Epstein Secrets

lationship; Improper Invocation; Overriding Need; Claims Against ■ 6/25/2007 letter from Gerald Public Prosecutor, Attorney Conduct at Issue; Lefeourt to Jeffrey Sloman, Matt Factual Materials; Court Authorized Under Menchal, Andrew Lourie, and 6(e)(3)(E); Court Inherent Power to Release; Marie

s; Fiduciary Duty; Claims Against Public Prosecutor; Overriding Need; Attorney Conduct at Issue Suppl. Box 3 P-013859 Through P413860 Email, Gerald Lefcourt to Marie Villafana, Lilly Ann Sanchez, Roy Black, re: Jeffrey Epstein [Not considered privileged. Will be produced to opposing counsel upon li

517 Thru P-008535 6/25/2007 Letter from Gerald Lefcourt to Jeffrey Sloman and Andrew Lourie [pursuant t

(May 23, 2007, 5:00 p.m.), Andrew Lourie to Gerald Lefcourt (May 22, 2007, 6:32 p.m.), and Gerald Lefcourt to Andrew Lourie Marie Villafana, and Lilly Ann Any work-product Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Waiver, Claims Against Public Prosecutor; Overriding Need; Attorney C

ral investigation of Mr. Epstein. He asked to meet with her and she stated that she believed such a meeting woilaremature. In December, Sanchez and Gerald Lefcourt again contacted AUSA to set a meeting. AUSA requested documents in advance of such a meeting, but the request was refused. Ms. Sanchez then contac

the request was refused. Ms. Sanchez then contacted AUSA Andrew—, who agreed to meet with iiihez fcourt. On February 1, 2007, Ms. Sanchez and Mr. Lefcourt met with AUSA an as well as a member ofthe Federal Bureau of Investigation, presented defense counsel's view of the case, and promised a willingne

Jul 1 2007, meetin between FAUSA „ Criminal Chief West Palm Beach Chief AUSA • and two FBI agents who met with Roy Black, Gerald Lefcourt, and Lilly Ann anchez. On at ate, the prosecutors presented a written, four-bullet-point term sheet that would satisfy the federal interest in the case and discus

rald Lefcourt provided written arguments for why Epstein should not be charged federal) Exhibit 32). The following day, Alan Dershowitz, Roy Black, Gerald Lefcourt, and Lilly M presented their arguments to FAUSA and Chief Sil her supervisor, and I also attended (Exhibit 5). At some point during the meeting,

that, prior to this investigation, I had ever prepared' request for 6001 immunity, so I was researching the process. The meetingwith Ms. and Mr. Lefcourt was set for February 1, 2007. As noted above, despite Ms. statements of Epstein's willina to cooperate, she complained that my document requests w

gued above, but I will try to collect them into general categories in chronological order. 1. b. I did not want to meet with counsel for Epstein (Lilly Ann and Gerald Lefcourt) prior to completi.n investigation. My co-counsel agreed with me. Our supervisor, M, overruled us. and I did not want to h

ORNEY(S): Fishman, Marshall H [COR LD NTC] Kramer, Levin, Naftalis & Frankel, LLP 919 Third Avenue N w Y rk NY USA 10022 DEFENDANT ATTORNEY(S): Lefcourt, Gerald B [COR LD NTC] Law Office Gerald B Lefcourt 148 East 78TH Street New York, NY, USA 10021 Email: THE COURT UPDATED THIS RECORD ON: 07/26/

Kramer, Levin, Naftalis & Frankel, LLP 919 Third Avenue N w Y rk NY USA 10022 DEFENDANT ATTORNEY(S): Lefcourt, Gerald B [COR LD NTC] Law Office Gerald B Lefcourt 148 East 78TH Street New York, NY, USA 10021 Email: THE COURT UPDATED THIS RECORD ON: 07/26/2005 12:00:00 AM Confidential - This report is not t

of Law University of Utah 332 South 1400 East Room 101 Salt Lake City, UT, USA 68333 <i>pro Hac Vice</ I> Email: DEFENDANT ATTORNEY(S): Sanchez, Lilly Ann [COR LD NTC] Fowler White Burnett 1395 Brickell Avenue 14TH Floor Miami, FL, USA 33131-3302 Fax: Email: Goodner, Helaine S [COR LD NTC] Fowler

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 to a Sloman, Menchal , and with handwritten attorney I I notes ml 6/25/2007 email from to and entitled "Thoughts on Lefcourt's letter" Han

attorney notes; • 6/25/2007 letter from Gerald Lefcourt to a Sloman, Menchal , and with handwritten

P-013872 E-mailil and p.m., FW: Lefcourt to Sanchez a 22, to Matthew ■ Any work-product May 22, 2007, 3:11 a Mi l with e-mail from , and Lilly Ann 2007 2:05 p.m. attached Suppl. Box 3 P-013873 E-mail 2007, 10:52 . e-mail from (May 14 2007 10:38 to and May 14, Any work-product RE: Oper

S) From: Sent: To: Sanchez, Lilly Ann Subject: Jeffrey Epstein Contacts: Lilly Ann Sanchez ); Gerald Lefcourt Esq. ( Hi Lilly and Gerry -- I have been out sick and have a 2255 due by the end of the week. I will give you a call next week. Thank you. Assistant

Epstein Contacts: Lilly Ann Sanchez ); Gerald Lefcourt Esq. ( Hi Lilly and Gerry -- I have been out sic

S) From: Sent: To: Sanchez, Lilly Ann Subject: Jeffrey Epstein Contacts: Lilly Ann Sanchez ); Gerald Lefcourt Esq. ( Hi Lilly and Gerry -- I have been out sick and have a 2255 due b

C. (USAFLS) From: , IM C. (USAFLS) Sent: Friday, July 06, 2007 9:25 AM To: 'Sanchez, Lilly Ann ([email protected]); Gerald Letourt Subject: Extension of Time re Computer Subpoena Hi Lilly and Gerry — I hope you are enjoying your time off. Your request to extend the time to res

C. (USAFLS) From: , IM C. (USAFLS) Sent: Friday, July 06, 2007 9:25 AM To: 'Sanchez, Lilly Ann ([email protected]); Gerald Letourt Subject: Extension of Time re Computer Subpoena Hi Lilly and Gerry — I hope you are enjoying your time

hibit 8, but also the 18 submissions from Jerry Lefcourt, and that -- that had 19 not had a chance to a

hibit 8, but also the 18 submissions from Jerry Lefcourt, and that -- that had 19 not had a chance to a

hibit 8, but also the 18 submissions from Jerry Lefcourt, and that -- that had 19 not had a chance to a

a fair one. 2 Q Well, I can -- I may help amplify the bell a little 3 bit. One of the defense attorneys who was present there in 4 addition to Gerald Lefcourt, Roy Black, and Lillian Sanchez 5 was Alan Dershowitz. 6 A Yeah. 7 Q Does that ring a bell? 8 A So, it does. There's -- 9 Q Okay. 10 A

a fair one. 2 Q Well, I can -- I may help amplify the bell a little 3 bit. One of the defense attorneys who was present there in 4 addition to Gerald Lefcourt, Roy Black, and Lillian Sanchez 5 was Alan Dershowitz. 6 A Yeah. 7 Q Does that ring a bell? 8 A So, it does. There's -- 9 Q Okay. 10 A

a fair one. 2 Q Well, I can -- I may help amplify the bell a little 3 bit. One of the defense attorneys who was present there in 4 addition to Gerald Lefcourt, Roy Black, and Lillian Sanchez 5 was Alan Dershowitz. 6 A Yeah. 7 Q Does that ring a bell? 8 A So, it does. There's -- 9 Q Okay. 10 A

TA00009351 --- PAGE BREAK --- Page 124 1 believe you had any understanding of what amount of jail time 2 was in play at this point when tells Lilly Ann 3 Sanchez -- 4 5 6 7 8 9 A I can't pinpoint that timeline -- Q All right. A -- to that degree. Q All right. A Of accuracy. Q He als

TA00009351 --- PAGE BREAK --- Page 124 1 believe you had any understanding of what amount of jail time 2 was in play at this point when tells Lilly Ann 3 Sanchez -- 4 5 6 7 8 9 A I can't pinpoint that timeline -- Q All right. A -- to that degree. Q All right. A Of accuracy. Q He als

TA00009351 --- PAGE BREAK --- Page 124 1 believe you had any understanding of what amount of jail time 2 was in play at this point when tells Lilly Ann 3 Sanchez -- 4 5 6 7 8 9 A I can't pinpoint that timeline -- Q All right. A -- to that degree. Q All right. A Of accuracy. Q He als

July. Okay. So, on that 31st, it was 15 , Jerry Lefcourt, Sanchez, and the purpose of 16 the meeting wi

July. Okay. So, on that 31st, it was 15 , Jerry Lefcourt, Sanchez, and the purpose of 16 the meeting wi

July. Okay. So, on that 31st, it was 15 , Jerry Lefcourt, Sanchez, and the purpose of 16 the meeting wi

and & Ellis, and Lilly Ann Sanchez, I believe who met 16 with you. 17 A Fair. I remember it was Starr and Lefkowitz. I 18 don't know if it was Lilly Ann. 19 Q All right, and our information is it was you, Drew 20 Oosterbaan, Sloman, , and John MacMillan. Do you -- 21 do you know John MacMillan?

and & Ellis, and Lilly Ann Sanchez, I believe who met 16 with you. 17 A Fair. I remember it was Starr and Lefkowitz. I 18 don't know if it was Lilly Ann. 19 Q All right, and our information is it was you, Drew 20 Oosterbaan, Sloman, , and John MacMillan. Do you -- 21 do you know John MacMillan?

and & Ellis, and Lilly Ann Sanchez, I believe who met 16 with you. 17 A Fair. I remember it was Starr and Lefkowitz. I 18 don't know if it was Lilly Ann. 19 Q All right, and our information is it was you, Drew 20 Oosterbaan, Sloman, , and John MacMillan. Do you -- 21 do you know John MacMillan?