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

ilege Also contains information subject to privacy rights of victims who are not parties to this litigation Investigative Privilege Acosta, and Alan Santiago regarding results of additional victim-witness interviews and requesting intervention with CEOS to move review process along P-014574 thru 2/20/

EPSTEIN INVESTIGATION TIMELINE Date To From Re: Exhibit # 5/1/2006 State Attorney Barry E. ICrischer Michael S. Reiter, Chief of Police for Town

McSorley. B-15 12/7/2007 Sloman Lilly Ann Sanchez Letter - 1 pages with Affirmation signed by Epstein and Notice of Hearing, State of Florida I. Jeffrey Epstein, attached 12/7/2007 Victim notification letter prepared 12/7/2007 at 9:10 pm B-6 12/7/2007 Unmailed victim notification letters B-14 12/10/200

hat there are some inaccuracies and omissions in Mr. Epstein's fde. i 12/ 11/2008 Villafatia, cc: Senior

a 9/2/2008 Richard H. Willits), #4, #13, #8 (via Jeffrey Herman), #9, #10, #11, #14, #16, #17 (via Theodore Leopold), #20, #21, #23, #24, #25 (via Jeffrey B \ , ' Herman), #26 (via Jeffrey Herman), #30, #31, #32, #33, #37 (via Michael E. Dutko), #38, #44 (via Jeffrey Herman) 9/3/2008 Victim notific

Vitiator-1a Critton Letter re NPA with attached Defendant Epstein's Motion to Dismiss Plaintiffs Complaint (Jane D

. Marie Villafafia Lilly Ann Sanchez Because of the Palm Beach Police Department and the State Attorney's ti investigation for almost two years, E stein hired counsel for all employees so contact Ms. Sanchez for contact information for the attorneys. I 1/22/2007 Andrew Lourie Lilly Ann Sanchez

and served B-108 1/31/2008 1/28/2008-2/1/2008 Emails between Marie Vil!ataxia, Jeff Sloman, Alex Acosta, Nesbitt Kuyrkendall, Jason Richards, and Alan Santiago regarding results of additional victim-witness interviews and requesting intervention with CEOS to move review process along B-109 1/31/2008 Slo

) From: Sloman. Jeff (USAFLS) Sent: Monday, October 22, 2007 5:26 PM To: Villafana, Ann Marie C. (USAFLS); Acosta, Alex (USAFLS) Subject: Fw: Epstein Fyi Sent from my BlackBerry Wireless Handheld Original Message From: Sloman, Jeff (USAFLS) To: '[email protected]. <JLefkowitz@kirklan

[email protected]> To: Sloman, Jeff (USAFLS) Cc: Acosta, Alex (USAFLS); Villafana, Ann Marie C. (USAFLS) Sent: Mon Oct 22 17:10:00 2007 Subject: Re: Epstein Jeff -- I will review these materials this evening and be in touch with you tomorrow with the expectation of wrapping this up by nd of the day. One que

McSorley. R I s 12/7/2007 Sloman Lilly Ann Sanchez Letter -1 pages with Affirmation signed by Epstein and Notice of Heating, State of Florida I. Jeffrey Epstein, attached 12/7/2007 Victim notification letter prepared 12/7/2007 at 9:10 pm B-6 12/7/2007 Unmailed victim notification letters B-14 12/10/200

the attorney representative be told clearly that Mr. Epstein has agreed to pay the lawyer's hourly rate only f

a 9/2/2008 Richard H. Willits), #4, #13, #8 (via Jeffrey Herman), #9, #10, #11, #14, #16, #17 (via Theodore Leopold), #20, #21, #23, #24, #25 (via Jeffrey B-89 Herman), #26 (via Jeffrey Herman), #30, #31, #32, #33, #37 (via Michael E. Dutko), #38, #44 (via Jeffrey Herman) 9/3/2008 Victim notificatio

Villafafia Critton Letter rc NPA with attached Defendant Epstein's Motion to Dismiss Plaintiffs Complaint (Jane D

grand jury subpoenas B-109 1/28/2008• 2/1/2008 Entails between Marie Villafana,Jeff Sloman, Alex Acosta, Nesbit Kuyrkendall, Jason Richards, and Alan Santiago regarding results of additional victim-witness interviews and requesting intervention with CEOS to move review process along B-I 10 2/12/2008- 2/

mail from Andy Lourie to Man Menchel and Jeff Sloman (cc: Marie Villafaila) re letter received from Gerald Lefcourt discussing a meeting to discuss Epstein investigation Work Product Deliberative Process P-013982 5/23/2007 email from Jason Richards to Marie Villafaiia re extradition research Work P

on P-014569 thru P-014573 1/31/2008-2/1/2008 emails between Marie Villafafta, Jeff Sloman, Alex Acosta, Nesbitt Kuyrkendall, Jason Richards, and Alan Santiago regarding results of additional victim-witness interviews and requesting intervention with CEOS to move review process along Work Product Deliber

mail from Andy Lourie to Man Menchel and Jeff Sloman (cc: Marie Villafaila) re letter received from Gerald Lefcourt discussing a meeting to discuss Epstein investigation Work Product Deliberative Process P-013982 5/23/2007 email from Jason Richards to Marie Villafaiia re extradition research Work P

on P-014569 thru P-014573 1/31/2008-2/1/2008 emails between Marie Villafafta, Jeff Sloman, Alex Acosta, Nesbitt Kuyrkendall, Jason Richards, and Alan Santiago regarding results of additional victim-witness interviews and requesting intervention with CEOS to move review process along Work Product Deliber

arlave, Tim Delaney, Nucci, Jason Richards, Nezbitt Kurkendall. Eliasib Ortiz, Alan Santiago regarding the prosecution (or non-prosecution) of the Epstein case, any of the Epstein victims, or federal prosecutors obtaining benefits from Epstein. EFTA00211065 I later met with you and your team on the p

mental Discovery Request 3. Any emails to or from FBI employees Val Parlave, Tim Delaney, Nucci, Jason Richards, Nezbitt Kurkendall. Eliasib Ortiz, Alan Santiago regarding the prosecution (or non-prosecution) of the Epstein case, any of the Epstein victims, or federal prosecutors obtaining benefits from Epste

ail from Andy Lourie to Matt Menchel and Jeff Sloman (cc: Marie Villafafia) re letter received from Gerald Lefcourt discussing a meeting to discuss Epstein investigation Work Product Deliberative Process P-013982 5/23/2007 email from Jason Richards to Marie Villafafia re extradition research Work P

on P-014569 thru P-014573 1/31/2008-2/1/2008 emails between Marie Villafafia, Jeff Sloman, Alex Acosta, Nesbitt Kuyrkendall, Jason Richards, and Alan Santiago regarding results of additional victim-witness interviews and requesting intervention with CEOS to move review process along Work Product Deliber

ail from Andy Laurie to Matt Menchel and Jeff Sloman (cc: Marie Villafatia) re letter received from Gerald Lefcourt discussing a meeting to discuss Epstein investigation Work Product Deliberative Process P-013982 5/23/2007 email from Jason Richards to Marie Villafaila re extradition research Work P

on P-014569 thru P-014573 1/31/2008-2/1/2008 emails between Marie Villafafta, Jeff Sloman, Alex Acosta, Nesbitt Kuyrkendall, Jason Richards, and Alan Santiago regarding results of additional victim-witness interviews and requesting intervention with CEOS to move review process along Work Product Deliber