Epstein Secrets

m to Alex Acosta, Work Product Deliberative Process and regarding state cases mentioned by Epstein's counsel P-014443 12/14/2007 email from Villafafia to Alex Acosta, , and with draft letters to State Attome 's Office and victims Work Product Deliberative Process P-014444 12/17/2007 email fr

t response to Jay Leflcowitz and victim notification letters Work Product Deliberative Process P414355 thru P-014361 12/3/2007 emails between Villafafia, Alex Acosta, and Work Product Deliberative Process regarding history of plea negotiations and drafting response to correspondence from Jay Lekow

estigative Privilege and regarding status of ongoing investigation, planned presentation to grand jury, continued delay in awaiting decision from Washington, DC, and • roblems with victims bein harassed P-014830 thru P-014837 4/2/2008 emails between Alex Acosta, and regarding efforts by Jay Lefkowitz a

laundering and aiding & abetting 58 2/12/2007 Entails between l'illafafia and Lilly Ann Sanchez regarding employee representation with Lourie and Villafafia handwritten notes 59 5/21/2007 Subpoena to Paul A. Lavery 60 6/18/2007 Subpoena to Witham Riley 61 «18/2007 Subpoena to Riley Kiraly 62 7/18/

Proposed Non-Prosecution Agreement incorporating Acosta edits provided to Gerald Lefeourt on 9/11/2007 68 6/18/2008- 6/19/2008 Entails between Villafafia, Krischer, Atkinson, Senior, Acosta, Sloman. and Garcia regarding Epstein's case with state court and how it might breach the NPA 69 12/14/2007 Dr

a possible "perjury trap." In the middle of this period, which started in November 2006 and ran through January 2007, USA Acosta and I traveled to Washington, DC at the beginning of December 2006 for the inaugural Project Safe Childhood Conference. Although I did not attach much significance to this at the t

enue, Suite 400 West Palm Beach, Florida 33401 July 18, 2007 Subpoena Duces Tecum dated June 18, 2007, to Custodian of Records, NES, LLC Dear Ms. Villafafia: I write concerning the grand jury subpoena duces tecum dated June 18, 2007, directed to the Custodian of Records, NES, LLC ("NES"). By agreement,

be particularized. EFTA00204829 LAW O/FICCS Or GERALD B. LEIPCOURT. PC. Assistant United States Attorney Office of the United States Attorney Ibuthem District of Florida July 18, 2007 Page 2 With respect to Request 17, it is our understanding that you were previously provided with employment information

of these 39 pages is: "File folder entitled 'CORR RE GJ SUBPOENAS' containing correspondence related to various grand jury subpoenas and attorney (Villafafia) handwritten notes." 64. Another good illustration of the inadequacies of the privilege log is provided on page 20 of the first privilege log, with

investigating these (or releated) allegations, including any grand jury meeting in the Southern District of Florida, the Middle District of Florida, the District of EFTA00615911 Case 9:08-cv-80736-KAM Document 265-1 Entered on FLSD Docket 10/20/2014 Page 44 of 64 New Jersey, and/or the District of Columbia.

Villafafia to respond to OPR's written questions; (b) prepare for OPR's interview of Villafaila; and (c) participate fully in OPR's interview of Villafafia. b. The government and Mr. Biran will undertake efforts to minimize the amount of grand jury material produced to or maintained by Mr. Biran. Mr.

4). 12. To assist in responding to the OPR investigation, Villafana secured the representation of Jonathan Biran, a partner at Baker Donelson in Washington, DC. Mr. Biran graduated from Stanford Law School in 1993 and clerked for the Hon. David F. Levi at the U.S. District Court for the Eastern District of

to this litigation Box #1 P-001008 thru P-001056 File folder entitled "Notes from Fed Ex Records" containing handwritten and typed attorney (Villafafia) notes and screen shots of FedEx subpoena response electronic file Work Product 6(e) Contains information subject to investigative privilege. A

and Nesbitt Kuyrkendall regarding status of ongoing investigation, planned presentation to grand jury, continued delay in awaiting decision from Washington, DC, and problems with victims being harassed 6(e) Work Product Deliberative Process Investigative Privilege 51 4/10/20084/18/2008 emails between