Epstein Secrets

Objections Box #1 P-000983 thru P-001007 File folder entitled "Attorney Notes from Document Review" containing typed and handwritten attorney (Villafafia) notes, target letters, correspondence re grand jury subpoena Work product 6(e) Contains information subject to investigative privilege. Also

hru summary chart, witness/victim names and Contains information and Anticipation of Litigation; Improper P-002386 contact list, attorney (Villafafia) documents subject to Invocation; Overriding Need; Claims Against handwritten notes, 302s, portions of state investigative privilege. Public Pro

ange Description Privilege(s) Asserted Victims' Objections Suppl. Box 3 P-013883 E-mail, Villafana to Acosta, Lourie, Garcia, Atkinson, and McMillan, September 18, 2007, 9:31 a.m., RE: Epstein Negotiations Atty work-product No Factual Underpinnings; Fiduciary Duty; Crime-Fraud-Misconduct; Wa

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

ber 18 2007, 9:14 .), ande Lefkowitz to (September 18, 2007, 8:59 attached Suppl. Box 3 P-013883 E-mail to Acosta, , Any work-product and McMillan, September 18, 2007, 9:31 ., RE: tein Ne otiations Suppl. Box 3 P-013884 Thru P413886 E-mail, to and l=, September 17, 2007 10:35 ., RE:

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

stigation IS 9/10/07- 9/19/07 Entails between Alex Acosta, Jeff Montan, Andrew Laurie, Rolando Garcia, Karen Atkinson, Marie Villafafia, andJohn McMillan regarding plea negotiations 47 9/10/07- 9/11/07 Entails from Marie Viktoria to Gerakl I cfcourt with proposed Non-Prosecution Apvements PI 9/1

ea resolution. The inclusion of a Section 2255 remedy was specifically raised and discussed at the September 7th meeting. Indeed, according to AUSA Villafafia's notes, you thanked her for bringing it to your attention. Again, no objection to the Section 2255 issue was raised. After considering that argume

n Mr. Lefkowitz and myself that any appeal to Washington would be undertaken expeditiously. On September 7, 2007, I, along with FAUSA Sloman, AUSAs McMillan and Villafaiia, and FBI agents, met with you, Mr. Lefkowitz, and Ms. Sanchez. I understood that you wished to present federalism-based concerns reg

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

na (September 18, 2007, 8:59 a.m.), attached Atty work-product Suppl. Box 3 P-013883 E-mail, Villafana to Acosta, Louric, Garcia, Atkinson, and McMillan, September 18, 2007, 9:31 a.m., RE: Epstein Negotiations Atty work-product Suppl. Box 3 P-013884 Thru P-013886 E-mail, Villafana to Garcia

hru summary chart, witness/victim names and Contains information and Anticipation of Litigation; Improper P-002386 contact list, attorney (Villafafia) documents subject to Invocation; Overriding Need; Claims Against handwritten notes, 302s, portions of state investigative privilege. Public Pro

ange Description Privilege(s) Asserted Victims' Objections Suppl. Box 3 P-013883 E-mail, Villafana to Acosta, Lourie, Garcia, Atkinson, and McMillan, September 18, 2007, 9:31 a.m., RE: Epstein Negotiations Atty work-product No Factual Underpinnings; Fiduciary Duty; Crime-Fraud-Misconduct; Wa

Epstein Work Product Investigative Privilege Privacy Act P-014011 thru P-014025 7/3/2007-7/13/2007 email chain between Matt Menchel and Marie Villafafia regarding disagreement on Menchel's plea negotiations and written request for meeting between USAO management and victims 6(e) Work Product Delib

package Work Product Deliberative Process 6(e) Investigative Privilege P-014069 9/10/2007 email from Marie Villafaila to Jeff Slornan and John McMillan regarding Acosta inquiry about FBI investigation into State grand jury proceeding Work Product 6(e) Investigative Privilege P-014070 thru P-01