Epstein Secrets

on lift of stay by 11 th Circuit]) Box #2 P-008364 Thru P-008382 File folder entitled "Lacerda Immunity Request" containing internal memoranda, Justice Department documentation, and subpoena regarding immunity request 6(e) Work Product Deliberative Process Investigative privilege Box #2 P-008383 Thru P

ated December 16 and 17, 2010, with attached letter from Paul Cassell to Wifredo A. Ferrer, dated December 10, 2010 Page 23 of 23 EFTA00191236 U.S. Department of Justice United States Attorney Southern District of Florida 500 S. Ausfrallan Ave, Ste 400 West Palm Beach, FL 33401 (561)820-8711 Facsimile: (561)820-

" containing attorney research Work product Box #1 P-003679 Thru P-003680 File folder entitled "Serene Cano (N.Y. AUSA)" containing attorney (Villafafla) handwritten notes Work product Box #1 P-003681 Thru P-003687 File folder entitled "Dr. Anna Salter" containing attorney (Villafafia) memo to

LY-01 through OLY-81, correspondence and research related to enforcement of same, documents produced in response to some subpoenas; and attorney (Villafafla) handwritten notes 6(e) Work Product Contains documents subject to investigative privilege Also contains documents subject to privacy rights of

908 Inadvertently marked as privileged, will be produced N/A Suppl. Box 3 P-013909 Thru P-013911 Memorandum, Lisa Howard, Assistant Counsel, U.S. Department of Justice, Office of Professional Responsibility (OPR), to Ruth Plagenhoef, Acting Associate Counsel, OPR, undated, Subject: Recommendation Deliberati

with the person who was being prosecuted. 50. RFP No. 17 asks for documents concerning an investigation into the Epstein prosecution undertaken by the Justice Department's Office of Professional Responsibility (OPR) in Washington, D.C. The investigation was undertaken at the request of the victims, who asked the Justi

Public Prosecutor, Attorney Conduct at Issue Box #1 P-004561 Thru P-004565 Filed folder entitled "JANUSZ BANASIAK" containing attorney (Villafafla) handwritten notes of interview Work product Investigative privilege • Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Not in Anticipa

information about possible improper behavior during the investigation of the Epstein matter. Gov't Answers to RFA ¶22 (government admits that "The Justice Department's Office of Professional Responsibility and/or other Government entities have collected information about ... other government attorney's [apart from

with the person who was being prosecuted. 50. RFP No. 17 asks for documents concerning an investigation into the Epstein prosecution undertaken by the Justice Department's Office of Professional Responsibility (OPR) in Washington, D.C. The investigation was undertaken at the request of the victims, who asked the Justi

meet to provide information about the federal crimes committed by Epstein, hoping to secure a significant federal indictment against Epstein. AUSA Villafafla and I discussed the possibility of federal charges being filed. At the end of the call, AUSA Villafafla asked me to send any information that I want

hat you now object to the Agreement that you negotiated, this is akin to "buyer's remorse." However, you and Mr. Starr have, instead, made claims to the Justice Department that these thoroughly negotiated terms "leave[) wide open the opportunity for misconduct by federal investigators." You then misinterpret several st

Lot 6410 Case No. 08-80736-CV-MARRA P-013333 EFTA00230238 " /13/0 I S(60--)-104; Le:4w 1.3 Case No. 08-80736-CV-MARRA P-013334 EFTA00230239 U.S. Department of Justice United States Attorney Southern District of Florida DELIVERY BY FACSIMILE Jay P. Lefkowitz, Esq. Kirkland & Ellis LLP Citigroup Center 153 Eas

osta met with Kirkland & Ellis partners Jay Lefkowitz and former Solicitor General Ken Starr and Ms. Sanchez, along with Chief Oosterbahn and AUSAs Villafafla, John McMillan, and FAUSA S lomat' Messrs. Starr and Lefkowitz presented arguments regarding the sufficiency of the federal interest in the case and