Epstein Secrets

Mau MencheLjeff Sloman, mid Marie Villakula 27 5/15/2007 Transcript of Kuyrkendall Testimony 28 5/22/07- 5/24/07 Emails between Andrew Laurie, Gerald Lel-court, Man Mencheljeff Sloman, Marie Villafaiia, Lilly Ann Sanchez, and Karen Atkinson regarding second meeting with counsel for Epstein 29 5/22/2007 T

ainst federal prosecution. 34 7/13/2007 Letter from Roy Black to Marie Villa' la with handwritten attorney Lourie notes 35 7/25/2007 latter from Gerald l.efrourt and Alan Dershowia to Matthew Menchel arguing that no charge can or should be made under 18 U.S.C. S 2422(b). 36 7/26/2007 Email from Marie ViIla

f the individuals who have accepted Epstein's offer of payment for representation and the names of their attorneys. 2/1/2007 A. Marie Villafafia Gerald B. Lefcourt Talking points and documents for 2/1/07 meeting 4 2/5/2007 A. Marie Villafatia Gerald B. Lefcourt Production of debit/credit card statement r

inson A. Marie Villafaila Draft of email to be sent to Sloman and Menchel stating that Villafatia disagrees with promising to have a meeting with Lefcourt or any of Epstein's other attorneys. Believes the prior meeting disclosed prosecution strategy and holding another meeting will disclose even more.

in employees — Janusz Banasiak Both initially asked for immunity. After speaking with Banasiak's attorney, r. anasi was satisfied with a standard Kastigar letter, but Ms. Mucinska's attorney was insistent on formal immunity, and as noted above, so was Individual #28. I don't believe that, prior to thi

ct Deliberative process 6(e) Attorney-Client Privilege ■ 7/13/2007 letter from to with handwritten attorney (Lourie) notes; ■ 6/2 /2 I from Gerald Lefcourt Matt Menchal , and with handwritten attorney • ■ 6/25/2007 email fro to Matt Menchel and entitled "Thoughts on Lefcourt's letter" Handwrit

ttorney (Lourie) notes; ■ 6/2 /2 I from Gerald Lefcourt Matt Menchal , and with handwritten attorney

investigation, and Ms. likely testimony. Exhibit 1 at P-003732 thru P-003733. 7. On February 5, 2007, I provided Mr. Eisenberg with two proposed Kastigar letters that, again, discuss the grand jury's investigation. Exhibit 1 at P-003739 thru P-003743, P-003745. 8. In response to a complaint from Mr.

timony solely as a victim/winless. During our last conversation regarding Ms. , you indicated that she was unwilling to speak with us pursuant to a Kastigar letter and that she also was unwilling to speak with the grand jury and intends to invoke the Fifth Amendment if questioned. Please confer with her

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

nusz Banasiak and Mucinska. Both initially asked for immunity. After speaking with Banasiak's attorney, Mr. Banasiak was satisfied with I standard Kastigar letter, but Ms. Mucinska's attorney was insistent on formal immunity, and as noted above, so was Individual #28. I don't believe that, prior to thi

red on FLSD Docket 07/19/2013 Page 12 of 23 Bates Range Description Privikge(s) Asserted Box #2 P-008517 Thru P-008535 6/25/2007 Letter from Gerald Lefcourt to Jeffrey Sloman and [pursuant to Court's Order, not being withheld as privileged — will be produced to opposing counsel upon lift of stay by 11

517 Thru P-008535 6/25/2007 Letter from Gerald Lefcourt to Jeffrey Sloman and [pursuant to Court's Orde

imony solely as, a victim/witness. During our last conversation regarding Ms. , you indicated that she was unwilling to speak with us pursuant to a Kastigar letter and that she also was unwilling to speak with.the grand jury and intends to invoke the Fifth Amendment if questioned. Please confer with her

As you put it, your group has a "combined 250 years experience" to my fourteen. The agreement itself was signed by Mr. Epstein, Ms. Sanchez, and Mr. Lcfcourt, whose experience speaks for itself. You and I spent hours negotiating the terms, including when to use "a" versus "the" and other minutiae. When y

ee Ex. A. I had several oral and written communications with Mr. Eisenberg asking him if Jane Doe 2 would appear under the protection of a standard Kastigar letter, but he told me that Jane Doe 2 would only appear if statutory immunity pursuant to 18 U.S.C. § 6001 was received. For example, in my letter

As you put it, your group has a "combined 250 years experience" to my fourteen. The agreement itself was signed by Mr. Epstein, Ms. Sanchez, and Mr. Lefcourt, whose experience speaks for itself. You and I spent hours negotiating the terms, including when to use "a" versus "the" and other minutiae. When o

imony solely as a victim/witness. During our last conversation regarding Ms. =, you indicated that she was unwilling to speak with us pursuant to a Kastigar letter and that she also was unwilling to speak with the grand jury and intends to invoke the Fifth Amendment if questioned. Please confer with her

LY ANN SANCHEZ, ESQ. NOveMBat 16, 2006 PAGE 3 oF 3 Thank you for your assistance with this matter, and I look forward to working with you and Mr. Lercourt. Sincerely, Alexander Acosta United States Attorney By: Assistant United States Attorney EFTA00179051 EXHIBIT E EFTA00179052 JUL-09-2007

521-23. Interestingly, in that case, the government conceded that "the leaking of privileged materials to investigators would raise the specter of Kastigar-like evidentiary hearings". Id. at 517. This case presents the same specter should Mr. Epstein be indicted. The recognized importance of the attorn