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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
e victims were not properly notified about event during that investigation. 59. RFP No. 25 requests all initial productions that are required under the Federal Rules of Civil Procedure. This is a protective request to ensure that, should it be determined that the Civil Rules apply, they then receive all materials to whic
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
e victims were not properly notified about event during that investigation. 59. RFP No. 25 requests all initial productions that are required under the Federal Rules of Civil Procedure. This is a protective request to ensure that, should it be determined that the Civil Rules apply, they then receive all materials to whic
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
e victims were not properly notified about event during that investigation. 59. RFP No. 25 requests all initial productions that are required under the Federal Rules of Civil Procedure. This is a protective request to ensure that, should it be determined that the Civil Rules apply, they then receive all materials to whic
l privilege log (DE 216-1), with Bard to supplemental box No. 3 (P-013282 to 83). The entry here reads: "7/08/08 email from 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
e victims were not properly notified about event during that investigation. 59. RFP No. 25 requests all initial productions that are required under the Federal Rules of Civil Procedure. This is a protective request to ensure that, should it be determined that the Civil Rules apply, they then receive all materials to whic
Entities connected to both Karen Atkinson and the Federal Rules of Civil

A. Marie Villafana
PERSON
Jeffrey Epstein
PERSON
Alexander Acosta
PERSON
Dexter Lee
PERSONJack Goldberger
PERSONLeon Black
PERSON
Kenneth Marra
PERSON
Jay Lefkowitz
PERSONRoy Black
PERSON
Bill Richardson
PERSONMarie
PERSONRolando Garcia
PERSON
United States
LOCATION
Prince Andrew
PERSON
Bradley Edwards
PERSON
Department of Justice
ORGANIZATIONJane Doe
PERSONGarcia
PERSONKuyrkendall
PERSON
George W. Bush
PERSON