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

5 thru P-013989 6/14/2007-6/21/2007 emails between 6(e) Work Product Deliberative Process Investigative Privilege and regarding addendum to Pros Memo, grand jury presentation and changes to indictment, and meetin with counsel for E stein P-013990 thru P-013991 6/26/2007 email from to , Work

EPSTEIN BOX INVENTORY Box 1: Redwell with different files for each Jane Doe v. Epstein case Cd's with Documents on 2" Supplemental Privilege Log (2) and B

d; printout of brief regarding Alvin F. Aguirre-Gonzalez; Westlaw printouts Redwell with emails from 2007-2008 Box 11: 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

, OLY-53, OLY-54 (red folder) Colonial Bank (green file folder) JEGE & Hyperion from Goldberger OLY-46 & 0LY-47 (file folder) Box 19: Research re JE websites (file folder) Victim Civil Suits (file folder) NY AUSA) - (file folder) Dr. Anna Salter (file folder) Interview (file folder) Research

rom 2007-2008 Box 11: FBI Palm Beach County RA, Jeffrey E. Epstein, 31E-MM White binder with PBPD Reports

rom 2007-2008 Box 11: FBI Palm Beach County RA, Jeffrey E. Epstein, 31E-MM White binder with PBPD Reports P

Wexner (file folder) Kastigar Letters (file folder) 2703 Motion & Order-Cingular (red file folder) Grand Jury Transcripts (redwell) with folders Pros Memo (file folder) labeled Duplicate Proposed Jury Instructions for Violations of 18 USC 2423(b) (Travel in Interstate or Foreign Commerce to Engage in

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

ocess 47 6/14/2007-6/21/2007 emails between Marie Viilafalla, Karen Atkinson, Andrew Lourie, Matt Menchel, and Jeff Sloman regarding addendum to Pros Memo, grand jury presentation and changes to indictment, and meeting with counsel for Epstein 6(e) Work Product Deliberative Process Investigative P

but it is more vague in terms of date allegations because, with few exceptions, the victims cannot provide specific dates of when they traveled to Epstein's home. • I have renumbered the Jane Does so that they are numbered in chronological order based upon the start of their contact with Epstein or M

elephone and travel activity are attached. C. New Victims and Charges ane Doe Jane Doe # 2 was identified by M. as the person who brought her to Jeffrey Epstein's house for the first time. JD#2's name also appears on several message pads recovered from JE's home. JD#2 was interviewed at her home in West Palm

further part of the conspiracy that Defendant JEFFREY EPSTEIN would a minor females to engage in lewd conduct with Defendant to satisfy Defendant JEFFREY EPSTEIN'S prurient interests. I also added overt acts where engaged in sexual activity with one of the victims. In the introductory section, I li

by M. as the person who brought her to Jeffrey Epstein's house for the first time. JD#2's name also appears on several message pads recovered from JE's home. JD#2 was interviewed at her home in West Palm Beach. JD#2 reported that she was brought to JE's home byllit[Jane Doe #l].2 JD#2 was 14 whe

sage" for Epstein, but she did recruit two other girls. One has not yet been interviewed, and the other iffillffirwho was discussed in the original Pros Memo. Becauslaterformed only one massage and remained fully clothed, I have not charged 9 EFTA00234513 any substantive offenses related to her, but I

(USAFLS) From: (USAFLS) Sent: llayRIP$008 11:18 AM To: Oosterbaan, Andrew Subject: RE Epstein update Attachments: Indictment.pdf. 2nd Add Pros Memo003 pdf. 3rd Addendum Pros Memo pdf. Epstein Pros Memo pdf Iii prev‘ - Here you go. Please l

ason to have another meeting. I'm surprised that Mr. Epstein hasn't started complaining about legal lees. I M

t: llayRIP$008 11:18 AM To: Oosterbaan, Andrew Subject: RE Epstein update Attachments: Indictment.pdf. 2nd Add Pros Memo003 pdf. 3rd Addendum Pros Memo pdf. Epstein Pros Memo pdf Iii prev‘ - Here you go. Please let me know if you need anything else. ■ As Alex and Jelican tell you. the defense can

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

P-013989 6/14/2007-6/21/2007 emails between Marie Villafafia, Karen Atkinson, Andrew Lourie, Matt Menchel, and Jeff Sloman regarding addendum to Pros Memo, grand jury presentation and changes to indictment, and meeting with counsel for Epstein 6(e) Work Product Deliberative Process Investigative Pr

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

P-013989 6/14/2007-6/21/2007 emails between Marie Villafafia, Karen Atkinson, Andrew Lourie, Matt Menchel, and Jeff Sloman regarding addendum to Pros Memo, grand jury presentation and changes to indictment, and meeting with counsel for Epstein 6(e) Work Product Deliberative Process Investigative Pr

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

P-013989 6/14/2007-6/21/2007 emails between Marie Villafafia, Karen Atkinson, Andrew Lourie, Matt Menchel, and Jeff Sloman regarding addendum to Pros Memo, grand jury presentation and changes to indictment, and meeting with counsel for Epstein 6(e) Work Product Deliberative Process Investigative Pr

proposed indictment contains 60 counts and seeks the forfeiture of Epstein's Palm Beach home and two airplanes.' The FBI has information regarding Epstein's whereabouts on May 16th and May 19th and they would like to arrest him on one of those dates. Epstein is considered an extremely high flight risk

k." Up to three appointments each day would be made. The girls would travel to Epstein's barsip Palm Beach where they would meet Epstein's chef and Epsteiti's assistant—usually an the kitchen. The assistant normally would escort the girls upstairs to the master bedroom/bathroom area and set up the mass

minute later, again called JD#2. and th say that = A security guard at Epstein's home asked why they were there, and said they were there to see Jeffrey. The guard let them in and they entered the house t ough a side door into the kitchen. igh School at the time. cousin, was Epstein and an assist