Epstein Secrets

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

the federal investigation of Mr. Epstein. He asked to meet with her and she stated that she believed such a meeting would be premature. In December, Lilly Ann Sanchez and Gerald Lefcourt again contacted AUSA Villafafia to set a meeting. AUSA Villafafia requested documents in advance of such a meeting,

witz and myself that any appeal to Washington would be undertaken expeditiously. On September 7, 2007,1, along with FAUSA Sloman, AUSAs McMillan and Villafafta, and FBI agents, met with you, Mr. Lefkowitz, and Ms. Sanchez. I understood that you wished to present federalism-based concerns regarding our pros

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.

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

ivilege(s) Asserted Box #3 P-011923 Thru P-011966 Folder entitled "Responses to Arguments from JE Counsel" containing: ■ 7/13/2007 letter from Lilly Ann Sanchez to Andrew Lourie with handwritten attorney (Lourie) notes; ■ 6/25/2007 letter from Gerald Lefcourt to Jeffrey Sloman, Matt Menchal, A

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

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 Lefeourt and Jay Lefkowitz had the opportunity to review and raise objections to the term

owitz and myself that any appeal to Washington would be undertaken expeditiously. On September 7, 2007,1, along withFAUSA Sloman, AUSAs McMillan and Villafafta, and FBI agents, met with you, Mr. Lefkowitz, and Ms. Sanchez. I understood that you wished to present federalism-based concerns regarding our pros