Epstein Secrets

member the phone call, 16 but from the e-mail, I accept that it happened. 17 Q So, what had been your knowledge and relationship 18 of -- with Ken Starr of Kirkland S Ellis -- 19 A Right. 20 Q -- up to this point? 21 A So, I had been an associate at Kirkland, I think I 22 indicated, what was

member the phone call, 16 but from the e-mail, I accept that it happened. 17 Q So, what had been your knowledge and relationship 18 of -- with Ken Starr of Kirkland S Ellis -- 19 A Right. 20 Q -- up to this point? 21 A So, I had been an associate at Kirkland, I think I 22 indicated, what was

member the phone call, 16 but from the e-mail, I accept that it happened. 17 Q So, what had been your knowledge and relationship 18 of -- with Ken Starr of Kirkland S Ellis -- 19 A Right. 20 Q -- up to this point? 21 A So, I had been an associate at Kirkland, I think I 22 indicated, what was

12 A They wanted to argue -- they, being defense 13 counsel, wanted to argue why we should not pursue this case. 14 Q And in this case, it was Starr and Lefkowitz from 15 Kirkland & Ellis, and Lilly Ann Sanchez, I believe who met 16 with you. 17 A Fair. I remember it was Starr and Lefkowitz

12 A They wanted to argue -- they, being defense 13 counsel, wanted to argue why we should not pursue this case. 14 Q And in this case, it was Starr and Lefkowitz from 15 Kirkland & Ellis, and Lilly Ann Sanchez, I believe who met 16 with you. 17 A Fair. I remember it was Starr and Lefkowitz

12 A They wanted to argue -- they, being defense 13 counsel, wanted to argue why we should not pursue this case. 14 Q And in this case, it was Starr and Lefkowitz from 15 Kirkland & Ellis, and Lilly Ann Sanchez, I believe who met 16 with you. 17 A Fair. I remember it was Starr and Lefkowitz

and & Ellis, and Lilly Ann Sanchez, I believe who met 16 with you. 17 A Fair. I remember it was Starr and Lefkowitz. I 18 don't know if it was Lilly Ann. 19 Q All right, and our information is it was you, Drew 20 Oosterbaan, Sloman, , and John MacMillan. Do you -- 21 do you know John MacMillan?

and & Ellis, and Lilly Ann Sanchez, I believe who met 16 with you. 17 A Fair. I remember it was Starr and Lefkowitz. I 18 don't know if it was Lilly Ann. 19 Q All right, and our information is it was you, Drew 20 Oosterbaan, Sloman, , and John MacMillan. Do you -- 21 do you know John MacMillan?

and & Ellis, and Lilly Ann Sanchez, I believe who met 16 with you. 17 A Fair. I remember it was Starr and Lefkowitz. I 18 don't know if it was Lilly Ann. 19 Q All right, and our information is it was you, Drew 20 Oosterbaan, Sloman, , and John MacMillan. Do you -- 21 do you know John MacMillan?

which as Drew politely reminded me, is required under the law. (Exhibit 44). On September 7, 2007, USA Acosta, FAUSA , CEOS Chief and I met with Kenneth Starr, Jay Lefkowitz, and Lilly Ell (Exhibit 5). At the meeting, Mr. Starr focused primarily on federalism/policy arguments, and Mr. Epstein's backgroun

On September 7, 2007, USA Acosta, FAUSA , CEOS Chief and I met with Kenneth Starr, Jay Lefkowitz, and Lilly Ell (Exhibit 5). At the meeting, Mr. Starr focused primarily on federalism/policy arguments, and Mr. Epstein's background. I remember Mr. Starr thanking me for bringing § 2255 to their attent

d numerous emails and conversations (mostly via telephone and possibly some in person) with members of the defense team. USA Acosta had contact with Ken Starr, Jay Lefkowitz, Gerry Lefcourt, and Alan Dershowitz. FAUSA had contact with Alan Dershowitzi • Lefcourt, and Lilly . Criminal Chief had contact

gued above, but I will try to collect them into general categories in chronological order. 1. b. I did not want to meet with counsel for Epstein (Lilly Ann and Gerald Lefcourt) prior to completi.n investigation. My co-counsel agreed with me. Our supervisor, M, overruled us. and I did not want to h

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

(May 23, 2007, 5:00 p.m.), Andrew Lourie to Gerald Lefcourt (May 22, 2007, 6:32 p.m.), and Gerald Lefcourt to Andrew Lourie Marie Villafana, and Lilly Ann Any work-product Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Waiver, Claims Against Public Prosecutor; Overriding Need; Attorney C

ch may be initiated to enforce those claimed rights. We do not believe there is any ht to in this case. Moreover, we do not believe that whatever Kenneth Starr or may have said to this office, or what this office said to Kenneth Starr or Lilly Ann , has any bearing on whether a duty existed under 18 U.S.C

stand you to take the position that you can withhold the other half of the U.S. Attorney's correspondence, correspondence between the Department and Ken Starr and Lillian on behalf of Epstein, and information about role in the Epstein case. In short, we understand you to be asserting a blanket position t

oreover, we do not believe that whatever Kenneth Starr or may have said to this office, or what this of

n this case. Moreover, we do not believe that whatever Kenneth Starr or may have said to this office, or what this office said to Kenneth Starr or Lilly Ann , has any bearing on whether a duty existed under 18 U.S.C. 3771(a) to consult with plaintiffs prior to entering into a non-prosecution agreement,

ch may be initiated to enforce those claimed rights. We do not believe there is any ht to in this case. Moreover, we do not believe that whatever Kenneth Starr or may have said to this office, or what this office said to Kenneth Starr or Lilly Ann , has any bearing on whether a duty existed under 18 U.S.C

stand you to take the position that you can withhold the other half of the U.S. Attorney's correspondence, correspondence between the Department and Ken Starr and Lillian on behalf of Epstein, and information about role in the Epstein case. In short, we understand you to be asserting a blanket position t

oreover, we do not believe that whatever Kenneth Starr or may have said to this office, or what this of

n this case. Moreover, we do not believe that whatever Kenneth Starr or may have said to this office, or what this office said to Kenneth Starr or Lilly Ann , has any bearing on whether a duty existed under 18 U.S.C. 3771(a) to consult with plaintiffs prior to entering into a non-prosecution agreement,

U.S. Department of Justice United States Attorney Southern District of Florida R ALEXANDER ACOSTA UNITED STATES ATTORNEY DELIVERY BY FACSIMILE Kenneth W. Starr, Esq Kirkland & Ellis LLP 777 South Figueroa Street Los Angeles, CA 90017 Re: Jeffrey Epstein Dear Mr. Starr: 99 ME. 4 Street 331 2 - Faalml

DELIVERY BY FACSIMILE Kenneth W. Starr, Esq Kirkland & Ellis LLP 777 South Figueroa Street Los Angeles, CA 90017 Re: Jeffrey Epstein Dear Mr. Starr: 99 ME. 4 Street 331 2 - Faalmlle I write in response to your November 286 letter, in which you raise concerns regarding the Non-Prosecution Agr

Jul 1 2007, meetin between FAUSA „ Criminal Chief West Palm Beach Chief AUSA • and two FBI agents who met with Roy Black, Gerald Lefcourt, and Lilly Ann anchez. On at ate, the prosecutors presented a written, four-bullet-point term sheet that would satisfy the federal interest in the case and discus

d privileged. Will be produced to opposing counsel upon lifting of stay] Suppl. Box #3 P-013342 Thru P-013350 File folder entitled "12/05/07 Starr to Acosta" containing drafts of 11/30/07 letters from A. Acosta to K. Starr and from to J. Leflcowitz re performance and victim notification wit

y-Client Privilege Deliberative Process Work Product Investigative privilege Suppl. Box #3 P-013504 Thru P-013507 File folder labeled "Mtg w/ Ken Starr, RAA_I_La S Drew" containing handwritten notes by A. = Attorney-Client Privilege Work Product Suppl. Box #3 P-013508 Thru P-013514 File folde

P-013872 E-mailil and p.m., FW: Lefcourt to Sanchez a 22, to Matthew ■ Any work-product May 22, 2007, 3:11 a Mi l with e-mail from , and Lilly Ann 2007 2:05 p.m. attached Suppl. Box 3 P-013873 E-mail 2007, 10:52 . e-mail from (May 14 2007 10:38 to and May 14, Any work-product RE: Oper

nigans and will keep the defense on a strict timeline. Before this counter-offer, I was going to propose that we include in our response to Messrs. Starr and Lefkowitz one page of the draft overt acts section. I have attached the proposed overt acts related to two of the girls, as an example. Wert a

ntion a couple of things that I hoped to talk to you about. There are two things that I think might lx tricks up the sleeves of the defense. First, Lilly Ann had mentioned in our Miami meeting with all the defense attorneys that Epstein would be willing to do a split sentence of community control followe

nigans and will keep the defense on a strict timeline. Before this counter-offer, I was going to propose that we include in our response to Messrs. Starr and Lefkowitz one page of the draft overt acts section. I have attached the proposed overt acts related to two of the girls, as an example. Overt

ntion a couple of things that I hoped to talk to you about. There arc two things that I think might be tricks up the sleeves of the defense. First, Lilly Ann had mentioned in our Miami meeting with all the defense attorneys that Epstein would be willing to do a split sentence of community control followe

TA00009351 --- PAGE BREAK --- Page 124 1 believe you had any understanding of what amount of jail time 2 was in play at this point when tells Lilly Ann 3 Sanchez -- 4 5 6 7 8 9 A I can't pinpoint that timeline -- Q All right. A -- to that degree. Q All right. A Of accuracy. Q He als

TA00009351 --- PAGE BREAK --- Page 124 1 believe you had any understanding of what amount of jail time 2 was in play at this point when tells Lilly Ann 3 Sanchez -- 4 5 6 7 8 9 A I can't pinpoint that timeline -- Q All right. A -- to that degree. Q All right. A Of accuracy. Q He als

TA00009351 --- PAGE BREAK --- Page 124 1 believe you had any understanding of what amount of jail time 2 was in play at this point when tells Lilly Ann 3 Sanchez -- 4 5 6 7 8 9 A I can't pinpoint that timeline -- Q All right. A -- to that degree. Q All right. A Of accuracy. Q He als

t I wanted to bring him into this. 13 Q So, the -- we know he was present at the December 14 14, 2007 meeting, right? 15 A Yeah. 16 Q With Ken Starr and company. He is not present 17 at -- to -- according to our investigation, at any other case 18 with defense counsel. Others are. His ASAC, i

07 meeting, right? 15 A Yeah. 16 Q With Ken Starr and company. He is not present 17 at -- to -- a

t I wanted to bring him into this. 13 Q So, the -- we know he was present at the December 14 14, 2007 meeting, right? 15 A Yeah. 16 Q With Ken Starr and company. He is not present 17 at -- to -- according to our investigation, at any other case 18 with defense counsel. Others are. His ASAC, i

07 meeting, right? 15 A Yeah. 16 Q With Ken Starr and company. He is not present 17 at -- to -- a

t I wanted to bring him into this. 13 Q So, the -- we know he was present at the December 14 14, 2007 meeting, right? 15 A Yeah. 16 Q With Ken Starr and company. He is not present 17 at -- to -- according to our investigation, at any other case 18 with defense counsel. Others are. His ASAC, i

07 meeting, right? 15 A Yeah. 16 Q With Ken Starr and company. He is not present 17 at -- to -- a