Epstein Secrets

ation; Ordinary Government ■ 11/28/07 e-mail from A. Lourie to Investigative Privilege Communication; No Attorney-Client A. Marie Villafafia, A. Oosterbaan, R. Garcia re non-prosecution agreement, with attached correspondence; Relationship; Improper Invocation; Overriding Need; Claims Against P

ocess Crime-Fraud-Misconduct; Crime-Fraud- Thru ■ 7/13/2007 letter from Lilly Ann 6(e) Misconduct; Not in Anticipation of Litigation; P-011966 Sanchez to Andrew Lourie with handwritten attorney (Lourie) notes; Attorney-Client Privilege Ordinary Government Communication; No Attorney-Client Re

ly aware, the Department's prior review of this matter was incomplete and, by its own admission, not "de novo." See Tab 38, May 15, 2008 Letter from A. Oosterbaan. Without considering the Non Prosecution Agreement that left this matter to be resolved in the State or any of the misconduct, CEOS reviewers, task

Lefcourt and Lilly Ann Sanchez, both counsel to Jeffrey Epstein, that as a result of a telephone conversation had amongst you, Mr. Lefcourt and Ms. Sanchez, you are now seeking documents reflecting: 1. Ownership of JEGE and Hyperion; 2. Assets of JEGE and Hyperion; and 3. Employees of JEGE and Hyperio

nity control," and agree that the girls are victims for purposes of damages. Also includes deadlines for a plea and sentencing date 46 9/11/2007 A. Oosterbaan A. Marie Villafaila Email re status of negotiations with attached correspondence 48 9/11/2007 Lefcourt Villafafia Email with 4 page NPA attac

rn date 12/1/06) 11/13/2006 Subpoena to Adriana Mucinska (former assistant) (return date 12/1/06) 15 11/15/2006 A. Marie Villafafia Lilly Ann Sanchez Gerald Lefcourt from New York and Lilly Ann Sanchez will be dealing with the U.S. Attorney's Office in the Jeffrey Epstein matter I 11/16/2006 Li

ation; Ordinary Government ■ 11/28/07 e-mail from A. Lourie to Investigative Privilege Communication; No Attorney-Client A. Marie Villafatia, A. Oosterbaan, IL Garcia re non-prosecution agreement, with attached correspondence; Relationship; Improper Invocation; Overriding Need; Claims Against Pub

ocess Crime-Fraud-Misconduct; Crime-Fraud- Thru ■ 7/13/2007 letter from Lilly Ann 6(e) Misconduct; Not in Anticipation of Litigation; P-011966 Sanchez to Andrew Lourie with handwritten attorney (Lourie) notes; Attorney-Client Privilege Ordinary Government Communication; No Attorney-Client Re

nity control," and agree that the girls are victims for purposes of damages. Also includes deadlines for a plea and sentencing date 46 9/11/2007 A. Oosterbaan A. Marie Villafaiia Email re status of negotiations with attached correspondence 48 9/11/2007 Lefcourt Villafatia Email with 4 page NPA attac

es to schedule meeting 11 1/8/2007 Lilly Ann Sanchez A. Marie Vaifan_a Request for documents prior to setting meeting 1 1/17/200- Lilly Ann Sanchez Andrew Lourie Client wants to cooperate with the investigation, but requests for documents were overly broad. Provided shortened and narrowed list

ely aware, the Department’s prior review of this matter was incomplete and, by its own admission, not “de novo.” See Tab 38, May 15, 2008 Letter from A. Oosterbaan. Without considering the Non Prosecution Agreement that left this matter to be resolved in the State or any of the misconduct, CEOS reviewers, tasked

an “mere solicitation;” it must be more than an offer or the providing of an opportunity to engage in prohibited conduct. See, e.g,. United States v. Sanchez-Berrios, 424 F.3d 65, 76-77 (1* Cir. 2005); United States v. Brown, 43 F.3d 618, 625 (11™ Cir. 1995). The government cannot fairly, or consistent wit