Epstein Secrets

Asserted Victims' Objections Box #2 File folder entitled "FINAL P-008299 Thru AGREEMENTS" containing subfolder entitled "Agrmts Filed in State Court" (P- N/A P-008363 008300-P-008327 [not being withheld as privileged — have been produced to opposing counsel]); signed Non- Prosecution Agree

176 Draft of September 2009 letter from Marie Villafalia to Roy Black regarding breach of Non Prosecution Agreement with handwritten attorney (Villafafta) notes Work Product Attorney-Client Privilege Deliberative Process Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Not in Anticipation

arties to this litigation Box #2 P-008299 Thru P-008363 File folder entitled "FINAL AGREEMENTS" containing subfolder entitled "Agrmts Filed in State Court" (P-008300-P-008327 [not being withheld as privileged — have been produced to opposing counsel]); signed Non-Prosecution Agreement, Addendum, and

70 Bates Range Description Privilege(s) Asserted Box #1 P-004561 Thru P-004565 Filed folder entitled "JANUSZ BANASIAK" containing attorney (Villafafta) handwritten notes of interview Work product Investigative privilege Box #1 P-004566 Thru P-004716 File folder entitled "JANUSZ BANASIAK REC

ment available to the victims, the United States sought to confirm that counsel for Mr. Epstein had filed the complete Agreement under seal with the State Court at the time of the entry of his guilty plea to the State charges, to insure that an exact copy of that Agreement would be provided in this case, sh

owitz and myself that any appeal to Washington would be undertaken expeditiously. On September 7, 2007,1, along withFAUSA Sloman, AUSAs McMillan and Villafafta, and FBI agents, met with you, Mr. Lefkowitz, and Ms. Sanchez. I understood that you wished to present federalism-based concerns regarding our pros