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

FLSD Docket 06/23/2015 Page 16 of 18 Bates Range Description Privilege(s) Asserted P-014728 thru P-014742 3/14/2008-3/19/2008 emails between Nesibtt S.mkendall , and about Epstein attempts to contact victims and finding counsel for victims Work Product Deliberative Process Attorney-client p

mail from Andy Lourie to Man Menchel and Jeff Sloman (cc: Marie Villafaila) re letter received from Gerald Lefcourt discussing a meeting to discuss Epstein investigation Work Product Deliberative Process P-013982 5/23/2007 email from Jason Richards to Marie Villafaiia re extradition research Work P

/2015 Page 16 of 18 Bates Range Description Privilege(s) Asserted P-014728 thru P-014742 3/1412008-3/1912008 emails between Marie Villafafia, Nesibtt Kuyrkendall, Jason Richards, Robert Senior, Jeff Sloman, Karen Atkinson, and Rolando Garcia about Epstein attempts to contact victims and finding

mail from Andy Lourie to Man Menchel and Jeff Sloman (cc: Marie Villafaila) re letter received from Gerald Lefcourt discussing a meeting to discuss Epstein investigation Work Product Deliberative Process P-013982 5/23/2007 email from Jason Richards to Marie Villafaiia re extradition research Work P

/2015 Page 16 of 18 Bates Range Description Privilege(s) Asserted P-014728 thru P-014742 3/1412008-3/1912008 emails between Marie Villafafia, Nesibtt Kuyrkendall, Jason Richards, Robert Senior, Jeff Sloman, Karen Atkinson, and Rolando Garcia about Epstein attempts to contact victims and finding

ail from Andy Lourie to Matt Menchel and Jeff Sloman (cc: Marie Villafafia) re letter received from Gerald Lefcourt discussing a meeting to discuss Epstein investigation Work Product Deliberative Process P-013982 5/23/2007 email from Jason Richards to Marie Villafafia re extradition research Work P

/2015 Page 16 of 18 Bates Range Description Privilege(s) Asserted P-014728 thru P-014742 3/14/2008-3/19/2008 emails between Marie Villafafia, Nesibtt Kuyrkendall, Jason Richards, Robert Senior, Jeff Sloman, Karen Atkinson, and Rolando Garcia about Epstein attempts to contact victims and finding