Epstein Secrets

ssue Suppl. Box #3 P-013338 Thru 013341 File folder entitled "12/6/07 Sloman to Lefkowitz" containing 12/5/07 faxed letter w/ cover sheet from K. Starr and J. Lefkowitz to A. Acosta [Not considered privileged. Will be produced to opposing counsel upon lifting of stay] N/A Suppl. Box #3 P-013

Objections Box #1 P-000983 thru P-001007 File folder entitled "Attorney Notes from Document Review" containing typed and handwritten attorney (Villafafia) notes, target letters, correspondence re grand jury subpoena Work product 6(e) Contains information subject to investigative privilege. Also

hru summary chart, witness/victim names and Contains information and Anticipation of Litigation; Improper P-002386 contact list, attorney (Villafafia) documents subject to Invocation; Overriding Need; Claims Against handwritten notes, 302s, portions of state investigative privilege. Public Pro

Suppl. Box #3 P-013338 Thru 013341 File folder entitled "12/6/07 Sloman to Lefkowitz" containing 12/5/07 faxed letter w/ cover sheet from K. Starr and J. Leflcowitz to A. Acosta (Not considered privileged. Will be produced to opposing counsel upon lifting of stay] Suppl. Box #3 P-013342

m to Alex Acosta, Work Product Deliberative Process and regarding state cases mentioned by Epstein's counsel P-014443 12/14/2007 email from Villafafia to Alex Acosta, , and with draft letters to State Attome 's Office and victims Work Product Deliberative Process P-014444 12/17/2007 email fr

t response to Jay Leflcowitz and victim notification letters Work Product Deliberative Process P414355 thru P-014361 12/3/2007 emails between Villafafia, Alex Acosta, and Work Product Deliberative Process regarding history of plea negotiations and drafting response to correspondence from Jay Lekow

uraging civil lawsuits against Mr. Epstein under the guise of the terms of the Non Prosecution Agreement. See Tab 35, November 28, 2007 Letter from K. Starr to A. Fisher. 43. Late in the day on November 28, Epstein's attorneys received from AUSA a copy of the USAO's proposed victim-notification letter

orida 500 South Australian Avenue, Suite 400 West Palm Beach, Florida 33401 RE: JEGE, Inc. ("JEGE") and Hyperion Air; Inc. ("Hyperion") Dear Ms. Villafafia: Thank you very much for your letter dated May 15, 2007 concerning the subpoenas issued to JEGE, Inc. and Hyperion Air, Inc., along with your agree

#3 P-013342 to P-013350. The entry reads: "File folder entitled `12/05/07 Starr to Acosta' containing drafts of 11/30/07 letters from A. Acosta to K. Starr and from J. Sloman to J. Leflcowitz re performance and victim notification with handwritten notes and edits by A. Again, these materials are centra

of these 39 pages is: "File folder entitled 'CORR RE GJ SUBPOENAS' containing correspondence related to various grand jury subpoenas and attorney (Villafafia) handwritten notes." 64. Another good illustration of the inadequacies of the privilege log is provided on page 20 of the first privilege log, with

Suppl. Box #3 P-013338 Thm 013341 File folder entitled "12/6/07 Sloman to Lefkowitz" containing 12/5/07 faxed letter w/ cover sheet from K. Starr and J. Lefkowitz to A. Acosta [Not considered privileged. Will be produced to opposing counsel upon lifting of stay) Suppl. Box #3 P-013342

to this litigation Box #1 P-001008 thru P-001056 File folder entitled "Notes from Fed Ex Records" containing handwritten and typed attorney (Villafafia) notes and screen shots of FedEx subpoena response electronic file Work Product 6(e) Contains information subject to investigative privilege. A

Issue Suppl. Box #3 P413338 Thru 013341 File folder entitled "12/6/07 Sloman to Lefkowitz" containing 12/5/07 faxed letter w/ cover sheet from K. Starr and J. Lefkowitz to A. Acosta [Not considered privileged. Will be produced to opposing counsel upon lifting of stay N/A Suppl. Box #3 P41334

hru summary chart, witness/victim names and Contains information and Anticipation of Litigation; Improper P-002386 contact list, attorney (Villafafia) documents subject to Invocation; Overriding Need; Claims Against handwritten notes, 302s, portions of state investigative privilege. Public Pro

to Suppl. Box #3 P-013342 to P-013350. The entry reads: "File folder entitled `12/05/07 Starr to containing drafts of 11/30/07 letters from A. to K. Starr and from J. Lefkowitz re performance and victim notification with handwritten notes and edits by A. Villafafta." Again, these materials are central

of these 39 pages is: "File folder entitled 'CORR RE GJ SUBPOENAS' containing correspondence related to various grand jury subpoenas and attorney (Villafafia) handwritten notes." 64. Another good illustration of the inadequacies of the privilege log is provided on page 20 of the first privilege log, with