Epstein Secrets

LY-01 through OLY-81, correspondence and research related to enforcement of same, documents produced in response to some subpoenas; and attorney (Villafafia) handwritten notes 6(e) Work Product Contains documents subject to investigative privilege Also contains documents subject to privacy rights of

litigation 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 c

70 Bates Range Description Privilege(s) Asserted Box #1 P-004561 Thru P-004565 Filed folder entitled "JANUSZ BANASIAK" containing attorney (Villafafta) handwritten notes of interview Work product Investigative privilege Box #1 P-004566 Thru P-004716 File folder entitled "JANUSZ BANASIAK REC

er Prindle for possession of child pornography (04-Cr- 80156) If ve any questions about any of the above information and the information included Villafafia's attached letter, please contact me at your convenience. Very truly yours, BAKER, DONELSON, BEARMAN, CALDWELL & BERKOWITZ, PC /s/ Jonathan Bira

• VIRGINIA • WASHINGTON, D.C. EFTA00223095 Laura Ingersoll May 10, 2019 Page 2 of 7 AUSAs, described the job as the best of their careers. Ms. Villafafta also wanted to serve her community. She was in the first generation of her family to graduate from college. She is the only member of her family to

edged that investigators were aware of Epstein's longtime relationship with a close female friend who was a well- known socialite, but, according to Villafafia, in 2007, they "didn't have any specific evidence against her." Accordingly, Villafaiia believed that the only "co-conspirators" of Epstein who wou

complying with certain parts of the NPA. OPR Report at 95. According to the report: At the same time, at [USAO-SDFL supervisor] Lourie's request, Villafafta sent the NPA and its addendum to Lourie and Oosterbaan. Oosterbaan responded to Lourie that he was "not thrilled" about the NPA; described Epstein'

edged that investigators were aware of Epstein's longtime relationship with a close female friend who was a well- known socialite, but, according to Villafafia, in 2007, they "didn't have any specific evidence against her." Accordingly, Villafaiia believed that the only "co-conspirators" of Epstein who wou

complying with certain parts of the NPA. OPR Report at 95. According to the report: At the same time, at [USAO-SDFL supervisor] Lourie's request, Villafafta sent the NPA and its addendum to Lourie and Oosterbaan. Oosterbaan responded to Lourie that he was "not thrilled" about the NPA; described Epstein'

, OPR concluded that "the evidence does not show that [Former USAO-SDFL U.S. Attorney Alex] Acosta, [Former USAO-SDFL supervisor Andrew] Lourie, or Villafafia agreed to the nonprosecution provision to protect any of Epstein's political, celebrity, or other influential associates." OPR Report at 168." In

complying with certain parts of the NPA. OPR Report at 95. According to the report: At the same time, at [USAO-SDFL supervisor] Lourie's request, Villafafta sent the NPA and its addendum to Lourie and Oosterbaan. Oosterbaan responded to Lourie that he was "not thrilled" about the NPA; described Epstein'

the victims $50,000 damages under § 2255? Thank you for any clarification you can provide on these questions. Sincerely, BE/sg Brad Edwards cc: Ann Marie C. Villafafia, AUSA United States Attorney's Office 500 South Australian Avenue West Palm Beach, Florida 33401 2028 HARRISON 8TREXT,SUITE 202, HOLLYWOOD, FLORI

seek for violations of their rights in this case. The second statement may or may not be false, but may need some clarification. At page 4 of Ms. Villafafta declaration, she states that "[i]n October 2007, shortly after the agreement was signed, four victims [including C.W.] were contacted and these prov

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

176 Draft of September 2009 letter from Marie Villafalia to Roy Black regarding breach of Non Prosecution Agreement with handwritten attorney (Villafafta) notes Work Product Attorney-Client Privilege Deliberative Process Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Not in Anticipation