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/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
tween 6(e) Work Product Deliberative Process Investigative Privilege and regarding preparation for grand jury presentation; communication with S/A Kuyrkendall regarding plea negotiations; and status of on oin investigation P414912 thru P-014919 5/23/2008-5/27/2008 emails between Work Product 6(e) De
) 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
tt Kuyrkendall approached me about an investigation being conducted by the Town of Palm Beach Police Department ("PBPD"). I do not know how or when S/A Kuyrkendall was first contacted about the matter. The first mentions of the investigation were just passing comments during meetings on other matters. S/A Kuyr
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
ails between Marie Villafafia, Karen Atkinson, Robert Senior, and Jeff Sloman regarding preparation for grand jury presentation; communication with S/A Kuyrkendall regarding plea negotiations; and status of ongoing investigation 6(e) Work Product Deliberative Process Investigative Privilege P-014912 thru
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
ails between Marie Villafafia, Karen Atkinson, Robert Senior, and Jeff Sloman regarding preparation for grand jury presentation; communication with S/A Kuyrkendall regarding plea negotiations; and status of ongoing investigation 6(e) Work Product Deliberative Process Investigative Privilege P-014912 thru
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
ails between Marie Villafafia, Karen Atkinson, Robert Senior, and Jeff Sloman regarding preparation for grand jury presentation; communication with S/A Kuyrkendall regarding plea negotiations; and status of ongoing investigation 6(e) Work Product Deliberative Process Investigative Privilege P-014912 thru
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
Page: EFTA00020711 →ails between Marie Villafafia, Karen Atkinson, Robert Senior, and Jeff Sloman regarding preparation for grand jury presentation; communication with S/A Kuyrkendall regarding plea negotiations; and status of ongoing investigation 6(e) Work Product Deliberative Process Investigative Privilege P-014912 thru
Page: EFTA00020728 →Entities connected to both Jeffrey Epstein and S/A Kuyrkendall

Lesley Groff
PERSONLeon Black
PERSON
Prince Andrew
PERSON
Ghislaine Maxwell
PERSON
Alan Dershowitz
PERSON
Bradley Edwards
PERSON
United States
LOCATIONJack Goldberger
PERSONSouthern District
LOCATIONJane Doe
PERSON
Department of Justice
ORGANIZATIONMaria Farmer
PERSON
Kenneth Marra
PERSON
Alexander Acosta
PERSONthe Southern District
LOCATION
Paul Cassell
PERSONFBI
ORGANIZATION
A. Marie Villafana
PERSON
Jay Lefkowitz
PERSONRoy Black
PERSON