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lafana to Jeff Sloman, September 6, 2007, 9:29 a.m., Re: Meeting on Friday atty work-product 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 lift
. Sloman, A. Marie Villafafia re meeting with G. Lefcourt with attached email from G. Lefcourt re solicita
A. Marie Villafaila to A. Oosterbaan re trust agreement; ■ 9/13/07 e-mail from A. Marie Villafana to R. Garcia, J. Sloman re conference call with J. Leflcowitz; ■ 9/13/07 e-mail from A. Marie Villafana to A. Lourie re plea negotiations with attached correspondence; ■ 9/13/07 e-mail from A. Marie Villafai
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
ile folder entitled "8/14/08 E-mail from Lefk to AMCV" containing undated entails from A. to A. Acosta, re draft response to 8/14/08 email from J. Leflcowitz regarding "the December 2007 proposal" Attorney-Client Privilege Work Product Page 1 of 14 EFTA00185414 Case 9:08-cv-80736-KAM Document 216-1
tant prosecutor Dahlia Weiss and thereby influence the outcome of the State prosecution, that assertion is frivolous. Mr. Goldberger was retained by Gerald Lefcourt after Mr. Epstein already had been indicted by the Grand Jury. Mr. Lefcourt had never heard the name Dahlia Weiss when he hired Mr. Goldberger, and
tion, that assertion is frivolous. Mr. Goldberger was retained by Gerald Lefcourt after Mr. Epstein already had been indicted by the Grand Jury. Mr. Lefcourt had never heard the name Dahlia Weiss when he hired Mr. Goldberger, and had no idea that Mr. Goldberger's law partner was married to a sex-crimes p
ledged the application of the Petite Policy in drafts of the Deferred Prosecution Agreement. See e.g., September 17, 2007 email from M. Villafana to J. Leflcowitz attaching draft Deferred Prosecution Agreement, Exhibit 32. 17 While federal prosecutors once suggested that Mr. Epstein's retention of Jack Goldbe
." See Tab 23, August 16, 2007 Letter from to G. Lefcourt ("In other words, if the sex offense case is res
attorneys stating that "I intend to notify the victims by letter after COB Thursday [two days later]." See Tab 34, November 27, 2007 Email from to J. Leflcowitz. 42. The morning of November 28, attorneys for Mr. Epstein faxed a letter to Assistant Attorney General Alice Fisher, requesting a meeting with he
." See Tab 23, August 16, 2007 Letter from to G. Lefcourt ("In other words, if the sex offense case is res
attorneys stating that "I intend to notify the victims by letter after COB Thursday [two days later]." See Tab 34, November 27, 2007 Email from to J. Leflcowitz. 42. The morning of November 28, attorneys for Mr. Epstein faxed a letter to Assistant Attorney General Alice Fisher, requesting a meeting with he
Entities connected to both Gerald Lefcourt and J. Leflcowitz

Jeffrey Epstein
PERSON
Alexander Acosta
PERSONLeon Black
PERSON
United States
LOCATIONthe Southern District
LOCATIONAnn Sanchez
PERSONRoy Black
PERSONJack Goldberger
PERSON
Jay Lefkowitz
PERSON
Department of Justice
ORGANIZATION
Ken Starr
PERSON
Prince Andrew
PERSON
A. Marie Villafana
PERSON
Kenneth Marra
PERSONJane Doe
PERSON
Bill Clinton
PERSON
George W. Bush
PERSON
Bradley Edwards
PERSON
Palm Beach
LOCATION
Jeffrey Sloman
PERSON