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

Esq. in Support of Motion 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 J

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

Esq. in Support of Motion 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 J

provide notice to the victims. It is also needed to demonstrate why the victims at first received inaccurate information about the NPA, as well as Jeffrey Epstein's involvement in that inaccurate notice. See, e.g., DE 48 at 15-16. 43. RFP No. 16 requests documents regarding Bruce Reinhart, a senior prosecutor w

ch re Travel for Prostitution" containing attorney (Villafafta) handwritten notes regarding grand jury presentation, chart entitled "Brought to Epstein's House" with handwritten notes, Message Pad meta- analysis chart, summary of evidence related to one victim/witness, and relevant grand jury inf

serted Victims' Objections Box #3 Folder entitled "Responses to Arguments Work product No Factual Underpinnings; Fiduciary Duty; P-011923 from JE Counsel" containing: Deliberative process Crime-Fraud-Misconduct; Crime-Fraud- Thru ■ 7/13/2007 letter from Lilly Ann 6(e) Misconduct; Not in A

of course, is a defense attorney who represented defendant Epstein. Recording information provided by a defense att

net (617) 338-9538 Criminal Defense Counsel for Jeffrey Epstein /s/ Bradley J. Edwards 3 EFTA00179621

rt Inherent Power to Release; Proper Victim's Petition; CVRA-authorized release; Material Severable Box #3 P-012089 Tin P412129 United States' Response to Motion of Jeffrey Epstein to Intervene and to Quash Grand Jury Subpoenas and Cross-Motion to Compel 6(e) Inadequate Log; No Factual Underpinnings; Fiduciar

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

-sq. in Support of Motion 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

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

Esq. in Support of 6(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

/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

Esq. in Support of 6(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

"Victim Civil Suits" Not privileged. Produced to counsel for Petitioners N/A Box #1 P-003664 Thru P-003678 File folder entitled "Research it JE Websites" containing attorney research Work product Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Not in Anticipation of Litigation;

re Travel for Prostitution" containing attorney (Villafaria) handwritten notes regarding grand jury presentation, chart entitled "Brought to Epstein's House" with handwritten notes, Message Pad meta- analysis chart, summary of evidence related to one victim/witness, and relevant grand jury i

ecutor; Overriding Need; Attorney Conduct at Issue Suppl. Box 3 P-013836 Thru P-013837 Palm Beach Daily News Article, "Attorneys want Jeffrey Epstein Agreement Thrown Out," with attorney's notes written on margin Atty work-product Inadequate Log; No Factual Underpinnings; Fiduciary Duty;

recusal of Southern District of Florida, dated July 29, 2011, with attached memorandum from A. Marie Villafafia to Benjamin Greenberg summarizing Jeffrey E stein Investi ation Attorney-Client Privilege Deliberative Process Work Product No Factual Underpinnings; Fiduciary Duty; Not in Anticipation

Inherent Power to Release; Proper Victim's Petition; CVRA-authorized release; Material Severable 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) Inadequate Log; No Factual Underpinnings; Fiduciar

-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

Esq. in Support of Motion 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 J

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

Esq. in Support of Motion 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 J

JANE DOE I AND JANE DOE 2, Plaintiffs v. UNITED STATES OF AMERICA, Defendant I REPLY TO JANE DOE #1 AND JANE DOE #2'S RESPONSE TO MOTION OF JEFFREY EPSTEIN FOR LIMITED INTERVENTION In their Response, plaintiffs first contend that Mr. Epstein's limited motion to intervene is not timely because they firs

O JANE DOE #1 AND JANE DOE #2'S RESPONSE TO MOTION OF JEFFREY EPSTEIN FOR LIMITED INTERVENTION In their Response, plaintiffs first contend that Mr. Epstein's limited motion to intervene is not timely because they first filed their discovery requests more than a year and a half ago. Response at 3-4. Tha

E DOE #1 AND JANE DOE #2'S RESPONSE TO MOTION OF JEFFREY EPSTEIN FOR LIMITED INTERVENTION In their Respon

In their Response, plaintiffs first contend that Mr. Epstein's limited motion to intervene is not timely beca

Subpoenas," "Affidavit of Roy Black, Esq. in Support of Motion of Jeffrey Epstein to Intervene and to Quash Grand Jury Subpoenas," "United States' Response to Motion of Jeffrey Epstein to Intervene and to Quash Grand Jury Subpoenas, " Declaration of Joseph Recarey (in support of United States' response)," "Ex Parte