Epstein Secrets

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

2011, 11:19 a.m., RE: Re-write of Epstein letters for your review, with c-mail from Lisa Howard to Ruth Plagenhoef (May 5, 2011, 11:08 a.m.), and Plagenhoef to Howard (May 5, 2011, 11:10 a.m.), and Howard to Plagenhoef (May 5, 2011, 10:41 a.m.), attached Deliberative Process Privilege Attorney Work P

view, with c-mail from Lisa Howard to Ruth Plagenhoef (May 5, 2011, 11:08 a.m.), and Plagenhoef to Howard (May 5, 2011, 11:10 a.m.), and Howard to Plagenhoef (May 5, 2011, 10:41 a.m.), attached Deliberative Process Privilege Attorney Work Product Suppl. Box 3 P-013944 E-mail, Plagenhoef to Howard, M

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

2011, 11:19 a.m., RE: Re-write of Epstein letters for your review, with e-mail from Lisa Howard to Ruth Plagenhoef (May 5, 2011, 11:08 am.), and Plagenhoef to Howard (May 5, 2011, 11:10 am.), and Howard to Plagenhoef (May 5, 2011, 10:41 a.m.), attached Deliberative Process Privilege Attorney Work P

Page 69 of 70 Bates Range Description Privilege(s) Asserted Victims' Objections Plagenhoef to Howard (May 5, 2011, 11:01 a.m.), and Howard to Plagenhoef (May 5, 2011,10:41), attached Suppl. Box 3 P-013945 E-mail, Plagenhoef to Howard, May 4, 2011, 5:01 p.m., RE: draft letters in Epstein matter,

"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

2011, 11:19 a.m., RE: Re-write of Epstein letters for your review, with e-mail from Lisa Howard to Ruth Plagenhoef (May 5, 2011, 11:08 a.m.), and Plagenhoef to Howard (May 5, 2011, 11:10 a.m.), and Howard to Plagenhoef (May 5, 2011, 10:41 a.m.), attached Deliberative Process Privilege Attorney Work

Page 69 of 70 Bates Range Description Privilege(s) Asserted Victims' Objections Plagenhoef to Howard (May 5, 2011, 11:01 a.m.), and Howard to Plagenhoef (May 5, 2011, 10:41), attached Suppl. Box 3 P-013945 E-mail, Plagenhoef to Howard, May 4, 2011, 5:01 p.m., RE: draft letters in Epstein matter,

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

view, with e-mail from Lisa Howard to Ruth Plagenhoef (May 5, 2011, 11:08 a.m.), and Plagenhoef to Howard (May 5, 2011, 11:10 a.m.), and Howard to Plagenhoef (May 5, 2011, 10:41 a.m.), attached Deliberative Process Privilege Attorney Work Product Suppl. Box 3 P-013944 E-mail, Plagenhoef to Howard, M

2011, 11:19 a.m., RE: Re-write of Epstein letters for your review, with e-mail from Lisa Howard to Ruth Plagenhoef (May 5, 2011, 11:08 a.m.), and Plagenhoef to Howard (May 5, 2011, 11:10 a.m.), and Howard to Plagenhoef (May 5, 2011, 10:41 a.m.), attached Deliberative Process Privilege Attorney Work P

ct: RE: OPR matter Thank you!! From: (USAFLS) [mailto Sent: Monday, March 09, 2009 2:58 PM To: Subject: RE: OPR matter Dear At this time, the Epstein matter is essentially resolved. Pursuant to a confidential Non-Prosecution Agreement with our Office, Mr. Epstein entered a plea to state charges, a

Sent: Monday, March 09, 2009 2:34 PM To: . (USAFLS) Subject: OPR matter I have been asked to get an update from you on your self-referral in the Jeffrey Epstein investigation that you submitted April 22 2008. This is a different subject matter than the Adam McDaniel case — I think you were interviewed last

t an update from you on your self-referral in the Jeffrey Epstein investigation that you submitted April 2

ntial Non-Prosecution Agreement with our Office, Mr. Epstein entered a plea to state charges, and is currently

ance: Normal FYI. Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 Phone 561 209-1047 Fax 561 820-8777 From: Plagenhoef, Ruth (OPR) Sent: Monday, March 09, 2009 3:00 PM To: . (USAFLS) Subject: RE: OPR matter Thank you!! From: (USAFLS) [mailto Sent: Monday, Mar

ice Department has access to information that will help us respond to Reinhard's claim that he was not privy to any non-public information about the Epstein case. We are therefore EFTA00205030 respectfully requesting that the Justice Department provide this information to us by Tuesday, May 10, 2011, s

Brad, We can talk today or tomorrow. I am in the office both days. Thanks. From: Paul Cassell [mailto: Sent: Wednesday, May 04, 2011 3:36 PM To: Plagenhoef, Ruth (OPR); (USAFLS) Cc: Brad Edwards Subject: RE: OPR inquiry - request for information - - when can chat? Ruth — Thanks. — When can we chat