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

e victims were not properly notified about event during that investigation. 59. RFP No. 25 requests all initial productions that are required under the Federal Rules of Civil Procedure. This is a protective request to ensure that, should it be determined that the Civil Rules apply, they then receive all materials to whic

box No. 3 (P-013504 to P-013507). The entry here reads: "File folder labeled `Mtg w/ Ken Starr, RAA, JS, Drew' containing handwritten notes by a ' Kenn Starr, of course, is a defense attorney who represented defendant Epstein. Recording information provided by a defense attorney is not part of any governm

3 of the supplemental privilege log (DE 216-1), with regard to Suppl. Box #3 P-013342 to P-013350. The entry reads: "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 with

e victims were not properly notified about event during that investigation. 59. RFP No. 25 requests all initial productions that are required under the Federal Rules of Civil Procedure. This is a protective request to ensure that, should it be determined that the Civil Rules apply, they then receive all materials to whic

ith regard to supplemental box No. 3 (P-013504 to P-013507). The entry here re l. folder labeled `Mtg w/ Ken Starr, containing handwritten notes by Kenn Starr, of course, is a defense attorney who represented defendant Epstein. Recording information provided by a defense attorney is not part of any governm

3 of the supplemental privilege log (DE 216-1), with regard to Suppl. Box #3 P-013342 to P-013350. The entry reads: "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. Leflcowitz re performance and victim notificat

e victims were not properly notified about event during that investigation. 59. RFP No. 25 requests all initial productions that are required under the Federal Rules of Civil Procedure. This is a protective request to ensure that, should it be determined that the Civil Rules apply, they then receive all materials to whic

lemental privilege log (DE 216- 1), with regard to supplemental box No. 3 (P-013504 to P-013507). The entry here reads: "File folder labeled `Mtg w/ Ken Starr, RAA, JS, Drew' containing handwritten notes by A. Marie Villafaiia." Kenn Staff, of course, is a defense attorney who represented defendant Epstein

3 of the supplemental privilege log (DE 216-1), with regard to Suppl. Box #3 P-013342 to P-013350. The entry reads: "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 notificati

e victims were not properly notified about event during that investigation. 59. RFP No. 25 requests all initial productions that are required under the Federal Rules of Civil Procedure. This is a protective request to ensure that, should it be determined that the Civil Rules apply, they then receive all materials to whic

rch, handwritten notes, draft victim notification letter, and draft correspondence to Jay Lefkowitz (Also contains a November 28 2007 letter from Kenneth Starr to , and a November 29, 2007 letter from Jay Lefkowitz to R. Alexander Acosta (P-010528 thru P-010530 and P410556 thru P-010559). Pursuant to the

contains a November 28 2007 letter from Kenneth Starr to , and a November 29, 2007 letter from Jay Le

26(a)(1). Although Petitioners have already served their Rule 26(a)(1) disclosures (DE 266 at 13), and although this Court has repeatedly held that the Federal Rules of Civil Procedure "govern the general course of this proceeding," the Government maintains that the rule governing initial disclosures in civil litigation d

al box No. 3 (P-013504 to P-013507). The entry here reads: "File folder labeled `Mtg w/ Ken Starr, RAA, JS, Drew' containing handwritten notes by n Kenn Starr, of course, is a defense attorney who represented defendant Epstein. Recording information provided by a defense attorney is not part of any governm

3 of the supplemental privilege log (DE 216-1), with regard to Suppl. Box #3 P-013342 to P-013350. The entry reads: "File folder entitled `12/05/07 Starr to containing drafts of 11/30/07 letters from A. to K. Starr and from J. to J. Lefkowitz re performance and victim notification with handwritten

e victims were not properly notified about event during that investigation. 59. RFP No. 25 requests all initial productions that are required under the Federal Rules of Civil Procedure. This is a protective request to ensure that, should it be determined that the Civil Rules apply, they then receive all materials to whic

gnificant publicity between 2006 and 2008, not only because of their well-known names but also the unusual number of them. Epstein hired Roy Black, Ken Starr, Jay Lefkowitz, Guy Lewis, Michael Tien, Lily Ann Sanchez, Gerald Lefcourt, Guy Fronstein, Jack Goldberger, and more. All of these lawyers were now

ual number of them. Epstein hired Roy Black, Ken Starr, Jay Lefkowitz, Guy Lewis, Michael Tien, Lily An

e other Class members. 284. This action has been brought and may properly be maintained as a class action against JP Morgan pursuant to Rule 23 of the Federal Rules of Civil Procedure because there is a well-defined community of interest in the litigation and the proposed Class is easily ascertainable from JP Morgan's r

mental privilege log (DE 216-1) contains an entry concerning Suppl. Box #3 P-013342 through P-013350, which involves "File folder entitled '12/05/07 Starr to Acosta' containing drafts of 11/30/07 letters from A. Acost to K. Starr and from J. Sloman to J. Leficowitz re performance and victim notificati

fforts by former President Bill Clinton, Andrew Albert Christian Edward (a/k/a Prince Andrew, Duke of York), Harvard Law Professor Alan Dershowitz, Ken Starr, Lillian Sanchez, Jay Lefkowitz, and Roy Black on his behalf. EFTA00179727 Case 9:08-cv-80736-KAM Document 225-1 Entered on FLSD Docket 08/16/201

ell). Id. The Court then noted: "Because the Court will allow this limited factual development, it is unnecessary to decide here whether the CVRA or the Federal Rules of Civil Procedure provide discovery rights in this context. The Court therefore reserves ruling on [the victims'] motion [for an order directing the Govern

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

e, correspondence between the Department and Ken Starr and Lillian on behalf of Epstein, and informatio

at some of these positions may conflict with other positions taken by the Department. In particular I believe that the Department's position is that the Federal Rules of Civil Procedure do not apply because this is not a civil action. As to point number 4, I would recommend that we make clear that the matter should be fil

P-013504 to P-013507). The entry here reads: "File folder labeled `Mtg w/ Ken Starr, RAA, JS, Drew' containing handwritten notes by A. Villafalla." Kenn Starr, of course, is a defense attorney who represented defendant Epstein. Recording information provided by a defense attorney is not part of any governm

3 of the supplemental privilege log (DE 216-1), with regard to Suppl. Box #3 P-013342 to P-013350. The entry reads: "File folder entitled `12/05/07 Starr to containing drafts of 11/30/07 letters from A. to K. Starr and from J. Lefkowitz re performance and victim notification with handwritten notes a

e victims were not properly notified about event during that investigation. 59. RFP No. 25 requests all initial productions that are required under the Federal Rules of Civil Procedure. This is a protective request to ensure that, should it be determined that the Civil Rules apply, they then receive all materials to whic