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

o make a statement under oath at the state sentencing.s44 81. On November 28, 2007, Lefkowitz sent an email to U.S. Attorney Acosta (with a copy to AUSA Sloman) objecting to victim notifications: We do, however, strongly and emphatically object to your sending a letter to the alleged victims. Finally, we d

SUMMARY In March 2005, the Palm Beach Police Department opened a criminal investigation of Palm Beach homeowner, Jeffrey E. Epstein when the father and stepmother of complained to police about a visit by their daughter to Mr. Epstein's Palm Beach home. After the police investig

tigation of Palm Beach homeowner, Jeffrey E. Epstein when the father and stepmother of complained to police about a visit by their daughter to Mr. Epstein's Palm Beach home. After the police investigated the matter and interviewed Ms. Gonzales, no charges were brought. true motivation for going to th

11 FOR PURPOSES OF DISCUSSION WITH JEE -, DIDN'T JE LEARN THAT BRAD WAS NOT THE INFORMANT? IF SO, WH

criminal investigation of Palm Beach homeowner, Jeffrey E. Epstein when the father and stepmother of comp

criminal investigation of Palm Beach homeowner, Jeffrey E. Epstein when the father and stepmother of compl

awsuit seeking substantial monetary damages from Mr. Epstein. apparently seeking her own payday, denied that

ll, engaged the attorney representative, Mr. Josefsberg, to obtain a settlement payment from Mr. Epstein under the NPA. On October 31, 2007, First AUSA Sloman emailed Mr. Epstein's counsel, confirming that "I understand that the plea and sentence will occur on or before the January 4th [2008] date." See O

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 EFTA00081333 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

ng the procedures for the third-party representative for the victims under the NPA's compensation provisions. (DE 407 at ¶ 64.) On October 25, 2007, AUSA Sloman sent a letter to Retired Judge Davis about selecting an attorney to represent the victims under the 11 EFTA00081343 Case 9:08-cv-80736-KAM Docum

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

ictims. (DE 407 at ¶ 76.) After these meetings with three victims, Epstein's defense team complained. (DE 407 at ¶ 77.) On about November 27, 2007, AUSA Sloman sent an e-mail to Lefkowitz, (with a copy to U.S. Attorney Acosta) stating that the Office had a statutory obligation to notify the victims about E

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 EFTA00098414 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

ictims. (DE 407 at ¶ 76.) After these meetings with three victims, Epstein's defense team complained. (DE 407 at ¶ 77.) On about November 27, 2007, AUSA Sloman sent an e-mail to Lefkowitz, (with a copy to U.S. Attorney Acosta) stating that the Office had a statutory obligation to notify the victims about E

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

ng the procedures for the third-party representative for the victims under the NPA's compensation provisions. (DE 407 at ¶ 64.) On October 25, 2007, AUSA Sloman sent a letter to Retired Judge Davis about selecting an attorney to represent the victims under the 11 EFTA00794132 Case 9:08-cv-80736-KAM Docum

the victims explained in their motion for summary judgment (DE 361), the undisputed facts of this case show that for nine months, the Government and Epstein conspired to conceal a non-prosecution agreement (NPA) from Epstein's victims in order to prevent them from voicing any objection to the agreement.

ed Jane Doe 1 and Jane Doe 2 (and several other victims) in civil suits against Jeffrey Epstein for injuries my clients suffered as a consequence of Jeffrey Epstein's sexual abuse of them. 2. I have previously filed an affidavit in this matter (see DE 225-1). This affidavit repeats some of the information contai

Undisputed Fact 1 ("Between about 1999 and 2007, Jeffrey Epstein sexually abused more than 30 minor girls,

she, herself] procured additional young women for Mr. Epstein and [was] paid commissions or referral fees for

under oath at the state sentencing." See DE 361, Statement of Undisputed Fact 80 (not disputed by the Government). Similarly, on December 6, 2007, AUSA Sloman sent a letter to Epstein's defense counsel that explained: Finally, let me address your objections to the draft Victim Notification Letter. You wr

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

o make a statement under oath at the state sentencing."' 81. On November 28, 2007, Lefkowitz sent an email to U.S. Attorney Acosta (with a copy to AUSA Sloman) objecting to victim notifications: We do, however, strongly and emphatically object to your sending a letter to the alleged victims. Finally, we d

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

o make a statement under oath at the state sentencing."' 81. On November 28, 2007, Lefkowitz sent an email to U.S. Attorney Acosta (with a copy to AUSA Sloman) objecting to victim notifications: We do, however, strongly and emphatically object to your sending a letter to the alleged victims. Finally, we d