Epstein Secrets

Document 361 Entered on FLSD Docket 02/10/2016 Page 1 of 57 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 9:08-cv-80736-KAM JANE DOE 1 AND JANE DOE 2, Petitioners, UNITED STATES, Respondent. JANE DOE 1 AND JANE DOE 2'S CONSOLIDATED STATEMENT OF UNDISPUTED MATERIAL FACTS AND MOTI

m letter to Jane Doe 5 also acknowledged the victims' rights under the CVRA at the same time as the Office was not disclosing the NPA's existence to Jane Doe 5 and the other victiim."6 101. In mid-June 2008, Mr. Edwards contacted the line AUSA handling the case to inform her that he represented Jane Doe 1 a

ile folder entitled "8/14/08 E-mail from Lefk to AMCV" containing undated entails from A. to A. Acosta, re draft response to 8/14/08 email from J. Leflcowitz regarding "the December 2007 proposal" Attorney-Client Privilege Work Product Page 1 of 14 EFTA00185414 Case 9:08-cv-80736-KAM Document 216-1

ict of Florida Brad Edwards, Esq., Farmer Jaffe Weissing Edwards Fistos Lehrman Paul G. Cassell S.J. I uinne olle e of Law at the Attorneys for Jane Doe # 1 and Jane Doe # 2 2 EFTA00209307 Case 9:08-cv-80736-KAM Document 216-1 Entered on FLSD Docket 07/27/2013 Page 1 of 14 SUPPLEMENTAL PRIVILEGE

A. Marie Villafaila to A. Oosterbaan re trust agreement; ■ 9/13/07 e-mail from A. Marie Villafana to R. Garcia, J. Sloman re conference call with J. Leflcowitz; ■ 9/13/07 e-mail from A. Marie Villafana to A. Lourie re plea negotiations with attached correspondence; ■ 9/13/07 e-mail from A. Marie Villafai

partner in the former firm of Herman, Mermelstein, filed five lawsuits, each asking for $50 million, against Mr. Epstein. Each lawsuit is entitled "Jane Doe # vs. Jeffrey Epstein," despite the fact that each of the plaintiffs is an adult and not entitled to plead anonymously. See Tab 32, Examples of Feder

attorneys stating that "I intend to notify the victims by letter after COB Thursday [two days later]." See Tab 34, November 27, 2007 Email from to J. Leflcowitz. 42. The morning of November 28, attorneys for Mr. Epstein faxed a letter to Assistant Attorney General Alice Fisher, requesting a meeting with he

the University of Utah 332 S. 1400 E. Salt Lake City, Utah 84112 (801) 585-5202 Fax: (801) 585-6833 E-mail: [email protected] Attorneys for Jane Doe # 1 and Jane Doe # 2 2 EFTA00211431 Case 9:08-cv-80736-KAM Document 338-1 Entered on FLSD Docket 08/03/2015 Page 1 of 7 JANE DOE v. UNITED STATE

P-015187 thru P-015194 8/20/2008-8/26/2008 emails between A.M. Villafafia, A. Acosta, J. Sloman, R. Senior, and K. Atkinson re draft response to J. Leflcowitz and draft amended victim notification letter (NB: Final version of letter to Lefkotiz and Black has been produced to Petitioners' counsel) Work P

9. who is the named partner in the former firm of filed five lawsuits, each asking for $50 million, against Mr. Epstein. Each lawsuit is entitled "Jane Doe # vs. Jeffrey Epstein," despite the fact that each of the plaintiffs is an adult and not entitled to plead anonymously. See Tab 32, Examples of Feder

attorneys stating that "I intend to notify the victims by letter after COB Thursday [two days later]." See Tab 34, November 27, 2007 Email from to J. Leflcowitz. 42. The morning of November 28, attorneys for Mr. Epstein faxed a letter to Assistant Attorney General Alice Fisher, requesting a meeting with he

PSTEIN asked Jane Doe #18 to recruit other females to travel to 358 El Brillo Way. (189) On or about March 5, 2004, Defendant JEFFREY EPSTEIN asked Jane Doe #19, who was then a seventeen-year-old girl, to leave when she refused to remove her shirt. 31 EFTA00225809 (174) On or about September 30, 2005

ledged the application of the Petite Policy in drafts of the Deferred Prosecution Agreement. See e.g., September 17, 2007 email from M. Villafana to J. Leflcowitz attaching draft Deferred Prosecution Agreement, Exhibit 32. 17 While federal prosecutors once suggested that Mr. Epstein's retention of Jack Goldbe