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

6. The correspondence further discussed a possible plea disposition that would make it hard for a judge to see what was happening: Andy [i.e., AUSA Andrew Laurie] recommended that some of the timing issues be addressed only in the state agreement, so that it isn't obvious to the judge that we are trying to c

orney The United States Attorney's Office Southern District of Florida 500 South Australian Avenue, Suite 400 West Palm Beach, Florida 33401 Re: Jeffrey E. Epstein Dear Messrs. Sloman, Menchel and Lourie and Ms. Villafana: LLLLL .R3Nt .2o2I 7370400 FACSIMILE 221/066102 As you are aware, we represent Jeffre

sent I Jeffrey Epstein, the target of a pending Grand Jury investigation. Prior to the initiation of this federal investigation, I represented Mr. Epstein on a Palm Beach Florida State Attorney's Office investigation and subsequently an Information, the factual basis of which is identical to, and gave

e, Suite 400 West Palm Beach, Florida 33401 Re: Jeffrey E. Epstein Dear Messrs. Sloman, Menchel and Lourie

tion of this federal investigation, I represented Mr. Epstein on a Palm Beach Florida State Attorney's Office

e, Suite 400 West Palm Beach, Florida 33401 Re: Jeffrey E. Epstein Dear Messrs. Sloman, Menchel and Lourie

nsion already requested by Ms. Sanche2 prior to Mr. Richey's appearance as counsel for Mr. Riley. Sincerely, Assistant United States Anorncy cc; Andrew Laurie, Esq. William Richey, Esq. Lilly Ann Sanchez, Esq. Case No. 08-80736-CV-MARRA P-011927 EFTA00226715 LAW O1•1Of • Of GISliALD 13. Incotrirr,

of 2007 through September of 2007, discussions took place between the U.S. Attorney's Office for the Southern District of Florida ("the Office") and Jeffrey Epstein's attorneys. (DE 407 at ¶ 9.) On February I, 2007, Epstein's defense team sent a 24-page letter to the Office going over what they intended to presen

ial Facts (hereinafter, "DE 407" at 9 1.) Because EFTA00083566 Case 9:08-cv-80736-KAM Document 435 Entered on FLSD Docket 02/21/2019 Page 2 of 33 Epstein and his co-conspirators knowingly traveled in interstate and international commerce to sexually abuse Jane Doe 1, Jane Doe 2 and others, they commit

re as follows: From between about 1999 and 2007, Jeffrey Epstein sexually abused more than 30 minor girls

ern about "the effect of taking the position that Mr. Epstein's house is in the special maritime and territori

e Office was "not investigating Mr. Epstein [for] abusing his girlfriend." (DE 407 at 11- 25.) The correspondence further stated: Andy [i.e., AUSA Andrew Laurie] recommended that some of the timing issues be addressed only in the state agreement, so that it isn't obvious to the judge that we are tying to cr

e R. Alexander Acosta United States Attorney United States Attorney's Office Southern District of Florida 99 NE 4th Street Miami, FL 33132 Re: Jeffrey Epstein INair Alex: 777 South Finumon Sunni tun Attuuluu, et-tidying, 900'7 (213) 080-8400 www.lorNItuul.com December I I. 2007 HICSul Wu: (213) 600.

at this case is not only extraordinary and unprecedented. it is deeply and uniquely troubling. The constellation of issues. large and small. renders Jeffrey's matter entirely sal genesis. We say this not lightly. Indeed, as you will glean from our two letters. we arc gravely concerned Mat in addition to

Was I S because said .. . if you're not then he [Epsteinl won't wally let you in his house. So I said I wa

ded to review some of the issues and concerns of Mr. Epstein's defense learn. Importantly. I appreciate your a

tter have no relation to the allegations against Mr. Epstein. Notably, after we objected to these overly broad and intrusive requests. Deputy Chief Andrew Laurie denied knowledge of Ms. Villalima's actions and Mr. Laurie commendably sought to significantly narrow the list of documents requested. In a subsequ

of 2007 through September of 2007, discussions took place between the U.S. Attorney's Office for the Southern District of Florida ("the Office") and Jeffrey Epstein's attorneys. (DE 407 at ¶ 9.) On February I, 2007, Epstein's defense team sent a 24-page letter to the Office going over what they intended to presen

ial Facts (hereinafter, "DE 407" at 9 1.) Because EFTA00794122 Case 9:08-cv-80736-KAM Document 435 Entered on FLSD Docket 02/21/2019 Page 2 of 33 Epstein and his co-conspirators knowingly traveled in interstate and international commerce to sexually abuse Jane Doe 1, Jane Doe 2 and others, they commit

re as follows: From between about 1999 and 2007, Jeffrey Epstein sexually abused more than 30 minor girls

ern about "the effect of taking the position that Mr. Epstein's house is in the special maritime and territori

e Office was "not investigating Mr. Epstein [for] abusing his girlfriend." (DE 407 at 11- 25.) The correspondence further stated: Andy [i.e., AUSA Andrew Laurie] recommended that some of the timing issues be addressed only in the state agreement, so that it isn't obvious to the judge that we are tying to cr

and privacy."' 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

cv-80736-KAM Document 361 Entered on FLSD Docket 02/10/2016 Page 3 of 57 prepared an 82-page prosecution memorandum and a 53-page indictment against Epstein and his co-conspirators.4 At that time, rather than confer with the victims about how to proceed, the Government began conferring about this issue

BPD") had identified numerous girls as victims of Jeffrey Epstein's sexual crimes. In 2006, the PBPD turne

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

6. The correspondence further discussed a possible plea disposition that would make it hard for a judge to see what was happening: Andy [i.e., AUSA Andrew Laurie] recommended that some of the timing issues be addressed only in the state agreement, so that it isn't obvious to the judge that we are trying to c

and privacy."' 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

cv-80736-KAM Document 361 Entered on FLSD Docket 02/10/2016 Page 3 of 57 prepared an 82-page prosecution memorandum and a 53-page indictment against Epstein and his co-conspirators.4 At that time, rather than confer with the victims about how to proceed, the Government began conferring about this issue

BPD") had identified numerous girls as victims of Jeffrey Epstein's sexual crimes. In 2006, the PBPD turne

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

6. The correspondence further discussed a possible plea disposition that would make it hard for a judge to see what was happening: Andy [i.e., AUSA Andrew Laurie] recommended that some of the timing issues be addressed only in the state agreement, so that it isn't obvious to the judge that we are trying to c

aveled from to Palm Beach County, Florida aboard the Gulfstream aircraft owned by Hyperion Air, Inc. (200) On or about August 18, 2005, Defendants JEFFREY EPSTEINS and traveled from to Palm Beach County, Florida aboard the Gulfstream aircraft owned by Hyperion Air, Inc. (201) On or about August 18, 2005, De

9, 2005 Jane Doe #6 JEFFREY EPSTEIN 11111 25 . July 2004 Jane Doe #7 JEFFREY EPSTEIN 26 July 2004 through December 29, 2004 Jane Doe #8 JEFFREY EPSTEL\ I wk. 27 July 2004 through January 31, 2005 Jane Doe #9 • JEFFREY EPSTEIN 44 EFTA01718620 COUNT DATE(S) MINOR(S) INVOLVED DEF

) On or about August 18, 2005, Defendants JEFFREY EPSTEINS and traveled from to Palm Beach County, Florid

pond to your asserted "policy concerns" regarding Mr. Epstein's Non- Prosecution Agreement, which will be addre

ter have no relation to the allegations against Mr. ISpstein. Notably. affix we objected to these overt broad and intrusive requests. Deputy Chief Andrew Laurie denied knowledge of Ms. s actions and Mr Laurie commendably so t igni tiara ly narrow the list of documen requested. In a subsequent court filin

2. Any emails or other documents, including those circulated within the FBI on intranet server, suggesting or complaining about or recognizing that Jeffrey Epstein or his agents or attorneys or acquaintances had offered (or were possibly offered) current or future opportunities, employment prospects, future cli

, direct or indirect, between Alex Acosta, n the one hand and Jeffrey Epstein (or any individual or business entity associated or connected with Epstein) on the other. This request includes all emails exchanged on the FBI intranet email as well as emails or correspondence exchanged through other ema

rect, between Alex Acosta, n the one hand and Jeffrey Epstein (or any individual or business entity as

it of any kind to any United States Attorney or Assistant United States Attorney, including but not limited to Alex Acosta, Matthew Menchel, and/or Andrew Laurie, prior to Epstein's plea in June of 2008. upplemental Discovery Request 4. Any emails or other documents, including those circulate within the FBI