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

age 8 of 14 Bates Range Description Privilege(s) Asserted 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 Suppl. Box 3 P-013838 Thru P-013841 Letter from to Atty work-product December 1

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

TA00191256 Bates Range Description Privilege(s) Asserted 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 Ally work-product Suppl. Box 3 P-013838 Thru P-013841 Letter from Paul Cassell to Wifrcdo A. Ferrer,

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

age 8 of 14 Bates Range Description Privilege(s) Asserted 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 Suppl. Box 3 P-013838 Thru P-013841 Letter from Paul Cassell to Wifredo A. Ferrer,

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

age 8 of 14 Bates Range Description Privilege(s) Asserted 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 Suppl. Box 3 P-013838 Thru P-013841 Letter from Paul Cassell to Wifredo A. Ferrer,