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

ims in the in Exhibit 26; Exhibit 27; Exhibit 63 at 4-6, 18-19, 22-23; Exhibit 99; Exhibit 101; Exhibit 102. 136 us_Atty_cor. 00323 (Exhibit 103); RFP WPB 000515.000520 (Exhibit 104). 127 Exhibit 99. 36 EFTA00185493 Case 9:08-cv-80736-KAM Document 361 Entered on FLSD Docket 02/10/2016 Page 37 of 57 federal case were aware o

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

ims in the 125 Exhibit 26; Exhibit 27; Exhibit 63 at 4-6, 18.19, 22-23; Exhibit 99; Exhibit 101; Exhibit 102. 126 US_Atty_Cor. 00323 (Exhibit 103); RFP WPB 000515.000520 (Exhibit 104). 127 Exhibit 99. 36 EFTA00804363 Case 9:08-cv-80736-KAM Document 361 Entered on FLSD Docket 02/10/2016 Page 37 of 57 federal case were aware o

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

ims in the 125 Exhibit 26; Exhibit 27; Exhibit 63 at 4-6, 18.19, 22-23; Exhibit 99; Exhibit 101; Exhibit 102. 126 US_Atty_Cor. 00323 (Exhibit 103); RFP WPB 000515.000520 (Exhibit 104). 127 Exhibit 99. 36 EFTA00591640 Case 9:08-cv-80736-KAM Document 361 Entered on FLSD Docket 02/10/2016 Page 37 of 57 federal case were aware o