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

at 4-5; Exhibit 69. 24 and met in EFTA00185481 Case 9:08-cv-80736-KAM Document 361 Entered on FLSD Docket 02/10/2016 Page 25 of 57 person with Jane Doe I. During this litigation, the Special Agents have said that they explained that Epstein would plead guilty to state charges involving another victim,

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

(2) and Bates Its 002111-002266 Redwell with printout of Documents in the 2" Supplemental Privilege Log 6001 Orders 6001 Immunity Request folder Jane Doe I. U.S. 6/23/15 production (redwell) with documents 2" Supplemental Privilege Log Box 4 2" Supplemental Privilege Log Letter 6-23-15 to Box B: Data

g using the Court's CMIECF system: Attorneys for the Government Roy Eric Black Jacqueline Perczek Black Srebnick Komspan & Stumpf Attorneys for Jeff Epstein Is/ Bradley J. Edwards Bradley J. Edwards 4 EFTA00211613

ck Srebnick Komspan & Stumpf Attorneys for Jeff Epstein Is/ Bradley J. Edwards Bradley J. Edwards 4 E

tes Marshal for this purpose. A proposed Writ is being separately filed from this motion, under seal, which includes the name and booking number of Jane Doe I. DATED: April 15, 2016 Respectfully Submitted, /s/ Bradley . Edwards Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L.