Epstein Secrets

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

not necessary" (DE 17 at 1). The Office asserted that the Court need only take judicial notice of the fact that no indictment had been filed against Epstein to resolve the case. 6. On August 1, 2008, the victims filed a response to the Government's "Notice," giving a proposed statement of facts surroun

Epstein," _ ' "Morrison," "Visoki," "Rogers," "Hammond," Roxburgh," "Villafana, " "Florida Science Foundation," "Starr," "Black," "Goldberger," "Jeffrey," "Australian," "Lewis," "Sanchez," "358 El Brillo Way" appears and which are connected to or related to Jeffrey Epstein, Jack Goldberger, or the J

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

riminal prosecution commensurate with the crimes Mr. Epstein has committed, and we further urge you to take th

13653). The entry here reads: "File folder entitled "Notes Re Plea Negotiations" containing 9/17/07 e-mail from A. Marie Villafafia to J. Richards, N. Kuyrkendall re status update; undated and typed handwritten notes by A. Marie Villafafia re items to be completed on case, strength of case, victim interviews,

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

x #3 P-013644 Thru P-013653 File folder entitled "Notes Re Plea Negotiations" containing 9/17/07 c-mail from A. Mark Villafafla to J. Richards, N. Kuyrkendall re status update; undated and typed handwritten notes by A. Marie Villafafia re items to be completed on case, strength of case, victim interviews

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

#3 P-013644 Thru P-013653 File folder entitled "Notes Re Plea Negotiations" containing 9/17/07 e-mail from A. Marie Villafafia to J. Richards, N. Kuyrkendall re status update; undated and typed handwritten notes by A. Marie Villafafia re items to be completed on case, strength of case, victim intervie