9
Shared Docs
9
Same-Page
9 / 9
Mentions
ts against Jeffrey Epstein for sexually abusing them. I am also familiar with the criminal justice system, having served as state prosecutor in the Broward County State Attorney's Office. 2. This affidavit covers factual issues regarding the Government's assertions of privilege to more than 13,000 pages of do
Epstein (including, but not limited to, Roy Black, Jay Lefkowitz, Jack Goldberger, Martin Weinberg, Gerald Lefcourt, Michael Tien, Guy Lewis, Lilly Ann Sanchez, Ken Starr, Alan Dershowitz) and agents acting in support of Epstein (including, but not limited to former President Bill Clinton and Andrew Albert
ts against Jeffrey Epstein for sexually abusing them. I am also familiar with the criminal justice system, having served as state prosecutor in the Broward County State Attorney's Office. 2. This affidavit covers factual issues regarding the Government's assertions of privilege to more than 13,000 pages of do
Epstein (including, but not limited to, Roy Black, Jay Lefkowitz, Jack Goldberger, Martin Weinberg, Gerald Lefcourt, Michael Tien, Guy Lewis, Lilly Ann Sanchez, Ken Starr, Alan Dershowitz) and agents acting in support of Epstein (including, but not limited to former President Bill Clinton and Andrew Albert
ion for damages in an amount in excess of the minimum jurisdictional limits of this Court. 2. Counter/plaintiff, EDWARDS, is sui juris, resides in Broward County, Florida, and is an attorney licensed to practice in the State of Florida at all times material hereto. 3. Counter/defendant, EPSTEIN, is sui juri
S. Nurik One E Broward Blvd., Suite 700 Fort Lauderdale, FL 33301 Phone: (954)-745-5849 Fax: (954)-745-3556 Attorneys for Scott Rothstein Lilly Ann Sanchez, Esquire lsanchez(e)thelsfirm.com The L-S Law Firm 1441 Brickell Avenue, 15th Floor Miami, FL 33131 Phone: (305)-503-5503 Fax: (305)-503-6801
pated in the trafficking of Jane Doe No. 3. Where sexual issues are relevant to a case, they must not be stricken. See, e.g., Zdenekl School Bd. of Broward County, No. 07-CV-61110, 2007 WL 4521489, at •2 (S.D. Fla. Dec. 19, 2007) ("given the Eleventh Circuit standards on what constitutes actionable sexual hara
ng. I welcome any questions or comments you may have and am available to discuss this and any other issues at your earliest convenience. cc: Lilly Ann Sanchez, Esq. Roy Black, Esq. Very truly yours, Goudf? Gerald B. Lefcourt a t41^- 1 A— l t Alan Dershowitz MIA_CEOS_00099 EFTA00191466
ts against Jeffrey Epstein for sexually abusing them. I am also familiar with the criminal justice system, having served as state prosecutor in the Broward County State Attorney's Office. 2. This affidavit covers factual issues regarding the Government's assertions of privilege to more than 13,000 pages of do
Epstein (including, but not limited to, Roy Black, Jay Lefkowitz, Jack Goldberger, Martin Weinberg, Gerald Lefcourt, Michael Tien, Guy Lewis, Lilly Ann Sanchez, Ken Starr, Alan Dershowitz) and agents acting in support of Epstein (including, but not limited to former President Bill Clinton and Andrew Albert
isting his wife at her place of employment and would not be able to meet with me. Mr. Rodriguez stated he would meet with me on January 6, 2006, in Broward County, in the morning hours. On January 6, 2006, at approximately 9:00 am, I received a telephone call from Mr. Rodriguez who advised he had the file in
ich we address more specifically the applicable law once we have had the benefit of narrowing the focus at our meeting. cc: Roy Black, Esq. Lilly Ann Sanchez, Esq. ri Gerald B. ( EFTA00176260 C C. c C c c t EFTA00176261 Date: 2/17/06 PALM BEACH POLICE DEPARTMENT Page: 1 Time: 11:36:35 I
isting his wife at her place of employment and would not be able to meet with me. Mr. Rodriguez stated he would meet with me on January 6, 2006, in Broward County, in the morning hours. On January 6, 2006, at approximately 9:00 am, I received a telephone call from Mr. Rodriguez who advised he had the file in
he approval of Mr. Tein) approves of the portion of my proposed Notification that quotes directly from the U.S. Attorney's December letter to Lilly Ann Sanchez. The second portion is where Mr. Goldberger provides his interpretation of the Agreement, and nowhere mentions that he does not believe that the De
ts against Jeffrey Epstein for sexually abusing them. I am also familiar with the criminal justice system, having served as state prosecutor in the Broward County State Attorney's Office. 2. This affidavit covers factual issues regarding the Government's assertions of privilege to more than 13,000 pages of do
secutor; Overriding Need; Attorney Conduct at Issue Suppl. Box 3 P-013859 Through P413860 Email, Gerald Lefcourt to Marie Villafana, Lilly Ann Sanchez, Roy Black, re: Jeffrey Epstein [Not considered privileged. Will be produced to opposing counsel upon lifting of stay) N/A Suppl. Box 3 P-01
ion for damages in an amount in excess of the minimum juriSdietional limits of this Court. 2. Counter/plaintiff, EDWARDS, is sui juris, resides in Broward County, Florida, and is an attorney licensed to practice in the State of Florida at all times material hereto. 3. Counter/defendant, EPSTEIN, is sui juri
: Fax; Toiija Haddad Coleman, Esquire La* Offices of Tonja Haddad, P.A. 5241S Andrews Avenue, Suite 200N Fort, Lauderdale FL 33301 Fax i LAS, Ann Sanchez, Esquire Thet-S Law Finn 1441 Brickell Avenue, 15th Floor Miami, FL 33131 Phony Fax; EFTA00299744
Entities connected to both Broward County and Ann Sanchez

Jeffrey Epstein
PERSON
Bradley Edwards
PERSONGerald Lefcourt
PERSON
Alexander Acosta
PERSONJack Goldberger
PERSON
Alan Dershowitz
PERSON
United States
LOCATIONthe Southern District
LOCATIONLeon Black
PERSON
Department of Justice
ORGANIZATION
Kenneth Marra
PERSONJane Doe
PERSONRoy Black
PERSONMaria Farmer
PERSONFBI
ORGANIZATION
Palm Beach Police Department
ORGANIZATION
Jay Lefkowitz
PERSON
George W. Bush
PERSON
A. Marie Villafana
PERSON
Prince Andrew
PERSON