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onfidential. Except as otherwise admitted above, the government denies Request No. 14. 8 EFTA00191206 IS. (a) The government admits that, while Bruce E. Reinhart was an Assistant U.S. Attorney, he learned confidential, non-public information about the Epstein matter. (b) The government admits that, while Br
ox 3 P-013906 E-mail Menchel to Villafana and Lourie, May 14, 2007, 10:52 a.m., RE: Operation Leap Ycar, with e-mail from Villafana to Lourie and Menchel (May 14, 2007, 10:38 a.m.), attached Atty work-product Suppl. Box 3 P-013907 Through P-013908 Inadvertently marked as privileged, will be pro
stay] Suppl. Box 3 P-013861 Thru P-013865 E-mail, Marie Villafana to Matthew Menchel, July 13, 2007, 3:14 p.m., RE: Epstein, with c- mail from Menchel (July 5, 2007, 3:30 p.m.), Villafana to Menchel (July 4, 2007, 5:16 p.m.), and Sloman to Villafana (July 3, 2007, 1:47 p.m.), attached Atty work-
roduct Investigative Privilege Privacy Act 5 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 Deliberative Process Investigative Pr
tence of the non-prosecution agreement confidential. Except as otherwise admitted above, the government denies Request No. 14. 15. Defense attorney Bruce E. Reinhart: (a) learned confidential, non-public information about the Epstein matter; UNITED STATES RESPONSE: 15. (a) The government admits that, while Bru
dmits that it has information about a personal or business relationship between Jeffrey Epstein and another prosecutor involved in the Epstein case, Matthew Menchel. Answers I0 EFTA00081125 Case 9:08-cv-80736-KAM Document 225-1 Entered on FLSD Docket 08/16/2013 Page 11 of 64 to Requests for Admission at I 2
chel has a personal or business relationship with defendant Jeffrey Epstein. Gov't Answers to RFA's ¶ 20. This could potentially show misconduct by Menchel, and also potentially a motive to violate the victims' rights as explained previously. The Government's privilege log has numerous entries showing
luding, but not limited to, federal prosecutors Alexander Acosta, Jeffrey H. Sloman, Matt Menchel, Andy Lourie, Ann Marie Villafana, Dexter Lee, and Bruce Reinhart and state prosecutors Dahlia Weiss, Lana Belolovek, and others involved in the Epstein investigation) and defense attorneys representing Epstein (i
ny type between government prosecutors working on the case (including, but not limited to, federal prosecutors Alexander Acosta, Jeffrey H. Sloman, Matt Menchel, Andy Lourie, Ann Marie Villafana, Dexter Lee, and Bruce Reinhart and state prosecutors Dahlia Weiss, Lana Belolovek, and others involved in the Eps
ney's Office and Epstein's defense attorneys were working to keep the existence of the non-prosecution agreement confidential. 15. Defense attorney Bruce E. Reinhart: (a) (b) learned confidential, non-public information about the Epstein matter; discussed the Epstein matter with an attorney working on the case
elephone logs, photographs, emails or statement(s) of other credible sources) about a personal or business relationship between Jeffrey Epstein and Matthew Menchel. 21. The government possesses, or has knowledge or information (including telephone logs, photographs, emails or statement(s) of other credible sou
luding, but not limited to, federal prosecutors Alexander Acosta, Jeffrey H. Sloman, Matt Menchel, Andy Lourie, Ann Marie Villafana, Dexter Lee, and Bruce Reinhart and state prosecutors Dahlia Weiss, Lana Belolovek, and others involved in the Epstein investigation) and defense attorneys representing Epstein (i
ny type between government prosecutors working on the case (including, but not limited to, federal prosecutors Alexander Acosta, Jeffrey H. Sloman, Matt Menchel, Andy Lourie, Ann Marie Villafana, Dexter Lee, and Bruce Reinhart and state prosecutors Dahlia Weiss, Lana Belolovek, and others involved in the Eps
existence, which was disclosed to the state court judge during the change of plea. 15. (a) Admit in part. While he was an Assistant U.S. Attorney, Bruce E. Reinhart learned confidential, non-public information about the Epstein matter. (b) Admit in part. While he was an Assistant U.S. Attorney, Bruce E. Reinhar
f any such relationships with Epstein directly. We will need to review emails and possibly interview Alex/Jeff/Matt/Andy.] 20. Admit. [I know that Menchel now has a business relationship with Epstein. I don't have any documentary evidence, but I have been told this by Jeff Sloman.] 21. [I don't know.]
ney's Office and Epstein's defense attorneys were working to keep the existence of the non-prosecution agreement confidential. 15. Defense attorney Bruce E. Reinhart: (a) (b) learned confidential, non-public information about the Epstein matter; discussed the Epstein matter with an attorney working on the case
elephone logs, photographs, emails or statement(s) of other credible sources) about a personal or business relationship between Jeffrey Epstein and Matthew Menchel. 21. The government possesses, or has knowledge or information (including telephone logs, photographs, emails or statement(s) of other credible sou
ney's Office and Epstein's defense attorneys were working to keep the existence of the non-prosecution agreement confidential. 15. Defense attorney Bruce E. Reinhart: (a) (b) learned confidential, non-public information about the Epstein matter; discussed the Epstein matter with an attorney working on the case
elephone logs, photographs, emails or statement(s) of other credible sources) about a personal or business relationship between Jeffrey Epstein and Matthew Menchel. 21. The government possesses, or has knowledge or information (including telephone logs, photographs, emails or statement(s) of other credible sou
ney's Office and Epstein's defense attorneys were working to keep the existence of the non-prosecution agreement confidential. 15. Defense attorney Bruce E. Reinhart: (a) (b) learned confidential, non-public information about the Epstein matter; discussed the Epstein matter with an attorney working on the case
elephone logs, photographs, emails or statement(s) of other credible sources) about a personal or business relationship between Jeffrey Epstein and Matthew Menchel. 21. The government possesses, or has knowledge or information (including telephone logs, photographs, emails or statement(s) of other credible sou
uit by voluntary requests for interview with persons who are no longer employed by the Justice Department. For example, I have sent letters to both Bruce Reinhart and Alex Acosta, who both have information about the Epstein case, requesting an opportunity to discuss the case with them. Both of them have ignor
No Attorney-Client Relationship; Waiver; Claims Against Public Prosecutor, Overriding Need; Attorney Conduct at Issue Epstein, with e- mail from Menchel (July 5, 2007, 3:30 p.m.), Villafana to Menchel (July 4, 2007, 5:16 p.m.), and Sloman to Villafana (July 3, 2007, 1:47 p.m.), attached Suppl. Bo
Entities connected to both Bruce E. Reinhart and Matthew I. Menchel

Jeffrey Epstein
PERSONJack Goldberger
PERSONJane Doe
PERSON
Bradley Edwards
PERSON
Paul Cassell
PERSONJack Scarola
PERSONRichard Horace Willits
PERSON
Sarah Kellen
PERSON
Kenneth Marra
PERSON
Lake Worth
LOCATIONRobert C. Josefsberg
PERSONLeon Black
PERSON
Alan Dershowitz
PERSONScott Rothstein
PERSONSpencer Kuvin
PERSON
Salt Lake City
LOCATION
Jay Lefkowitz
PERSON
Lesley Groff
PERSON
A. Marie Villafana
PERSON
Palm Beach Gardens
LOCATION