Epstein Secrets

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

o J. Lefkowitz; 5/22/07 e- mail from A. Lourie to M. Menchel, J. Sloman, A. Marie Villafafia re meeting with G. Lefcourt with attached email from G. Lefcourt re solicitation for meetings Work Product Government Communication; No Attorney- Client Relationship; Claims Against Public Prosecutor; Overriding

jections P-0133303 proposed letter to J. Lefkowitz; 5/22/07 e- mail from A. Lourie to M. Menchel, J. Sloman, A. Marie Villafafia re meeting with G. Lefcourt with attached email from G. Lefcourt re solicitation for meetings Work Product Government Communication; No Attorney- Client Relationship; Claims

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

o J. Lefkowitz; 5/22/07 e- mail from A. Lourie to M. Menchel, J. Sloman, A. Marie Villafafta re meeting with G. Lefcourt with attached email from G. Lefcourt re solicitation for meetings Work Product Government Communication; No Attorney- Client Relationship; Claims Against Public Prosecutor; Overriding

jections P-0133303 proposed letter to J. Lefkowitz; 5/22/07 e- mail from A. Lourie to M. Menchel, J. Sloman, A. Marie Villafafta re meeting with G. Lefcourt with attached email from G. Lefcourt re solicitation for meetings Work Product Government Communication; No Attorney- Client Relationship; Claims

you mention in your letter, I -a simple line AUSA — handled the primary negotiations for the Office, and conducted those negotiations with you, Ms. Sanchez, Mr. Lewis, and a host of other highly skilled and experienced practitioners. As you put it, your group has a "combined 250 years experience" to my

approval) promised to close the money-laundering investigation "if the sex offense case is resolved." See Tab 23, August 16, 2007 Letter froze to G. Lefcourt ("In other words, if the sex offense case is resolved, the Office would close its investigation into other areas as well. The matter has not been,

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

approval) promised to close the money-laundering investigation "if the sex offense case is resolved." See Tab 23, August 16, 2007 Letter from M. to G. Lefcourt ("In other words, if the sex offense case is resolved, the Office would close its investigation into other areas as well. The matter has not been,

ll of the terms and conditions of the [Deferred Prosecution] Agreement, as modified by the United States Attorney's December 19, 2007 letter to Ms. Sanchez by close of business on Monday, June 2, 2008, the SDFL will elect to terminate the Agreement." Id., p.1 The Truth: • The Deferred Prosecution Agre

approval) promised to close the money-laundering investigation "if the sex offense case is resolved." See Tab 23, August 16, 2007 Letter from I. to G. Lefcourt ("In other words, if the sex offense case is resolved, the Office would close its investigation into other areas as well. The matter has not been,

fcourt to and Lilly Ann Sanchez (May 22, 2007, 2:05 p.m. attached Any work-product Suppl. Box 3 P-013872 E-mailil and p.m., FW: Lefcourt to Sanchez a 22, to Matthew ■ Any work-product May 22, 2007, 3:11 a Mi l with e-mail from , and Lilly Ann 2007 2:05 p.m. attached Suppl. Box 3 P-01387

/18/08 Lefkowitz Ltr to AMCV" containing handwritten draft notes for proposed letter to J. Lefkowitz; 5/22/07 e-mail from to M. re meeting with G. Lefcourt with attached email from G. Lefcourt re solicitation for meetings Attorney-Client Privilege Work Product Suppl. Box #3 P-013304 Thru P-013325

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

ll disclose even more. If meeting is held, Villafaiii will ask to have the case reassigned. Attached email correspondence between Andrew Laurie and G. Lefcourt 28/C-4 5/31/2007 Subpoena to J. Epstein Virgin Islands Foundation, Inc. (return date 6/21/07) 5/31/2007 Subpoena to J. Epstein & Company, Inc. (re

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

) promised to close the money-laundering investigation “if the sex offense case is resolved.” See Tab 23, August 16, 2007 Letter from M. Villafana to G. Lefcourt (“In other words, if the sex offense case is resolved, the Office would close its investigation into other areas as well. The matter has not been, an