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

" containing attorney research Work product Box #1 P-003679 Thru P-003680 File folder entitled "Serene Cano (N.Y. AUSA)" containing attorney (Villafafla) handwritten notes Work product Box #1 P-003681 Thru P-003687 File folder entitled "Dr. Anna Salter" containing attorney (Villafafia) memo to

LY-01 through OLY-81, correspondence and research related to enforcement of same, documents produced in response to some subpoenas; and attorney (Villafafla) handwritten notes 6(e) Work Product Contains documents subject to investigative privilege Also contains documents subject to privacy rights of

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

Public Prosecutor, Attorney Conduct at Issue Box #1 P-004561 Thru P-004565 Filed folder entitled "JANUSZ BANASIAK" containing attorney (Villafafla) handwritten notes of interview Work product Investigative privilege • Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Not in Anticipa

hereby states that he understands the conditions of this Non- Prosecution Agreement and agrees to comply with them. Dated: JEFFREY EPSTEIN Dated: GERALD LEPCOURT, ESQ. COUNSEL TO JEFFREY EPSTEIN Dated: UNITED STATES ATTORNEY Page 5 of S US_Atty_Cor 0087 EFTA00184715 Case 9:08-cv-80736-KAM Document 361-

ated: VILLAFARA ASSISTANT U.S. ATTORNEY GERALD LEFCOURT, ESQ. COUNSEL TO JEFFREY EPSTEIN LILLY ANN SANC

meet to provide information about the federal crimes committed by Epstein, hoping to secure a significant federal indictment against Epstein. AUSA Villafafla and I discussed the possibility of federal charges being filed. At the end of the call, AUSA Villafafla asked me to send any information that I want

spondence, wherein you state that "we have reiterated in previous submissions that Mr. Epstein does not believe he is 'See July 6, 2007 letter from Gerald B. Lefcourt, Esq. and Alan Dershowitz. Case No. 08-80736-CV-MARRA P-013363 EFTA00230268 12/28/07 FRI 14:27 FAX 305 530 6440 EXECUTIVE OFFICE 1002 guilty

was refused. Ms. Sanchez then contacted AUSA who agreed to meet with Mit an as well as a member fcourt. On February 1, 2007, Ms. Sanchez and Mr. Lefcourt met with AUSAs of the FBI, and presented defense counsel's view of the case and proms a willingness to assist in the investigation. The SDFL was u

osta met with Kirkland & Ellis partners Jay Lefkowitz and former Solicitor General Ken Starr and Ms. Sanchez, along with Chief Oosterbahn and AUSAs Villafafla, John McMillan, and FAUSA S lomat' Messrs. Starr and Lefkowitz presented arguments regarding the sufficiency of the federal interest in the case and