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d rights. EFTA00207876 We do not believe there is any right to discovery in this case. Moreover, we do not believe that whatever Kenneth Starr or Lilly Ann Sanchez may have said to this office, or what this office said to Kenneth Starr or Lilly Ann Sanchez, has any bearing on whether a duty existed
ke the position that you can withhold the other half of the U.S. Attorney's correspondence, correspondence between the Department and Ken Starr and Lillian Sanchez on behalf of Epstein, and information about role in the Epstein case. In short, we understand you to be asserting a blanket position that you can w
ce those claimed rights. We do not believe there is any right to discovery in this case. Moreover, we do not believe that whatever Kenneth Starr or Lilly Ann Sanchez may have said to this office, or what this office said to Kenneth Starr or Lilly Ann Sanchez, has any bearing on whether a duty existed
ke the position that you can withhold the other half of the U.S. Attorney's correspondence, correspondence between the Department and Ken Starr and Lillian Sanchez on behalf of Epstein, and information about Bruce Reinhart's role in the Epstein case. In short, we understand you to be asserting a blanket positio
ce those claimed rights. We do not believe there is any right to discovery in this case. Moreover, we do not believe that whatever Kenneth Starr or Lilly Ann Sanchez may have said to this office, or what this office said to Kenneth Starr or Lilly Ann Sanchez, has any bearing on whether a duty existed
ke the position that you can withhold the other half of the U.S. Attorney's correspondence, correspondence between the Department and Ken Starr and Lillian Sanchez on behalf of Epstein, and information about Bruce Reinhart's role in the Epstein case. In short, we understand you to be asserting a blanket positio
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
ve process privilege. 3 EFTA00191201 6. (a) Denied. (b) Denied. (c) Admitted. (d) Admitted. (e) Admitted to the extent that the reference to "Lillian Sanchez" was meant to refer to Lilly Ann Sanchez. (0 Admitted. (g) Admitted. 7. The government admits that, on about January 10, 2008, when Jane Doe # I
Entities connected to both Lilly and Lillian Sanchez

Jeffrey Epstein
PERSONAnn Sanchez
PERSON
Lesley Groff
PERSONLeon Black
PERSONJack Goldberger
PERSON
Bradley Edwards
PERSONRoy Black
PERSONGerald Lefcourt
PERSON
Ken Starr
PERSON
Kenneth Marra
PERSON
Department of Justice
ORGANIZATION
Jay Lefkowitz
PERSON
Alexander Acosta
PERSONJane Doe
PERSON
Alan Dershowitz
PERSONSanchez
PERSONthe Southern District
LOCATION
United States
LOCATION
Paul Cassell
PERSON
Prince Andrew
PERSON