Epstein Secrets

/2013 Page 19 of 23 Bates Range Description Privilege(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 t

ml 6/25/2007 email from to and entitled "Thoughts on Lefcourt's letter" Handwritten and typed attorney ( ) notes regarding main themes raised by Epstein counsel Work product Deliberative process 6(e) Attorney-Client Privilege Box #3 P-011967 Thru P-012016 Composition book entitled "Operation

y and privacy."2 The undisputed evidence begins in 2005, when the Palm Beach Police Department ("PBPD") had identified numerous girls as victims of Jeffrey Epstein's sexual crimes. In 2006, the PBPD turned the case over to federal authorities for further investigation. As early as March 15, 2007 and throughout t

e victims. The letter also falsely claimed that "Mr. Epstein never targeted minors," and urged the Government

tion Box #3 P-012017 Thru P-012055 Motion of Jeffrey Epstein to Intervene and to Quash Grand Jury Sub

ains information subject to privacy rights of victims who are not parties to this litigation regarding Lefkowitz email about lawsuit filed against Epstem by one of the victims identified during the state investigation. Page 12 of 18 EFTA00185441 Case 9:08-cv-80736-KAM Document 329-1 Entered on FLS

-015028 7/8/2008 email from . to A. Acosta, and Work Product Deliberative Process regarding victim notification letter provided to counsel for J. Epstein on 11/28/2007 with attachment (NB: The 11/28/2007 email to J. Leflcowitz with attachment will be produced to petitioners' counsel contemporaneously

tached Suppl. Box 3 P-013954 Thru P-013955 E-mail, to OPR, December 16, 2010, 10:59 ., FW: OPR Referral — Allegation of Misconduct — U.S. Attome 's Office S.D.Fla., with e-mail from to (December 16, 2010, 10:22 .), attached. Handwritten attorney any work-product, any- client privilege n

"Victim Civil Suits" Not privileged. Produced to counsel for Petitioners N/A Box #1 P-003664 Thru P-003678 File folder entitled "Research it JE Websites" containing attorney research Work product Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Not in Anticipation of Litigation;

re Travel for Prostitution" containing attorney (Villafaria) handwritten notes regarding grand jury presentation, chart entitled "Brought to Epstein's House" with handwritten notes, Message Pad meta- analysis chart, summary of evidence related to one victim/witness, and relevant grand jury i

ecutor; Overriding Need; Attorney Conduct at Issue Suppl. Box 3 P-013836 Thru P-013837 Palm Beach Daily News Article, "Attorneys want Jeffrey Epstein Agreement Thrown Out," with attorney's notes written on margin Atty work-product Inadequate Log; No Factual Underpinnings; Fiduciary Duty;

recusal of Southern District of Florida, dated July 29, 2011, with attached memorandum from A. Marie Villafafia to Benjamin Greenberg summarizing Jeffrey E stein Investi ation Attorney-Client Privilege Deliberative Process Work Product No Factual Underpinnings; Fiduciary Duty; Not in Anticipation

Factual Underpinnings; Fiduciary Duty; Not in Anticipation of Litigation; Improper Invocation; Overriding Need; Claims Against Public Prosecutor; Attome Conduct at Issue Suppl. Box 3 P-013937 Thru P-013939 Draft Letter, Robin C. Ashton to Professor Paul G. Cassell, with handwritten correcti

venue New York, NY 10022 Laura Menninger, Esq. Jeffrey Pagliuca, Esq. Haddon, Morgan and Foreman, P.C.

y 2016 meeting, AUSA deceived copies of Jeffrey Epstein's black book, excerpts of flight records, and certain Palm Beach Police Department reports. Epstein's black book and the Palm Beach Police Department reports were previously produced to you on August 21, 2020, and can be found at SDNY_GM_00 174731

stigation. The notes from that interview contain the following line on page 12: "rumor is that JE is gay," apparently referring to a rumor regarding Jeffrey Epstein's sexual orientation. The Government recognizes that its discovery obligations are ongoing and will promptly produce any additional discoverable ma

ruary 2016 meeting Confidential Among the ma erials contained in this production is an excerpt of a flight log that former Assistant United States Attome received during a February 29, 2016 meeting with attorneys representing the "February 2016 meeting"). At the February 2016 meeting, AUSA deceived