📄 Extracted Text (307 words)
March 29, 2010
Jeffrey Sloman MM.=
United States Attorney USAO — W Palm Beach
Address
Miami
Robert Senior
Address
Re Jeffrey Epstein
Dear Counsel
On April 5, 2010, Jeffrey Epstein has a deadline for filing a responsive Motion
to Dismiss and thereafter an Answer to claims brought by Jane Doe 103
pursuant to 18 USC 2255 that were referenced in our earlier letter to you dated
March 5, 2010 to which there has been no response. We firmly believe that the
issues raised in the draft motion that we append hereto do not conflict with nor, if
filed, breach Mr. Epstein's obligations under the NPA.
Please advise if any of the issues in the draft motion authored by his civil
counsel Robert Critton are, from your perspective, in conflict with the 2255
provisions of the NPA so that we may reassess our legal opinion that Mr.
Epstein's civil counsel can litigate the legal issues contained in the draft motion
without fear that the litigation will be construed by your Office as being in violation
of the NPA. If the Government believes that any of the issues intended to be
raised in defense of the Jane Doe 103 lawsuit are in breach of Mr. Epstein's
obligations under the NPA, we request notice so that we could decide before any
filing whether to file a Declaratory Judgment action asking the Court presiding
over the Jane Doe 103 lawsuit to determine whether the raising of the issue by
motion or defense would be in conflict with Mr. Epstein's contractual duties under
the NPA or to withdraw the issue to the extent we become convinced that your
position, if in conflict with ours, is correct.
Again, Mr. Epstein's paramount priority, and ours, is that the terms of Mr.
Epstein's agreement with the Government be followed and fulfilled.
YT
RB
MGW
EFTA00725500
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EFTA00725500
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