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

Florida matter Suppl. Box 3 P-013947 E-mail, to May 3, 2011, for atty work product; law enforcement investigatiory record 12:23 p.m., RE: OPR Inquiry — request information, with post-it note attached with handwritten attorney notes on tele 'hone call between and with and Suppl. Box 3 P-0139

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

cord, atty work product; deliberative process privilege Suppl. Box 3 P-013947 E-mail, Paul Cassell to Plagenhoef, May 3, 2011, 12:23 p.m., RE: OPR Inquiry — request for infonnation, with post-it note attached with handwritten attorney notes on telephone call between Plagenhoef and Howard with Dexter

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

secutor; Attorney Conduct at Issue; Final Decision; Waiver Suppl. Box 3 P-013947 E-mail, Paul Cassell to Plagenhoef, May 3, 2011,12:23 pan., RE: OPR Inquiry — request for information, with post-it note attached with handwritten attorney notes on telephone call between Plagenhoef and Howard with Dexter

"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

secutor; Attorney Conduct at Issue; Final Decision; Waiver Suppl. Box 3 P-013947 E-mail, Paul Cassell to Plagenhoef, May 3, 2011,12:23 p.m., RE: OPR Inquiry — request for information, with post-it note attached with handwritten attorney notes on telephone call between Plagenhoef and Howard with Dexter

sta and , and re proposed correspondence to Jay Leflcowitz Attorney-Client Privilege Work Product Suppl. Box #3 P-013281 Handwritten note re Epstein investigation Attorney-Client Privilege Work Product Investigative privilege Also contains information subject to privacy rights of victims who

Suppl. Box #3 P-013285 Thru P-013289 File folder entitled "8/5/08 AMCV e-mail re correct a t" containing 8/5/08 email from to A. Acosta, re "Jeffrey Epstein A ement" discussing 6/24/08 email from to R. Black and J. Goldberger concerning the binding nature of the Agreement Attorney-Client Privilege W

Ann Sanchez (May 22, 2007, 2:05 •.m.), attached Suppl. Box 3 P-013872 E-mail, to Atty work-product MI, and , May 22, 2007, 3:11 p.m., FW: Jeffrey EIS; with e-mail from Lefcourt to M, and Lilly Ann SancheLE42 2, 2007 2:05 p.m: ached Suppl. Box 3 P-013873 E-mail to and M, May 14, Atty work

containing 8/5/08 email from to A. Acosta, re "Jeffrey Epstein A ement" discussing 6/24/08 email from

aul 12:23 p.m., information, handwritten between and Cassell to May 3, 2011, atty work product; law enforcement investigatiory record RE: OPR Inquiry — request for with post-it note attached with attorney notes on telephone call and Howard with Suppl. Box 3 P-013948 Thru P-013951 E-mail, t

e and K. Atkinson re proposed correspondence to Jay Lefkowitz Attorney-Client Privilege Work Product Suppl. Box #3 P-013281 Handwritten note re Epstein investigation Attorney-Client Privilege Work Product Investigative privilege Also contains information subject to privacy rights of victims who

led "8/5/08 AMCV e-mail re correct agrmt" containing 8/5/08 email from A. Marie Villafafia to A. Acosta, J. Sloman, R. Senior, K. Atkinson re "Jeffrey Epstein Agreement" discussing 6/24/08 email from A. Marie Villafafia to R. Black and J. Goldberger concerning the binding nature of the Agreement Attorne

costa, J. Sloman, R. Senior, K. Atkinson re "Jeffrey Epstein Agreement" discussing 6/24/08 email fro

cord, atty work product; deliberative process privilege Suppl. Box 3 P-013947 E-mail, Paul Cassell to Plagenhoef, May 3, 2011, 12:23 p.m., RE: OPR Inquiry — request for information, with post-it note attached with handwritten attorney notes on telephone call between Plagenhoef and Howard with Dexter