Epstein Secrets

llafana to Lourie, Garcia, and Atkinson, September 18, 2007, 11:43 a.m., RE: Dratt Agreemcnts?, with e-mails from Villafana to Lourie, Garcia and Atkinson (September 18, 2007, 11:18 a.m.), Leficowitz to Villafana (September 18, 2007, 11:09 a.m.), and Villafana to Lefkowitz (September 18, 2007, 9:14 a

P-013875 Inadvertently marked as privileged, will be produced Suppl. Box 3 P-013876 Thru P-013877 E-mail, Villafana to Louric, 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 Lefkowit

" 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

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

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

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

meet to provide information about the federal crimes committed by Epstein, hoping to secure a significant federal indictment against Epstein. AUSA Villafafla and I discussed the possibility of federal charges being filed. At the end of the call, AUSA Villafafla asked me to send any information that I want