Epstein Secrets

Epstein (including, but not limited to, Roy Black, Jay Lefkowitz, Jack Goldberger, Martin Weinberg, Gerald Lefcourt, Michael Tien, Guy Lewis, Lilly Ann Sanchez, Ken Starr, Alan Dershowitz) and agents acting in support of Epstein (including, but not limited to former President Bill Clinton and Andrew Albert

to which the crime-fraud-misconduct exception applies on this basis is found on page 3 of the supplemental privilege log (DE 216-1), with regard to Suppl. Box #3 P-013342 to P-013350. The entry reads: "File folder entitled `12/05/07 Starr to Acosta' containing drafts of 11/30/07 letters from A. Acost

cutor; 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. Box 3 P-01

fafia re negotiations with attached correspondence; ■ 9/17/07 e-mail from A. Marie Villafafia to R. Garcia A. Lourie re negotiation strategy Suppl. Box #3 P-013609 Thru P-013615 File folder entitled "0 Target Letter" containing copy of signed letter and contact info for counsel for target

7, 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 3 P-013861

ege Work Product Investigative privilege Also contains information subject to privacy rights of victims who are not parties to this litigation Suppl. Box #3 P-013282 Thru P-013283 7/9/08 Email from A. Marie Villafafia to A. Acosta, J. Sloman, K. Atkinson, and FBI re proposed response to Gold

Epstein (including, but not limited to, Roy Black, Jay Lefkowitz, Jack Goldberger, Martin Weinberg, Gerald Lefcourt, Michael Tien, Guy Lewis, Lilly Ann Sanchez, Ken Starr, Alan Dershowitz) and agents acting in support of Epstein (including, but not limited to former President Bill Clinton and Andrew Albert

to which the crime-fraud-misconduct exception applies on this basis is found on page 3 of the supplemental privilege log (DE 216-1), with regard to Suppl. Box #3 P-013342 to P-013350. The entry reads: "File folder entitled `12/05/07 Starr to Acosta' containing drafts of 11/30/07 letters from A. Acost

859 Through P-013860 Email, Gerald Lefcourt to Lilly [Not considered privileged. Will be produced to opposing counsel upon lifting of stay] Ann Sanchez, Roy Black, re: Jeffrey Epstein Suppl. Box 3 P-013861 Thru P-013865 E-mail, to Atty work-product atty-client privilege July 13, 2007, 3:14 p

lege Work Product Investigative privilege Also contains information subject to privacy rights of victims who are not arties to this liti ation Suppl. Box #3 P-013282 Thru P-013283 7/9/08 Email from to A. Acosta, and FBI re proposed response to Goldberger letter re victim notification Att

) 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 and Jane Doe #2 were sent letters advisin

ege Work Product Investigative privilege Also contains information subject to privacy rights of victims who are not parties to this litigation Suppl. Box #3 P-013282 Thru P-013283 7/9/08 Email from A. Marie Villafafia to A. Acosta, J. Sloman, K. Atkinson, and FBI re proposed response to Gold

Epstein (including, but not limited to, Roy Black, Jay Lefkowitz, Jack Goldberger, Martin Weinberg, Gerald Lefcourt, Michael Tien, Guy Lewis, Lilly Ann Sanchez, Ken Starr, Alan Dershowitz) and agents acting in support of Epstein (including, but not limited to former President Bill Clinton and Andrew Albert

to which the crime-fraud-misconduct exception applies on this basis is found on page 3 of the supplemental privilege log (DE 216-1), with regard to Suppl. Box #3 P-013342 to P-013350. The entry reads: "File folder entitled `12/05/07 Starr to Acosta' containing drafts of 11/30/07 letters from A. Acost

(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 attorney I I note

ilege Work Product Investigative privilege Also contains information subject to privacy rights of victims who are not rties to this liti ation Suppl. Box #3 P-013282 Thru P-013283 7/9/08 Email from to A. Acosta, and FBI re proposed response to Goldberger letter re victim notification Att

secutor; 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. Box 3 P-01

rials; Attorney Conduct at Issue ftom J. Leflcowitz to A. Acosta re performance of NPA and appeal to Washington with attorney handwritten notes Suppl. Box #3 P-013362 Thm P413366 File folder labeled "12/26/07 Le&owitz to Acosta" containing 2 copies of draft letter from A. Acosta to J. Lefkowi

Epstein (including, but not limited to, Roy Black, Jay Lefkowitz, Jack Goldberger, Martin Weinberg, Gerald Lefcourt, Michael Tien, Guy Lewis, Lilly Ann Sanchez, Ken Starr, Alan Dershowitz) and agents acting in support of Epstein (including, but not limited to former President Bill Clinton and Andrew Albert

to which the crime-fraud-misconduct exception applies on this basis is found on page 3 of the supplemental privilege log (DE 216-1), with regard to Suppl. Box #3 P-013342 to P-013350. The entry reads: "File folder entitled '12/05/07 Stan• to Acosta' containing drafts of 11/30/07 letters from A. Acost