is printed beside it.

August and September 2007: the terms of an appeal are agreed in advance

The earliest account of how the campaign began is the U.S. Attorney’s own, in a letter of 4 December 2007 to Kenneth Starr. “In mid August 2007,” Acosta wrote, “your defense team, dissatisfied with my staff’s review of the case, asked to meet with me. Mr. Lefkowtiz [sic] indicated your busy schedule, and asked me to put off until September 7, 2007, so that you could attend. Mr. Lefkowitz also indicated that he might appeal my decision to Washington D.C., if my decision was contrary to his client’s interest. I agreed to the September 7th meeting, despite the fact that our AUSA had an indictment ready for presentation to the grand jury. An explicit condition of that agreement, however, was an understanding between Mr. Lefkowitz and myself that any appeal to Washington would be undertaken expeditiously.”25

The same letter records what happened at and after that meeting. Acosta, his First Assistant, Assistant U.S. Attorneys whose names are blacked out and FBI agents met the defence on 7 September 2007; “During the September 7th meeting, your co-counsel, Mr. Lefkowitz, offered a plea resolution.”25 After the meeting the office decided to indict, and, Acosta wrote, “I reminded Mr. Lefkowitz that he had previously indicated his desire to appeal such a decision to the Attorney General, the Deputy Attorney General, or the Assistant Attorney General for the Criminal Division, and I offered to direct our prosecutors to delay the presentation of the indictment to allow you or he to appeal our decision if you so chose. He decided not to do so.”25 The agreement was signed instead, on 24 September 2007.14

Three days later Lefkowitz was negotiating with the line prosecutor, A. Marie Villafaña, over the lawyer the agreement required Epstein to pay for on the victims’ behalf. Villafaña had forwarded four questions raised by Bert Ocariz, the lawyer then under consideration for that role, and his firm. Lefkowitz answered each in turn: to “Can we get a copy of the indictment (or can you tell me the nature of the crimes against the girls)?” he wrote “Certainly he should not get a copy of any indictment”; to a request to see the plea agreement, “I don’t think he should get the plea agreement either”; and he closed, “In any event, I need to consider these issues carefully and I cannot agree to any of these issues before we speak.”26 Villafaña replied the same day: “Hi Jay — I already told Bert that there is no indictment and, as I mentioned, he doesn’t really need to/want to see the entire plea agreement, just the relevant paragraphs so that he understands what the scope of his representation will be… The concern is, if all 40 girls decide they want to sue, they don’t want to be in a situation where Mr. Epstein says this is getting too expensive, we won’t pay any more attorneys’ fees.”27

October to December 2007: the letters to the U.S. Attorney

A 52-page run in the release holds the exchange that followed, letters and replies interleaved in date order.28 It does not hold everything: the breakfast Lefkowitz and Acosta had in West Palm Beach on 12 October 2007, and the letter of 23 October 2007 in which Lefkowitz set out what he said Acosta had assured him there, are described on Acosta’s page from the Office of Professional Responsibility’s account and are not repeated here. Every one of the defence letters in it is addressed not to the prosecutors handling the case but to the U.S. Attorney personally, and opens “Dear Alex”.191112

The first, of 10 October 2007, is headed “Confidential. For Settlement Purposes Only, Pursuant to Rule 408.” It opens: “I write as a follow up to our conversation yesterday regarding the open issues that remain in the Epstein matter. As you are aware, we continue to have serious disagreements with Ms. [redacted] regarding the nature of the settlement process for identified individuals’ § 2255 claims.”1 Its argument is that the agreement’s attorney representative existed only to settle claims, not to litigate them: “If the identified individuals cannot settle or opt not to settle on a damages amount with Mr. Epstein, then the attorney representative may not continue his representation and is barred from filing lawsuits pursuant to § 2255…”29 It proposes a joint communication to Judge Edward Davis, the judge the parties had agreed on; the text it proposes ends: “The details regarding the United State’s investigation of this matter and its resolution with Mr. Epstein is confidential. You may not make public statements regarding this matter. If you have any questions regarding this matter, including the settlement process, you must contact Mr. Epstein’s counsel and request a joint clarification from said counsel and the United States. You should not contact the United States directly. The parties will make every effort to answer your questions via a joint communication.” It then asks Acosta for an assurance “that after you and I agree to the issues raised in this letter, that it will be the end of the United States’ involvement barring a willful breech of the Agreement. Specifically, the government or any of its agents will not make any further communications to the identified individuals and will not make any ex parte communications with Judge Davis.”30 The line prosecutor’s surname is blacked out at every occurrence in this copy of the 10 October letter, whose six pages were all read at the image.

The 29 November 2007 letter answers a draft of the letter the office proposed to send to the women it had identified as victims. Lefkowitz objected to it in eight numbered points: that it implied Epstein had waived liability whether or not a claim settled; that there was “no basis to refer to Mr. Epstein as a ‘sexual predator’” as against “sexual offender” under Florida law; that the recipients had no right to appear at the state sentencing; that the term “minor victim” was “notably absent from the Agreement” and that “To confer on these women the imprimatur of a government ‘finding’ is both incendiary and unwarranted”; that the letter mischaracterised the reach of the civil remedy; that the lawyers named in it might not accept the role; that “the identified individuals should not contact lawyers in your Office or agents of the FBI”; and that the letter should be mailed rather than hand-delivered.93132 It ends by disclosing the first step over the U.S. Attorney’s head: “Finally, as you know, Judge Starr has requested a meeting with Assistant Attorney General Fisher to address what we believe is the unprecedented nature of the § 2255 component of the Agreement… Accordingly, we respectfully request that we postpone our discussion of sending a letter to the alleged victims until after that meeting.”32 A handwritten signature mark stands over the printed name at the foot.32

Three further letters followed in December: one of 11 December 2007 setting out the defence’s objections to the civil-remedy provisions at length; one of 21 December 2007 responding to Acosta’s proposed modifications, which describes “the problem of integrating in an unprecedented manner what is at its core a $150,000 minimum lump sum damage federal civil statute… into a federal deferred/non-prosecution agreement that requires pleas of guilty to state criminal offenses”; and one of 26 December 2007 answering two questions Acosta had put to him, in the letter’s words, “during a conversation we had late last week”, on victim notification and on the civil-remedy language.331112 Parts of the December letters argue about individual women on the government’s list, quoting from depositions taken in the civil cases; that material is not reproduced or located here.

What the office wrote back

The office’s reply of 6 December 2007 is in the same run, on Justice Department letterhead, “Dear Jay”. It is signed by the First Assistant United States Attorney, whose name is blacked out under the signature, beneath the printed lines “R. Alexander Acosta / United States Attorney”; a folder on the office’s 2013 privilege log is titled “12/6/07 Sloman to Lefkowitz”, and is logged as containing not that letter but the 5 December one.3416

It answers each objection and concedes some of them. On the label: “We also have no objection to referring to Mr. Epstein as a ‘sexual offender’ rather than a ‘predator.’”35 On the description of the civil remedy: “I have asked AUSA [redacted] to simply quote the terms of the Agreement directly into the Notification Letter.”35 And on hand delivery: “We have no objection to sending the letters through the mail…” A footnote to that sentence makes the concession “contingent, however, on being able to provide adequate notice of the change of plea and sentencing”, and the sentence itself runs on into a refusal set out below.36 Others it rejected. On the assertion, as the office put it, “that we are seeking to ‘federalize’ the state plea”: “our office is simply informing the victims of their rights. It does not command them to appear at the hearing or to file a victim impact statement.”35 On the objection that the two lawyers named in the letter might not accept the role: “The letter’s assertions regarding representation by the Podhurst firm and Mr. Josefsberg are accurate. Judge Davis conferred with Messrs. Podhurst and Josefsberg to insure their willingness to undertake this assignment prior to finalizing his selection.”35 On the wording of the notification letter, including the characterisation the 29 November letter’s fourth objection had attacked, it wrote in one continuous passage: “We will not include the language that we take no position as to the validity of any claims. While the Office has no intention to take any position in any civil litigation arising between Mr. Epstein and any individual victim, as stated above, the Office believes that it has proof beyond a reasonable doubt that each listed individual was a victim of Mr. Epstein’s criminal conduct while the victim was a minor. The law requires us to treat all victims ‘with fairness and with respect for the victim’s dignity and privacy.’ 18 U.S.C. § 3771(a)(8). We will not include any language that demeans the harm they may have suffered.” It would not remove the prosecutor’s and case agent’s names from the notification letter either: “Again, federal law requires that victims have the ‘reasonable right to confer with the attorney for the Government in this case.’”3536

It also answered, flatly, an allegation the defence had made about press leaks: “Next, let me address your allegation that attorneys in our office and agents of the FBI have leaked information to the press in an effort to affect possible civil litigation with Mr. Epstein. This is untrue.”37 And it disputed the account of the delay, listing the postponements and adding: “Mr. Epstein currently has four Florida Bar members on his defense team, so attorney scheduling is not an adequate basis for delay.”1037 It ends: “please provide us with a definitive statement, signed by your client, of his intention to abide by each and every term of the Agreement by close of business on Friday, December 7, 2007… There must be closure in this matter.”36 See Alex Acosta for the parallel ultimatum sent to Starr on 30 November 2007, and Jack Goldberger for the state plea the deadline concerned.

Acosta’s own answer, on 19 December 2007, addressed to another member of the defence team, recorded that his prosecutors “asked me several weeks ago to declare the Agreement in breach because of those delays. I resisted that invitation. I share this fact because it is background to my frustration with what appears to be an 11th hour appeal, weeks before the now scheduled January 4th plea date.”14 Then: “This said, the issues raised are important and must be fully vetted irrespective of timeliness concerns… I spoke this past Monday with the Assistant Attorney General Fisher, to inform her of a possible appeal, to ask her to grant the potential request for review, and to in fact review this case in an expedited manner to attempt to preserve the January 4th plea date.”14 The letter is copied to “Alice Fisher, Assistant Attorney General”, to the First Assistant, and to the line prosecutor.14 In the earlier 4 December letter Acosta had put the same position more bluntly: “Although it happens rarely, I do not mind this Office’s decision being appealed to Washington, and have previously directed our prosecutors to delay filings in this case to provide defense counsel with the option of appealing our decisions.”3

November 2007 to June 2008: up the Department

Lefkowitz set out the whole escalation himself eighteen months later, in a letter of 19 June 2009 answering the office’s charge that Epstein had breached the agreement by delay. His timeline, with exhibits attached to it, opens with the agreement itself, “signed on September 24, 2007” and requiring Epstein to “begin serving his sentence not later than January 4, 2008”, and then runs:45

  • 28 November 2007. “Mr. Epstein’s defense counsel contacted Assistant Attorney General Alice Fisher to request a review of certain provisions of the NPA. We informed the USAO of this request the very next day in a letter to Mr. Acosta.”4
  • 4 December 2007. Acosta’s letter stating that he supported the appeal to Washington.4
  • 11 December 2007. “Pursuant to Mr. Acosta’s request, the defense team sent him submissions detailing the defense’s concerns related to the NPA.”5
  • 14 December 2007. “Mr. Acosta met with members of the defense team to discuss the serious issues raised about the NPA.”5
  • 19 December 2007. Acosta’s letter, and his statement in it that he had spoken with the Assistant Attorney General.5
  • January 2008. “Mr. Acosta and I discussed the need for further consideration of the issues raised by the defense. He postponed the plea and sentencing until the Child Exploitation and Obscenity Section (CEOS) was finished with its review of the case.”5
  • 29 February 2008. An email from Lefkowitz to Acosta, and the First Assistant’s reply the same day: “Please be assured that it has not, and never has been, this Office’s intent to interfere or restrict the ‘review process’ for either Mr. Epstein or CEOS. I leave it to you and CEOS to figure out how best to proceed and will await the results of that process.”5
  • 15 May 2008. CEOS’s decision, which in the defence’s account “left open the need for a more thorough review of critical issues by others at the Justice Department.”5
  • 28 May 2008. An email from the First Assistant to Lefkowitz that “further postponed the deadline to plead until the Deputy Attorney General’s Office (DAG) completed its review.”5

The step to the Deputy Attorney General himself is documented from the other side of the correspondence. On 19 May 2008 Kenneth Starr and Joe D. Whitley wrote jointly to Mark Filip in the Office of the Deputy Attorney General, asking “for a review of the federal involvement in a quintessentially state matter involving our client, Jeffrey Epstein,” and arguing that the Criminal Division’s review had been too narrow.38 The letter names Lefkowitz once. Where it alleges that “Federal prosecutors then leaked highly sensitive information about the case to a New York Times reporter,” a footnote adds: “One of the other members of Mr. Epstein’s defense team, Jay Lefkowitz, has personally reviewed the reporter’s contemporaneous notes.”39 That allegation is the defence’s; the office had denied the underlying charge in writing six months earlier.37 Nothing cited here records a response by the individual prosecutor the May 2008 letter names, and this page does not name him.

The release also holds the firm’s own answer to a letter the district’s First Assistant sent Lefkowitz on the same date, and it disputes the account of how the appeal to Washington began. It is a ten-sheet document headed “Response to Letter by FAUSA [redacted] Dated May 19, 2008”, set out as a table: under each numbered heading it prints “Mr. [redacted] Letter:” with a quotation from that letter, and then, under the heading “The Truth:”, what the defence says happened. It opens: “In a May 19, 2008 letter to Jay Lefkowitz (See Tab 1), SDFL First Assistant U.S. Attorney Jeffrey [redacted] provided what purported to be a summary of the events that have occurred during the investigation of Mr. Epstein. Mr. [redacted] letter is fraught with inconsistencies, false and misleading characterizations and outright falsehoods.”40 The document carries no date of its own, and its last sheet ends three lines into a paragraph and is otherwise blank: no signature, no signature line, no signature block. Whether it was sent, and to whom, is not established by it.41

Its fifth heading is “WAIVER OF APPEAL TO ASSISTANT ATTORNEY GENERAL FISHER.” The government’s letter, as the firm quotes it, said that “[T]he SDFL provided you with 30 days to appeal the decision to the Assistant Attorney General of the United States Alice Fisher” and that “you chose to forego an appeal to AAG Fisher.” Under “The Truth:” the firm answered: “Mr. Acosta tolled an August 17 deadline, acknowledging that there were ‘serious issues’ about the case that needed to be discussed, and scheduled a meeting with the defense for September 7, 2007. At the September 7, 2007 meeting, with Drew [redacted] in attendance, the government dismissed the defense’s objections and set a September 21, 2007 deadline to finalize a non-prosecution agreement or the defense would face an already-drafted 53-page indictment, purportedly identifying 40 minors, with a guideline range of 188 months.” The bullet after it says the defence negotiated the agreement “without the claimed offer of the right to raise objections in an appeal to AAG Fisher”.42

That is a dispute of fact, on the record, about the step this page is otherwise made of. The government’s position in May 2008 was that a thirty-day route of appeal to the Assistant Attorney General had been offered in 2007 and not taken. Acosta had put a version of the same point to Starr six months earlier, in the 4 December 2007 letter quoted above: he had reminded Lefkowitz of his stated wish to appeal and “offered to direct our prosecutors to delay the presentation of the indictment to allow you or he to appeal our decision if you so chose. He decided not to do so.”25 The firm’s answer is that the choice was made under a threatened indictment and without the offer the government describes. This page does not carry a reply from the government to that answer. The Assistant Attorney General’s own part in the review is at Alice Fisher.

The office was writing to Filip’s office too. Its file folder “6/3/08 Sloman Submission to the DAG”, 131 Bates numbers for the letter and its attachments together, contained a “6/3/08 letter from J. Sloman to Mark Filip, Office of the DAG” with “relevant attachments” and was withheld from the victims in 2013 as attorney-client privileged, deliberative process, work product and investigative privilege.43 The defence’s own principal submission followed on 20 June 2008; it is held at Submission to the Deputy Attorney General.

23 June 2008: the answer, and where it came from

The campaign had run from the line prosecutors to the U.S. Attorney to the Criminal Division to the Deputy Attorney General. The answer came back from West Palm Beach.

At 5:55 p.m. Eastern on Monday 23 June 2008 (a second copy of the same message carries an RFC date header with an explicit +0000 offset, 21:54:57 UTC) an Assistant U.S. Attorney in the office’s West Palm Beach branch, whose name is blacked out above the signature line “Assistant U.S. Attorney”, emailed Lefkowitz:4417

Dear Mr. Lefkowitz:

I understand that the Deputy Attorney General has completed his review of the Epstein matter and has determined that federal prosecution of Mr. Epstein’s case is appropriate.

Accordingly, Mr. Epstein has until the close of business on Monday, June 30, 2008, to comply with the terms and conditions of the agreement between the United States and Mr. Epstein (as modified by the U.S. Attorney’s December 19th letter to Ms. Sanchez), including entry of a guilty plea, sentencing, and surrendering to begin his sentence of imprisonment.44

The two copies of this message cited here do not carry the same redactions, and the wording above is quoted from the second.17 Epstein pleaded guilty in state court on 30 June 2008.45

2009: the office’s “continuing pattern”, and his answer

A year later the correspondence resumed as a dispute about breach. On 15 June 2009 the office wrote to Lefkowitz, Roy Black and Goldberger over the printed name of Acting U.S. Attorney Jeffrey H. Sloman, signed by an Assistant U.S. Attorney whose name is blacked out: “I would like to address what appears to be a continuing pattern in this matter. There have been several instances of breaches by Mr. Epstein of the letter and spirit of the Non-Prosecution Agreement, including the implied duty of good faith and fair dealing.”46 Among the instances listed was the delay itself: “After several appeals were made throughout the Department of Justice resulting in a nine-month delay, the U.S. Attorney’s Office had to remind Mr. Epstein of his obligation to provide a copy of the plea agreement with the State Attorney’s Office…”46

Lefkowitz answered on 19 June 2009, in a letter whose addressee’s name is blacked out: “We respectfully submit (and support through documentary evidence) that there have been no past breaches of the NPA. There have been no ‘willful’ breaches of the NPA. There has been no pattern of breaches of the NPA.”45 On the nine months specifically: “The date of entry of the state plea was deferred with the express written consent of United States Attorney Acosta, who recognized and expressly provided us with the opportunity to pursue an independent assessment of this matter by the Justice Department. The subsequent nine-month ‘delay’ was a direct result of the Justice Department’s determination that it was appropriate to convene an intense and time-consuming review. Thus, the delay was not dictated at all by Mr. Epstein, but instead, by the review process agreed to and, if you recall, initiated by Mr. Acosta.”45 It is that answer the timeline above was written to support. Jack Goldberger carries the rest of the same exchange.

2010 and 2011: New York, and the sex-offender register

The next stretch of the record is not federal. Under New York’s Sex Offender Registration Act a person convicted elsewhere is assessed by the Board of Examiners of Sex Offenders and given a risk level by a justice of the Supreme Court. For Epstein the Board recommended the highest of the Act’s three levels. Kirkland & Ellis argued for the lowest, and the New York County District Attorney’s Office asked the court for less than the Board had recommended. The court refused them both. That proceeding has its own page at Ruth Pickholz, which carries the hearing and the order; this section is his part in it, and the papers on either side of it.

On 5 October 2010 a Kirkland & Ellis memorandum marked CONFIDENTIAL went to three named Assistant District Attorneys of that office: the Chief and the Deputy Chief of its Sex Crimes Unit, and a third from the Sex Crimes Bureau and Trial Bureau 40. It is over three names, his first: “Jay P. Lefkowitz, P.C.”, then Matthew Solum, then Sandra Lynn Musumeci. Its case is that “Jeffrey Epstein, a 57-year old financial advisor and philanthropist who is required to register by virtue of a single conviction for a prostitution-related offense, who maintains his primary residence in Florida but owns a vacation home in Manhattan, and who has never before been convicted of a crime, clearly belongs in this latter category.”6

The section headed “Degree of Harm to Society” opens: “Without minimizing the seriousness of the offenses to which Jeffrey Epstein pleaded guilty in Florida, it must be noted that Mr. Epstein’s crimes did not inflict any actual harm on his ‘victims,’ and when considering the range of reportable sex offenses under SORA, imposed relatively minimal harm on society at large.” The quotation marks around the word victims are the memorandum’s own. It calls the conduct “consensual”, and says of the complainant, whom it identifies by two initials and whom this page does not identify at all, that she came to the house “for the purpose of participating in what she apparently viewed as a lucrative business transaction”.47 Against the Board it sets Florida’s own treatment, which it says imposed “the most minimal of reporting requirements”, New Mexico’s determination “that it will not require Mr. Epstein to register at all”, and a named clinical psychologist’s opinion that “the probability of his reoffending is negligible”.48

The copy in the release is a working draft and says so on its face. Three questions to the drafting team stand in the running text in bold brackets: “[Do we have the letter from Ms. Chacon in NM Department of Public Safety?]”, “[Is Epstein required to register in US Virgin Islands? What is the status of that?]” and “[when did JE begin with therapy?]”.48

The hearing came on 18 January 2011, in Part 66 at 111 Centre Street. The appearance is his: “MR. LEFKOWITZ: Jay Lefkowitz and Sandra Musumeci for Mr. Epstein.” His client was not there. “THE COURT: Mr. Epstein is not here.” “MR. LEFKOWITZ: That’s correct.” The court asked whether the appearance was waived, and he waived it.18

What followed was not an ordinary contested hearing. The Assistant District Attorney appearing for the People told the court that the People could not rely on the Florida probable-cause affidavit, “because in Florida of all of the victims in that probable cause affidavit, they actually only went forward on one case”, and that under the Board’s own interim guidelines “if an offender is not indicted for an offense, it is strong evidence that the offense did not occur” - a sentence the court cut off before she finished it: “Do you find that if somebody is not indicted it is strong evidence that it did not occur?”1849 The court went on to say that it was “a little overwhelmed because I have never seen the prosecutor’s office do anything like this.”49

Musumeci then argued the residence point: “The first is that Mr. Epstein is not a resident of New York, unlike most of these out of state, he has not changed his address and moved to New York, he maintains a vacation home in New York. His primary residence is the U.S. Virgin Islands.”50 The memorandum of 5 October over his own name had said that Epstein “maintains his primary residence in Florida”.6 Both statements are in the record, from the same team, and this page does not reconcile them.

When the People described the conduct, the court answered in four words. The Assistant District Attorney said the complainant “gave him approximately 15 massages, including with sexual contact, and ultimately when she is 17 had intercourse with him.” The court: “She is a child.” Musumeci answered that under SORA “prostitution offenses are only registrable when in fact by clear and convincing evidence the women or victim is 17, is under 17”, and, pressed on the guilty plea, that “He plead guilty to under 18, which is the law in Florida, which is a different standard than what the law is in New York.”51

The court read the Board’s scoring aloud, finished “They gave him 130 points, which is the highest level, and I agree with that”, and then heard him. “MR. LEFKOWITZ: If I could be heard for one moment. It appears that the state board made its determination based on access to a police report in Florida. The prosecutor, the lead prosecutor, the lead sex crimes prosecutor in Palm Beach made a determination that the complainants and the police report itself was not credible and decided not to prosecute on the basis of all of that. In addition, there has been through the course of the last few years some civil litigation, as you might imagine, involving these matters and we now have sworn testimony in evidence from the complainants themselves disclaiming much of what appears in the police report.”52 He finished on the next sheet: “So, Your Honor, we would submit and this is not to make light in any way of the conduct what Mr. Epstein did or what Mr. Epstein plead guilty to, but with respect to everything and that is why Mr. Epstein voluntarily registered in New York even though there is a question about whether he has any obligation just as a jurisdictional matter, but Your Honor, with respect to the appropriate level for him to register, we would submit Your Honor that the evidence simply does not support the foundation of the state’s determination.”53

The court’s whole answer was three sentences: “You have made a very clear record and you have your right to appeal. I feel the board looked into all of this, made their recommendation, found him to have 130 points and I see no reason to disturb that. Thank you.”53

A preargument statement dated 24 January 2011 followed, over the printed names “Jay P. Lefkowitz, P.C.” and “Sandra Lynn Musumeci” beneath a rule that carries no mark of any kind on this copy. Its stated ground is that the designation “was an abuse of discretion and constituted reversible legal error, as the District Attorney’s Office agreed that there was not clear and convincing evidence to support a Level 3 designation.”54

Six months later the appeal reached back into the federal file, and it reached the line prosecutor. On 29 July 2011, over his name and Martin G. Weinberg’s, a letter marked CONFIDENTIAL went by facsimile to A. Marie Villafaña, answering a letter of hers of 27 July about a request from the New York District Attorney for copies of the non-prosecution agreement and the “victim list”. It argues that disclosure would breach the agreement’s confidentiality and Rule 6(e), and quotes her own filings back at her: “in paragraph 6 of Document 14, your own Declaration, you stated that the NPA contained ‘an express confidentiality provision.’” Then it gives its reason: “The New York Assistant District Attorney, Ms Morse, is representing the prosecution in an appeal regarding a sex offender registration determination, and any disclosure of the NPA to her has the potential to result in its use in that appeal and the real risk that the appellate court will unseal it.”55 It closes: “We both believe that confidentiality applies to the requested information. We believe that any non-compulsory handover of the list or NPA is inconsistent with the positions you have previously taken in related litigation. Accordingly, we request that you reconsider and decline the request of the New York District Attorney.”56 Whether the office declined it is not in anything cited here, and searching the release for the letter itself returns thirteen documents, all of them copies of it.57

2011 and 2012: an intervenor in the victims’ case, in his own name

In the CVRA case the two women had brought against the United States, the correspondence he wrote in 2007 became the thing being fought over. In 2011 he stopped being a subject of that case and became a party to it.

He, Roy Black and Martin Weinberg moved for “limited” intervention “for the purpose of seeking a protective order” and for the chance to answer the petitioners’ motion for disclosure of correspondence the three had written. The government’s later account records what they told the court: “Attorneys Black, Weinberg, and Lefkowitz do not seek intervention to litigate whether the [CVRA] was violated and if so, against whom a remedy is appropriate”, and that “District Judge Marra granted the attorneys’ motion, allowing limited intervention to ‘assert[] a claim that the documents in question may be privileged’”.7

Their reply in support, filed on 12 May 2011 under the caption “REPLY IN SUPPORT OF MOTION TO INTERVENE OF ROY BLACK, [redacted] WEINBERG, AND JAY LEFKOWITZ”, says the two women “are mistaken” in thinking they already hold the letters: counsel had spoken to one of their lawyers, “and he confirmed that he and his clients do not have any of the negotiation and settlement letters prepared by the defense attorneys.”58 Its first heading is “COLORABLE CLAIMS OF PRIVILEGE ARE A TEXTBOOK EXAMPLE OF AN ENTITLEMENT TO INTERVENTION AS OF RIGHT”, a phrase it takes from a Southern District of Florida decision it quotes beneath it.59 It argues that the letters are protected under Rule 6(e) as well: “To put in the hands of an adversary who was not involved in the settlement negotiations correspondence that by its nature includes a [redacted] discussion of the nature of the grand jury’s investigation is to upset the expectations of confidentiality possessed by prosecutors and defense counsel who regularly engage in [redacted], open discussions of such matters without apprehension that their discussions will end up in the hands of litigants seeking to exploit them for purposes extrinsic to Federal Rule of Evidence 410.”60

At a hearing before Judge Marra on 12 August 2011 Roy Black announced himself “on behalf of the intervening lawyers, Black, Weinberg and Lefkowitz”; nothing in that transcript places Lefkowitz in the room.61 By the next spring the court’s own docket carried him as a party in his own right: the electronic filing notice for a reply of 23 April 2012 lists the filers as “Roy Black”, “Jeffrey Epstein”, “Jay Lefkowitz” and “Martin G. Weinberg”, and describes the paper as filed by “Intervenors Black, Weinberg and Lefkowitz”.19 On 6 June 2012 a motion to strike was filed by “limited intervenors Jeffrey Epstein and attorneys Black, Weinberg, and Lefkowitz”.62

They lost. The government’s memorandum records that “The document privilege issue was later resolved by the district court in favor of Petitioners (DE188), and the attorneys appealed (DE194, DE196). The Eleventh Circuit affirmed the district court’s ruling on the merits”, reported at 749 F.3d 999 (11th Cir. 2014). In the same memorandum the government could write: “The attorneys’ issue has, thus, been completely resolved, and they have no issue or claim left to ‘settle.’” At a status conference on 28 March 2016 Weinberg agreed the three need not take part in the court-ordered settlement conference, and the United States agreed with him.7

2010 and 2011: the press

The same years hold a second line of work, and the record for it is unusually full because two of the firms doing it billed for it.

On 23 September 2010 he wrote to Tina Brown, then editor of The Daily Beast, by hand delivery and courier. The letter asks her “to review both the accuracy of a series of past articles originating with The Daily Beast, each authored by one of The Daily Beast’s contributing writers, [redacted], and the appropriateness of The Daily Beast’s publication of any further articles about Mr. Epstein.” It asks her to determine “whether the intensity of repetitive articles is appropriate”, states that “Mr. Epstein has completed his state sentence for events that occurred over five years ago” and that “There have been no allegations of any improper conduct since the fall of 2005”, and, on the stated ground that the articles “contain provably untruthful inaccuracies and omissions of material fact”, asks her “to defer any future articles authored by Ms. [redacted] about Mr. Epstein until such a time as you can review the articles, and meet with us to discuss the subject matter.” The writer’s name is covered at each of the three places it appears on that sheet and is not taken from this document.63

On 7 March 2011 he opened a channel to a reporter who had been asking about Epstein: “Dear Ms. Wolfe, I understand you have some questions about my client, Jeffrey Epstein. Given that much of the press coverage surrounding Mr. Epstein has been inaccurate and in some instances, defamatory, I would like to suggest that you send me any facutal questions so that I can provide you with accurate responses. I am also available to speak with you.” The misspelling is the sheet’s.64 Her reply that afternoon sets out the questions she wanted put, among them whether Epstein was “still close with Ghislaine Maxwell”, whether his business was “still at $15 billion”, whether he “still work[ed] while in prison”, and whether he was “continuing the charity initiatives he started with Bill Clinton, etc”. He forwarded the exchange to Epstein, to Darren Indyke and to Martin Weinberg.65

The next day he was in a three-way exchange with Epstein and the crisis-communications consultant Michael Sitrick. Sitrick: “I know the new editor of Newsweek, but am not sure how much we can do with this. We could point out the VR situation, not for attribution. But since we are kind of flying in the dark on this article, it’s hard to tell where she is going. Sarah Ferguson is really fueling this, as demonstrated on The Today Show. Jay - do you have our statement?” Epstein: “I believe she intends to write that the govt is going to open an investigation,, we think highly unlikely,, but makes for a good story”. Sitrick again, in the message at the top of the sheet: “I will give Jay a call. Just spoke with defamation lawyer friend who said it depends on what you pled to - specifically- and what the conviction says.” His own line in the chain is one sentence and an instruction: “Correct. See my emails.”66

Sitrick’s firm afterwards fell out with Epstein over its fee, and its lawyers wrote to Black and to Lefkowitz on 12 July 2011 setting out how the engagement had begun. “In early March of this year, your client Jeffrey Epstein called Michael Sitrick to ask for his and his firm’s help in stemming a tsunami of negative publicity resulting from a photograph of Prince Andrew and Mr. Epstein walking in Central Park. The focus of the publicity, as you are aware, was that Prince Andrew was friends with Mr. Epstein who the British press called a pedophile. Mr. Epstein said this was not only disturbing, but threatening the viability of his business.” Then: “At the onset of this engagement, Mr. Sitrick asked if he should have Black Srebnick sign a new engagement letter. As you know, the Black Srebnick firm signed the 2005 letter (which by the way was never terminated and therefore is still in effect). Mr. Epstein responded that the letter should be sent to Jay Lefkowitz of Kirkland & Ellis. On March 11, Mr. Sitrick sent Mr. Lefkowitz a copy of Sitrick And Company’s standard engagement letter.” It adds: “(You both were involved in the work that Sitrick did and were part of many, many email chains reflecting same.)”67

The letter runs to three sheets, and the two after the first are about the work being stopped and about the money. On its second sheet the firm says its client’s account of the case did not match counsel’s: Sitrick and his team “believe they would have been able to do a great deal more — particularly with respect to the pedophilia allegations — if what they had been told by Mr. Epstein agreed with what they were told by the attorneys representing him with respect to the ages of the girls who provided the massages and other facts of the case. Because the lawyers involved disputed Mr. Epstein’s version of the facts, the lawyers intervened and told Sitrick not to move forward on their plan.” The sentence does not name the lawyers it refers to.68 The same sheet puts him in the chase for the signed engagement letter: “Mr. Sitrick has repeatedly tried to get a signed copy of his new engagement letter returned and his invoices paid, but to no avail”, and “On March 31, Mr. Sitrick wrote Darren Indyke of Mr. Epstein’s office stating that he understood that Mr. Lefkowitz had forwarded him a copy of the Sitrick engagement letter and that he would appreciate getting it executed and returned.” The rest of that paragraph is a chase of Indyke and Epstein rather than of him, and ends “Mr. Indyke never did get back to Mr. Sitrick.”68 The third sheet states the sum: “The amount due is $103,518. As stated, Mr. Epstein is obligated to pay both on the basis of the earlier letter, an implied contract and quantum meruit.” It ends “Mr. Sitrick does not want to have to pursue legal remedies and turn what has been a good relationship into an adversarial one. Thank you for your attention to this matter.”, over a manuscript signature and the printed name “J. Michael Hennigan”.69

The ten sheets before the letter are three invoices, and they run cumulatively. Sitrick And Company’s invoice of 7 April 2011, for services through 26 March, is $71,319.07; it is addressed to Epstein and copied to “Jay Lefkowitz, P.C., Kirkland & Ellis LLP”.22 The invoice of 3 May 2011, for services through 23 April, carries that figure forward as a previous balance and closes at $99,490.32; the invoice of 8 June 2011, for services through 28 May, carries $99,490.32 forward and closes at a balance due of $103,517.82, which is the figure the letter of 12 July states as “$103,518.”70

On 29 June 2011 he wrote to the general counsel for programming at IAC/InterActiveCorp: “It has come to my attention that three reporters who work for Newsweek and the Daily Beast - [redacted], Bill Kline, and Wayne Barnett - are working on new articles about my client, Jeffrey Epstein. Based on some of the prior coverage of Mr. Epstein in your publications, I am very concerned that these forthcoming articles may contain inaccurate and libelous information about Mr. Epstein.” It asks for “a careful review of any forthcoming article about Mr. Epstein for the purpose of determining whether the facts are accurate”, offers “to check and/or correct any facts about Mr. Epstein in advance of publication”, and closes by asking that the two titles treat the letter “with the seriousness that Mr. Epstein deserves and that you owe to the public as a responsible journalistic enterprise.” Beneath a cursive ink mark the printed name reads “Jay P. Lefkowtiz”, the letters transposed, on a letterhead that spells it correctly at the head of the same sheet.71

What the firm charged, and who else sent him bills

Kirkland & Ellis’s invoices to Epstein are in the release, and they price the work this page describes.

For legal services to 31 March 2009, billed on 12 May 2009: 56.30 hours, $35,068.50 in fees, $36,368.97 in all. His own line is 18.80 hours at $895.00 an hour, $16,826.00; two associates and a research specialist make up the rest.23 Much of that month’s work is about the lawyer the agreement had appointed for the women. On 4 March 2009, 1.00 hour: “Telephone conferences with R. Josefsberg; report to client.” On 6 March 2009, 1.50 hours: “Work on evaluation of Josefsberg’s bills.”72

For legal services to 31 May 2011, billed on 14 July 2011, there are two invoices. The first is 276.50 hours and $172,620.00, of which his own is 33.50 hours at $995.00, $33,332.50, and Musumeci’s 157.50 hours at $665.00, $104,737.50; its entries are the SORA hearing and the appeal from it.20 The second is 40.70 hours and $39,964.00, of which his own is 39.20 hours at $995.00, $39,004.00, and its March 2011 entries are the press and the intervention: “Work on press issues; telephone conference with J. Epstein; look into defamation issues” (4 March); “Follow up re UK lawyers; telephone conferences with team; work on defamation issues” (7 March); “Telephone conferences with M. Weinberg and team; work on press issues; review Sitrick’s draft and respond to it” (8 March); “Research confidentiality issues for J. Epstein re former employees; review settlement agreements from D. Indyke” (11 March); “E-mail to J. Epstein and team re next steps; discuss intervention options; review legal issues re 3771; read WP cases” (22 March); “Read Acosta letter; confer with J. Epstein” (25 March).73 The covering letter enclosing both is over his name, signed in blue ink, and is addressed to Epstein care of Darren Indyke: “Enclosed please find our invoices for legal services rendered and related expenses incurred through May 31, 2011. For your convenience, payment can be made by wire transfer to:”. Two of the five wire-transfer fields under that line are covered on this copy, and no value from any of the five is reproduced here.74

Money also ran the other way through him. Podhurst Orseck, the Miami firm whose senior partner the agreement had made the attorney representative for the women, addressed its bills for that work to “Kirkland & Ellis, LLP / Attn: Jay P. Lefkowitz, Esq.”, under the client name “Kirkland & Ellis, LLP” and the matter name “Epstein, Jeffrey adv. USA”. Its invoice of 25 September 2008 is $63,718.75 in fees and $63,992.15 in all, at hourly rates from $75.00 to $750.00. A pre-billing report of 10 November 2009 carries the same billing address and totals $4,648.26 billed through 31 October 2009.2175 So the lawyer who had written in October 2007 that the attorney representative “may not continue his representation and is barred from filing lawsuits pursuant to § 2255…” was, a year later, the addressee of that representative’s bills.29

What Epstein himself said he had paid is on the record once. Examined under oath on 17 March 2010, in his own abuse-of-process suit in the Circuit Court in Palm Beach County, he was taken through his lawyers one by one and asked what each had cost. On Lefkowitz: “Q. How much are you paying Jay - how much have you paid Jay Lefkowitz? A. I’m not sure, sir. Q. Do you have any idea at all? A. More than a hundred thousand dollars. Q. Are you paying him on an hourly basis? A. Yes, sir. Q. What’s the hourly rate? A. I don’t know.” He said he did not know the hourly rate of any lawyer he was asked about on that sheet.24

After 2011: the engagement continues

The record does not stop at the CVRA appeal, and this page does not follow it to the end.

Breakfast was arranged, and two documents carry it. On 23 May 2011 Lesley Groff wrote “Hi Jay…Jeffrey is wondering if you could come by for breakfast on WEd. May 25th. Let me know what time works…”; he answered “sure — how about 815?”; she asked the next day whether there was “anything in particular you would like for breakfast tomorrow so we may have it available for you?!”; and he replied “i am easy to please. She usually makes an egg and has some berries in the house. But strong coffee is really my only necessity. (I don’t eat lox, so please don’t buy any on my account, though if Jeffrey likes it, that’s great).”76 Epstein’s schedule for that Wednesday, 25 May 2011, circulated the day before, opens: “8:15 Breakfast with Jay Lefkowitz”.77 The schedule is a plan and neither document records how the morning went.

In June 2013 the matter is commercial and the person being advised is not Epstein. Scott D. Price wrote to Steven Sinofsky and to “Lefkowitz, Jay P.”, copying Epstein, about a non-disparagement clause in Sinofsky’s separation agreement: “what this language prohibits you from doing is disparaging Windows and any other product put out while you were with MSFT, even if you’re not using confidential information.” Sinofsky wrote back worrying about being misquoted in the press. Epstein answered him: “relax , ,you are making yourself crazy. sign and go on”. Nothing on that sheet is written by Lefkowitz; he is a named recipient of the advice.78

The last direct exchanges reached for this page are from 2016 and 2018. On 15 April 2016 he wrote to Epstein: “Am here giving a speech this weekend. Very nice building you built.” The sheet names no place, and the photograph its header names is not in the release copy. Epstein replied the next morning: “sorry im not there”.79 On 6 December 2018 Epstein sent him a link to a news report about the Florida agreement, and nothing else.8

What the office kept, and how it indexed him

Two later filings show how the U.S. Attorney’s Office had stored this correspondence.

When the office was ordered in 2013 to log what it was withholding from the two women suing it, several of the folders it listed were titled by Lefkowitz’s name: “11/8/07 Lefkowitz to Sloman”, “11/13/07 Sloman to Lefkowitz (was this sent?)”, “12/6/07 Sloman to Lefkowitz”, “12/21/07 Lefkowitz to Acosta”, “12/26/07 Lefkowitz to Acosta”, “8/18/08 Lefkowitz Ltr to AMCV”, and “Draft ltr from Sloman to Lefkowitz re termination”, the last containing a “draft letter dated ‘April , 2008’ from J. Sloman to J. Lefkowitz concerning the compliance with the Agreement”, the day of the month left blank.1516 The folder for the 21 December letter describes it as “12/21/07 letter from J. Lefkowitz to A. Acosta re performance of NPA and appeal to Washington with attorney handwritten notes.”16 The copies of that log in the release do not carry the same redactions, and the version of these rows used here is the one filed on the docket.1680 The claim itself, and the victims’ objections to it, are at the 2013 privilege logs; the 2015 log, whose rows describe January 2008 emails among the prosecutors about a telephone conference between Acosta and Lefkowitz, is at the Second Supplemental Privilege Log.

Second, when the United States made its initial disclosures in the same case on 20 July 2015, the entries in its list of documents it might use that name him ran, in the order the list gives them: an October 10, 2007 letter from him to Acosta; November 29; a December 5 letter over both his name and Starr’s; a December 6 letter to him from the First Assistant; December 11; December 21; December 26; then “January – May 2008 correspondence from Jay Lefkowitz regarding DOJ review of non-prosecution agreement”; a May 2008 letter to him from the Chief of the Child Exploitation and Obscenity Section; “May – June 2008 correspondence from Jay Lefkowitz and/or Kenneth Starr, to Deputy Attorney General [redacted]; Assistant Attorney General [redacted]; and Senior Associate Deputy Attorney General [redacted]”; and a June 2008 letter back to him and Starr from the Senior Associate Deputy Attorney General.8182 The officials’ names are blacked out on that page and are not taken from it. The list is the government’s own index of the campaign, and it is arranged as a ladder.

What this page does not establish

It does not establish what was said in the meetings of 7 September, 12 October or 14 December 2007, except as one party’s later letter describes it. It does not establish the contents of anything the government withheld as privileged, including the April 2008 draft and the June 2008 submission from the office to the Deputy Attorney General. Where one copy of a document blacks out a name that another copy cited here prints, this page uses the copy that prints it and identifies that copy in the footnote; it resolves no redacted name from outside the documents cited here. It does not reproduce the deposition material that parts of the defence correspondence quote. For the later material it does not establish what the U.S. Attorney’s Office did with the July 2011 request it opposed, and it does not follow the engagement to its end: the record reached here runs to December 2018 and there is more of it than this page carries.

Footnotes

  1. Letter, Jay P. Lefkowitz (Kirkland & Ellis LLP) to R. Alexander Acosta, 10 October 2007, p.1; headed “Confidential. For Settlement Purposes Only, Pursuant to Rule 408.” and sent “VIA E-MAIL”. The line prosecutor’s surname is blacked out on the image at both places it appears on this page; the firm’s direct-dial and fax lines are also boxed. Read from the page image at 300 dpi. https://epstein-data.com/EFTA00209047 p.1. ↩ ↩2 ↩3 ↩4

  2. Office of Professional Responsibility, Investigation into the U.S. Attorney’s Office for the Southern District of Florida’s Resolution of its 2006-2008 Federal Criminal Investigation of Jeffrey Epstein, narrative p. 9, section on Epstein’s defense attorneys, from the copy in the Epstein Files Transparency Act release. That copy names Lefkowitz, Starr and Joe D. Whitley in the clear. In the same paragraph it covers the surnames of two other defence lawyers, each following a visible given name; for a third it covers the given name and leaves the surname printed; for Starr it covers a title rather than a name; and it covers the given names of both Presidents. The bracketed omissions above are its redaction boxes, and nothing beneath them is resolved from this document. Read from the page image at 300 dpi. https://epstein-data.com/EFTA02830776 p.35. ↩ ↩2 ↩3

  3. Same letter, same page: “Although it happens rarely, I do not mind this Office’s decision being appealed to Washington, and have previously directed our prosecutors to delay filings in this case to provide defense counsel with the option of appealing our decisions.” https://epstein-data.com/EFTA00213048 p.26. ↩ ↩2

  4. Same letter, its own p. 2: the first three entries of the timeline, with exhibit references. https://epstein-data.com/EFTA00183732 p.36. ↩ ↩2 ↩3 ↩4 ↩5

  5. Same letter, its own p. 3: the remaining timeline entries, including the quoted 29 February 2008 reply from the First Assistant U.S. Attorney and the 28 May 2008 email postponing the deadline. Read from the page image at 300 dpi. https://epstein-data.com/EFTA00183732 p.37. ↩ ↩2 ↩3 ↩4 ↩5 ↩6 ↩7 ↩8 ↩9 ↩10

  6. Memorandum, Kirkland & Ellis LLP, marked CONFIDENTIAL, 5 October 2010, its own p. 1, to three named Assistant District Attorneys and from “Jay P. Lefkowitz, P.C.”, Matthew Solum and Sandra Lynn Musumeci. Nothing on this sheet is covered by the producing party. A state identity number printed on this sheet is not reproduced here. Read at the image at 400 dpi. https://epstein-data.com/EFTA00723408 p.1. ↩ ↩2 ↩3

  7. “UNITED STATES’ MEMORANDUM OF LAW REGARDING INTERVENORS’ RIGHTS TO OBSERVE AND PARTICIPATE IN THE SETTLEMENT CONFERENCE”, Jane Doe #1 and Jane Doe #2 v. United States, No. 08-80736-Civ-Marra/Matthewman (S.D. Fla.), its own p. 2, section A, “Group 1: Attorneys Black, Weinberg, and Lefkowitz”. Filed after the status conference of 28 March 2016 to which it refers. A single character in the case citation is covered on this sheet, twice. Read at the image at 400 dpi. https://epstein-data.com/EFTA00211513 p.2. ↩ ↩2 ↩3

  8. E-mail, Jeffrey Epstein to Jay Lefkowitz, “Date: Thu, 06 Dec 2018 01:11:30 +0000”, one sheet, with no subject line. Its whole body is a single link to an NBC News report on the Florida agreement; the corpus extraction of the link is damaged and the address is legible at the image. The recipient’s e-mail address is covered and is not reproduced. Read at the image at 400 dpi. https://epstein-data.com/EFTA01014240 p.1. ↩ ↩2

  9. Letter, Jay P. Lefkowitz to R. Alexander Acosta, 29 November 2007, p.1. The name of the person who sent the draft notification letter is blacked out on the image and is not taken from this document. Read from the page image at 300 dpi. https://epstein-data.com/EFTA00209047 p.7. ↩ ↩2 ↩3

  10. Letter, U.S. Attorney’s Office for the Southern District of Florida to “Jay P. Lefkowitz, Esq.”, 6 December 2007, p.1 of 4: “Dear Jay: I write in response to your recent e-mails and letters regarding victim notification and other issues”, and the account of the scheduling delay. Read from the page image at 300 dpi. https://epstein-data.com/EFTA00209047 p.17. ↩ ↩2

  11. Letter, Jay P. Lefkowitz to R. Alexander Acosta, 21 December 2007, p.1, faxed; the quoted passage is its second paragraph. Read from the page image at 300 dpi. https://epstein-data.com/EFTA00209047 p.41. ↩ ↩2 ↩3

  12. Letter, Jay P. Lefkowitz to R. Alexander Acosta, 26 December 2007, its own p. 1: “I write to address the questions you posed to me during a conversation we had late last week.” Read from the page image at 300 dpi; the letter does not say the conversation was by telephone. https://epstein-data.com/EFTA00209047 p.48. ↩ ↩2 ↩3

  13. Letter, Kenneth W. Starr and Jay P. Lefkowitz (Kirkland & Ellis LLP) to R. Alexander Acosta, 5 December 2007, faxed from the firm’s Los Angeles office: “We are in receipt of your letter faxed to Jay on December 4 and faxed to Ken today in Los Angeles”. The letterhead’s direct-dial block is Starr’s; its own p. 2 carries two signature blocks under “Yours Sincerely,” — a cursive mark over the printed name “Kenneth W. Starr”, and below it a second cursive mark over the printed name “Jay Lefkowitz”. Both pages read from the page image at 300 dpi; the corpus extraction of the second page renders the lower printed name as unreadable characters and a reader working from it would see one signer. This page does not quote the letter beyond the line above. https://epstein-data.com/EFTA00209047 pp.15-16. ↩

  14. Letter, R. Alexander Acosta, United States Attorney, to Lilly Ann Sanchez, 19 December 2007, its own p. 3: the sentence “Our Agreement was first signed on September 24th, 2007”, the passage on his prosecutors’ request that he declare the agreement in breach, the “fully vetted” sentence, the sentence recording that he had spoken with the Assistant Attorney General, and the cc line naming “Alice Fisher, Assistant Attorney General”. A manuscript signature stands over the printed name. Read from the page image at 300 dpi. https://epstein-data.com/EFTA00209047 p.40. ↩ ↩2 ↩3 ↩4 ↩5

  15. “SUPPLEMENTAL PRIVILEGE LOG”, Document 216-1 in Jane Doe #1 and Jane Doe #2 v. United States, No. 9:08-cv-80736-KAM (S.D. Fla.), entered on the FLSD docket 27 July 2013, its own p. 2 of 14: the folder entries titled “8/18/08 Lefkowitz Ltr to AMCV”, “11/8/07 Lefkowitz to Sloman” and “11/13/07 Sloman to Lefkowitz (was this sent?)”. Read at 400 dpi from the copy at pp. 209–222 of a 310-page run, and that row again at 800 dpi to settle the closing parenthesis, which is present. https://epstein-data.com/EFTA00185206 p.210. ↩ ↩2

  16. Same log, its own p. 3 of 14: the folder entries titled “12/6/07 Sloman to Lefkowitz” (marked “[Not considered privileged. Will be produced to opposing counsel upon lifting of stay]” and logged as containing a “12/5/07 faxed letter w/ cover sheet from K. Starr and J. Lefkowitz to A. Acosta”), “12/05/07 Starr to Acosta”, “12/21/07 Lefkowitz to Acosta”, “12/26/07 Lefkowitz to Acosta” and “Draft ltr from Sloman to Lefkowitz re termination”. Read at 400 dpi from two copies: https://epstein-data.com/EFTA00185206 p.211 and https://epstein-data.com/EFTA00209306 p.5. ↩ ↩2 ↩3 ↩4 ↩5

  17. Email to Jay Lefkowitz, subject “Jeffrey Epstein”, carrying an RFC date header “Mon, 23 Jun 2008 21:54:57 +0000” — an explicit UTC offset. On this copy the sender, the other addressees, the name of the lawyer to whom the December 19 letter was sent, and the whole signature block are blacked out; Lefkowitz’s name in the “To” line is not covered. Read from the page image at 300 dpi. https://epstein-data.com/EFTA00067500 p.1. ↩ ↩2 ↩3

  18. Transcript, SORA hearing, Supreme Court of the State of New York, New York County, Trial Term Part 66, 111 Centre Street, 18 January 2011, filed as an exhibit on the FLSD docket in the CVRA case on 10 February 2016; its own pp. 1-2. Two people’s names, at six boxes between the two sheets, and two street addresses are covered across these two sheets, and none of them is taken from this document. On the second of these sheets the speaker label on the line waiving the client’s appearance is a damaged rendering of his surname and is not reproduced. Read at the image at 400 dpi. https://epstein-data.com/EFTA00184224 pp.339-340. ↩ ↩2 ↩3

  19. Notice of Electronic Filing, U.S. District Court, Southern District of Florida, transaction entered 23 April 2012 at 11:12 a.m. EDT, its own p. 1: the “Filer:” block and the docket text for Document 169. A single character in the case name is covered. No e-mail address on this sheet is reproduced here. Read at the image at 400 dpi. https://epstein-data.com/EFTA00205529 p.1. ↩ ↩2

  20. Invoice, Kirkland & Ellis LLP to Jeffrey Epstein, 14 July 2011, for legal services through 31 May 2011; its “Summary of Hours Billed”, the invoice’s own p. 2. Six timekeepers, 276.50 hours, $172,620.00. Each line’s amount is the product of its hours and its rate and the six sum to the total. Read at the image at 400 dpi. https://epstein-data.com/EFTA00312716 p.3. ↩ ↩2 ↩3

  21. Invoice, Podhurst Orseck to “Kirkland & Ellis, LLP / Attn: Jay P. Lefkowitz, Esq.”, 25 September 2008, Reference No. 14835, four sheets; client “5501 - Kirkland & Ellis, LLP”, matter “30608 - Epstein, Jeffrey adv. USA”. Total for services $63,718.75 on its own p. 3; total for services and expenses $63,992.15 on its own p. 4. The firm’s own suffix is covered in its letterhead. Several time entries on its p. 3 are covered by hand-drawn strokes rather than boxes; those entries concern individual complainants and are not used here. Read at the image at 400 dpi. https://epstein-data.com/EFTA00600774 pp.1, 3. ↩ ↩2

  22. Invoice, Sitrick And Company to Jeffrey Epstein, 7 April 2011, for professional services and expenses through 26 March 2011: professional fees $70,255.00, expenses $1,064.07, current fees and expenses $71,319.07 and balance due $71,319.07, there being no previous balance on it. It is the first of the three invoices in this run and occupies its pp. 1-5. The copy line reads “CC: Jay Lefkowitz, P.C., Kirkland & Ellis LLP”. No bank, tax-identification or contact value on this sheet is reproduced here. Where each invoice begins and ends was established by reading six sheets at the image rather than by inference: pp. 1, 6 and 9 each head a new invoice, and pp. 5, 8 and 10 are each headed “Page 5”, “Page 3” and “Page 2” of the invoice above them and carry its closing totals. Read at the image at 300 dpi. https://epstein-data.com/EFTA00593185 pp.1, 5. ↩ ↩2

  23. Invoice, Kirkland & Ellis LLP to Jeffrey Epstein, 12 May 2009, for legal services through 31 March 2009; its “Summary of Hours Billed”, the invoice’s own p. 2. Four timekeepers, 56.30 hours, $35,068.50, with disbursements taking the invoice to $36,368.97 on its own p. 1. Each line’s amount is the product of its hours and its rate and the four amounts sum to the total, which is how the thousands separator was settled: at 600 dpi the separator and the decimal point on this sheet are the same mark. A two-character box follows his printed name in the timekeeper column. Read at the image at 400 dpi, and the amount column again at 600 dpi. https://epstein-data.com/EFTA01108745 p.2. ↩ ↩2

  24. Videotaped deposition of Jeffrey Epstein, Jeffrey Epstein v. Scott Rothstein, Bradley J. Edwards and [redacted], No. 502009CA040800XXXXMBAG, Circuit Court of the Fifteenth Judicial Circuit in and for Palm Beach County, Florida, 17 March 2010; transcript p. 119, printed as one of four transcript pages on the sheet. The examiner is Mr. Scarola and the objecting lawyer Mr. Pike. The image prints “Jay Lefkowitz”; the corpus extraction of this sheet renders it “Jay Letkowitz”. The caption, the case number, the court and the date are not on that sheet: they are on the deposition’s own p. 1, which prints “SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, and [redacted]., individually,” with the third defendant’s name covered, and which is pinned below with it. No telephone value on either sheet is reproduced here. Both read at the image at 400 dpi. https://epstein-data.com/EFTA01076611 pp.1, 32. ↩ ↩2

  25. Letter, R. Alexander Acosta, United States Attorney, to “Kenneth W. Starr, Esq”, 4 December 2007, its own p. 5, faxed 12/04/07: the August 2007 approach, the condition attached to the 7 September meeting, the meeting itself, and the offer to delay the indictment. The addressee is established from the letter’s own first page, which is headed “DELIVERY BY FACSIMILE / Kenneth W. Starr, Esq / Kirkland & Ellis LLP” and opens “Dear Mr. Starr”. Both pages read at the image at 300 dpi. https://epstein-data.com/EFTA00213048 pp.22, 26. ↩ ↩2 ↩3 ↩4

  26. The message Villafaña was answering, quoted beneath hers on the same sheet: Jay Lefkowitz to Villafaña, 27 September 2007, with his answers interleaved among the four questions; the fourth answer and the sign-off run onto the following page. https://epstein-data.com/EFTA00208970 pp.11-12. ↩

  27. Email, A. Marie Villafaña (USAO, S.D. Fla.) to “Jay Lefkowitz”, 27 September 2007, subject “RE: Conference Call with Bert Ocariz”. Read from the page image at 300 dpi; the Outlook stamps on this sheet carry no time zone and are not reproduced. https://epstein-data.com/EFTA00208970 p.11. ↩

  28. The correspondence run. A 52-page document in Data Set 9, stamped RFP MIA 000001 onwards, holding in date order: Lefkowitz to Acosta, 10 October 2007 (its pp.1–6); Lefkowitz to Acosta, 29 November 2007 (pp.7–10); the office’s draft victim notification letter (pp.11–14); Starr and Lefkowitz to Acosta, 5 December 2007 (pp.15–16); the office to Lefkowitz, 6 December 2007 (pp.17–20); a further copy of the notification letter (pp.21–24); Lefkowitz to Acosta, 11 December 2007 (pp.25–37); Acosta to Lilly Ann Sanchez, 19 December 2007 (pp.38–40); Lefkowitz to Acosta, 21 December 2007 (seven pages from p.41); Lefkowitz to Acosta, 26 December 2007 (pp.48–52). Boundaries established by reading every page’s header. https://epstein-data.com/EFTA00209047 p.1. ↩

  29. Same letter, its own p. 2, on the scope of the attorney representative’s role under paragraphs 7 and 8 of the agreement. https://epstein-data.com/EFTA00209047 p.2. ↩ ↩2

  30. Same letter, its own pp. 5–6: the proposed joint communication and the request for an assurance, after which one further sentence stands before the signature block. It is introduced by the sentence “We propose that the following joint communication be made to Judge Davis, who will act as the attorney representative and communicate accordingly with the identified individuals”; the letter’s own p. 1 names him “Judge Edward Davis”. The proposed text is set as a block quotation running from its p. 5 to its p. 6, and its last sentence is the one about a joint communication quoted above. The letter reads “the United State’s investigation” and “willful breech”; both are reproduced above as it has them. Read from the page images at 200 dpi, and its p. 6 again at 300 dpi. https://epstein-data.com/EFTA00209047 pp.5-6. ↩

  31. Same letter, its own pp. 2–3: the objections to “sexual predator”, to the right to appear at sentencing, and to the term “minor victim”. https://epstein-data.com/EFTA00209047 pp.8-9. ↩

  32. Same letter, its own p. 4: the seventh and eighth objections, the request to postpone pending the meeting with the Assistant Attorney General, and the signature. A fluid mark, off the baseline grid and overlapping the printed characters, stands over the printed name “Jay P. Lefkowitz”; whether it is ink cannot be told from a black-and-white scan. Read from the page image at 300 dpi. https://epstein-data.com/EFTA00209047 p.10. ↩ ↩2 ↩3

  33. Letter, Jay P. Lefkowitz to R. Alexander Acosta, 11 December 2007, its own p. 1: “I thank you for the opportunity to express my concerns with the Section 2255 component of the Non-Prosecution Agreement… I respectfully request that you consider the issues I discuss below in conjunction with the ethics opinion of Mr. Joe D. Whitley that I faxed to your Office on December 7.” Thirteen pages. Read from the page image at 300 dpi, where the phrase the corpus extraction garbles reads “Section 2255 component” plain; its later pages discuss individual complainants and are not used. https://epstein-data.com/EFTA00209047 p.25. ↩

  34. Same letter, its own p. 4 of 4, signature block: a manuscript signature above a black box, above the printed line “First Assistant United States Attorney”, beneath the printed lines “R. Alexander Acosta / United States Attorney”. The signer’s name is blacked out on this copy and is not resolved from this document; the folder title quoted in the body above comes from the 2013 privilege log. The cc line names “R. Alexander Acosta, U.S. Attorney” and one Assistant U.S. Attorney whose surname is boxed. https://epstein-data.com/EFTA00209047 p.20. ↩

  35. Same letter, its own p. 3 of 4: the concessions on “sexual offender” and on quoting the agreement’s terms, the answers on the state sentencing and on the two lawyers named in the notification letter, and the passage refusing to state that the government took no position, which runs on without a break into the two sentences on 18 U.S.C. § 3771(a)(8) quoted above. One Assistant U.S. Attorney’s name is blacked out on this page. Read from the page image at 300 dpi. https://epstein-data.com/EFTA00209047 p.19. ↩ ↩2 ↩3 ↩4 ↩5

  36. Same letter, its own p. 4 of 4: the concession on sending the letters through the mail and its footnote 2 making that contingent, the refusal to remove the prosecutor’s and case agent’s names from the notification letter, and the closing demand. Read from the page image at 300 dpi. https://epstein-data.com/EFTA00209047 p.20. ↩ ↩2 ↩3

  37. Same letter, its own p. 2 of 4: the four-Florida-Bar-members passage, the denial of the leak allegation, and the office’s statement of its evidence about each person on the victim list. https://epstein-data.com/EFTA00209047 p.18. ↩ ↩2 ↩3

  38. Letter, Kenneth W. Starr (Kirkland & Ellis LLP) and Joe D. Whitley (Alston & Bird LLP) to the Honorable Mark Filip, Office of the Deputy Attorney General, 19 May 2008, marked CONFIDENTIAL and sent by facsimile; its own p. 1. Read from the page image at 300 dpi; the two firms’ telephone and facsimile lines and the fax number of the addressee are boxed on this copy. A separate copy of the same letter sits in the House Oversight production under its own per-page identifiers, and is not cited here. https://epstein-data.com/EFTA00597542 p.1. ↩

  39. Same letter, its own p. 3: the sentence about the New York Times reporter and footnote 1 beneath it, which reads in full, “One of the other members of Mr. Epstein’s defense team, Jay Lefkowitz, has personally reviewed the reporter’s contemporaneous notes.” Read from the page image at 300 dpi. https://epstein-data.com/EFTA00597542 p.3. ↩

  40. “KIRKLAND & ELLIS LLP / Response to Letter by FAUSA [redacted] Dated May 19, 2008”, its own p. 1, marked Exhibit B-37 and stamped RFP MIA 000431. Ten sheets. The First Assistant U.S. Attorney’s surname is covered at every occurrence on this sheet and is not taken from this document. Three solid discs down the left margin are hole-punch artefacts, not redaction bars. Read at the image at 400 dpi. https://epstein-data.com/EFTA00224814 p.1. ↩

  41. Same document, its own p. 10, the last sheet of the run: three lines of type at the head, ending “…not an appropriate basis for the exercise of federal prosecutorial authority.”, and nothing else on the sheet. No signature, no signature rule, no printed name, no date. The rest of the sheet is blank. Read at the image at 400 dpi. https://epstein-data.com/EFTA00224814 p.10. ↩

  42. Same document, its own p. 5: heading 5, “WAIVER OF APPEAL TO ASSISTANT ATTORNEY GENERAL FISHER.”; the two quotations from the government’s letter, cited on the sheet as “Id., p. 2.”; and the two bullets under “The Truth:”. Surnames of at least three different people are covered on this sheet, at six boxes in all, and none of them is taken from this document. In the second bullet the covering box overlaps the type on either side of it without destroying it: it takes the first letter of “threatened” and leaves the rest printed, and its lower edge clips the ascender tops of the two words that follow “rais” while leaving them legible, so that at 600 dpi the sheet reads “Facing Ms. [redacted]hreatened draconian indictment, without the claimed offer of the right to raise objections in an appeal to AAG Fisher, the defense chose to negotiate an”; the sentence continues on its p. 6 with “Agreement to Defer Prosecution to the State, an agreement without precedent and fraught with substantial practical and legal hurdles to its implementation.” The corpus extraction of this sheet reads “FISIIER” for the heading and “The Trutb:” for the sub-heading, and drops the bracketed “[T]” from the government’s quotation; the image is followed. Both sheets read at the image at 400 dpi, and its p. 5 again at 600 dpi. https://epstein-data.com/EFTA00224814 pp.5-6. ↩

  43. Same log page: the folder entry “6/3/08 Sloman Submission to the DAG”, Bates P-013373 through P-013503, “containing 6/3/08 letter from J. Sloman to Mark Filip, Office of the DAG, cc’d to R. Senior, A. Marie Villafaña, K. Atkinson, re Jeffrey Epstein, detailing events concerning the Agreement and thereafter and with relevant attachments”, against Attorney-Client Privilege, Deliberative Process, Work Product and Investigative privilege. The names in this row are taken from the docketed filing, which carries them. https://epstein-data.com/EFTA00209306 p.5. ↩

  44. A second copy of the same message, printed from Outlook rather than as an RFC header: “Sent: Monday, June 23, 2008 5:55 PM”, From and Cc suffixed “(USAFLS)”, the sender’s name blacked out, the signature block reading “Assistant U.S. Attorney / 500 S. Australian Ave, Suite 400 / West Palm Beach, FL 33401”. This is the copy the quotation above is taken from; the lawyer it names as the recipient of the December 19 letter is named the same way in the government’s own correspondence index. Read from the page image at 300 dpi. https://epstein-data.com/EFTA00211946 p.2. ↩ ↩2

  45. Letter, Jay P. Lefkowitz (Kirkland & Ellis LLP) to the U.S. Attorney’s Office for the Southern District of Florida, 19 June 2009, its own pp. 1–2. The addressee’s name is blacked out on the image, which prints only “Ms. [redacted], Esq.”; it is not taken from this document. Read from the page image at 300 dpi. https://epstein-data.com/EFTA00183732 pp.35-36. ↩ ↩2 ↩3

  46. Letter, U.S. Attorney’s Office for the Southern District of Florida to Jay P. Lefkowitz, Roy Black and Jack A. Goldberger, 15 June 2009, its own p. 2 of 4. The sentence quoted above continues “prior to his entering into that agreement”, which the ellipsis marks. The addressees and the date are established from the letter’s own p. 1 of 4, which is headed “DELIVERY BY ELECTRONIC MAIL” and opens “Dear Messrs. Lefkowitz, Goldberger, and Black”; its own p. 4 of 4 carries the block “Sincerely,” / “Jeffrey H. Sloman” / “Acting United States Attorney” / “By:”, a cursive mark, a black box beneath it, and the printed line “Assistant United States Attorney”. The name under that box is not resolved from this document. All three pages read from the page images at 250 dpi. https://epstein-data.com/EFTA00213048 pp.2, 3, 5. ↩ ↩2

  47. Same memorandum, its own p. 3, section II.A, “Degree of Harm to Society”. Nothing on this sheet that could identify the complainant is reproduced here. Read at the image at 400 dpi. https://epstein-data.com/EFTA00723408 p.3. ↩

  48. Same memorandum, its own p. 5: the Florida and New Mexico comparisons, the psychologist’s quoted opinion, and the three bracketed questions to the drafting team, which are printed in bold on the face of the sheet. Read at the image at 400 dpi. https://epstein-data.com/EFTA00723408 p.5. ↩ ↩2

  49. Same transcript, its own p. 3, run p. 341: the Assistant District Attorney on the Board’s interim guidelines, and the court’s answer. Her sentence breaks off at “and I don’t think —” and the court’s question and her answer to it stand between the two passages quoted above. Read at the image at 400 dpi. https://epstein-data.com/EFTA00184224 p.341. ↩ ↩2

  50. Same transcript, its own p. 6, run p. 344: Musumeci’s opening submission. Read at the image at 400 dpi. https://epstein-data.com/EFTA00184224 p.344. ↩

  51. Same transcript, its own p. 11, run p. 349. The exchange runs continuously: the Assistant District Attorney’s answer to the court’s question about the length of the relationship, the court’s “She is a child.”, and Musumeci’s reply. Read at the image at 400 dpi. https://epstein-data.com/EFTA00184224 p.349. ↩

  52. Same transcript, its own p. 14, run p. 352: the court’s reading of the Board’s scoring, and his submission, which begins at line 10 and runs to the foot of the sheet. Read at the image at 400 dpi. https://epstein-data.com/EFTA00184224 p.352. ↩

  53. Same transcript, its own p. 15, run p. 353, the last sheet: the close of his submission, the court’s three sentences, and the reporter’s certification, whose name is covered in the certification and printed in the running footer of every sheet. Read at the image at 400 dpi. https://epstein-data.com/EFTA00184224 p.353. ↩ ↩2

  54. “PREARGUMENT STATEMENT”, Supreme Court of the State of New York, County of New York, Index No. 30129-2010, People of the State of New York v. Jeffrey E. Epstein, dated 24 January 2011, both sheets. Item 7 records the result below, “Supreme Court, New York County, adjudged appellant Jeffrey E. Epstein to be a Level 3 sexual offender, without additional designation”; item 8 is the ground quoted above. The signature block is two printed names beneath a rule with no manuscript mark on it; the appellant’s counsel address block is covered on the first of these sheets and partly covered on the second; the closing line reads “Attorneys for Defendant-Appellant Jeffrey E. Esptein.” as printed. Read at the image at 400 dpi. https://epstein-data.com/EFTA00589579 pp.1-2. ↩

  55. Letter, Jay P. Lefkowitz, P.C. and Martin G. Weinberg to A. Marie Villafaña, Assistant United States Attorney, United States Attorney, Southern District of Florida, West Palm Beach, 29 July 2011, marked “Delivery by Facsimile” and “CONFIDENTIAL”, its own p. 1. Three sheets. One contact value is covered in the letterhead of this copy and is not reproduced here. Everything quoted above, and both names, are legible on this sheet. Read at the image at 400 dpi. https://epstein-data.com/EFTA00586200 p.1. ↩

  56. Same letter, its own p. 3: the closing paragraph and the signature block, which is two printed names with no rule and no manuscript mark, above the reference “JPL/kla”. Read at the image at 400 dpi. https://epstein-data.com/EFTA00586200 p.3. ↩

  57. The search. pages_fts on "New York District Attorney" AND "victim list" on 2026-09-10 returns 13 pages in 13 documents; "request by the New York District Attorney" returns the same 13; "decline the request of the New York District Attorney" returns 10 of them. Every one of the 13 is a copy of this letter or of its first sheet. No document among them is an answer to it, and this page makes no claim about the release beyond that search. ↩

  58. “REPLY IN SUPPORT OF MOTION TO INTERVENE OF ROY BLACK, [redacted] WEINBERG, AND JAY LEFKOWITZ”, Document 80 in Jane Doe 1 and Jane Doe 2 v. United States of America, No. 08-80736-CIV-MARRA (S.D. Fla.), entered on the FLSD docket 12 May 2011, its own p. 1. Two values in the caption of this sheet are covered and neither is taken from this document. Read at the image at 400 dpi. https://epstein-data.com/EFTA02753356 p.1. ↩

  59. Same reply, its own p. 2: the first heading, and the sentence beneath it quoting El-Ad Residences at Miramar Condo. Ass’n, Inc. v. Mt. Hawley Ins. Co., 716 F. Supp. 2d 1257, 1262 (S.D. Fla. 2010). Nothing on this sheet is covered. Read at the image at 400 dpi. https://epstein-data.com/EFTA02753356 p.2. ↩

  60. Same reply, its own p. 4: the Rule 6(e) passage. Two single words inside that sentence are covered by the producing party. Read at the image at 400 dpi. https://epstein-data.com/EFTA02753356 p.4. ↩

  61. Transcript, hearing before the Honorable Kenneth A. Marra, United States Federal Courthouse, West Palm Beach, Friday 12 August 2011, filed as Document 208 on the FLSD docket on 10 July 2013; its own pp. 1 and 3. A short box covers the meridiem after the sitting’s closing time on the title sheet. The statement that nothing in the transcript places Lefkowitz in the room is taken from the transcript’s own word index, at run p. 105, which lists his surname once, at transcript page 3 line 18 — the line quoted above — and nowhere else in the 113 sheets. Read at the image at 400 dpi. https://epstein-data.com/EFTA01122989 pp.1, 3, 105. ↩

  62. “MOTION TO STRIKE NOTICE OF SUPPLEMENTAL AUTHORITY”, Document 177, entered on the FLSD docket 6 June 2012, its own p. 1. The surname of the lawyer Epstein had sued in the state court is covered at each occurrence on this sheet and is not taken from this document. The image prints “Lefkowitz”; the corpus extraction of this sheet renders it “Leflcowitz”. Read at the image at 400 dpi. https://epstein-data.com/EFTA02753909 p.1. ↩

  63. Letter, Jay P. Lefkowitz, P.C. (Kirkland & Ellis LLP) to Ms. Tina Brown, Editor, The Daily Beast, 23 September 2010, marked “VIA HAND DELIVERY & FED EX”. The run in the release is a single sheet and the letter breaks off mid-sentence at its foot, so the numbered examples it promises are not in this copy. The contributing writer’s name is covered at all three places it appears. No telephone, facsimile or e-mail value on this sheet is reproduced here. Read at the image at 400 dpi. https://epstein-data.com/EFTA00602994 p.1. ↩

  64. E-mail, Jay Lefkowitz to a reporter, 7 March 2011, quoted within a forward Epstein sent on to Michael Sitrick; its own p. 2 of two sheets. The sheet prints “facutal” as quoted. No telephone value on this sheet is reproduced here. Read at the image at 400 dpi. https://epstein-data.com/EFTA00906111 p.2. ↩

  65. Same document, its own p. 1: the reporter’s reply of 7 March 2011, stamped “02:04 PM EST”, and above it his forward of the exchange to Jeffrey Epstein, Darren and Martin Weinberg. Two fields on the sheet carry a time zone: the outermost header, “Date: Tue, 08 Mar 2011 01:10:38 +0000”, and that stamp; the other stamps carry none, and no interval is computed here. The forward’s addressee line gives the forename “Darren” with no surname: the surname is not covered on this sheet, it is simply not on it, and the full name used in the sentence above is taken from the covering letter of 14 July 2011 at 74, which is addressed to him. Six further copies of this exchange sit in the House Oversight production, whose page images this desk cannot render. Read at the image at 400 dpi. https://epstein-data.com/EFTA00906111 p.1. ↩

  66. E-mail thread, Michael Sitrick, Jeffrey Epstein and Jay Lefkowitz, 8 March 2011, one sheet, read bottom-up. Only two fields on the sheet carry a time zone: the outermost header, “Date: Tue, 08 Mar 2011 18:23:55 +0000”, and Epstein’s own “Sent: 03/08/2011 07:33 AM PST”; the three intermediate stamps carry none and no interval is computed here. No e-mail address on this sheet is reproduced here. Read at the image at 400 dpi. https://epstein-data.com/EFTA00682221 p.1. ↩

  67. Letter, Hennigan Dorman LLP to Mr. Roy Black and Mr. Jay Lefkowitz, 12 July 2011, “VIA EMAIL”, its own p. 1, being p. 11 of a thirteen-sheet run. The letter occupies the last three sheets of that run; the first ten are three separate Sitrick And Company invoices, at 22 and 70. No e-mail, telephone or facsimile value on this sheet is reproduced here. Read at the image at 400 dpi. https://epstein-data.com/EFTA00593185 p.11. ↩

  68. Same letter, its own p. 2, run p. 12, headed “July 12, 2011 / Page 2”. The paragraph quoted first continues past the words quoted with a further Sitrick complaint, about advice on the Duchess of York, which is not about the addressees. The engagement-letter paragraph continues after the words quoted with an exchange between Sitrick, Epstein and Darren Indyke through April and May 2011 and ends at the sentence quoted; nothing in the remainder of it is attributed to Lefkowitz. This sheet prints “Mr. Lefkowitz” as quoted, read again at 600 dpi. Read at the image at 400 dpi. https://epstein-data.com/EFTA00593185 p.12. ↩ ↩2

  69. Same letter, its own p. 3, run p. 13, the last sheet: the amount due, the basis on which it is claimed, the closing paragraph, and a fluid mark off the baseline grid over the printed name “J. Michael Hennigan”, above the reference “JMH/ebm” and a copy line. One value on the copy line is covered and is not reproduced here. Read at the image at 400 dpi. https://epstein-data.com/EFTA00593185 p.13. ↩

  70. The two later invoices in the same run. Sitrick And Company to Jeffrey Epstein, 3 May 2011, for professional services and expenses through 23 April 2011, its pp. 6-8: professional fees $23,171.25, expenses $5,000.00, current fees and expenses $28,171.25, previous balance $71,319.07, balance due $99,490.32. And 8 June 2011, for professional services and expenses through 28 May 2011, its pp. 9-10: professional fees $4,027.50, expenses $0.00, previous balance $99,490.32, balance due $103,517.82; its own p. 2, the run’s p. 10, carries a one-line professional summary at 4.50 hours and a rate of 895.00, two service entries dated 29 and 30 April 2011, and the line “Total time charges 4.50 $4,027.50”. Both are addressed to Epstein and carry the same copy line to Kirkland & Ellis. Each figure above is read from the sheet, not computed. No bank, tax-identification or contact value on these sheets is reproduced here. Read at the image at 300 dpi. https://epstein-data.com/EFTA00593185 pp.6, 8, 9, 10. ↩ ↩2

  71. Letter, Jay P. Lefkowitz, P.C. (Kirkland & Ellis LLP) to Joshua Sussman, VP, General Counsel, Programming, IAC/InterActiveCorp, 29 June 2011, one sheet, marked “VIA HAND DELIVERY & FED EX”. One of the three reporters’ names is covered on this sheet and is not taken from this document. The signature is a fluid mark that sits off the baseline and overlaps the printed characters; the printed name beneath it reads “Jay P. Lefkowtiz”, which is how the sheet has it, while the letterhead at the head of the same sheet reads “Jay P. Lefkowitz, P.C.” The transposition was settled by re-rendering the block at 600 dpi. No contact value on this sheet is reproduced here. Read at the image at 400 dpi and the signature block again at 600 dpi. https://epstein-data.com/EFTA01110843 p.1. ↩

  72. Same invoice, its “Description of Legal Services”, the invoice’s own p. 3. The two entries quoted are his. On the same sheet an associate’s entries name the same lawyer as “B. Josefsberg” while his own entry names him “R. Josefsberg”; both are as printed. Read at the image at 400 dpi. https://epstein-data.com/EFTA01108745 p.3. ↩

  73. The second invoice in the same enclosure, also dated 14 July 2011 and also for legal services through 31 May 2011: two timekeepers, 40.70 hours, $39,964.00, on its own p. 2, and the March 2011 entries on its own p. 3. The entries are quoted as the sheet punctuates them, with semicolons. A box follows his printed name on every line. Read at the image at 400 dpi. https://epstein-data.com/EFTA00312716 pp.16-17. ↩

  74. Letter, Jay P. Lefkowitz (Kirkland & Ellis LLP) to Jeffrey Epstein c/o Darren Indyke, 14 July 2011, opening “Dear Mr. Indyke:”, the first sheet of the run. This is a colour scan and the signature is a blue cursive mark over the printed name. No routing, account, contact or address value from this sheet is reproduced here. Read at the image at 400 dpi. https://epstein-data.com/EFTA00312716 p.1. ↩ ↩2

  75. “Pre-Billing Report”, Podhurst Orseck, 10 November 2009, its own p. 1: client code 5502, client name “Kirkland & Ellis, LLP”, billing address “Kirkland & Ellis, LLP / Attn: Jay P. Lefkowitz, Esq.”, fees and costs billed through 31 October 2009, total $4,648.26. The image prints his name correctly; the corpus extraction of this sheet renders it “Jay P. Leibowitz. Esq.”, which is why the document is not returned by any correct spelling of the surname. The matter description is partly covered, and the fee detail on this and the following sheets concerns an individual complainant and is not used here. Read at the image at 400 dpi. https://epstein-data.com/EFTA00601013 p.1. ↩

  76. E-mail thread, Lesley Groff and Jay Lefkowitz, 23-24 May 2011, subject “Re: Jeffrey Epstein”, one sheet, read bottom-up. Her name is printed on this sheet, in the outer header, in both quoted header blocks and in the sign-off, and is taken from it; the sheet states no role, title or employer for her, and none is taken from it. Only the outermost header carries a time zone; the three inner stamps carry none and no clock time from them is printed here. The original invitation reads “WEd.” as quoted. No e-mail address on this sheet is reproduced here. Read at the image at 400 dpi. https://epstein-data.com/EFTA00433466 p.1. ↩

  77. Daily schedule for Wednesday 25 May 2011, circulated by e-mail on 24 May 2011 at 20:54:11 +0000, its own p. 1. The image prints “Breakfast with Jay Lefkowitz”; the corpus extraction renders the surname “Leflcowitz”, and no correct spelling of it returns this document. Contact values and one appointment’s participant are covered on this sheet and nothing else from it is used here. Read at the image at 400 dpi. https://epstein-data.com/EFTA00433556 p.1. ↩

  78. E-mail thread, 10 June 2013, subject “Re: privileged”, one sheet, read bottom-up: Scott D. Price to Steven Sinofsky and “Lefkowitz, Jay P.”, copying Jeffrey Epstein; Sinofsky’s reply; and Epstein’s answer at the head of the sheet. Only the outermost header carries a time zone. No employer is stated on the sheet for the writer of the advice and none is supplied here. Read at the image at 400 dpi. https://epstein-data.com/EFTA00962143 p.1. ↩

  79. E-mail, Jay Lefkowitz to Jeffrey Epstein, “Date: Fri, 15 Apr 2016 23:34:01 +0000”, one sheet. The header names an inline image, “IMG_0156.JPG”, which the release copy does not carry: the sheet shows a broken-image placeholder where it would be. His own e-mail address is covered. Read at the image at 400 dpi. https://epstein-data.com/EFTA00829354 p.1. Epstein’s reply, “Date: Sat, 16 Apr 2016 13:41:58 +0000”, quotes it back in full and is at https://epstein-data.com/EFTA00829368 p.1, which was read from the corpus text and not at the image. ↩

  80. The copy comparison. The same log page was rendered at 400 dpi from both copies and read side by side. The rows are word for word identical; the redaction is not. The docketed filing at https://epstein-data.com/EFTA00209306 p.5 names Department officials inside the descriptions, among them one of the Office of the Deputy Attorney General and not of the U.S. Attorney’s Office, and the copy at https://epstein-data.com/EFTA00185206 p.211 covers those names with solid boxes while leaving the folder titles that contain the same surnames untouched. The names this page uses are taken from the docketed filing. ↩

  81. “RESPONDENT’S INITIAL DISCLOSURES”, Jane Doe #1 and Jane Doe #2 v. United States, Case No. 08-80736-CIV-MARRA, filed by the United States and dated 20 July 2015, its own p. 7: the list of correspondence under Fed.R.Civ.P. 26(a)(1)(A)(ii), running from the 10 October 2007 letter to the 26 December 2007 letter. That list also opens with the Attorney General Guidelines for Victim and Witness Assistance (May 2005) and carries a “December 19, 2007 letter from R. Alexander Acosta to Lilly Ann Sanchez” between the December 11 and December 21 entries; neither names him, and the sequence given in the body above is of the entries that do. The First Assistant U.S. Attorney’s name is blacked out in the 6 December entry, and a contact block higher on the page is blacked out entirely, and the extraction of this page closes that gap without marking it. Read from the page image at 200 dpi, and again at 300 dpi for the two entries noted above. https://epstein-data.com/EFTA00210110 p.7. ↩

  82. Same disclosures, its own p. 8: the 2008 entries, including “May – June 2008 correspondence from Jay Lefkowitz and/or Kenneth Starr, to Deputy Attorney General [redacted]; Assistant Attorney General [redacted]; and Senior Associate Deputy Attorney General [redacted]” and “June 2008 letter [redacted], Senior Associate Deputy Attorney General, to Jay Lefkowitz and Kenneth Starr.” Each official’s name is covered by a box on the image; none is taken from this document. The page is signed off “DATED: July 20, 2015” above a boxed name and the printed line “UNITED STATES ATTORNEY”. Read from the page image at 200 dpi. https://epstein-data.com/EFTA00210110 p.8. ↩

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