Epstein Secrets

ll be considered a breach of the Non-Prosecution Agreement and the United States will proceed accordingly. Sincerely, United States Attorney cc: Karen Atkinson, AUSA By: Assistant United States Attorney 08-80736-CV-MARRA RFP WPB 000513 EFTA00184958 Case 9:08-cv-80736-KAM Document 362-32 Entered on FLS

rivilege log (DE 216-1), with regard to supplemental box No. 3 (P-013282 to 83). The entry here reads: "7/08/08 email from A. to A. =, J. =, Ki. Atkinson, and FBI re proposed response to Goldberger's letter re victim notification." The log then indicates that the Government is asserting attorney-clie

ation against any public interest in non-disclosure. That balancing process is ordinarily made with reference to factors discussed in Frankenhauser Rizzo, 59 F.R.D. 339, 344 (E.D.Pa.1973), specifically: (1) the extent to which disclosure will thwart governmental processes by discouraging citizens fr

llafana to Lourie,Garcia, and Atkinson, September 18, 2007, 11:43 a.m., RE: Draft Agreements?, with e-mails from Villafana to Lourie, Garcia and Atkinson (September 18, 2007, 11:18a.m.), Atty work-product No Factual Underpinnings; Fiduciary Duty; Waiver; Claims Against Public Prosecutor; Overriding

ion Privilege(s) Asserted Victims' Objections Through P-013875 Suppl. Box 3 P-013876 Thru P-013877 E-mail, Villafana to Lourie,Garcia, and Atkinson, September 19, 2007, 4:33 p.m., RE: Draft Plea Agreement, with e-mail from Lefkowitz to Villafana (September 19, 2007, 3:44 p.m.), and Lefkowitz t

Tuite v. Henry, 98 F.3d 1411, 1418 (D.C. Cir. 1996). The balancing is ordinarily made by considering the ten factors identified in Frankenhauser v. Rizzo, 59 F.R.D. 339, 344 (E.D. Pa. 1973). Those ten factors decisively tip in favor of the victims receiving access to the information. D. Work Product

with regard to supplemental box No. 3 (P-013282 to 83). The entry here reads: "7/08/08 email from A. Marie Villafafia to A. Acosta, J. Sloman, Ki. Atkinson, and FBI re proposed response to Goldberger's letter re victim notification." The log then indicates that the Government is asserting attorney-clie

ion against any public interest in non-disclosure. That balancing process is ordinarily made with reference to factors discussed in Frankenhauser v. Rizzo, 59 F.R.D. 339, 344 (E.D.Pa.1973), specifically: (1) the extent to which disclosure will thwart governmental processes by discouraging citizens fr