Epstein Secrets

MARIE VILLAFARA ASSISTANT U.S. ATTORNEY GERALD LEFCOURT, BSQ. COUNSEL TO JEFFREY EPSTEIN LILLY ANN SANC

d agrees to comply with them. R. ALEXANDER ACOSTA UNITED STATES ATTORNEY Dated: Dated: Dated: By: A. MARIE VILLAFARA ASSISTANT U.S. ATTORNEY GERALD LEFCOURT, BSQ. COUNSEL TO JEFFREY EPSTEIN LILLY ANN SANCM3Z, BSQ. ATTORNEY FOR JEFFREY EPSTEIN Page 7 of 7 EFTA00076091 Case 1:19-cr-00490-RMB Document

2 (11th Cir. 2011), such as if the claim "'rests upon contingent future events that may not occur as anticipated, or indeed may not occur at all,"' Atlanta Gas Light Co. v. FERC, 140 F.3d 1392, 1404 (11th Cir. 1998) (quoting Texas v. United States, 523U.S. 296, 300 (1998)). Indeed, "[t]he ripeness doctrine is designe

d agrees to comply with them. R. ALEXANDER ACOSTA UNITED STATES ATTORNEY Dated: Dated: Dated: By: A. MARIE VILLAFARA ASSISTANT U.S. ATTORNEY GERALD LEFCOURT, BSQ. COUNSEL TO JEFFREY EPSTEIN LILLY ANN SANCM3Z, BSQ. ATTORNEY FOR JEFFREY EPSTEIN Page 7 of 7 EFTA00095894 Case 1:19-cr-00490-RMB Document

MARIE VILLAFARA ASSISTANT U.S. ATTORNEY GERALD LEFCOURT, BSQ. COUNSEL TO JEFFREY EPSTEIN LILLY ANN SANC

2 (11th Cir. 2011), such as if the claim "'rests upon contingent future events that may not occur as anticipated, or indeed may not occur at all,"' Atlanta Gas Light Co. v. FERC, 140 F.3d 1392, 1404 (11th Cir. 1998) (quoting Texas v. United States, 523U.S. 296, 300 (1998)). Indeed, "[t]he ripeness doctrine is designe

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

330 Entered on FLSD Docket 07/06/2015 Page 12 of 51 if they were created by or for a party to the subsequent litigation," Underwriters Ins. Co. v. Atlanta Gas Light Co., 248 F.R.D. 663, 668 (N.D. Ga. 2008). These cases rely on the Supreme Court's dicta in Federal Trade Communication v. Grolier, Inc., that "the liter