Epstein Secrets

re correct a t" containing 8/5/08 email from A. to A. Acosta, a re "Jeffrey Epstein Agreement" discussing 6/24/08 email from to R. Black and J. Goldberger concerning the binding nature of the Agreement Attorney-Client Privilege Work Product Deliberative Process Suppl. Box #3 P-013290 Thru P-0132

efore June 30, 2008, the Office prepared a draft victim notification to be sent to the victims—a letter that it intended to show to both Epstein and Jack Goldberger, as reflected by a place for the initials of both Epstein and Goldberger on the document. The notification was designed to inform the victims of th

t thru and regarding analysis of JeffiSstem agreement, with Deliberative Process P-015135 attached 6/24/2008 email from . I II to R. Black and J. Goldberger and attached Epstein agreement. (NB: Privilege is not being asserted for the two attachments. The 6/24/2008 email will be produced to petitioners'

ile folder entitled "8/14/08 E-mail from Lefk to AMCV" containing undated entails from A. to A. Acosta, re draft response to 8/14/08 email from J. Leflcowitz regarding "the December 2007 proposal" Attorney-Client Privilege Work Product Page 1 of 14 EFTA00185414 Case 9:08-cv-80736-KAM Document 216-1

Act/TVPA/CVRA P-015005 thru P-015006 6/28/2008 emails between A.M. Villafafia, J. Sloman, A. Acosta, and R. Senior regarding correspondence with J. Goldberger and proposed change to state plea agreement Work Product Deliberative Process Attorney-Client Privilege P-015007 7/3/2008 emails between A.M. V

man, 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 being asserted for the two attachments. The 6/24/2008 email will be produced to petitioners'

P-015187 thru P-015194 8/20/2008-8/26/2008 emails between A.M. Villafafia, A. Acosta, J. Sloman, R. Senior, and K. Atkinson re draft response to J. Leflcowitz and draft amended victim notification letter (NB: Final version of letter to Lefkotiz and Black has been produced to Petitioners' counsel) Work P

those words have real meaning by providing a telling example of an inadequate State process: "a state prosecution for assault and battery in a Mr. Goldberger. In short, it is hard to imagine how the recusal of an assistant to the lead prosecutor could have resulted in any advantage to Mr. Epstein; more to

Leflcowitz attaching draft Deferred Prosecution Agreement, Exhibit 32. 17 While federal prosecutors once suggested that Mr. Epstein's retention of Jack Goldberger was intended to trigger the recusal of assistant prosecutor Dahlia Weiss and thereby influence the outcome of the State prosecution, that assertion

ledged the application of the Petite Policy in drafts of the Deferred Prosecution Agreement. See e.g., September 17, 2007 email from M. Villafana to J. Leflcowitz attaching draft Deferred Prosecution Agreement, Exhibit 32. 17 While federal prosecutors once suggested that Mr. Epstein's retention of Jack Goldbe

A. Acosta, J. Sloman, R. Senior, K. Atkinson re "Jeffrey Epstein Agreement" discussing 6/24/08 email from A. Marie Villafafia to R. Black and J. Goldberger concerning the binding nature of the Agreement Attorney-Client Privilege Work Product Deliberative Process Suppl. Box #3 P-013290 Thru P-0132

A. Marie Villafaila to A. Oosterbaan re trust agreement; ■ 9/13/07 e-mail from A. Marie Villafana to R. Garcia, J. Sloman re conference call with J. Leflcowitz; ■ 9/13/07 e-mail from A. Marie Villafana to A. Lourie re plea negotiations with attached correspondence; ■ 9/13/07 e-mail from A. Marie Villafai