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KIRKLAND & ELLIS LLP See Tab 1, May 19, 2008 Letter from J. Sloman, p. 4, 4 1. The Truth: e The defense engaged in days of negotiation and made 14 separate substantive objections to the unprecedented notification letter that Mr. Sloman threatened to send to an undisclosed list of “victims.” The eventual transmission of this highly misleading letter was only halted by an appeal to AAG Fisher. Among those substantive objections (which related to far more than the “time and place” of the state’s sentencing hearing) were: o Sending the letter would contravene the government’s commitment to take no position regarding potential claims of government witnesses. See Tab 39, November 28, 2008 Email from J. Lefkowitz to J. Sloman. © The letter cited to an inapplicable statute (the Justice for All Act of 2004) as its justification for being sent. Jd. AUSA Acosta later conceded that the citation to this statute as a justification was wholly incorrect. o The letter wrongly advised all recipients that Mr. Epstein would be required to register as “a sexual predator for the remainder of this life.” o The letter amounted to an invitation to civil litigation against Mr. Epstein, advising recipients that they had the right to seek civil damages from Mr. Epstein, and in an underlined instruction, stated that if they chose an attorney other than the one chosen by the government they would be required to pay his fees, but if they chose the government’s choice, Mr. Epstein would be required to pay the fees. 3. MISCHARACTERIZATION OF OUR ARGUMENTS. Mr. Sloman’s Letter: ¢ Mr. Sloman’s letter misleadingly characterizes our substantive defense of the government’s investigation as, “the investigation merely produced evidence of relatively innocuous sexual conduct with some minors who, unbeknownst to Mr. Epstein, misrepresented their ages.” See Tab 1, May 19, 2008 Letter from J. Sloman, p. 2. The Truth: ¢ We never made such a claim. To the contrary, we argued that sworn statements we have taken of the alleged victims demonstrate that law enforcement has presented versions of their testimony that are necessarily sensationalized and fictionalized. We presented HOUSE_OVERSIGHT_012174