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

3 Page 45 of 70 Bates Range Description Privilege(s) Asserted Victims' Objections Box #3 P-013227 April 23, 2008 Memo from Jeffrey Sloman to Office of Professional Responsibility re Self Reporting, Corrected Version of the previously submitted April 21, 2008 Letter to OPR Privacy Act Inadequate Log; No Factual Underpinnin

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

osure is "in connection with a judicial proceeding," that is, in connection with an administrative proceeding conducted by the Justice Department's Office of Professional Responsibility (OPR) arising out of a decision by United States District Judge Kenneth A. Marra in the matter of Jane Doe 1 and Jane Doe 2I United States, S.D. Fl

e Leap Year team, was excluded from consideration because she had disagreed with Lilly Ann Sanchez about the handling of an obscenity case while Ms. Sanchez was an AUSA. 29 According to PBPD Chief Reiter, the State Attorney initially planned to file no charges against Epstein. Following complaints, the

elson.com JONATHAN BRAN Direct Dial: 410.862.1073 E-Mail [email protected] May 10, 2019 VIA EMAIL °N4" Laura Ingersoll Counsel, Office of Professional Responsibility U.S. Department of Justice 950 Pennsylvania Avenue, N.W. — Room 3266 Washington, D.C. 20530 Re: OPR Investigation Relating to Jeffrey Epstein Fed

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

tions. Conclusion We bring these difficult and delicate matters of misconduct to your attention not to require any disciplinary action or review by the Office of Professional Responsibility. Although we have been told that some of this misconduct has been self-reported (only after we raised these complaints in writing), we feel confident