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/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
ege reasons to approve continued prosecution of J. Epstein (NB: The Court has already determined that final version of this letter is protected by Work Product/Deliberative Process/Attorney-Client Privileges) P-014955 thru P-014971 6/3/2008 draft letter to Deputy Attorney General regarding Work Product 6(e) Deliberative
Florida DELIVERY BY ELECTRONIC MAIL Roy Black, Esq. Black Srebnick Komspan & Stumpf P.A. 201 S. Biscayne Blvd, Suite 1300 Miami, FL 33131 Re: Jeffrey Epstein Dear Roy: 500 S. Australian Ave, Ste 400 West Palm Beach, FL 33401 (561) 820-8711 Facsimile: (56!) 820-8777 November 24, 2008 On Thursday I le
0 S. Australian Ave, Ste 400 West Palm Beach, FL 33401 (561) 820-8711 Facsimile: (56!) 820-8777 November 24, 2008 On Thursday I learned that Mr. Epstein applied for and was admitted to the Palm Beach County Sheriff's Office's work release program and that he has been on work release for the past few
77 November 24, 2008 On Thursday I learned that Mr. Epstein applied for and was admitted to the Palm Beach C
y BLACK Cc: Atkinson, Karen (USAFLS) Subject: Jeffrey Epstein Attachments: 081124 Villafana lir to Bl
thru P-015028 7/8/2008 email from A.M. Villafafia to D. Lee, A. Acosta, and J. Sloman regarding victim notification letter provided to counsel for J. Epstein on 11/28/2007 with attachment (NB: The 11/28/2007 email to J. Lefkowitz with attachment will be produced to petitioners' counsel contemporaneously
ing reasons to approve continued prosecution of J. Epstein (NB: The Court has already determined that final version of this letter is protected by Work Product/Deliberative Process/Attorney-Client Privileges) Work Product 6(e) Deliberative Process Investigative Privilege PM 14955 thru P-014971 6/3/2008 draft letter to D
Description Privilege(s) Asserted P-014924 5/27/2008 emails between A.M. Villafafia and K. Atkinson regarding report of new state plea deal for J. Epstein Work Product Deliberative Process P-014925 thru P-014927 5/27/2008 emails between A.M. Villafafia, R. Senior, J. Sloman, and K. Atkinson regar
u P-015028 7/8/2008 email from A.M. Villafafia to D. Lee, A. Acosta, and J. Sloman regarding victim notification letter provided to counsel for I Epstein on 11/28/2007 with attachment (NB: The 11/28/2007 email to J. Lefkowitz with attachment will be produced to petitioners' counsel contemporaneously
ive Process P-015117 thru P-015135 8/5/2008 email from A.M. Villafafia to A. Acosta, J. Sloman, R. Senior, and K. Atkinson regarding analysis of Jeffrey Epstein agreement, with attached 6/24/2008 email from A.M. Villafafia to R. Black and J. Goldberger and attached Epstein agreement. (NB: Privilege is not
R. Senior, and K. Atkinson regarding analysis of Jeffrey Epstein agreement, with attached 6/24/2008 email
ing reasons to approve continued prosecution of J. Epstein (NB: The Court has already determined that final version of this letter is protected by Work Product/Deliberative Process/Attorney-Client Privileges) Work Product 6(e) Deliberative Process Investigative Privilege P-014955 thru P-014971 6/3/2008 draft letter to D
Entities connected to both Jeffrey Epstein and Work Product/Deliberative Process
Leon Black
PERSON
George W. Bush
PERSON
Bradley Edwards
PERSON
United States
LOCATIONJack Goldberger
PERSON
Sarah Kellen
PERSONSouthern District
LOCATIONJane Doe
PERSON
Department of Justice
ORGANIZATIONMaria Farmer
PERSON
Kenneth Marra
PERSON
Alexander Acosta
PERSON
Paul Cassell
PERSON
A. Marie Villafana
PERSON
Jay Lefkowitz
PERSONRoy Black
PERSON
Salt Lake City
LOCATION
Dexter Lee
PERSONSanchez
PERSON
the University of Utah
ORGANIZATION