Epstein Secrets

aimen1 and *pm to tomply wkihztote. R. ALEXANDER ACOSTA VinTED STATER ATTOMEY A. MARE VII1APA A ASSISTANT VS. ATTORNEY Dáie.1 ril - Os& Dw.* GERALD LEPCOURT,ESO. COUNSEL TO MPFREY MIEN LILLY ANN SANCHEZ. ESQ. ATTORNEY POR WEM ETSTEN Case No. 08-80736-CV-MARRA P-011814 EFTA00192860 By signing this

MARIE VTLLAFARA ASSISTANT U.S. ATTORNEY OERALD LEFCOURT, ESQ. COUNSEL TO JEFFREY EPSTEIN LILLY ANN SANC

with them. R. ALEXANDER ACOSTA UNITED STATES ATTORNEY Dated: By: Dated: 77P/4" Dated: Dated: A. MARIE VTLLAFARA ASSISTANT U.S. ATTORNEY OERALD LEFCOURT, ESQ. COUNSEL TO JEFFREY EPSTEIN LILLY ANN SANCHEZ, ESQ. ATTORNEY FOR JEFFREY EPSTEIN Page 7 of 7 Case No. 08-80736-CV-MARRA P-01 1810 EFTA001

09). Courts have long consulted official CRS summariesto assess legislative intent, see, e.g., &nig Pension Ben. Guar. Com. 744 F.2d 133, 145 & n.7 (D.C. Cir. 1984); fIRECI'V Inc. I. Cignarella No. I. Civ.A 03-2384, 2005 W 1252261 at *7 (D.N.J. May 24, 2005); Clokesav St. Francis Hoso. & Healthcare No.

even when the information would incriminate the client "in the very case in which the Firm was engaged to provide criminal defense representation." Gerald B. Lefcourt, P.C. v. United States , 125 F.3d 79, 87 (2d Cir. 1997). In that case, Attorney Lefcourt refused to identify in an IRS reporting form a client who p

aged to provide criminal defense representation." Gerald B. Lefcourt, P.C. v. United States , 125 F.3d 79, 87 (2d Cir. 1997). In that case, Attorney Lefcourt refused to identify in an IRS reporting form a client who paid him more than $10,000 cash, and Lefcourt was fined $25,000. Lefcourt sought to avoid

ry Matter No. 91-01386 , 969 F.2d 995, 997 (11th Cir. 1992) (citation omitted). In United States v. Legal Servs. for New York City , 249 F.3d 1077 (D.C. Cir. 2001), the D.C. Circuit stated that "[c]ourts have consistently held that the general subject matters of clients' representations are not privilege

even when the information would incriminate the client "in the very case in which the Firm was engaged to provide criminal defense representation." Gerald B. Lefcourt, P.C. I United States , 125 F.3d 79, 87 (2d Cir. 1997). In that case, Attorney Lefcourt refused to identify in an IRS reporting form a client who pa

gaged to provide criminal defense representation." Gerald B. Lefcourt, P.C. I United States , 125 F.3d 79, 87 (2d Cir. 1997). In that case, Attorney Lefcourt refused to identify in an IRS reporting form a client who paid him more than $10,000 cash, and Lefcourt was fined $25,000. Lefcourt sought to avoid

ury Matter No. 91-01386 , 969 F.2d 995, 997 (11th Cir. 1992) (citation omitted). In United States I Legal Servs. for New York City , 249 F.3d 1077 (D.C. Cir. 2001), the D.C. Circuit stated that "[c]ourts have consistently held that the general subject matters of clients' representations are not privilege

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

uct" does not rise to the level of conduct that triggers an exception to the work product doctrine. See, e.g., In re Sealed Case, 754 F.2d 395, 401 (D.C. Cir. 1985) (exception to attorney-client privilege applied where alleged wrongdoing included "perjured testimony, document destruction, and similar mis

alleged conduct. See, e.g., Letter from Gerald B. Lefcourt to a EFTA00299028 USAO-SDFL, June 25, 2007 (a

the many contradictory sworn statements and inconsistencies in the various witness accounts of Mr. Epstein's alleged conduct. See, e.g., Letter from Gerald B. Lefcourt to a EFTA00299028 USAO-SDFL, June 25, 2007 (attached as Exhibit 1). Those presentations also included detailed statutory analysis and discussion

Furthermore, "a district judge must be careful not to exceed his or her constitutional role." United States v. Microsoft Corp., 56 F.3d 1448, 1462 (D.C. Cir. 1995). "When a judge assumes the power to prosecute, the number [of branches] shrinks to two." In re United States, 345 F.3d 450, 454 (7th Cir. 20

et with counsel for Mr. Epstein. Sincerely, R. Alexander Acosta United States Attorney ...••••••• By: Chief, Criminal Division cc: Roy Black Gerald B. Lefcourt R. Alexander Acosta EFTA00179084 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA IN RE GRAND JURY SUBPOENAS DUCES TECUM NUMBERS OLY

aged to provide criminal defense representation." Gerald B. Lefcourt, P.C. v. United States, 125 F.3d 79, 87 (2d Cir. 1997). In that case, Attorney Lefcourt refused to identify in an IRS reporting form a client who paid him more than $10,000 cash, and Lefcourt was fined $25,000. Lefcourt sought to avoid

Jury Matter No. 91-01386, 969 F.2d 995, 997 (11th Cir. 1992) (citation omitted). In United States v. Legal Servs. for New York City, 249 F.3d 1077 (D.C. Cir. 2001), the D.C. Circuit stated that "[c]ourts have consistently held that the general subject matters of clients' representations are not privileg

tering; and that it would be “virtually impossible to comply” with four separate state registration requirements. A few minutes later, Sanchez sent Lefcourt’s phone number to Lourie “in case you want to speak to him directly.” In another email sent less than two hours later, Sanchez told Lourie she was

non-prosecution agreement or a related and similar mechanism, a deferred prosecution agreement. United States v. Fokker Servs. B.V., 818 F.3d 733 (D.C. Cir. 2016). These agreements “afford a middle-ground option to the prosecution when, for example, it believes that a criminal conviction may be diffic