Epstein Data Wiki

Jeffrey H. Sloman

Properties2
tagsperson, prosecutor, usao-sdfl, non-prosecution-agreement, victim-notification, justice-department, florida
aliasesJeffrey Sloman, Jeffrey H. Sloman, Jeff Sloman, Sloman, Jeffrey, Sloman, Jeff, J. Sloman

54 min read

What this page does not contain

Jeffrey Sloman was the second-ranking federal prosecutor in a case built on the accounts of teenage girls. Nothing any of them said appears on this page in any form: not quoted, not summarised, not characterised, not counted. No transcript of any deposition or hearing is cited here at all. The page is built instead on the second body of paper a prosecutor generates, the record of how the prosecution was conducted: letters he signed and received, the addendum he negotiated, the internal messages in which he gave instructions, the privilege logs in which his correspondence was later listed as withheld, and his own account of his conduct to the Justice Department’s internal investigators.

WhoCareer federal prosecutor. First Assistant United States Attorney for the Southern District of Florida from October 2006, with his office beside the U.S. Attorney’s in the Miami executive suite1
ThenSenior official supervising the Epstein matter from December 2008, after Alex Acosta was recused; Acting U.S. Attorney from June 2009; Interim U.S. Attorney by the Attorney General’s appointment in January 20101
CareerJoined the office in 1990 as a line prosecutor; Deputy Chief of the Fort Lauderdale narcotics and violent crimes section in 2001; Managing Assistant U.S. Attorney for that branch in 2003; Chief of the Criminal Division in early 20041
What he signedThe addendum to the non-prosecution agreement, on the office’s behalf, on 29 October 2007. The line prosecutor’s name was printed in the block; at her request he signed it instead2
The instructionOn 7 December 2007, asked for permission to post the letters that would tell Epstein’s victims what the office had agreed, he replied: “Hold the letter.”3
In his own words, the day before”The victims identified through the federal investigation should be appropriately informed, and our Non-Prosecution Agreement does not require the U.S. Attorney’s Office to forego [sic] its legal obligations.”4
Left the officeJune 2010, for private practice1

Jeffrey H. Sloman was the second in command of the United States Attorney’s Office that agreed not to charge Jeffrey Epstein. He had, in the Justice Department’s own words, “relatively little involvement in the decisions and negotiations that led to” the non-prosecution agreement, and he was on holiday when it was signed. What he did do is on the paper: he negotiated and signed its addendum, signed the correspondence that held Epstein to it, set the deadline on which the office threatened to tear it up, and on 7 December 2007 told the line prosecutor to hold the letters that would have told Epstein’s victims what had been done.1253

The Justice Department’s internal investigators reported in November 2020. They cleared him of professional misconduct and, in the same report, named him and the U.S. Attorney as the two officials who had taken “the unusual step of deciding to vet the USAO victim notification letters with the defense after the NPA was signed”.6

Where he sat

The office’s own hierarchy is set out in the Justice Department’s November 2020 report on the case. Sloman joined the United States Attorney’s Office for the Southern District of Florida in 1990 as a line prosecutor, became Deputy Chief of the Fort Lauderdale branch’s narcotics and violent crimes section in 2001 and the branch’s Managing Assistant U.S. Attorney in 2003, and was appointed Chief of the Criminal Division in early 2004. In October 2006 he became First Assistant United States Attorney. The report records that his office “was located with Acosta’s in the Miami office’s executive suite” and that as First Assistant he “was responsible for supervising the Civil, Criminal, and Appellate Divisions, and he was part of the supervisory team that oversaw the Epstein investigation.”1

The same paragraph states the limit the report places on his role, and the page keeps it: “Although Sloman had relatively little involvement in the decisions and negotiations that led to the NPA and did not review it before it was signed, he personally negotiated an addendum to the NPA, which he signed on behalf of the USAO in October 2007.”1

May 2007: the indictment the office had not approved

The line prosecutor, A. Marie Villafaña, sent an 82-page prosecution memorandum dated 1 May 2007 to Acosta, Sloman, Criminal Division Chief Matthew Menchel, Andrew Lourie and her immediate supervisor, supporting a proposed 60-count indictment.7 She intended to charge by 15 May and the FBI planned to arrest Epstein immediately afterwards.8

Within days, and after learning that the FBI was planning a press conference, Sloman advised her:

[t]his Office has not approved the indictment. Therefore, please do not commit us to anything at this time.8

Three weeks later she asked him and Menchel for “a sense of the direction where we are headed”. Sloman later told the investigators that because of his responsibilities as First Assistant he left it to Menchel, “as a highly experienced trial attorney and the Criminal Division Chief, to work directly with Acosta,” and that it was Menchel and Lourie who conducted a “granular review” of the charging package.9

September 2007: away when it was signed

On 6 September 2007, “almost three weeks before the NPA was signed” in the report’s phrase, he wrote to the line prosecutor: “Please refresh my recollection. What is the ‘deal’ on the table?” She sent him the term sheet. He told the investigators that his question reflected the fact that as First Assistant he was involved in “a hundred other things” at that time.10

Her reply that day also reported that the Palm Beach police chief “wanted to know if the victims had been consulted about the deal.” Sloman forwarded her email to Acosta with a note that read, in full, “fyi.”10

He then went on holiday, telling Acosta and the line prosecutor that in his absence Lourie had agreed “to help finalize this.”11 The report’s own finding on the week that followed is flat: “Sloman was on vacation in the week preceding the signing, when many significant changes were made to the agreement, and he did not participate in drafting or reviewing the NPA before it was signed,” and he “did not see the final, signed version of the NPA until he returned.”11

The non-prosecution agreement was signed on 24 September 2007.

October 2007: the addendum, which he did negotiate and did sign

With Lourie gone, Sloman took over the negotiation of the addendum, and the report records that he “quickly came up against the problem Villafaña and Lourie had faced: the defense attorneys continued to negotiate provisions to which they had seemingly already agreed.”2 He sent the text of a proposed addendum to Jay Lefkowitz on 11 October 2007.12

On 22 October he answered Lefkowitz’s objections, rejecting some and agreeing to change certain language to “satisfy your concern,” and closed:

[T]his needs to be concluded. Alex and I believe that this is as far as we can go. Therefore, please advise me whether we have a deal no later than COB tomorrow …2

Lefkowitz answered the next day with a three-page letter to Acosta reiterating the Epstein team’s disagreements with the office’s reading of the agreement. Sloman forwarded it to the line prosecutor with a one-line note: “Wait [until] you see this one.”2

On 25 October 2007, the report records, he wrote to the person the office had selected to carry out a function under the agreement, setting out that person’s duties.13

On 29 October 2007 Epstein and his attorneys signed the addendum. The report records what happened on the government’s side of the signature page: “Villafaña’s name was printed as the USAO representative, but at Villafaña’s request, Sloman signed the addendum for her on behalf of the USAO.”2

Afterwards she emailed him thanking him for “the advice and the pep talk,” which the report says “apparently related to the defense attorneys’ allegation of impropriety concerning her initial selection of the private attorney to assist the victims.” She wrote that she worried “that the defense’s attacks on me could harm the victims.” He replied that counsel had “put an … insidious spin” on her role, and added: “I hope that you understand that these ad hominem attacks against you do not diminish in our eyes what you and the agents have accomplished.”14

November 2007: the office tells the defence it is obliged to notify

Through November 2007 the correspondence about whether, when and how Epstein’s victims would be told what had been agreed ran over Sloman’s name. The report records that he “informed Lefkowitz of the government’s need to meet its ‘statutory obligation (Justice for All Act of 2004) to notify the victims of the anticipated upcoming events and their rights associated with the agreement’” and of his intent to “notify the victims by letter after COB Thursday, November 29.”15

Lefkowitz objected that notifying the victims was “incendiary and inappropriate,” that the defence “should have a right to review and make objections to that submission prior to it being sent to any alleged victims,” and that if letters went out at all “it should happen only after Mr. Epstein has entered his plea.” On 28 November 2007, at Sloman’s instruction, the line prosecutor gave Lefkowitz the draft of the letter the government proposed to send.15

The office’s own internal traffic over the same weeks shows the letters being drafted around him. A file named “071113_Sloman_Ltr_to_Lefkowitz.wpd” was circulated on 13 November under a covering note that reads, in part: “Here it is. It is firm, but no response to the ‘feds are overreaching’ comment from the article.”15 On 29 November a colleague wrote, of a different letter going out over the U.S. Attorney’s name, “I haven’t written the Sloman letter yet (referenced in Footnote 1).”15 Late the following evening the second letter went to Acosta as “071130_Sloman_Ltr_to_Lefkowitz.pdf.”15 See the December 2007 victim notification letters for the full sequence of that correspondence.

December 2007: the letter, and then “Hold the letter”

This is the sequence the page exists to set out, and it runs over two days.

On 5 December 2007 Kenneth Starr and Lefkowitz wrote to Acosta that it was “wholly inappropriate” for the office to send the victim notification letter it had drafted “under any circumstances,” and urged him to withhold it until the defence could discuss the matter with Assistant Attorney General Alice Fisher.4

The following day the office answered, over Sloman’s signature. The report records that the line prosecutor was the letter’s primary author and that “Sloman approved and signed the letter”.16 What it said was that the government was obliged to notify:

Just as in 18 U.S.C. § 3771 [the CVRA], these sections are not limited to proceedings in a federal district court. Our Non-Prosecution Agreement resolves the federal investigation by allowing Mr. Epstein to plead to a state offense. The victims identified through the federal investigation should be appropriately informed, and our Non-Prosecution Agreement does not require the U.S. Attorney’s Office to forego [sic] its legal obligations.4

Answering the defence’s objection to telling victims they could contact the prosecutor or the FBI agent with questions, he wrote: “Again, federal law requires that victims have the ‘reasonable right to confer with the attorney for the Government in this case.’” And he told the defence: “The three victims who were notified prior to your objection had questions directed to Mr. Epstein’s punishment, not the civil litigation. Those questions are appropriately directed to law enforcement.” With the letter he sent Lefkowitz, for comment, a revised draft of the notification letter itself.4

On 7 December 2007 the line prosecutor prepared the letters and emailed Acosta and Sloman asking permission to send them. That same day Sloman received a letter telling him Epstein’s plea hearing had been put off to 4 January 2008 and asking the office to “hold off” sending the notifications until “we can further discuss the contents.” Starr and Lefkowitz separately delivered to Acosta two “independent ethics opinions” supporting the defence’s position. The report’s next sentence is the one that matters:

Sloman responded to Villafaña’s request with an email instructing her to “Hold the letter.”3

His own account of that instruction, given to the investigators more than a decade later, is that he “wanted to push the [victim notification] letter out,” but that what he wrote was “the product of me speaking to somebody,” and he “could not be definitive as to whom.” He said that once the agreement “looked like it was going to fall apart,” the office “had concerns that if we g[a]ve them the victim notification letter … and the deal fell apart, then the victims would be instantly impeached by the provision that you’re entitled to monetary compensation.”3

On the broader question he told the investigators he had been “proceeding under the belief that we were going to notify [the victims], even though it wasn’t a federal case. Whether we were required or not.”3

The sequence raises a question this page states as a question and not as a finding: on 6 December 2007 he signed a letter telling Epstein’s lawyers that federal law obliged the government to inform the victims, and on 7 December 2007 he told the prosecutor who had written it to hold the letters.43 The letters were not sent. See the December 2007 victim notification letters.

May 2008: the deadline, and the closed door

By May 2008 Epstein had still not pleaded guilty. On 19 May 2008 Sloman sent Lefkowitz a letter asking that all further communication about the case go to the line prosecutor or her immediate supervisor, and repeating that Acosta would not answer counsel’s emails or calls personally. He wrote that the office had “bent over backwards to exhaustively consider and re-consider” Epstein’s objections, but that “these objections have finally been exhausted,” and gave notice that the office would terminate the agreement unless Epstein complied with all of its terms by the close of business on 2 June 2008.5

The defence’s response was to go over his head and to say so. In a 27 May 2008 letter to Deputy Attorney General Mark Filip, Epstein’s counsel wrote that they had tried to resolve their concerns with the office, “[b]ut those avenues have now been shut down. Mr. Sloman’s letter purports to prohibit any further contact between Mr. Epstein’s defense team and U.S. Attorney Acosta, and instead requires us to communicate with the USAO only though Mr. Sloman’s subordinates.” They asked Filip to begin “with the rescission of the arbitrary, unfair, and unprecedented deadline that Mr. Sloman demands to have imposed in this case.”17

A Senior Associate Deputy Attorney General handling the matter instructed the office to rescind the deadline, and on 28 May 2008, nine days after setting it, Sloman told Lefkowitz it was postponed.5

A defence misconduct submission prepared for the Department sets out his 19 May letter paragraph by paragraph beside what it called “The Truth,” attributing to “Tab 1, May 19, 2008 Letter from J. Sloman, p. 5” the assertion that “[W]e obliged your request for an independent de novo review of the investigation and facilitated such review at the highest levels of the Department of Justice.”18 Two further sheets of the same submission quote the letter again: on the factual basis for the state charge, “Mr. Sloman refuses to provide the requested factual allegations, which the State cannot furnish, and now demands a two week deadline to comply”;19 and on compensation, his sentence that “The Agreement provides for a method of compensation for the victims such that they would be placed in the same position as if Epstein had been convicted of one of the enumerated offenses set forth in Title 18, United States Code Section, 2255.”20 Those are the defence’s characterisations of his letter, recorded here as such; the letter itself is cited through them.

On 3 June 2008 he sent the Deputy Attorney General’s office a long letter of his own, setting out the history of the negotiations and answering Epstein’s allegations of professional misconduct.21 Five years later, ordered to say what it was withholding from the two petitioners in the victims’ rights litigation, the office logged that letter as “6/3/08 Sloman Submission to the DAG” and withheld it, with its attachments, against four separate privileges.21 It is held at Submission to the Deputy Attorney General.

June 2008: an indictment that was never filed

The Department’s review ended on 23 June 2008 with the conclusion that federal prosecution was appropriate. At Sloman’s instruction the line prosecutor told Lefkowitz that Epstein had until the close of business on Monday 30 June 2008 to comply with the agreement.22

On Friday 27 June 2008 she submitted to Sloman and the Criminal Division Chief a “final final” proposed federal indictment of Epstein.22 Nearly two years later, on 23 March 2010, she sent a colleague a copy of a file named, in her subject line and again in the body of her message, “080627 final indictment w Sloman signature.wpd”. Her covering note calls it “an old indictment that has 1591(a)(1) and 1591(a)(2) charges, if you want to see how I did them.”23 The office resolved the investigation without a federal criminal charge.23

Over the same weekend, at his instruction, she asked Palm Beach police chief Michael Reiter to notify victims of the state plea hearing. On Saturday 28 June she emailed Sloman that Reiter “is going to notify victims about the plea.” The report records his reply in one word: “Good.”22

Epstein pleaded guilty in state court on 30 June 2008.

On 21 July 2008 the line prosecutor asked him whether the office’s notifications should point out that a statement Epstein’s publicist, Howard Rubenstein, had given to a New York newspaper contradicted the agreement. Sloman answered:

I don’t think it’s necessary to point out the NY Post article to those victims and in the next breath say that Rubenstein’s statement contradicts the agreement. I think our notice to them should give them some comfort over a tabloid story.24

2009 and 2010: Acting United States Attorney

Acosta was formally recused from the Epstein matter in December 2008, and from that point Sloman was the senior official in the office responsible for it. When Acosta left in June 2009 Sloman became Acting United States Attorney; in January 2010 the Attorney General appointed him Interim United States Attorney for the district.1

In March 2009 he met Alan Dershowitz in Miami for what Dershowitz afterwards called “a relaxed drink and conversation”. Dershowitz emailed to thank him for his “assurance that the feds will not interfere with how the Palm Beach sheriff administers” Epstein’s sentence “as long as he is treated like any similarly situated inmate.” Sloman’s written answer drew the line narrowly:

Regarding Mr. Epstein, the United States Attorney’s Office will not interfere with how the Palm Beach Sheriff’s Office administers the sentence imposed by the Court. That being said, this does not mean that the USAO condones or encourages the PBSO to mitigate the terms and conditions of his sentence. Furthermore, it does not mean that, if contacted for our position concerning alternative custody or in-home detention, we would not object. To be clear, if contacted we will object. Naturally, I also expect that no one on behalf of Mr. Epstein will use my assurance to you to affirmatively represent to PBSO that the USAO does not object to an alternative custody or home detention.25

A week later Dershowitz wrote again, this time thanking him for his “willingness to call the sheriff and advise him that your office would take no position on how he handled Epstein’s sentence,” as long as Epstein received no special treatment, and adding, “[L]et’s put any call off for a while.”25

On 15 June 2009, over the printed block “Jeffrey H. Sloman / Acting United States Attorney,” the office wrote to Lefkowitz, Roy Black and Jack Goldberger:

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. As soon as Notice is provided by the United States, we are told that Mr. Epstein “was relying on his lawyers” and had not intended to willfully breach the Agreement. Mr. Epstein, through those same lawyers, then undertakes a perfunctory “cure” and continues to enjoy the benefit of his bargain until he decides to breach yet again.26

The letter then lists the breaches. The first of the post-plea set is in the office’s own voice: “Mr. Epstein’s counsel obstructed our ability to abide by our obligations to notify the victims of the outcome of the federal investigation.”26 The letter closes over his name and title and is signed on the office’s behalf by an Assistant United States Attorney.26

Correspondence addressed to him personally continued into 2010. On 8 February 2010 Roy Black wrote to him about Epstein’s community control; the office answered on 11 February, declining to give advisory opinions on what would and would not breach the agreement and recording that Epstein and his counsel “may not make a representation to the State Attorney’s Office, the Court, or any victim that the U.S. Attorney’s Office agrees with, joins in, or does not oppose such a motion.”27

He left the office for private practice in June 2010.1

What the privilege logs show

When the office was ordered in 2013 to list what it was withholding from the two petitioners in the Crime Victims’ Rights Act litigation, a run of the folders it listed were titled by his name. They include “11/8/07 Lefkowitz to Sloman”; “11/13/07 Sloman to Lefkowitz (was this sent?)”; “12/6/07 Sloman to Lefkowitz”; “Draft ltr from Sloman to Lefkowitz re termination,” containing a draft letter dated “April , 2008” with the day of the month left blank; and “6/3/08 Sloman Submission to the DAG,” 131 Bates numbers for the letter and its attachments together.28

Two of those titles are findings in themselves. The office’s own file on its own letter of 13 November 2007 carries the parenthesis “(was this sent?)”, so the office could not say from its own records whether it had sent it.28 And a letter terminating the non-prosecution agreement was drafted in April 2008 with the day left blank, which is the shape of an instrument prepared and held rather than one sent.28 See the 2013 privilege logs and the second supplemental privilege log.

A separate log of the office’s email traffic lists message after message to or from him across the whole negotiation: guidance on the grand jury presentation in May 2007; the addendum to the prosecution memorandum; a chain of 7 August 2007 to a Department section chief; exchanges in September 2007 on revisions to the agreement; October 2007 messages about Epstein’s request to delay his change of plea; and a February 2008 message about his own correspondence of 25 February.29

What the Justice Department concluded

The Office of Professional Responsibility reported in November 2020. It concluded that none of the subject attorneys, Sloman among them, committed professional misconduct, either in resolving the investigation or in the government’s dealings with victims, on the ground that there was no clear and unambiguous duty under the Crime Victims’ Rights Act to consult victims before the agreement was signed because the investigation was resolved without a federal charge.6

It did not stop there:

It is unfortunate, and appears fundamentally unfair to the victims, that Acosta and Sloman (after Menchel and Lourie departed) took the unusual step of deciding to vet the USAO victim notification letters with the defense after the NPA was signed, but failed to go beyond the requirements of the CVRA or the 2005 Guidelines to consult with the victims before the NPA was signed.6

The report also records one episode he reported against himself. In January 2008 he took a telephone call from a former law partner who, in the report’s words, “represented one of the victims,” and who asked whether the federal government could still bring charges. Sloman refused to answer any question about the case, reported the contact to Acosta, and the office reported it to the Office of Professional Responsibility shortly afterwards. The report’s conclusion is that “[b]ecause Sloman refused to provide any information, OPR found no basis for finding that Sloman misled the attorney.”30

And it records, more than once, how little he said he remembered. He told the investigators that he had “little recollection of the Epstein case”; that he did not know how the decision to offer a two-year state plea was reached; that he “vaguely” remembered a dispute over computer evidence seized from Epstein’s house; and that in commenting on the draft report he asked not to be identified among the people on whom Acosta relied in reaching the resolution. Acosta, for his part, “specifically recalled having discussed the case with both Sloman and Menchel.”31

What this page does not say

  • It does not say he decided the case. The report is explicit that he had “relatively little involvement in the decisions and negotiations that led to the NPA,” and his own answers to the investigators disclaim knowledge of how the two-year resolution was reached. The page records the acts the paper attributes to him and no more.131
  • It does not say why he wrote “Hold the letter.” He told the investigators it was “the product of me speaking to somebody” and that he could not say whom; no document read for this page identifies that person, and the page draws no inference about who it was.3
  • It does not reproduce the letter he sent on 25 October 2007, and names neither its recipient nor the function that person was carrying out. The report records that the letter was sent and what it was about; this page goes no further than the report does.13
  • It does not quote a transcript. Thirteen of the 563 documents this page was scoped on are deposition or hearing transcripts. None is cited here, because none can be read for his acts without reading testimony about other people.32
  • It makes no allegation and records none. Where the record holds his own answer to something adverse, his answer is printed beside it.

How this page is scoped

The name in these files is not one string. Searching the released files for “Jeffrey Sloman” returns 191 documents; “Jeffrey H. Sloman” returns 219; and between them they share a single sheet. Those are not two spellings of one body of paper, they are two bodies of paper, and a page built on either alone would miss most of the other. Adding the form “Jeff Sloman,” which the office itself used in its address lines, adds a further 101 documents. Taken together with the index forms “Sloman, Jeffrey” and “Sloman, Jeff” and the initial forms “J. Sloman” and “Sloman, J.”, the searches return 563 documents, and that is the body of paper this page was scoped on.32

The surname on its own returns 822 documents, and not all of them are his. The same surname is borne in these files by a writer in an unrelated correspondence, by a cognitive scientist whose published work is discussed in unrelated material, by a cited author in a bibliography, by a law firm’s style, and by a reported case caption that has nothing to do with this matter. Every document used on this page carries a forename or an initial with the surname, or was read and identified from its own contents.32

Notes

Footnotes

  1. U.S. Department of Justice, 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 and Its Interactions with Victims during the Investigation, November 2020, filed as Government Exhibit 3, Document 204-3 in United States v. Maxwell, No. 1:20-cr-00330-PAE (S.D.N.Y.), 16 April 2021. EFTA02830776, p. 31 of the 348-sheet filing, the sheet whose own header reads “Page 31 of 348” and whose foot prints the narrative page number 5. Read at the page image at the served file’s native resolution of 96 pixels per inch; the image agrees with the released text on every span quoted here. The whole of his career paragraph and the two paragraphs that follow it are on that one sheet. Sheet count of the served file: 348, which matches this project’s index for the same identifier. On the resolution of the three numbering systems this document carries, see the note at 33. ↩ ↩2 ↩3 ↩4 ↩5 ↩6 ↩7 ↩8 ↩9 ↩10

  2. Same report, pp. 118 and 119 of the 348-sheet filing, the sheets whose own headers read “Page 118 of 348” and “Page 119 of 348” and whose feet print the narrative pages 92 and 93. The 22 October 2007 letter, the closing sentence, the forwarding note “Wait [until] you see this one,” the agreement on the addendum’s terms after a further draft and a telephone call, the signing by Epstein and his attorneys on 29 October 2007, and the sentence “Villafaña’s name was printed as the USAO representative, but at Villafaña’s request, Sloman signed the addendum for her on behalf of the USAO” are all on those two sheets. The narrative sentence that he “quickly came up against the problem Villafaña and Lourie had faced” is on p. 117 of the 348-sheet filing, the sheet whose own header reads “Page 117 of 348” and whose foot prints the narrative page 91. P. 119 was read at the page image at the served file’s native 96 pixels per inch and carries the quoted signature sentence exactly as given above; p. 118 was read in the released text only. Marks on p. 119 cover spans of its text; nothing under any of them is read, supplied or described here. On the spelling of the line prosecutor’s surname inside these quotations, see 34. EFTA02830776. ↩ ↩2 ↩3 ↩4 ↩5 ↩6

  3. Same report, p. 241 of the 348-sheet filing, the sheet whose own header reads “Page 241 of 348” and whose foot prints the narrative page 215. Read at the page image at the served file’s native 96 pixels per inch; every span quoted here is on that sheet. See 34 on the one word where the image and the released text part company. “Hold the letter”; “wanted to push the [victim notification] letter out”; “the product of me speaking to somebody”; “although he could not be definitive as to whom”; the “instantly impeached” passage, quoted with the report’s own ellipses; and “proceeding under the belief that we were going to notify [the victims], even though it wasn’t a federal case. Whether we were required or not.” Two marks on this sheet cover spans of its text; nothing under either is read, supplied or described here, and the quotations above are broken at each mark rather than carried across it. A second defect in the released text was settled at the image: where the paper reads “Sloman, requesting”, the released text gives “Slornasuesting”, so that sentence too is quotable only from the paper. EFTA02830776. ↩ ↩2 ↩3 ↩4 ↩5 ↩6 ↩7

  4. Same report, pp. 239 and 240 of the 348-sheet filing, the sheets whose own headers read “Page 239 of 348” and “Page 240 of 348” and whose feet print the narrative pages 213 and 214. Both sheets were read at the page image at the served file’s native 96 pixels per inch. The 5 December 2007 letter is dated and described at the foot of the first of them: “On December 5, 2007, Starr and Lefkowitz sent a letter to Acosta, with copies to Sloman and Assistant Attorney General Fisher …”. Everything else quoted here is on the second. Read at the page image at the served file’s native 96 pixels per inch, and the image carries every one of the spans quoted here. The Starr and Lefkowitz demand of 5 December 2007, the sentence “The following day, Sloman sent a letter to Lefkowitz, with copies to Acosta and Villafaña”, the indented quotation from that letter, the “reasonable right to confer” sentence, the “three victims” sentence and the forwarding of the revised draft are all on that single sheet, which carries no producer mark of any kind. The italics on federal and the bracketed sic after “forego” are the report’s own and are reproduced. One defect in the released text was settled at the image on this sheet: where the paper reads “the acceptance of a plea” followed by a footnote marker, the released text gives “a *tom”, so that sentence is quotable only from the paper. EFTA02830776. ↩ ↩2 ↩3 ↩4 ↩5

  5. Same report, p. 134 of the 348-sheet filing, the sheet whose own header reads “Page 134 of 348” and whose foot prints the narrative page 108. Read at the page image at the served file’s native 96 pixels per inch; the image agrees with the released text on every span quoted here. “That same day, Sloman sent Lefkowitz a letter asking that all further communication about the case be made to Villafaña or her immediate supervisor, and reiterating that Acosta would not respond personally to counsel’s email or calls. Sloman noted that the USAO had ‘bent over backwards to exhaustively consider and re-consider’ Epstein’s objections, but ‘these objections have finally been exhausted.’ Sloman advised that the USAO would terminate the NPA unless Epstein complied with all of its terms by the close of business on June 2, 2008.” The rescission of the deadline on 28 May 2008 is on the same sheet. This sheet carries no producer mark. EFTA02830776. ↩ ↩2 ↩3

  6. Same report, two sheets and the executive summary. p. 282 of the 348-sheet filing, narrative page 256: “OPR concludes that none of the subject attorneys violated a clear and unambiguous duty under the CVRA because the USAO resolved the Epstein investigation without” a federal charge. p. 12 of the same filing, in the executive summary, which carries no narrative page number: “OPR further concludes that none of the subject attorneys committed professional misconduct with respect to the government’s interactions with victims. The subjects did not have a clear and unambiguous duty under the CVRA to consult with victims before entering into the NPA because the USAO resolved the Epstein investigation without a federal criminal charge.” The indented quotation is from p. 306 of the 348-sheet filing, the sheet whose own header reads “Page 306 of 348” and whose foot prints the narrative page 280, under the report’s heading “THE GOVERNMENT FAILED TO TREAT VICTIMS FORTHRIGHTLY AND WITH SENSITIVITY WHEN IT FAILED TO TIMELY PROVIDE VICTIMS WITH IMPORTANT INFORMATION ABOUT THE RESOLUTION OF THE FEDERAL INVESTIGATION”. Released text only. The five subject attorneys are named together on p. 307 of the 348-sheet filing, the sheet whose own header reads “Page 307 of 348” and whose foot prints the narrative page 281. The remainder of p. 306 sets out one individual’s dealings with the office and is not read, quoted, summarised or characterised here. EFTA02830776. ↩ ↩2 ↩3

  7. Same report, p. 51 of the 348-sheet filing, the sheet whose own header reads “Page 51 of 348” and whose foot prints the narrative page 25: Villafaña “drafted an 82-page prosecution memorandum directed to Acosta, Sloman, Menchel (who had replaced Sloman as the USAO’s Criminal Division Chief the previous October, when Sloman became the FAUSA), Lourie, and her immediate supervisor”, supporting a proposed 60-count indictment. The quotation stops before the date, because the released text of this sheet renders the day as the capital letter I. The date 1 May 2007 is taken instead from p. 226 of the same filing, which prints “Villafaña’s May 1, 2007 draft indictment” cleanly. Released text only. See 34. EFTA02830776. ↩

  8. Same report, p. 53 of the 348-sheet filing, the sheet whose own header reads “Page 53 of 348” and whose foot prints the narrative page 27: “When she submitted the prosecution memorandum, Villafaña intended to file charges by May 15, 2007, and the FBI planned to arrest Epstein immediately thereafter.” And: “Just a few days after he received the prosecution memorandum, and after learning that the FBI was planning a press conference for May 15, Sloman advised Villafaña that ‘[t]his Office has not approved the indictment. Therefore, please do not commit us to anything at this time.’” Quoted whole, including the report’s own bracketed lower-case opening. Released text only. See 34. EFTA02830776. ↩ ↩2

  9. Same report, pp. 53 and 56 of the 348-sheet filing, the sheets whose own headers read “Page 53 of 348” and “Page 56 of 348” and whose feet print the narrative pages 27 and 30. The “granular review” passage and Acosta’s confirmation that “Sloman and Menchel ‘were a team’” are on the first; the 21 May 2007 request for “a sense of the direction where we are headed” is on the second. Released text only. EFTA02830776. ↩

  10. Same report, pp. 87 and 88 of the 348-sheet filing, whose feet print the narrative pages 61 and 62, and p. 285 of the 348-sheet filing, the sheet whose own header reads “Page 285 of 348” and whose foot prints the narrative page 259, which sets out the 6 September 2007 exchange a second time in the report’s findings. “Please refresh my recollection. What is the ‘deal’ on the table?”; “a hundred other things”; the police chief “wanted to know if the victims had been consulted about the deal”; and “Sloman forwarded Villafaña’s email to Acosta with a note that read simply, ‘fyi.’” Released text only. See 34. EFTA02830776. ↩ ↩2

  11. Same report, three sheets. p. 95 of the 348-sheet filing, narrative page 69: “At this point, Sloman left on vacation, and he informed Acosta and Villafaña that in his absence Lourie had agreed ‘to help finalize this.’” p. 160, narrative page 134: “Sloman was absent during part of the most intense negotiations in September 2007 and did not see the final, signed version of the NPA until he returned.” p. 211, narrative page 185: “Sloman was on vacation in the week preceding the signing, when many significant changes were made to the agreement, and he did not participate in drafting or reviewing the NPA before it was signed.” Released text only. See 34. EFTA02830776. ↩ ↩2

  12. Same report, p. 186 of the 348-sheet filing, the sheet whose own header reads “Page 186 of 348” and whose foot prints the narrative page 160: “Sloman sent the text of a proposed NPA addendum to Lefkowitz on October 11, 2007.” Released text only. EFTA02830776. ↩

  13. Same report, p. 119 of the 348-sheet filing, the sheet whose own header reads “Page 119 of 348” and whose foot prints the narrative page 93: “On October 25, 2007, Sloman sent a letter to the person whom the USAO had selected to serve as special” and, after a mark, ”, outlining the special” and, after a second mark, “duties.” Read at the page image, where the sentence carries a comma after the year that the released text of the sheet omits. Marks on that sheet cover spans of the sentence quoted; nothing under either is read, supplied or described here, and the quotation is broken at each mark rather than carried across it. EFTA02830776. ↩ ↩2

  14. Same report, p. 119 of the 348-sheet filing, the sheet whose own header reads “Page 119 of 348” and whose foot prints the narrative page 93. Read at the page image at the served file’s native 96 pixels per inch. Quoted as the report prints it, including its own ellipsis inside “put an … insidious spin”. See 34. EFTA02830776. ↩

  15. Two kinds of document. (1) The report, p. 239 of the 348-sheet filing, the sheet whose own header reads “Page 239 of 348” and whose foot prints the narrative page 213, read at the page image at the served file’s native 96 pixels per inch: the “statutory obligation (Justice for All Act of 2004)” sentence; the intent to “notify the victims by letter after COB Thursday, November 29”; Lefkowitz’s objections, quoted as the report quotes them; and “On November 28, 2007, at Sloman’s instruction, Villafaña provided Lefkowitz with the draft victim notification letter”. See 34. EFTA02830776. (2) Three internal emails of the United States Attorney’s Office, each a single-sheet item. The first two were read at the page image at the served file’s native 96 pixels per inch; the third in the released text only. Subject: Response to Jay Lefkowitz re Epstein, Date: Tue, 13 Nov 2007 15:18:39 +0000, Attachments: 071113_Sloman_Ltr_to_Lefkowitz.wpd, the body reading, in part, “Here it is. It is firm, but no response to the ‘feds are overreaching’ comment from the article.” The message continues and the remainder is not quoted here. The same file name appears a second time in the body with spaces in place of the underscores; the form given above is the one the attachments line prints. EFTA01659905. Subject: Letter -- Please review, Date: Thu, 29 Nov 2007 22:56:25 +0000, Attachments: 071129_Acosta_Letter_to_Starr.pdf, the body reading, in part: “Sorry. Can you look at this and let me know if it is alright? I need to send it to the bigwigs tonight. I haven’t written the Sloman letter yet (referenced in Footnote 1). Thx” EFTA01659895. Date: Sat, 01 Dec 2007 03:53:52 +0000, which on the Eastern clock is the evening of Friday 30 November, attaching “071130_Sloman_Ltr_to_Lefkowitz.pdf” and the same letter in WordPerfect. EFTA01659885. Marks on all three sheets cover fields in the message headers and, on the first, part of the signature block; nothing under any of them is read, supplied or described here, and none of the three messages is attributed to any individual on this page. Both sheets double-space after a sentence; this page sets the quotations with single spaces and alters nothing else about them. ↩ ↩2 ↩3 ↩4 ↩5

  16. Same sheet, its footnote 315, read at the page image: “Emphasis in original. Sloman also stated that the USAO did not seek to ‘federalize’ a state plea, but ‘is simply informing the victims of their rights.’ Villafaña informed OPR that Sloman approved and signed the letter, but she was the primary author of the document. OPR notes that Villafaña was the principal author of most correspondence in the Epstein case, and that following the signing of the NPA, regardless of whether the letter went out with her, Sloman’s, or Acosta’s signature, the three attorneys reviewed and edited drafts of most correspondence before a final version was sent to the defense.” EFTA02830776. ↩

  17. Letter to the Honorable Mark Filip, 27 May 2008, its own second sheet, which the sheet itself heads “Honorable Mark Filip / May 27, 2008 / Page 2”: “We have attempted to resolve these and other issues through the USAO and CEOS, including raising our concerns about the USAO’s inappropriate conduct with respect to this matter. But those avenues have now been shut down. Mr. Sloman’s letter purports to prohibit any further contact between Mr. Epstein’s defense team and U.S. Attorney Acosta, and instead requires us to communicate with the USAO only though Mr. Sloman’s subordinates.” And: “beginning with the rescission of the arbitrary, unfair, and unprecedented deadline that Mr. Sloman demands to have imposed in this case.” The released text of this sheet renders the abbreviation USAO as “USA()” in four places; the quotations above give the word as the sentence states it and the damaged characters are not quoted. HOUSE_OVERSIGHT_019222, a single-sheet item. Released text only. This is the defence’s characterisation of his letter, not the letter. ↩

  18. “SUMMARY OF MISCONDUCT ISSUES IN THE MATTER OF JEFFREY E. EPSTEIN”, Kirkland & Ellis LLP, its own first and second sheets, the second of which opens a response to a letter of 19 May 2008 and cites “Tab 1, May 19, 2008 Letter from J. Sloman, p. 5” against the quoted assertion “[W]e obliged your request for an independent de novo review of the investigation and facilitated such review at the highest levels of the Department of Justice.” EFTA00208767 pp. 7 and 8 of an eight-sheet run. Released text only. Several names on these sheets are covered by the producer; nothing under any of those marks is read, supplied or described here, and the attribution above rests only on the citation line “Tab 1, May 19, 2008 Letter from J. Sloman, p. 5”, which the sheet prints in clear. This is the defence’s account of his letter, not the letter. ↩

  19. Same submission, the sheet whose foot prints the page number 5: “Mr. Sloman refuses to provide the requested factual allegations, which the State cannot furnish, and now demands a two week deadline to comply. Thus Mr. Sloman has unreasonably imposed a deadline with which he himself has made it impossible for Mr. Epstein to comply.” The same sheet quotes his letter directly under the heading “5. WAIVER OF APPEAL TO ASSISTANT ATTORNEY GENERAL FISHER” as “Mr. Sloman’s Letter: ‘[T]he SDFL provided you with 30 days to appeal the decision to the Assistant Attorney General of the United States Alice Fisher’ and ‘you chose to forego an appeal to AAG Fisher.’” HOUSE_OVERSIGHT_012176, a single-sheet item. Released text only. The passages on this sheet about individual witnesses are not read, quoted, summarised or characterised here. ↩

  20. Same submission, the sheet whose foot prints the page number 7, under the heading “8. ALL IDENTIFIED VICTIMS BE PUT IN SAME POSITION AS IF EPSTEIN HAD BEEN TRIED”: “Mr. Sloman’s Letter: ‘The Agreement provides for a method of compensation for the victims such that they would be placed in the same position as if Epstein had been convicted of one of the enumerated offenses set forth in Title 18, United States Code Section, 2255.’” The comma before “2255” is the sheet’s own. HOUSE_OVERSIGHT_012178, a single-sheet item. Released text only. The remainder of this sheet concerns individual women on the government’s list and is not read, quoted, summarised or characterised here in any respect. ↩

  21. Two documents. (1) The report, p. 135 of the 348-sheet filing, the sheet whose own header reads “Page 135 of 348” and whose foot prints the narrative page 109: “On June 3, 2008, Sloman sent to Roth a lengthy letter from Sloman to the Deputy Attorney General, recounting in detail the history of negotiations with Epstein’s counsel culminating in the NPA, and addressing Epstein’s claims of professional misconduct.” The same sheet records that Roth “limited his review to written materials submitted by Epstein’s attorneys and by Sloman to the Deputy Attorney General’s office”. Released text only. EFTA02830776. (2) “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.), its own third sheet of fourteen: 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”, withheld against Attorney-Client Privilege, Deliberative Process, Work Product and Investigative privilege. EFTA00209306 p. 5 of a sixteen-sheet run. Released text only. ↩ ↩2

  22. Same report, p. 257 of the 348-sheet filing, the sheet whose own header reads “Page 257 of 348” and whose foot prints the narrative page 231: the 23 June 2008 determination; “Immediately thereafter, at Sloman’s instruction, Villafaña notified Lefkowitz that Epstein had until ‘the close of business on Monday, June 30, 2008, to comply with the terms and conditions of the agreement’”; “Also on that Friday, Villafaña submitted to Sloman and Criminal Division Chief Senior a ‘final final’ proposed federal indictment of Epstein”; “at Sloman’s instruction, Villafaña contacted PBPD Chief Reiter to ask him to notify the victims of the plea hearing”; “On Saturday, June 28, 2008, Villafaña emailed Sloman to inform him that PBPD Chief Reiter ‘is going to notify victims about the plea.’”; and, in footnote 352 at the foot of the same sheet, “Sloman replied, ‘Good.’” Read at the page image at the served file’s native 96 pixels per inch. A fifth defect in the released text was settled there: the released text of footnote 352 gives a full stop after “replied” where the paper carries a comma. See 34. EFTA02830776. ↩ ↩2 ↩3

  23. Internal email of the United States Attorney’s Office for the Southern District of Florida, subject “Emailing: 080627 final indictment w Sloman signature.wpd”, dated Tue, 23 Mar 2010 15:02:16 +0000, from the line prosecutor to a colleague in the same office, attaching “080627_final_indictment_w_Sloman_signature.wpd”. The body reads: “Hi Strider — This is an old indictment that has 1591(a)(1) and 1591(a)(2) charges, if you want to see how I did them. Just double check that the statute language hasn’t changed.” The file name is printed three times on the sheet. The subject line and the body both give it as “080627 final indictment w Sloman signature.wpd”; the attachments line gives it as “080627_final_indictment_w_Sloman_signature.wpd”. A fourth defect in the released text was settled at the image here: the released text renders the attachments line with stray spaces, as “080627 _ final _indictment_w_Sloman_signature.wpd”, which the paper does not carry. This sheet carries no producer mark of any kind: the sender and the recipient are both printed in clear. EFTA00212161, a single-sheet item, read at the page image at the served file’s native 96 pixels per inch. This footnote establishes the existence and the name of a file; it does not establish that any signature was applied, and no copy of the file itself is among the documents read for this page. The statement that no federal charge was brought rests on the report’s own finding, on p. 12 and again on p. 282 of the same filing, that “the USAO resolved the Epstein investigation without a federal criminal charge”. ↩ ↩2

  24. Email within the United States Attorney’s Office for the Southern District of Florida, Monday, July 21, 2008, 3:52 PM, subject “RE: Epstein”, answering a message of 3:47 PM the same day. Read at the page image at the served file’s native 96 pixels per inch. EFTA00190318 p. 261 of a 446-sheet run, the sheet whose own foot prints the page number 251; the served file’s sheet count matches this project’s index. The message is attributed to him from the sheet’s own From line. Quoted whole and verbatim. The 3:47 PM message it answers, and the material quoted within that message, concern individual women and are not read, quoted, summarised or characterised here; what is stated above is only the question put to him, which is that message’s closing sentence: “Should I include anything about how Mr. Rubenstein’s statement to the New York Post directly contradicts Epstein’s agreement?” Several marks on this sheet cover fields in the message headers and part of the signature block; nothing under any of them is read, supplied or described here. ↩

  25. Same report, p. 143 of the 348-sheet filing, the sheet whose own header reads “Page 143 of 348” and whose foot prints the narrative page 117. The March 2009 meeting, “a relaxed drink and conversation”, the Dershowitz email, the indented reply quoted whole, and the further email a week later are all on that one sheet, which carries no producer mark. Read at the page image at the served file’s native 96 pixels per inch, and a third defect in the released text was settled there: the released text joins two words as “ofhis” where the paper reads “of his”, so the quotation above is given from the paper. EFTA02830776. ↩ ↩2

  26. Letter, United States Attorney’s Office for the Southern District of Florida to Jay P. Lefkowitz, Roy Black and Jack A. Goldberger, 15 June 2009, headed “DELIVERY BY ELECTRONIC MAIL” and “Re: Jeffrey Epstein”. Read at the page image at the served file’s native 96 pixels per inch, on three of its four sheets. EFTA00213048 pp. 2, 3 and 5 of a 135-sheet run, which are the letter’s own pages 1, 2 and 4 of 4 as it numbers itself; the served file’s sheet count matches this project’s index. The indented quotation and the sentence “Mr. Epstein’s counsel obstructed our ability to abide by our obligations to notify the victims of the outcome of the federal investigation” are on p. 3 of the run, which the sheet itself heads “PAGE 2 OF 4”. The closing block on p. 5 of the run, which the sheet heads “PAGE 4 OF 4”, prints “Sincerely,” then “Jeffrey H. Sloman” and “Acting United States Attorney”, then “By:” against a signature and the printed line “Assistant United States Attorney”. Marks on p. 5 cover part of the signature block and part of the distribution line; nothing under any of them is read, supplied or described here. ↩ ↩2 ↩3

  27. Two documents. (1) Letter, United States Attorney’s Office for the Southern District of Florida to Roy Black, 11 February 2010, both of its sheets, which the second heads “ROY BLACK, ESQ. / FEBRUARY 11, 2010 / PAGE 2 OF 2”: “As we have told you before, our Office cannot give advisory opinions as to what will and will not be a breach of the Non-Prosecution Agreement”; “As to the third item, we have reviewed your letter to Mr. Sloman of February 8, 2010”; and “Mr. Epstein and his counsel may not make a representation to the State Attorney’s Office, the Court, or any victim that the U.S. Attorney’s Office agrees with, joins in, or does not oppose such a motion.” EFTA00212179, a two-sheet letter. Released text only. (2) Internal email of the same office, subject “Sloman.pdf - Adobe Acrobat Professional”, dated Mon, 08 Feb 2010 20:47:16 +0000, attaching “Sloman.pdf”, whose body reads in full: “Attached please find a pdf of a letter being mailed today.” EFTA00213289, a single-sheet item. Released text only. It is cited only for the fact that a document under that name was circulated in the office on the day the 11 February letter gives for Black’s letter to him. ↩

  28. “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 docket 27 July 2013. Its own second sheet of fourteen carries the folder entries “11/8/07 Lefkowitz to Sloman” and “11/13/07 Sloman to Lefkowitz (was this sent?)”; its own third sheet carries “12/6/07 Sloman to Lefkowitz”, “Draft ltr from Sloman to Lefkowitz re termination” and “6/3/08 Sloman Submission to the DAG”. The termination folder is described as containing a “draft letter dated ‘April , 2008’ from J. Sloman to J. Lefkowitz concerning the compliance with the Agreement”, with the day of the month left blank in the log’s own quotation of the draft’s date line. Read from two copies: EFTA00185206 pp. 210 and 211 of a 310-sheet run, and EFTA00209306 p. 5 of a sixteen-sheet run. Released text only. The observation that an instrument drafted with its day left blank has the shape of one prepared and held is this page’s reading of the log entry and is offered as a reading, not as a finding about what the office did with the draft. ↩ ↩2 ↩3

  29. A log of the office’s email traffic filed in the same litigation, listing by date and Bates range messages to and from “Jeff Sloman”. The subjects it records, described here rather than quoted: guidance on the grand jury presentation, 21 May 2007; an addendum to the prosecution memorandum and the grand jury presentation, undated; a summary of a proposal, 31 July 2007; a chain of 7 August 2007 from him to Andrew Oosterbaan, the line prosecutor and Acosta; messages of 6 September 2007; proposed revisions to the non-prosecution agreement, in a chain with Acosta, the line prosecutor, Lourie and Garcia; Epstein’s request to delay his change of plea, 18 October 2007; efforts by Epstein’s counsel, 19 November 2007; a challenge to the state charge, 19 December 2007; renewed plea negotiations for federal charges, 2 January 2008; a Lefkowitz email about a lawsuit, 30 January 2008; and his own correspondence of 25 February, in a message of 26 February 2008. EFTA01325051, pp. 3 to 16 of a twenty-sheet run. Released text only. Nothing in this footnote is quoted, and that is deliberate. Several of the log’s descriptions run out at the right-hand edge of the released text of these sheets. Whether the words are cut on the paper or only in the released text has not been checked at the page image, so the page completes none of them inside quotation marks and reports the subjects in its own words instead. This is a container listing and no confirmation on this page rests on it: every act attributed to him in the body is sourced to a document read for this page, and the log is cited only to show the volume and the subjects of the correspondence the office later withheld. ↩

  30. Same report, pp. 250 and 306 of the 348-sheet filing, whose own headers read “Page 250 of 348” and “Page 306 of 348” and whose feet print the narrative pages 224 and 280: “In January 2008, Sloman received a telephone call from his former law partner, who represented one of the victims and who asked Sloman whether the federal government could bring charges against Epstein. Sloman, concerned about the potential for conflict of interest allegations due to his prior business relations with the attorney, refused to answer any questions regarding Epstein. … Because Sloman refused to provide any information, OPR found no basis for finding that Sloman misled the attorney.” The first sheet records that “Because Sloman and the attorney were former legal practice partners, Sloman reported the interaction to Acosta, and the USAO reported the incident to OPR shortly thereafter.” Released text only. Neither the attorney nor his client is named here. EFTA02830776. ↩

  31. Same report, four sheets. p. 63 of the 348-sheet filing, narrative page 37: “In commenting on OPR’s draft report, Sloman stated he had no involvement in assessing the Epstein case or deciding how to resolve it, and that OPR should not identify him as among the people upon whom Acosta relied in reaching the two-year-state-plea resolution through the NPA.” And: “However, Sloman also told OPR that he had little recollection of the Epstein case, while Acosta specifically recalled having discussed the case with both Sloman and Menchel.” p. 206, narrative page 180: “Sloman told OPR that he had no idea how the two-year sentence proposal was reached.” p. 204, narrative page 178: “Sloman told OPR during his interview that he ‘vaguely’ remembered the computer issue.” p. 167, narrative page 141: “However, Sloman was included in numerous emails discussing the merits of and issues relating to the investigation, participated in meetings with the defense team, and, according to Acosta, was one of the senior managers whom Acosta consulted in determining how to resolve the Epstein investigation.” Released text only. EFTA02830776. ↩ ↩2

  32. How the searches were run, and what they returned. All figures are counts of documents in the full-text search index this project maintains over the released files, taken in a single run on 27 October 2026 against a known-positive control that returned 752,295 sheets and a nonsense control that returned none. Documents are counted by stripping the sheet suffix from each sheet identifier. “Jeffrey Sloman” returns 191 documents across 423 sheets; “Jeffrey H. Sloman” returns 219 documents across 315 sheets; and the two forms share exactly one sheet, so neither is a subset of the other. “Jeff Sloman” returns 162 documents across 552 sheets, a form the office used in its own address lines. “J. Sloman” and “Sloman, J.” return 50 and 10 documents; the index forms “Sloman, Jeffrey” and “Sloman, Jeff” return 7 and 84. The union of all of those is 563 documents, against 379 for the three full-name and index forms alone. Three further spellings that the scan produces for the surname return 25 documents between them, 6 of which carry no clean spelling of the surname on any sheet. None of those 25 is cited on this page. Tested and returning nothing: “Jeffery Sloman”, “Geoffrey Sloman”, “Sloman, Jeffrey H.”, “J. H. Sloman”, and two further scan corruptions of the surname. The initials “JHS” return 21 documents. Ten of the twenty-one were read: on those ten the string is the abbreviation for a junior high school, the name of a supplement maker, or incidental characters inside encoded text, and on none of them is it his initials. The bearer question. The surname alone returns 822 documents. Read by which forename or initial stands beside it, and by the contents of the sheet where none does, those 822 divide as: 563 carrying a Jeffrey, Jeff, J. or H. form; 192 carrying the surname alone on a sheet whose other contents are this matter; 28 in bibliographies citing a different author of the same surname; 19 naming a different person in full, a cognitive scientist, and 2 more discussing that person’s published work by surname alone; 5 naming a writer; 4 giving a law firm’s style; 1 a reported case caption unrelated to this matter; and 8 that the sheet alone does not settle. Those figures sum to 822. On transcripts: of the 563 documents, thirteen are deposition or hearing transcripts, eight of the first kind and five of the second. None of the thirteen is cited on this page, because a transcript cannot be read for what he did without reading testimony about other people, and that is a hard exclusion here. Three of the eight unsettled are discussions of the cognitive scientist’s published work and five are messages in this matter whose sheets carry no forename. ↩ ↩2 ↩3

  33. This document prints two numbers on each narrative sheet and the project’s index supplies a third. The electronic filing header at the top of each sheet reads “Page N of 348”; the foot of each narrative sheet prints the report’s own page number, which runs 26 behind the filing header; and the released text of each sheet ends with a further identifier that, on every sheet of this document read at the image for this page, is not printed on the paper at all. This page therefore cites the filing header and the report’s own printed page number, both of which a reader can see on the sheet, and derives nothing. ↩

  34. On the spelling of the line prosecutor’s surname inside quotations from this report. The released text of this filing renders it inconsistently: “Villafafia”, “Villafaiia”, “Villafalia”, “Villafafta”, “Villafatia” and “Villaftuia” all occur, and on one sheet the released text joins it to the following word. On every one of the eight sheets of this document read at the page image for this page (pp. 31, 119, 134, 143, 239, 240, 241 and 257), the paper carries “Villafaña” with the tilde. Every quotation on this page therefore gives the spelling the paper carries. Where a sheet of this report was read only in the released text, the spelling is still given as “Villafaña”, on the strength of those eight image reads of the same printed document, and that normalisation is disclosed here rather than made silently. It is the only normalisation made inside any quotation on this page, and no other character, word, punctuation mark or elision has been altered anywhere. ↩ ↩2 ↩3 ↩4 ↩5 ↩6 ↩7 ↩8 ↩9

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