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

cludes the initiation of any and all criminal charges which might otherwise in the future be brought against Lesley Groff, and or any employee of N.E.S. for any criminal charge that arises out of the ongoing federal investigation as described above."41 29. On September 17, 2007, the line prosecutor w

l doesn't like the factual basis. In his opinion, the plea should only address the crimes that we were addressing, and we were not investigating Mr. Epstein abusing his girlfriend. • So, these are the only options that he recommended: 1. We go back to the original agreement where Mr. Epstein pleads on

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 (heieinafter "Epstein'); IT APPEARING that the State Attorney's Office has charged Epstein with three counts of solicitation of prostitution in vio

e a joint, binding recommendation that the Court impose a thirty (30) month sentence to Page 2 of 6 EFTA00193994 IN RE: INVESTIGATION OF JEFFR,EY EPSTEIN NON-PROSECUTION AGREEMENT . . IT APPEARING that the City of Palm Beach Police Department and the State Attorney's Office for the 15th Judicial Ci

to comply with them. R. ALEXANDER. ACOSTA UNITED STATES'ATTORNEY Dated:- By: • Dated: Dated: A. MARIE VILLAFARA . ASSISTANT U.S. ATTORNEY JEFFREY EPSTEIN• GERALD LEFCOURT, ESQ.- COUNSEL TO JEFFREY EPSTEIN Dated: . JACK GOLDBERGE'R, ESQ: ATTORNEY FOR JEFFREY EPSTEIN Page 6 of • 6 EFTA00193

we were addressing, and we were not investigating Mr. Epstein abusing his girlfriend. • So, these are the on

15th Judicial CirCuit in and for Palm Beach County (hereinafter, the "State Attorney's Office") have conducted an investigation into the conduct of Jeffrey Epitein (hereinafter "Epstein"); • IT APPEARING that the State Attorney's Office has charged Epstein by indictment with solicitation of prostitution, in v

al charges which might otherwise in the future be brought against Sarah Kellen, Adriana Ross, Lesley Groff, and Nadia Marcinkova or any employee of N.E.S. for any criminal charge that arises out of the ongoing federal investigation as described above; Further, no immigration "proceeding will be institu

IN RE: INVESTIGATION OF JEFFREY EPSTEIN Non-Prosecution Agreement IT APPEARING that the City of Palm Beach Police Department and the State Attorney's Office for the 15th Judicial Circuit

or 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 one count of solicitation of prostitution, in violation of Florida Statut

IN RE: INVESTIGATION OF JEFFREY EPSTEIN Non-Prosecution Agreement IT APPEARING

. JEFFREY EPSTEIN PLEA PROFFER On August 2007, Mr. Epstein learned that his Special Agents would attempt to

1 and 2 of this Agreement will be instituted in this District, and the charges against Epstein if any, will be dismissed. Terms of the Agreement: I. Epstein shall plead guilty to an Information charging one (1) count of a violation of 18 USC 1512(d). 2. Epstein and the Government agree to follow the Un

the Agreement also precludes the initiation an of and all criminal char es which might otherwise in the future be brought agains r any employee of N.E.S. for any criminal c arge at arises out o t e ongoing e era investigation as described above; Further, the United States Attorney's Office will not r

IN RE: INVESTIGATION OF JEFFREY EPSTEIN Non-Prosecution Agreement IT APPEARING that the City of Palm Beach Police Department and the State Attorney's Office for the 15th Judicial Circuit

or 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 one count of solicitation of prostitution, in violation of Florida Statut

IN RE: INVESTIGATION OF JEFFREY EPSTEIN Non-Prosecution Agreement IT APPEARING

. JEFFREY EPSTEIN PLEA PROFFER On August 2007, Mr. Epstein learned that his Special Agents would attempt to

1 and 2 of this Agreement will be instituted in this District, and the charges against Epstein if any, will be dismissed. Terms of the Agreement: I. Epstein shall plead guilty to an Information charging one (1) count of a violation of 18 USC 1512(d). 2. Epstein and the Government agree to follow the Un

reement also precludes the initiation of an and all criminal char es which mi ht otherwise in the future be brought against and or any employee of N.E.S. for any criminal charge that arises out of the ongoing federal investigation as described above; Further, the United States Attorney's Office will

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 by indictment with solicitation of prostitution, in viol

or 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 by indictment with solicitation of prostitution, in violation of Florida Statu

(3) IN RE: INVESTIGATION OF JEFFREY EPSTEIN NON-PROSECUTION AGREEMENT IT APPEARING

e specifying the conditions of the Agreement that he has violated. Leflcowitz proposed agrmt 9/16/07 12:21 EFTA00193050 Terms of the Agreement: I. Epstein shall plead guilty to the criminal charge in the Indictment as currently pending against him in the 15th Judicial Circuit in and for Palm Beach Coun

minal charges which might otherwise in the future be brought against Sarah Kellen, Adriana Ross, Lesley Groff, and Nadia Marcinkova, any employee of N.E.S. or any unnamed co-conspirators for any criminal charge that arises out of the ongoing federal investigation as described above. Further, although t

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

cludes the initiation of any and all criminal charges which might otherwise in the future be brought against Lesley Groff, and or any employee of N.E.S. for any criminal charge that arises out of the ongoing federal investigation as described above."41 29. On September 17, 2007, the line prosecutor w

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

cludes the initiation of any and all criminal charges which might otherwise in the future be brought against Lesley Groff, and or any employee of N.E.S. for any criminal charge that arises out of the ongoing federal investigation as described above."41 29. On September 17, 2007, the line prosecutor w

ies thereof, including all attachments. ************************* *********** *talc *************••w** EFTA00194025 By signing thiS Agreement, Epstein asserts and certifies that the above has been read and explained to him. Epstein hereby states that he understands the conditions of this Agreement

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

Ginail - Re: JE negotiations Page 1 of I i by,;OO3,e Re: JE ne

greement and agrees to comply with them. Dated: JEFFREY EPSTEIN Dated: GERALD LBFCOURT, ESQ. COUNSEL T

nal charges which might otherwise in the future be brought against Sarah Kellen, Adrian Ross, Lesley Groff, and Nadia Marcinkova or any employee of N.E.S. for any criminal charge that arises out of the ongoing federal investigation as described above; Further, no immigration proceeding will be institut

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

lso precludes the initiation of any and all criminal charges which might otherwise in the future be brought against M , and or any employee of N.E.S. for any criminal charge that arises out of the ongoing federal investigation as described above."41 29. On September 17, 2007, the line prosecutor w

15111 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

agreement, the Government agrees that it will not seek to initiate federal investigation or prosecution for conduct subject to this agreement. 4. Epstein shall enter his guilty plea to the federal Information no later than November 5, 2007. Epstein shall consent to the plea being entered and sentence

FLORIDA Case No. UNITED STATES OF AMERICA vs. JEFFREY EPSTEIN, Defendant. PLEA AGREEMENT The United

al charges which might otherwise in the future be brought against Sarah Kellen, Adriana Ross, Lesley Groff, and Nadia Marcinkova or any employee of N.E.S. for any criminal charge that arises out of the ongoing federal investigation as 6 EFTA00176616 described above; Further, the United States Attorn