Epstein Secrets

ocess Investigative Privilege 26 5/22/2007 email from Andy Lourie to Matt Menchel and Jeff Sloman (cc: Marie Villafaita) re letter received from Gerald Lefcourt discussing a meeting to discuss Epstein investigation Work Product Deliberative Process 27 5/23/2007 email from Jason Richards to Marie Villafa

13905 E-mail, Andrew Lourie to Matthew Menchel, Jeff Sloman, and Marie Villafana, May 22, 2007, 3:11 p.m., FW: Jeffrey Epstein, with c-mail from Lcfcourt to Lourie, Villafana, and Lilly Ann Sanchez (May 22, 2007, 2:05 p.m.), attached Atty work-product Page 11 of 14 EFTA00191260 Bates Range Descr

13872 E-mail, Andrew Lourie to Matthew Menchel, Jeff Sloman, and Marie Villafana, May 22, 2007, 3:11 p.m., FW: Jeffrey Epstein, with e-mail from Lefeourt to Lourie, Villafana, and Lilly Ann Sanchez (May 22, 2007, 2:05 p.m.), attached Atty work-product Suppl. Box 3 P-013873 E-mail Menchel to Villaf

typed notes, relevant pieces of grand jury materials, telephone records/flight records analysis charts, victim/witness photographs, DAVID records, NCICs, and related materials for persons identified as Jane Does #15, 16, 17, 18, 19, Past Employees, Misc. Witnesses Work product 6(e) Contains infor

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

VRA-authorized analysis charts, victim/witness who are not parties to this release; Material Severable; Redaction; No photographs, DAVID records, NCICs, and related materials for persons identified as litigation Assertion by Victims Jane Does #15, 16, 17, 18, 19, Past Employees, Misc. Witnesses

; Fiduciary Duty; Claims Against Public Prosecutor; Overriding Need; Attorney Conduct at Issue Suppl. Box 3 P-013859 Through P-013860 Email, Gerald Lefcourt to Marie Villafana, Lilly Ann Sanchez, Roy Black, re: Jeffrey Epstein [Not considered privileged. Will be produced to opposing counsel upon l

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

A-authorized analysis charts, victim/witness who are not parties to this release; Material Severable; Redaction; No photographs, DAVID records, NCICs, and related materials for persons identified as litigation Assertion by Victims Jane Does #15, 16, 17, 18, 19, Past Em lo ees, Misc. Witnesses

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

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

typed notes, relevant pieces of grand jury materials, telephone records/flight records analysis charts, victim/witness photographs, DAVID records, NCICs, and related materials for persons identified as Jane Does #15, 16, 17, 18, 19, Past Employees, Misc. Witnesses Work product 6(e) Contains infor

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

517 Thru P-008535 6/25/2007 Letter from Gerald Lefcourt . [pursuant to Court's Order, not being withheld

typed notes, relevant pieces of grand jury materials, telephone records/flight records analysis charts, victim/witness photographs, DAVID records, NCICs, and related materials for persons identified as Jane Does #15, 16, 17, 18, 19, Past Employees, Misc. Witnesses Work product 6(e) Contains infor

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

typed notes, relevant pieces of grand jury materials, telephone records/flight records analysis charts, victim/witness photographs, DAVID records, NCICs, and related materials for persons identified as Jane Does #15, 16, 17, 18, 19, Past Employees, Misc. Witnesses Work product 6(e) Contains infor

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

typed notes, relevant pieces of grand jury materials, telephone records/flight records analysis charts, victim/witness photographs, DAVID records, NCICs, and related materials for persons identified as Jane Does #15, 16, 17, 18, 19, Past Employees, Misc. Witnesses Work product 6(e) Contains infor

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

typed notes, relevant pieces of grand jury materials, telephone records/flight records analysis charts, victim/witness photographs, DAVID records, NCICs, and related materials for persons identified as Jane Does #9, 10, 11, 12, 13, 14 Work Product Deliberative Process 6(e) Also contains documents

is litigation Page 11 of 23 EFTA00191375 Bates Range Description Privilege(s) Asserted Box #2 P-008517 Thru P-008535 6/25/2007 Letter from Gerald Lefcourt to Jeffrey Sloman and Andrew Lourie [pursuant to Court's Order, not being withheld as privileged — will be produced to opposing counsel upon lift

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

typed notes, relevant pieces of grand jury materials, telephone records/flight records analysis charts, victim/witness photographs, DAVID records, NCICs, and related materials for persons identified as Jane Does #15, 16, 17, 18, 19, Past Employees, Misc. Witnesses Work product 6(e) Contains infor