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vilege(s) Asserted Box #3 P-011923 Thru P-011966 Folder entitled "Responses to Arguments from JE Counsel" containing: II 7/13/2007 letter from Lilly Ann Sanchez to with handwritten attorney notes; • 6/25/2007 letter from Gerald Lefcourt to a Sloman, Menchal , and with handwritten attorn
him and the girls about the agreement. I know that Andy promised Chief Reiter an update when a resolution was achieved.... Rolando is calling, but Rolando knows not to tell Chief Reiter about the money issue, just about what crimes Mr. Epstein is pleading guilty to and the amount of time that has been
discuss what I can tell him and the girls about the agreement. I know that Andy promised Chief Reiter an update when a resolution was achieved.... Rolando is calling, but Rolando knows not to tell Chief Reiter about the money issue, just about what crimes Mr. Epstein is pleading guilty to and the amoun
notifying Palm Beach Police Chief and victims about agreement P-014206 thru P-014216 9/24/2007-9/25/2007 emails between Alex Acosta, n --- and Rolando regarding Lefkowitz email about keeping agreement from becoming public and confidentiality provision in agreement Work Product Deliberative Proc
e NPA, but intentionally declined to confer with Epstein's victims about the Agreement.104 90. On December 19, 2007, U.S. Attorney sent a letter to Lilly Atm Sanchez stating, "I understand that the defense objects to the victims being given notice of time and place of Mr. Epstein's state court senten
I can tell him and the girls about the agreement. I know that promised Chief an update when a resolution was achieved.... Rolando is calling, but Rolando knows not to tell Chief about the money issue, just about what crimes Mr. Epstein is pleading guilty to and the amount of time that has been agree
ls, we can discuss what I can tell him and the girls about the agreement. I know that promised Chief an update when a resolution was achieved.... Rolando is calling, but Rolando knows not to tell Chief about the money issue, just about what crimes Mr. Epstein is pleading guilty to and the amount of
Prosecutor; Overriding Need; Attorney Conduct at Issue Suppl. Box 3 P-013859 Through P-013860 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.
ion Privilege(s) Asserted Victims' Objections Conduct at Issue Suppl. Box 3 P-013843 Thru P-013844 E-mail, Marie Villafana to Andrew Lourie, Rolando Garcia, and Karen Atkinson, September 19, 2007, 4:33 p.m., RE: Plea Agreement Atty work-product atty-client privilege Inadequate Log; No Factual Underp
6, 2007, 9:29 a.m., Re: Meeting on Friday atty work-product Suppl. Box 3 P-013859 Through P-013860 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] Suppl. Box
n-Prosecution Agreement Atty work-product Atty-client privilege Suppl. Box 3 P-013843 Thru P-013844 E-mail, Marie Villafana to Andrew Lourie, Rolando Garcia, and Karen Atkinson, September 19, 2007, 4:33 p.m., RE: Plea Agreement Atty work-product atty-client privilege Suppl. Box 3 P-013845 Thru P-01
ease ask the Custodian of Records to provide a certificate of nonexistence of records. Also, following our conversation 1 received a voicemail from Lilly Ann Sanchez addressing the subpoenas. Since you have provided a written statement that you represent JEGE and Hyperion, I will assume that you alon
, September 24, 2007 Email from J. Lefkowitz to M. 22. Ms. replied that she had "forwarded your message only to Alex [Acosta], Andy [Lourie], and Rolando [Garcia]. I don't anticipate it going any further than that." Id. 23. Ms. stated that the agreement would be "placed in the case file, which will
ic Prosecutor; 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.
tion Privilege(s) Asserted Victims' Objections Conduct at Issue SuppL Box 3 P-013843 Thru P-013844 E-mail, Marie Villafana to Andrew Lourie, Rolando Garcia, and Karen Atkinson, September 19, 2007, 4:33 p.m., RE: Plea Agreement Atty work-product arty-client privilege Inadequate Log; No Factual Underp
compensation for damages and will always support any disposition that eliminates the need for trial. See attached Tab B, August 2, 2007 letter from Lilly Ann Sanchez to SDFL Criminal Division Chief Menchel, p.2, fn I. Ironically, it is Epstein's "national" attorneys who are now representing to the De
Sloman, am writing this letter, I will continue to refer to myself as "First Assistant USA Sloman" or "FAUSA Sloman" to help reduce any confusion. Rolando Garcia replaced Mr. Lourie as the Deputy Chief of the Criminal Division. Confidential and Privileged — Attorney Work Product -2- EFTA00225179 with Crimi
were detailed and time-consuming. Mr. Epstein's defense team, including yourself, Professor Dershowitz, former United States Attorney Guy Lewis, Ms. Lilly Ann Sanchez and Messrs. Roy Black, Jack Goldberger, Gerry Lefcourt and Jay Lefkowitz had the opportunity to review and raise objections to the term
ic." See Tab 27, September 24, 2007 Email from J. Lefkowitz to M. 22. Ms. replied that she had "forwarded your message only to [=], (Loune], and Rolando [Garcia]. I don't anticipate it going any further than that." Id. 23. Ms. stated that the agreement would be "placed in the case file, which will
in child exploitation cases was an issue of growing concern, so I was mindful that this plea mechanism that Criminal Chief Menchel had devised with Lilly Ann Sanchez would extinguish, the victims' right to restitution. That was one of the reasons why, on July 4, 2007, I wrote to Mr. Menchel that I be
rk release and also should be able to tell us whether a plea and sentencing can be scheduled this month" (Exhibit 72). FAUSA Sloman and Acting MAUSA Rolando Garcia had conversations with the State Attorney and Jay Lefkowitz who both confirmed that Epstein would "be a sex offender and he'll be treated like any
Entities connected to both Lilly and Rolando Garcia

Jeffrey Epstein
PERSON
A. Marie Villafana
PERSON
Alexander Acosta
PERSONAnn Sanchez
PERSONGarcia
PERSON
Kenneth Marra
PERSON
Lesley Groff
PERSON
Karen Atkinson
PERSON
Jay Lefkowitz
PERSON
Jeffrey Sloman
PERSON
Prince Andrew
PERSONLeon Black
PERSONKaren
PERSONJack Goldberger
PERSON
Joe Biden
PERSONRoy Black
PERSON
Barry Diller
PERSONGerald Lefcourt
PERSONLourie
PERSON
Ken Starr
PERSON