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verly broad and intrusive requests. Deputy Chief Andrew 'Annie denied knowledge of lotions and Mr. I.our
turns out, all those identified except two) had reached the age of majority, and, in fact, no guardian was necessary to represent their interests. Defense Counsel was Falsely Advised Tbat the Non Prosecution Agreement Would Be Kept Confidential. 20. On September 24, Epstein and the USAO executed a Non Prosec
New York The Silvio J. Mollo Building One Saint Andrew's Plaza New York. New York 10007 August 21, 202
that any and all discovery material produced to the defendant by the Government, regardless of designation, "[s]hall be used by the Defendant or her Defense Counsel solely for purposes of the defense of this criminal action, and not for any civil proceeding or any purpose other than the defense of this action."
ssion nfelvil or criminal liahility in regards to any of those who seek compensation from the Trust. See draft proposal sent from Jay Lelliowitz to Andrew I ,nurle dated September 15, 2007. In response, Ms. Villafana demanded that the Agreement contain language considering the inclusion of a guardian
turns out, all those identified except two) had reached the age of majority, and, in fact, no guardian was necessary to represent their interests. Defense Counsel was Falsely Advised That the Non Prosecution Agreement Would Be Kept Confidential. 20. On September 24, Epstein and the USAO executed a Non Prosec
f New York The Silvio J. Mao Building One Saint Andrew's Plaza New York. New York 10007 July 28, 2020
Page: EFTA00026750 →such on the record in this case shall not be treated as Confidential Information. 9. Defense Counsel may, at any time, notify the Government that Defense Counsel does not concur in the designation of documents or other materials as Confidential Information. If the Government does not agree to de-designate s
Page: EFTA00026762 →Entities connected to both Prince Andrew and Defense Counsel

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
Lesley Groff
PERSON
Marc Rich
PERSONSouthern District
LOCATIONLeon Black
PERSON
Department of Justice
ORGANIZATION
Bill Clinton
PERSON
Alan Dershowitz
PERSON
United States
LOCATION
George W. Bush
PERSON
Michael Cohen
PERSONthe Southern District
LOCATION
Woody Allen
PERSON
Virginia Giuffre
PERSON
Bradley Edwards
PERSON
Joe Biden
PERSON
Julie K. Brown
PERSONMartin Weinberg
PERSON
Alexander Acosta
PERSON