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

he existence of the NPA.107 93. On January 10, 2008, Jane Doe I and Jane Doe 2 received victim notification letters from the FBI advising them that `Tiflis case is currently under investigation. This can be a lengthy process and we request your continued patience while we conduct a thorough investigati

e meeting? 2 A. No. They -- yeah. No. They have it. I'm 3 guessing. I don't have it. 4 Q. How much money are you hoping to get out of 5 Mr. Epstein? 6 MR. LEOPOLD: Objection to the form of the 7 question. Attorney/client privilege. 8 BY MR. TEIN: 9 Q. How much money are you hoping to get

ket 07/21/2008 Page 16 of 100 1. The plaintiff seeks damages in connection with her own illegal conduct. The plaintiff concedes that she went to Jeffrey Epstein's house "to give Epstein a massage for monetary compensation." (Am. Compl. ¶ 13.) The plaintiff also concedes, in the guise of an allegation, that "

court. I was later 20 informed that it was a deposition. 21 Q. I'm going to ask you some questions now 22 about what happened when you went to Jeff Epstein's house 23 three years ago. Okay? 24 A. Uh-huh. 25 Q. When the police interviewed you one month You wrote in this exhibit, "I got some Ph. 56

you got to Epstein's house you had never told Jeff that you were under 18, right? A. No. Q. Before you got to Epstein's house had you ever told Jeffrey that you were under 18? A. No. I never spoke to the man before that. Q. And you only went to Jeff Epstein's house that one time three years ago,

his associates. ) (describing character of party defendant Epstein as a "sexual predator" (a term defined by Florida

How much money are you hoping to get out of 5 Mr. Epstein? 6 MR. LEOPOLD: Objection to the form of the 7

fantasies" and inflicting "untold damage," and opining that he should "be held accountable;" also quoting the plaintiff's attorney as opining that. Tiflis case is both about justice and making sure that a wealthy and powerful man knows that he is not above the law;" also quoting the plaintiff's attorn

ling to pay for the transcript. 2. Your proposed stipulation indicates that in September 2007 the U.S. Attorney's Office reached an agreement with Epstein to resolve the case, which was then modified in Ontober and December of that year. While this seems plausible, to stipulate to the facts, I would o

0 0002 5519 8503 West Palm Beach, Florida 33401 Dear As you are aware, we represent several of the young girls that were victimized and abused by Jeffrey Epstein. While we are aware of his recent guilty plea and conviction in his State Court case, the sentence imposed in that case is grossly inadequate for a

his desire that federal charges be filed against defendant Epstein. In particular, he wrote on behalf of his client

e young girls that were victimized and abused by Jeffrey Epstein. While we are aware of his recent guilty

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

construction. After reciting the direct-and-proximate-harm language at issue here, one of the Act's two co-sponsors -- Senator Kyl -- explained that Tiflis is an intentionally broad definition because all victims of crime deserve to have their rights protected ." 150 Cong. Rec. 510912 (Oct. 9, 2004) (e

, I'd probably be mad at me,' he said." EFTA00046774 -- Attorney General Bill Barr has replaced the head of the Bureau of Prisons in the wake of Jeffrey Epstein's death in federal custody. Devlin Barrett reports: "Hugh J. Hurwitz, the agency's acting head, will be replaced by Kathleen Hawk Sawyer, who served

eau of Prisons director from 1992 to 2003. Barr also appointed Thomas R. Kane to serve as her deputy, a position currently vacant. ... Even before Epstein's death, Justice Department officials privately expressed frustration with senior officials at the Bureau of Prisons, but the apparent management f

known Page 17312 EFTA00046823 there?" -- Three state lawmakers acknowledge that lobbyists helped craft their op-eds attacking Medicare-for-all. Jeff Stein reports: "Montana state Rep. Kathy Kelker (D) and Sen. Jen Gross (D) acknowledged in interviews that editorials they published separately about the

the head of the Bureau of Prisons in the wake of Jeffrey Epstein's death in federal custody. Devlin Barre

er is ending his campaign for the Republican nomination in the U.S. Senate ... Tucker invested more than $1.5 million of his own money to challenge Tiflis, who is seeking a A 4 • '1!1'1!1 1114.4.44.41.-... .44.4..41..4.4 ♦L... 14.......:-...4:.44. ....f 414., nryln c i:...... Page 17315 EFTA00046