Epstein Secrets

#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 to J. Leflcowitz re performance and victim notification with handwritten notes and edits by a Again, these materials are central to the d

Epstein (including, but not limited to, Roy Black, Jay Lefkowitz, Jack Goldberger, Martin Weinberg, Gerald Lefcourt, Michael Tien, Guy Lewis, Lilly Ann Sanchez, Ken Starr, Alan Dershowitz) and agents acting in support of Epstein (including, but not limited to former President Bill Clinton and Andrew Albert

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

cutor; Overriding Need; Attorney Conduct at Issue Suppl. Box 3 P-013859 Through P-013860 Email, Gerald Lefcourt to Marie Villafana, Lilly Ann Sanchez, Roy Black, re: Jeffrey Epstein [Not considered privileged. Will be produced to opposing counsel upon lifting of stay] N/A Suppl. Box 3 P-01

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] Suppl. Box #3 P-013342

7, 9:29 a.m., Re: Meeting on Friday atty work-product Suppl. Box 3 P-013859 Through P-013860 Email, Gerald Lefcourt to Marie Villafana, Lilly Ann Sanchez, Roy Black, re: Jeffrey Epstein [Not considered privileged. Will be produced to opposing counsel upon lifting of stay] Suppl. Box 3 P-013861

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

your cooperation in this matter. If you have any questions, please do not hesitate to call. IACK A. GOLDBERGER CC: Gerald B. Lefcourt, Esq. Lilly Ann Sanchez, Esq. 2 08-80736-CV-MARRA RFP WPB 001693 EFTA00209872 i4a1 IA fit hIANUFACTLIPSER PAO 1.4AAL/FAC71REIVS OESVNATK)N Cc ARCRAF7 BOEING 72 7-

#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

Epstein (including, but not limited to, Roy Black, Jay Lefkowitz, Jack Goldberger, Martin Weinberg, Gerald Lefcourt, Michael Tien, Guy Lewis, Lilly Ann Sanchez, Ken Starr, Alan Dershowitz) and agents acting in support of Epstein (including, but not limited to former President Bill Clinton and Andrew Albert

onsidered privileged. Will be produced to opposing counsel upon lifting of stay] Lefkowitz" containing 12/5/07 faxed letter w/ cover sheet from K. Starr and J. Lefkowitz to A. Acosta Suppl. Box #3 P-013342 Thru P-013350 File folder entitled "12/05/07 Starr to Acosta" containing drafts of 11/30/

859 Through P-013860 Email, Gerald Lefcourt to Lilly [Not considered privileged. Will be produced to opposing counsel upon lifting of stay] Ann Sanchez, Roy Black, re: Jeffrey Epstein Suppl. Box 3 P-013861 Thru P-013865 E-mail, to Atty work-product atty-client privilege July 13, 2007, 3:14 p

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

) Denied. (b) Denied. (c) Admitted. (d) Admitted. (e) Admitted to the extent that the reference to "Lillian Sanchez" was meant to refer to Lilly Ann Sanchez. (0 Admitted. (g) Admitted. 7. The government admits that, on about January 10, 2008, when Jane Doe # I and Jane Doe #2 were sent letters advisin

#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. Lefkowitz re performance and victim notification with handwritten notes and edits by A. Marie Villafaiia." Again, these ma

Epstein (including, but not limited to, Roy Black, Jay Lefkowitz, Jack Goldberger, Martin Weinberg, Gerald Lefcourt, Michael Tien, Guy Lewis, Lilly Ann Sanchez, Ken Starr, Alan Dershowitz) and agents acting in support of Epstein (including, but not limited to former President Bill Clinton and Andrew Albert

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

(s) Asserted Box #3 P-011923 Thru P-011966 Folder entitled "Responses to Arguments from JE Counsel" containing: II 7/13/2007 letter from Lilly Ann Sanchez to with handwritten attorney notes; • 6/25/2007 letter from Gerald Lefcourt to a Sloman, Menchal , and with handwritten attorney I I note

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

secutor; Overriding Need; Attorney Conduct at Issue Suppl. Box 3 P-013859 Through P413860 Email, Gerald Lefcourt to Marie Villafana, Lilly Ann Sanchez, Roy Black, re: Jeffrey Epstein [Not considered privileged. Will be produced to opposing counsel upon lifting of stay) N/A Suppl. Box 3 P-01