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

0076 (Exhibit 11); RFP WPB 000220 (Exhibit 12); RFP MIA 000077- 000087 (Exhibit 13); RFP MIA 000088 (Exhibit 14); RFP WPB 000235.000244 (Exhibit 15); RFP WPB 000107- 000112 (Exhibit 16); RFP WPB 002188 (Exhibit 17); RFP WPB 000266-000277 (Exhibit 18); RFP MIA 000113 (Exhibit 19); RFP MIA 000151-000160 (Ex

l prosecutorial authority. IO 08-80736-CV-MARRA RFP WPB 001653 EFTA00209832 KIRKLAND & ELLIS LLP SUMMARY OF MISCONDUCT ISSUES IN THE MATTER OF JEFFREY E. EPSTEIN The manner in which federal prosecutors have pursued the allegations against Mr. Epstein is highly irregular and warrants full review by the Depar

SUMMARY OF MISCONDUCT ISSUES IN THE MATTER OF JEFFREY E. EPSTEIN The manner in which federal prosecutors have pursued the allegations against Mr. Epstein is highly irregular and warrants full review by the Department. While we repeatedly have raised our concerns regarding misconduct with the United S

LP SUMMARY OF MISCONDUCT ISSUES IN THE MATTER OF JEFFREY E. EPSTEIN The manner in which federal prosecutor

LP SUMMARY OF MISCONDUCT ISSUES IN THE MATTER OF JEFFREY E. EPSTEIN The manner in which federal prosecutors

prosecutors have pursued the allegations against Mr. Epstein is highly irregular and warrants full review by

t of Florida to discontinue its involvement in this matter, and return responsibility for this case to the State of Florida. 17 08-80736-CV-MARRA RFP WPB 001686 EFTA00209865 Villafana, Ann Marie C. (USAFLS) From: Jay Lefkowitz [[email protected]] Sent: y, September 27, 2007 2:53 PM To: ,

the victim, since she is considered one of the main perpetrators of the offenses that we planned to charge in the indictment. Can you talk to Mr. Epstein about a young woman named/MOW We have hearsay evidence that she traveled on Mr. Epstein's airplane when she was under 18, in around the 2000 or 200

e 15th Judicial Circuit in and for Palm Beach County (hereinafter the "State Attorney's Office") have conducted an investigation into the conduct of Jeffrey Epstein (hereinafter "Epstein"); IT APPEARING that the State Attorney's Office has charged Epstein with three counts of solicitation of prostitution in vio

Entered on FLSD Docket 02/10/2016 Page 5 of 11 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. UNITED STATES OF AMERICA vs. JEFFREY EPSTEIll DefendM- PLEA AGREEMENT The United States Attorney for he Southern District of Florida ("the United States"), and Jeffrey Epstein (herein

nd.com,jletkowitztakheland.corn cc bcc Subject JE negollations !E. I-Ii Jay -- Sorry to trouble y

ned to charge in the indictment. Can you talk to Mr. Epstein about a young woman named/MOW We have hearsay ev

se, the United States Attorney will furnish Epstein with notice specifying the conditions of the Agreement that he has violated. 08-80736-CV-MARRA RFP WPB 000108 EFTA00184343 Case 9:08-cv-80736-KAM Document 361-16 Entered on FLSD Docket 02/10/2016 Page 4 of 7 Terms of the Agreement: 1. Epstein shal

ed States Attorney 500 S. Australian Avenue RB: Jeff key Epstein Dear Man Thank you for your letter of July 17, 2008. In it, you ask whether Mr. Epstein 'Intends to fully abide by the Non Prosecution Agreement." The answer is yes. We confirm as you state in your letter that the Agreement requires th

ITBI61001 ClEtammeriltain-9iBitEetecaTiRlttifELB5cRellttIlf0221≥B-1180RagBalgeffilef 17 Investigation opened an investigation into allegations that Jeffrey Epstein had used facilities of interstate commerce to induce young girls between the ages of thirteen and seventeen to engage in prostitution (among other

032213:118 01453 gP Obef a of 17 Agreement with defendant Epstein that is at the center of this litigation and (2)

ion opened an investigation into allegations that Jeffrey Epstein had used facilities of interstate commer

r letter of July 17, 2008. In it, you ask whether Mr. Epstein 'Intends to fully abide by the Non Prosecution A

n or to discuss this matter in any way. Until then, I remain, • Very truly yours, Michael R. Thin cc; Jack Goldberger, Esq. 08-80736-CV-MARRA RFP WPB 000547 ••• • •I•MPISIM EFTA00185097 Case 9:08-cv-80736-KAM Document 362-52 Entered on FLSD Docket 02/10/2016 Page 1 of 17 EXHIBIT 122 EFTA0

ctims" and given our understanding that Ms. as well was one of those who is also on the list of persons the Utivernment contends were Mc MIN of Mr. Epstein's alleged violation of federal law, we have a principled concern about adopting your recommended language which would leave Mr. Epstein without a b

ND AITILIATLD PAVINIItSHIPS Citigroup Canter 153 Elam 53rd SWIM New York, Now 'font 10022.4811 ass.saoo www.hlrilsnd.00m December 26, 2007 Re: Jefflay Epstein For the purpose of enforcing the rights enumerated in article 1.13, a victim is 'a person directly and proximately harmed as a result of the commis

istration of criminal justice with profound consequences beyond the resolution in the matter at hand. • in a precedent-shattering investigation of Jeffrey Epstrein that raises important policy questions—and serious issues as to the fair and honorable enforcement of federal law—the USA.° in Miami is considering

ion that no telephonic or Internet persuasion, inducement, enticement or coercion of a minor, or of any other individual, occurred. In addition, Mr. Jeffrey Harmful. the former law partner of one of the federal prosecutors involved in this matter and die attorney for most of the civil complainants (as d

f persons the Utivernment contends were Mc MIN of Mr. Epstein's alleged violation of federal law, we have a pr

in effect, nor did CEOS review the federal prosecutors' inappropriate Wens to implement those terms. We detail this point below. 08-80736-CV-MARRA RFP WPB 001616 EFTA00184938 -`eat'iit FaCvNio %MAW. eauti;7nt 362-mriCigri iipirgy Docket 02/10/2016 Paij.Q34-3— hn IK.ON NON 13:22 FAX 1 213 8500 KIONI

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

second charge of assaulting a different co-conspirator. DE 361 at 13-14,1 24 (citing US_Atty_Cor. at 29 (Exhibit 54); RFP WPB 000122 (Exhibit 55); RFP WPB 000125-000126 (Exhibit 56); RFP WA 000281 (Exhibit 57)). In response, the Government does not contend that the victims lack factual support for the

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

0076 (Exhibit 11); RFP WPB 000220 (Exhibit 12); RFP MIA 000077- 000087 (Exhibit 13); RFP MIA 000088 (Exhibit 14); RFP WPB 000235.000244 (Exhibit 15); RFP WPB 000107- 000112 (Exhibit 16); RFP WPB 002188 (Exhibit 17); RFP WPB 000266-000277 (Exhibit 18); RFP MIA 000113 (Exhibit 19); RFP MIA 000151-000160 (Ex

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

0076 (Exhibit 11); RFP WPB 000220 (Exhibit 12); RFP MIA 000077- 000087 (Exhibit 13); RFP MIA 000088 (Exhibit 14); RFP WPB 000235.000244 (Exhibit 15); RFP WPB 000107- 000112 (Exhibit 16); RFP WPB 002188 (Exhibit 17); RFP WPB 000266-000277 (Exhibit 18); RFP MIA 000113 (Exhibit 19); RFP MIA 000151-000160 (Ex

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

00076 (Exhibit II); RFP WPB 000220 (Exhibit 12); RFP MR 000077- 000087 (Exhibit 13); RFP MIA 000088 (Exhibit 14); REP WPB 000235-000244 (Exhibit 15); RFP WPB 000107- 000112 (Exhibit 16); RFP WPB 002188 (Exhibit 17); REP WPB 000266-000277 (Exhibit 18); RFP MIA 000113 (Exhibit 19); RFP MIA 000151-000160 (Ex

y Southern District of Florida VIA FACSIMILF, Michael R. Tein, Esq. Lewis Tein, P.L. 3059 Grand Avenue, Suite 340 Coconut Grove, FL 33133 Re: Jeffrey Epstein Dear Mr. Tein: 500 South Australian Ave.. Saha 400 West Palm Beach. Vt. 3340/ July 17, 2008 The Office has reviewed your "Notice of Continued Pe

federal investigation. For example, you cite to — ' m"), as evidence that the federal criminal action remains pending. That is a citation to Mr. Epstein's Motion to Quash a subpoena for computer equipment removed from Mr. Epstein's home after he and his attorneys were aware of the existence of the s

Avenue, Suite 340 Coconut Grove, FL 33133 Re: Jeffrey Epstein Dear Mr. Tein: 500 South Australian Ave

nal action remains pending. That is a citation to Mr. Epstein's Motion to Quash a subpoena for computer equipm

ficer. 1) SIGNATURE DATE SIONAT RE IOU U 4Ily. .r. RECEIVED BY REASON i r DATE/TIME RECEIVED • - •-__-, • . . ' :-:' ... • Y pi , . RFP WPB 00048.6 - • EFTA00185092 Case 9:08-cv-80736-KAM Document 362-50 Entered on FLSD Docket 02/10/2016 Page 8 of 10 —a. Y. I r e n. ALT POPO Veen