Subject: RE: Review of Jay Lefkowitz's Tome re Epstein

From: To: Subject: RE: Review of Jay Lefkowitz's Tome re Epstein Date: Wed, 24 Jun 2009 14:41:12 +0000 Importance: Normal 'Sloman, Jeff (USAFLS)" "I wish to reiterate our firm belief that the NPA allowed Mr. Epstein the right to contest litigation whenever an express waiver of all other state, federal or common law claims or the right to bring contested litigation in the future was not sufficiently or correctly pleaded. ... More is required of a plaintiff than to simply allege, as did Jane Doe 101, that she `exclusively seeks civil remedies pursuant to 18 USC 2255.' Such an averment satisfies only the exclusivity portion of the twin conditions set forth in the NPA. Jane Doe 101 did no more than restate that her complaint ... was only for 2255 damages. She never affirmatively waived all future claims in state or federal court, as required by the NPA." Assistant U.S. Attorney Southern District of Florida 500 East Broward Boulevard, 7th Floor Ft. Lauderdale. FL 33394 From