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06/24/2009 Page 26 of 51 26 1 THE COURT: That's not my concern. So, again, I just 2 want to make sure that if the cases go forward and if 3 Mr. Epstein defends the case as someone ordinarily would defend 4 a case that's being prosecuted against him or her, that that in 5 and of itself is not going
hods, procedures and techniques. While it is publically known that the FBI conducts investigations into the type of criminal wrongdoing committed by Jeffrey Epstein, disclosing the precise details of the sensitive methods, procedures and techniques employed during an investigation might compromise their future e
IA FACSIMILE Brad Edwards, Esq. The Law Offices of Brad Edwards & Associates, LLC 2028 Harrison Street, Suite 202 Hollywood, Florida 33020. Re: Jeffrey Epstein1 IDENTIFIED VICTIM Dear Mr. Edwards: NOTIFICATION OF By virtue of this letter, the United States Attorney's Office for the Southern Distr
o believed that they had met through a group of friends while attending - a dropout prevention school. Willementioned another girl by the name of Ce EPSTEIN distinguished the two HINIMINNOW by referring to as fla ISOM worked at an ice cream shop. WIMMOstated that she did not like IMMO, and that UMMEMO
P-000694 thru P-000781 File folder entitled "JE Corporations" containing attorney research on Ep
make sure that if the cases go forward and if 3 Mr. Epstein defends the case as someone ordinarily would defe
ed her as a very pretty Hispanic female in her early twenties, with lon b own hair and approximately 5'5" to 5'6" tall. wiftstated that another o PSTEIN's assistants, or EPSTEIN would usually contact her. would telephone and ask if she was available or if she had any other Investigation on 08/07/
-302 of 01/31/2008 .Page 2 . said that during the massages EPSTEIN would push further and further regarding the sexual activity. According to el EPSTEIN never asked, "is this okay," he would just see how far one would let him go. Walrecalled seeing sculptures of naked women and lots of pictures of
-008383 Thru P-008516 File folder containing March 18, 2008 grand jury presentation materials, including "Operation Leap Year Revised Indictment Summary Chart (by victim)," grand jury materials, draft indictments, victim reference list, grand jury subpoena log Work product 6(e) Investigative privilege
EPSTEIN BOX INVENTORY Box A: Redwell with different files for each Jane Doe I. Epstein case Cd's with Documents on 2nd Supplemental Privilege Log (2) and
uments that are not Privileged; printout of brief regardin Westlaw printouts Redwell with emails from 2007-2008 Box K: FBI Palm Beach County RA, Jeffrey E. Epstein, 31E-MM White binder with PBPD Reports Palm Beach Police/SAO Records Redwell with post it that says "This whole stack is for opposing counsel" — in
ith 6/23/08 letter from (DAG) to and =; 11/2/2010 Privileged Communication letter re Litigation Hold; clipped Non-Prosecution Agreement Doe (..) I. Epstein, 08-80893-CV-KAM (red file folder) Box II: (labeled GJ Presentation Materials) Federal Criminal Code and Rules 2006 Edition with multiple post-its
ral Analysis File folder: FBI E. Log File folder no name — includes September 17, 2009 letter to M= from File folder: Responses to Arguments from JE counsel File folder: Overt Act Lists File folder: Breach Memo File folder: 6/12/09 Victim Notif Log File folder: 6/9/09 Signed Indictment Pkg Bi
from 2007-2008 Box K: FBI Palm Beach County RA, Jeffrey E. Epstein, 31E-MM White binder with PBPD Reports
from 2007-2008 Box K: FBI Palm Beach County RA, Jeffrey E. Epstein, 31E-MM White binder with PBPD Reports P
le folder) EFTA00194833 Epstein press coverage; Research re Florida Procurement and Sentencing Guidelines; Operation Leap Year Revised Indictment Summary Chart (by Victim) Research re FL DOC Regs (file folder) Research re BOP Regs (file folder) Supervised Release Rules (green file folder) al Transcripts
EPSTEIN BOX INVENTORY Box 1: Redwell with different files for each Jane Doe v. Epstein case Cd's with Documents on 2" Supplemental Privilege Log (2) and B
d; printout of brief regarding Alvin F. Aguirre-Gonzalez; Westlaw printouts Redwell with emails from 2007-2008 Box 11: FBI Palm Beach County RA, Jeffrey E. Epstein, 31E-MM White binder with PBPD Reports Palm Beach Police/SAO Records Redwell with post it that says "This whole stack is for opposing counsel" — in
, OLY-53, OLY-54 (red folder) Colonial Bank (green file folder) JEGE & Hyperion from Goldberger OLY-46 & 0LY-47 (file folder) Box 19: Research re JE websites (file folder) Victim Civil Suits (file folder) NY AUSA) - (file folder) Dr. Anna Salter (file folder) Interview (file folder) Research
rom 2007-2008 Box 11: FBI Palm Beach County RA, Jeffrey E. Epstein, 31E-MM White binder with PBPD Reports
rom 2007-2008 Box 11: FBI Palm Beach County RA, Jeffrey E. Epstein, 31E-MM White binder with PBPD Reports P
Withdrawal of Motion to Quash (green file folder) Research re Florida Procurement and Sentencing Guidelines Operation Leap Year Revised Indictment Summary Chart (by Victim) Research re FL DOC Regs (file folder) Research re BOP Regs (file folder) Supervised Release Rules (green file folder) al Transcripts
tion of Jeffrey Epstein to Intervene and to Quash Grand Jury Subpoenas 6(e) Box #3 P-012089 Thru P-012129 United States' Response to Motion of Jeffrey Epstein to Intervene and to Quash Grand Jury Subpoenas and Cross-Motion to Compel 6(e) Box #3 P-012130 Thru P-012150 Declaration of Joseph Recarey 6(
admits that the FBI and the U.S. Attorney's Office for the Southern District of Florida ("USAO") conducted an investigation into Jeffrey Epstein ("Epstein") and developed evidence and information in contemplation of a potential federal prosecution against Epstein for many federal sex offenses. Except
of 23 EFTA00191231 Bates Range Description Privilege(s) Asserted Box #3 P-011923 Thru P-011966 Folder entitled "Responses to Arguments from JE Counsel" containing: ■ 7/13/2007 letter from Lilly Ann Sanchez to Andrew Lourie with handwritten attorney (Lourie) notes; ■ 6/25/2007 letter fro
Florida ("USAO") conducted an investigation into Jeffrey Epstein ("Epstein") and developed evidence and i
ation of Jeffrey Epstein has been completed, and Mr. Epstein and the U.S. Attorney's Office have reached an ag
-008383 Thru P-008516 File folder containing March IS, 2008 grand jury presentation materials, including "Operation Leap Year Revised Indictment Summary Chart (by victim)," grand jury materials, draft indictments, victim reference list, grand jury subpoena log Work product 6(e) Investigative privilege
tion of Jeffrey Epstein to Intervene and to Quash Grand Jury Subpoenas 6(e) Box #3 P-012089 Thru P-012129 United States' Response to Motion of Jeffrey Epstein to Intervene and to Quash Grand Jury Subpoenas and Cross-Motion to Compel 6(e) Box #3 P-012130 Thru P-012150 Declaration o i 6(e) Box #3 P-
hibit 6. 17. In the declaration, Ms. makes a number of assertions, including that "there could not have been any doubt in anyone's mind .. . that Epstein sexually molested me as a minor"; "I believed that if I told the truth about what happened at Epstein's house, the police "; "I had been greatly in
/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: Work product Deliberative process 6(e) Attorney-Client Privilege ■ 7/13/2007 letter from to with handwritten attorney (
tified as a potential victim of the lead target, Jeffrey Epstein. 2. After service of the subpoena, Ms.=
have prepared documents to charge at least one of Mr. Epstein's lady friends in state court. If they can push
-008383 Thru P-008516 File folder containing March 18, 2008 grand jury presentation materials, including "Operation Leap Year Revised Indictment Summary Chart (by victim)," grand jury materials, draft indictments, victim reference list, grand jury subpoena log Work product 6(e) Investigative privilege
ms who are not parties to this litigation Box #1 P-000694 thru P-000781 File folder entitled "JE Corporations" containing attorney research on Epstein-owned corporations and prior litigation Work Product Contains information subject to investigative privilege Box #1 P-000782 thru P-000803 F
e) Motion of Jeffrey Epstein to Intervene and to Quash Grand Jury Subpoenas Box #3 P-012089 Thru P-012129 United States' Response to Motion of Jeffrey Epstein to Intervene and to Quash Grand Jury Subpoenas and Cross-Motion to Compel 6(e) Box #3 P-012130 Thru P-012150 Declaration of 6(e) Box #3 P-0
/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: Work product Deliberative process 6(e) Attorney-Client Privilege • 7/13/2007 letter from to with handwritten attorney
12 Thru P-009113 11/26/2008 Email from to re Jeffrey Epstein (work release) [pursuant to Court's Ord
-008383 Thru P-008516 File folder containing March 18, 2008 grand jury presentation materials, including "Operation Leap Year Revised Indictment Summary Chart (by victim)," grand jury materials, draft indictments, victim reference list, grand jury subpoena log Work product 6(e) Investigative privilege
/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: Work product Deliberative process 6(e) Attorney-Client Privilege ■ 7/13/2007 letter from to with handwritten attorney
ms who are not parties to this litigation Box #1 P-000694 thru P-000781 File folder entitled "JE Corporations" containing attorney research on Epstein-owned corporations and prior litigation Work Product Contains information subject to investigative privilege Box #1 P-000782 thru P-000803 F
e) Motion of Jeffrey Epstein to Intervene and to Quash Grand Jury Subpoenas Box #3 P-012089 Thru P-012129 United States' Response to Motion of Jeffrey Epstein to Intervene and to Quash Grand Jury Subpoenas and Cross-Motion to Compel 6(e) Box #3 P-012130 Thru P-012150 Declaration of 6(e) Box #3 P-0
Thru P-009113 11/2 2008 Email from to and re Jeffrey Epstein (work release) [pursuant to Court's Ord
-008383 Thru P-008516 File folder containing March 18, 2008 grand jury presentation materials, including "Operation Leap Year Revised Indictment Summary Chart (by victim)," grand jury materials, draft indictments, victim reference list, grand jury subpoena log Work product 6(e) Investigative privilege
-008535 6/25/2007 Letter from Gerald Lefcourt to Jeffrey Sloman and Andrew Lourie [pursuant to Court's O
ms who are not parties to this litigation Box #1 P-000694 thru P-000781 File folder entitled "JE Corporations" containing attorney research on Epstein-owned corporations and prior litigation Work Product Contains information subject to investigative privilege Box #1 P-000782 thru P-000803 F
tion of Jeffrey Epstein to Intervene and to Quash Grand Jury Subpoenas 6(e) Box #3 P-012089 Thru P-012129 United States' Response to Motion of Jeffrey Epstein to Intervene and to Quash Grand Jury Subpoenas and Cross-Motion to Compel 6(e) Box #3 P-012130 Thru P-012150 Declaration of Joseph Recarey 6(
/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: ■ 7/13/2007 letter from Lilly Ann Sanchez to Andrew Lourie with handwritten attorney (Lourie) notes; ■ 6/25/2007 letter fro
-008383 Thru P-008516 File folder containing March 18, 2008 grand jury presentation materials, including "Operation Leap Year Revised Indictment Summary Chart (by victim)," grand jury materials, draft indictments, victim reference list, grand jury subpoena log Work product 6(e) Investigative privilege
ms who are not parties to this litigation Box #1 P-000694 thru P-000781 File folder entitled "JE Corporations" containing attorney research on Epstein-owned corporations and prior litigation Work Product Contains information subject to investigative privilege Box #1 P-000782 thru P-000803 F
tion of Jeffrey Epstein to Intervene and to Quash Grand Jury Subpoenas 6(e) Box #3 P-012089 Thru P-012129 United States' Response to Motion of Jeffrey Epstein to Intervene and to Quash Grand Jury Subpoenas and Cross-Motion to Compel 6(e) Box #3 P-012130 Thru P-012150 Declaration of Joseph Recarey 6(
/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: • 7/13/2007 letter from Lilly Ann Sanchez to with handwritten attorney ( 1 notes; • 6/25/2007 letter from Gerald Lefcou
08 Email from Roy Black to and Karen Atkinson re Jeffrey Epstein (work release) [pursuant to Court's Ord
cess Also contains information and documents subject to privacy rights of victims who are not parties to this litigation Year Revised Indictment Summary Chart (by victim)," grand jury materials, draft indictments, victim reference list, grand jury subpoena log Page 11 of 23 EFTA00223837 Case 9:08-cv-8
ms who are not parties to this litigation Box #1 P-000694 thru P-000781 File folder entitled "JE Corporations" containing attorney research on Epstein-owned corporations and prior litigation Work Product Contains information subject to investigative privilege Box #1 P-000782 thru P-000803 F
tion of Jeffrey Epstein to Intervene and to Quash Grand Jury Subpoenas 6(e) Box #3 P-012089 Thru P-012129 United States' Response to Motion of Jeffrey Epstein to Intervene and to Quash Grand Jury Subpoenas and Cross-Motion to Compel 6(e) Box #3 P-012130 "Him P-012150 Declaration of Joseph Recarey 6(
of 23 EFTA00191382 Bates Range Description Privilege(s) Asserted Box #3 P-011923 Thru P-011966 Folder entitled "Responses to Arguments from JE Counsel" containing: ■ 7/13/2007 letter from Lilly Ann Sanchez to Andrew Lourie with handwritten attorney (Lourie) notes; ■ 6/25/2007 letter fro
-008535 6/25/2007 Letter from Gerald Lefcourt to Jeffrey Sloman and Andrew Lourie [pursuant to Court's O
-008383 Thru P-008516 File folder containing March 18, 2008 grand jury presentation materials, including "Operation Leap Year Revised Indictment Summary Chart (by victim)," grand jury materials, draft indictments, victim reference list, grand jury subpoena log Work product 6(e) Investigative privilege
Entities connected to both Jeffrey Epstein and Summary Chart
Leon Black
PERSON
Prince Andrew
PERSON
Ghislaine Maxwell
PERSON
George W. Bush
PERSON
Donald Trump
PERSON
Bradley Edwards
PERSON
United States
LOCATIONJack Goldberger
PERSON
Sarah Kellen
PERSON
FedEx
ORGANIZATIONSouthern District
LOCATIONJane Doe
PERSON
Department of Justice
ORGANIZATIONMaria Farmer
PERSON
Kenneth Marra
PERSON
Alexander Acosta
PERSONthe Southern District
LOCATION
Paul Cassell
PERSON
Wilbur Ross
PERSONFBI
ORGANIZATION