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

sel, Executive Office for United States Attorneys, and Benjamin Greenberg, First Assistant U.S. Attorney, Southern District of Florida, regarding Formal Notice of Office-wide Recusal of Southern District of Florida dated August 24 and August 29, 2011 Attorney-Client Privilege No Factual Underpinnings; Fiduciary Du

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

nsel, Executive Office for United States Attorneys, and Benjamin Greenberg, First Assistant U.S. Attorney, Southern District of Florida, regarding Formal Notice of Office-wide Recusal of Southern District of Florida dated August 24 and August 29, 2011 Attorney-Client Privilege Box #3 P-013252 Thru P-013253 Emai

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

vilege General Counsel, Executive Office for United States Attorneys, and First Assistant U.S. Attorney, Southern District of Florida, regarding Formal Notice of Office-wide Recusal of Southern District of Florida dated August 24 and Au l011 Box #3 P-013252 Thru P-013253 Emails between Assistant Attorney-Cli

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

nsel, Executive Office for United States Attorneys, and Benjamin Greenberg, First Assistant U.S. Attorney, Southern District of Florida, regarding Formal Notice of Office-wide Recusal of Southern District of Florida dated August 24 and August 29, 2011 Attorney-Client Privilege Box #3 P-013252 Thru P-013253 Emai

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

FL), Robert O'Neill (U.S. Attorney, MDFL), Benjamin Greenberg (FAUSA, SDFL), and Lee Bentley (FAUSA, MDFL) Richard Sudder Email regarding Formal Notice of Office-wide Recusal of Southern District of Florida. Cc's David MSODAG), Jay Macklin (USAEO), Thomas Anderson (USAEO), Tapken (USAEO), and James Read (US

withheld as privileged — copy provided to opposing counsel] Box #2 P-009104 Thru P-009111 File folder entitled "Meeting Timeline" containing Villafafia typed notes summarizing meetings with opposing counsel prepared at Work product Deliberative process request of with handwritten correction and

vilege General Counsel, Executive Office for United States Attorneys, and First Assistant U.S. Attorney, Southern District of Florida, regarding Formal Notice of Office-wide Recusal of Southern District of Florida dated Au ust 24 and Au ust 29, 2011 Box #3 P-013252 Thru P-013253 Emails between Assistant Atto

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

nsel, Executive Office for United States Attorneys, and Benjamin Greenberg, First Assistant U.S. Attorney, Southern District of Florida, regarding Formal Notice of Office-wide Recusal of Southern District of Florida dated August 24 and August 29, 2011 Attorney-Client Privilege Box #3 P-013252 Thru P-013253 Emai

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

sel, Executive Office for United States Attorneys, and Benjamin Greenberg, First Assistant U.S. Attorney, Southern District of Florida, regarding Formal Notice of Office-wide Recusal of Southern District of Florida dated August 24 and August 29, 2011 Attorney-Client Privilege No Factual Underpinnings; Fiduciary Du