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gement and/or non-prosecution agreement, including efforts on his behalf by former President Bill Clinton, Prince Andrew, and Harvard Law Professor Alan Dershowitz. These materials are needed to prove the victims allegation that, after Epstein signed the non-prosecution agreement, his performance was delayed w
n, Prince Andrew, and Harvard Law Professor Alan Dershowitz. These materials are needed to prove the victims
linton, Prince Andrew, and Harvard Law Professor Alan Dershowitz. These materials are needed to prove
o J. Lefkowitz; 5/22/07 e- mail from A. Lourie to M. Menchel, J. Sloman, A. Marie Villafafta re meeting with G. Lefcourt with attached email from G. Lefcourt re solicitation for meetings Work Product Government Communication; No Attorney- Client Relationship; Claims Against Public Prosecutor; Overriding
jections P-0133303 proposed letter to J. Lefkowitz; 5/22/07 e- mail from A. Lourie to M. Menchel, J. Sloman, A. Marie Villafafta re meeting with G. Lefcourt with attached email from G. Lefcourt re solicitation for meetings Work Product Government Communication; No Attorney- Client Relationship; Claims
IAL EFTA00225418 EXHIBITS TO WRITTEN RESPONSE OF A. MARIE VILLAFANA Exhibit 41 Date Description 33 7/6/2007 Letter from Gerald l.efcourt and Alan Dershonia toJeffrey Sloman and Andrei Londe arguing against federal prosecution. 34 7/13/2007 Letter from Roy Black to Marie Villa' la with handwritten atto
to subpoenas requested by Lilly Ann Sanchez and possible resolution of case 7/6/2007 Jeffrey Sloman and Andrew Lourie Gerald B. Lefcourt and Alan Dershowitz Follow-up letter to 6/26/07 meeting including facts, law, and policy that should inform any decision made on how and whether to proceed 33 7/13/2
07 Plea Notification Letter B-2 11/23/2007 Unscheduled meeting between Jay Lefkowitz, Alan Dershowitz and Jeff Sloman. (Drop in by Lefkowitz and Dershowitz) 11/26/2007 Jason Richards PBSO D/S Harold Elliott Research re work release: PBSO Post Orders for the Work Release Program Privileged Confidenti
n 33 7/6/2007 Letter from Gerald l.efcourt and Alan Dershonia toJeffrey Sloman and Andrei Londe argu
ll disclose even more. If meeting is held, Villafaiii will ask to have the case reassigned. Attached email correspondence between Andrew Laurie and G. Lefcourt 28/C-4 5/31/2007 Subpoena to J. Epstein Virgin Islands Foundation, Inc. (return date 6/21/07) 5/31/2007 Subpoena to J. Epstein & Company, Inc. (re
and warrant a full review. We appreciate your willingness to consider the evidence. We respectfully request that you review Judge Stem's letter to Alan Dershowitz faxed to you on December 7. 2007, in connection with the ameems we set forth in this submission. I. FEDERAL INVESTICATORS RELIED UPON TAINTED EVID
uest that you review Judge Stem's letter to Alan Dershowitz faxed to you on December 7. 2007, in connection w
y request that you review Judge Stem's letter to Alan Dershowitz faxed to you on December 7. 2007, in c
approval) promised to close the money-laundering investigation "if the sex offense case is resolved." See Tab 23, August 16, 2007 Letter froze to G. Lefcourt ("In other words, if the sex offense case is resolved, the Office would close its investigation into other areas as well. The matter has not been,
sed by AUSA Andy Lourie and then First AUSA Jeffrey Sloman. Each of Mr. Epstein's attorneys, including Roy Black, Gerald Lefcourt, Alan Dershowitz, Alan Dershowitz's brother, Nat Dershowitz, Ken Starr, Jay Lefkowitz, Lilly Sanchez, Jack Goldberger, Bruce Lyons, Martin Weinberg, Stephanie Thacker, Guy Lewis, Mike
rneys, including Roy Black, Gerald Lefcourt, Alan Dershowitz, Alan Dershowitz's brother, Nat Dershowitz, Ken
attorneys, including Roy Black, Gerald Lefcourt, Alan Dershowitz, Alan Dershowitz's brother, Nat Dersh
l) promised to close the money-laundering investigation only "if the sex offense case is resolved." See August 16, 2007 Letter from M. Villafana to G. Lefcourt ("In other words, if the sex offense case is resolved, the Office would close its investigation into other areas as well. The matter has not been,
litigation Investigative Privilege Acosta, and Alan Santiago regarding results of additional victim-
/18/08 Lefkowitz Ltr to AMCV" containing handwritten draft notes for proposed letter to J. Lefkowitz; 5/22/07 e-mail from to M. re meeting with G. Lefcourt with attached email from G. Lefcourt re solicitation for meetings Attorney-Client Privilege Work Product Suppl. Box #3 P-013304 Thru P-013325
Entities connected to both Alan Dershowitz and G. Lefcourt

Jeffrey Epstein
PERSONLeon Black
PERSON
Marc Rich
PERSON
Bradley Edwards
PERSONJack Goldberger
PERSON
Prince Andrew
PERSON
Lesley Groff
PERSON
United States
LOCATION
George W. Bush
PERSON
Paul Cassell
PERSONJane Doe
PERSON
Kenneth Marra
PERSON
Bill Clinton
PERSONMartin Weinberg
PERSONMaria Farmer
PERSONSouthern District
LOCATION
Joe Biden
PERSON
Virginia Giuffre
PERSON
Department of Justice
ORGANIZATIONthe Southern District
LOCATION