Epstein Secrets

handwritten notes, draft victim notification letter, and draft correspondence to Jay Lefkowitz (Also contains a November 28, 2007 letter from Kenneth Starr to Alice S. Fisher, and a November 29, 2007 letter Erom Jay Lefkowitz to IL Alexander Acosta (P- 010528 thru P-010530 and P-010556 thru P-010559).

privileged. Will be produced to opposing counsel upon lifting of stay N/A Suppl. Box #3 P413342 Thru P413350 File folder entitled "12/05/07 Starr to Acosta" containing drafts of 11/30/07 letters from A. Acosta to K. Starr and from J. Sloman to J. Lefkowitz re performance and victim notifica

s Against Public Prosecutor; Overriding Need; Attorney Conduct at Issue; Waiver Suppl. Box #3 P413504 Thru P413507 File folder labeled "Mtg w/ Ken Starr, RAA, JS, Drew" containing handwritten notes by A. Marie Villafttfla Attorney-Client Privilege Work Product Inadequate Log; No Factual Underpinn

y's Conduct is at Issue — If the attorney's conduct is a central issue in the case, the work-production protection does not apply. See, e.g., In re John Doe, 662 F.2d 1073, 1080 (4th Cir. 1981); Charlotte Moto• Speedway, Inc. v. International Ins. Co., 125 F.R.D. 127, 130 (M.D.N.C. 1989). E Rule 6(c) —

charged Mr. Epstein with a lesser offense, soliciting prostitution. Mr. Epstein's legal team, which would eventually include the former prosecutor Kenneth W. Starr and the Harvard law professor Alan M. Dershowitz, was elated: Mr. Epstein would avoid prison. http://www.nytimes.com/2008/07/01/business/Olepstein.

ntually include the former prosecutor Kenneth W. Starr and the Harvard law professor Alan M. Dershowitz,

s from the Internal Revenue Service. The Justice Department said Monday it asked a federal court in Miami to authorize the IRS to serve UBS with a "John Doe" summons. The IRS uses a "John Doe" summons to obtain information about potential tax fraud by unknown individuals. If approved, the summons will d

Dershowitz, and former U.S. Solicitor General Ken Starr l(io8l Linguist Steven Pinker also assisted (102

1°7i Epstein's defense lawyers included Roy Black, Gerald Lefcourt, Harvard Law School professor Alan Dershowitz, and former U.S. Solicitor General Ken Starr l(io8l Linguist Steven Pinker also assisted (102] httosIlen.vAkipedia.orgivvikVJeffrey_Epstein 8160 EFTA00261865 Cct•WIRMED C.C.) cc.04.51,tat

were released. Two sets of additional sealed documents will be analyzed by a federal judge to determine whether they should also be made public. A "John Doe" asked the judge on September 3 to permanently keep the documents secret, claiming "unproven allegations of impropriety" could damage his reputatio

lan Dershowitz, and former U.S. Solicitor General Ken Starr.ril°1 Linguist Steven Pinker also Epstein's 2006

Dershowitz, and former U.S. Solicitor General Ken Starr.ril°1 Linguist Steven Pinker also Epstein's 2006

were released. Two sets of additional sealed documents will be analyzed by a federal judge to determine whether they should also be made public. A "John Doe" asked the judge on September 3 to permanently keep the documents secret, claiming "unproven allegations of impropriety" could damage his reputatio

Dershowitz, and former U.S. Solicitor General Ken Starr. lartiVuist Steven Pinker also assiste arOT EF

1971 Epstein's defense lawyers included Ray. Black, Gerald Lekourt, Harvard Law School professor Alan Dershowitz, and former U.S. Solicitor General Ken Starr. lartiVuist Steven Pinker also assiste arOT EFTA00264310 5/10/22.3:82 PM SExUAL -regcacm.4 - PRoPti,,g6EpT„,_044,LT-chs viNscenn EsotooE anti -

were released. Two sets of additional sealed documents will be analyzed by a federal judge to determine whether they should also be made public. A "John Doe" asked the judge on September 3 to permanently keep the documents secret, claiming "unproven allegations of impropriety" could damage his reputatio

[J-cd Epstein's defense lawyers included Roy Black, GeraldLefcourt, Harvard Law School professor Alan Dershowitz, and former U.S. Solicitor General Ken Starr. 42 Steven Pinker also _ _ assisted. -- Epstein's 2006 mugshot EFTA00263450 5/22/22, 1:06PM RC e-re_r7 VICE rustiicialim7d43 t-firiLlacn OS

Dershowitz, and former U.S. Solicitor General Ken Starr. 42 Steven Pinker also _ _ assisted. -- Epst

were released. Two sets of additional sealed documents will be analyzed by a federal judge to determine whether they should also be made public. A "John Doe" asked the judge on September 3 to permanently keep the documents secret, claiming "unproven allegations of impro riety" could damage his reputatio