Epstein Secrets

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

" containing attorney research Work product Box #1 P-003679 Thru P-003680 File folder entitled "Serene Cano (N.Y. AUSA)" containing attorney (Villafafla) handwritten notes Work product Box #1 P-003681 Thru P-003687 File folder entitled "Dr. Anna Salter" containing attorney (Villafafia) memo to

LY-01 through OLY-81, correspondence and research related to enforcement of same, documents produced in response to some subpoenas; and attorney (Villafafla) handwritten notes 6(e) Work Product Contains documents subject to investigative privilege Also contains documents subject to privacy rights of

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

Public Prosecutor, Attorney Conduct at Issue Box #1 P-004561 Thru P-004565 Filed folder entitled "JANUSZ BANASIAK" containing attorney (Villafafla) handwritten notes of interview Work product Investigative privilege • Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Not in Anticipa

ers of Mr. Epstein's defense team, prior published reports of a pending State case against Mr. Epstein and public information available through the State Court system. Weinstein refused to answer the first question. As to the second question, Weinstein told him that any matter arising out of conduct in Pal

osta met with Kirkland & Ellis partners Jay Lefkowitz and former Solicitor General Ken Starr and Ms. Sanchez, along with Chief Oosterbahn and AUSAs Villafafla, John McMillan, and FAUSA S lomat' Messrs. Starr and Lefkowitz presented arguments regarding the sufficiency of the federal interest in the case and