Epstein Secrets

f federal statutes to places that they have never before reached. We sincerely appreciate your attention to this matter. ttespeetililly submitted, Kenneth W. Starr Kirkland & Ellis LLP Joc D. Whitley Alston & Bird LIP EFTA00225682 tAVULfUO WAN £O:VL CAA OU0 0001 OGSV otp. in • n8 WIN 13:211 PAX 1 213 080

). Ultimately, you requested an independent review. Subsequent to the above-mentioned meeting, the SDFL received three letters from you and/or Mr. Starr which expanded on some of the themes announced in the December 14th meeting. Essentially, you portrayed the SDFL as trying to coerce a plea to unkno

ee of Defendant JEFFREY EPSTEIN prepared a written telephoF message for Defendant JEFFREY EPSTEIN's review regarding a telephone call received from T.M. and Jane Doe #12 that stated: "They are available all weekend and maybe pane Doe #13] too". 20 EFTA00225764 (83) On or about December 30, 2004,

or more telephone calls to a telephone used by Jane Doe #7. (58) On or about July 16, 2004, Defendant placed a telephone call telephone used by T.M. (59) On or about July 17, 2004, one of Defendant JEFFREY EPSTEIN's employees prepared a written telephone message for Defendant JEFFREY EPSTEIN's

a telephone call to a telephone used by Jane Doe #8. D (56) On or about July 15, 2004, Defendant placed a telephone call to a telephone used by T.M. (57) On or about July 16, 2004, Defendant placed one or more telephone calls to a telephone used by Jane Doe #7. (58) On or about July 16, 2004

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

llafafia, Alex Acosta, Jeff Sloman, Karen Atkinson, Robert Senior, Rolando Garcia, and Nesbitt Kuyrkendall regarding efforts by Jay Lefkowitz and Ken Starr to speak with Alex Acosta and instructions to direct question to Marie Villafalla and Karen Atkinson Deliberative Process Work Product Attorney-

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 J. Sloman to J. Lefkowitz re performance and victim notificat

parties to this litigation 59 12/11/2007 email from Marie Villafafia to Jeff Sloman and Alex Acosta regarding call with lawyer for Jane Doe #2 (T.M.) Work Product Deliberative Process 60 12/3/2007 emails between Marie Villafatta, Alex Acosta, and Jeff Sloman regarding history of plea negotia

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

to Bradley Edwards' three clients, T.M.. C.W., and S.R.' Your Affiant's letter to C.W. was provided by the FBI. (Ex. I ). Your Affiant's letter to T.M. was hand-delivered by myself to T.M. at the time that she was interviewed (Ex. 2).= Both C.W. and T.M. also received letters from the FBI's Victim-

se the U.S. Attorney's modification limited Epstein's liability to victims whom the United States was prepared to name in an indictment. In light of T.M.'s prior statements to law enforcement, your Affiant could not in good faith include T.M. as a victim in an indictment and, accordingly, could not i

ASSISTANT UNITED STATES ATTORNEY 54 Case No. 08-80736-CV-MARRA P-013503 EFTA00230408 Case No. 08-80736-CV-141.11.5 P-013504 EFTA00230409 Mw Ken Starr Ak Acos-k 34 Sfe, etper_r(nkhrt it/4'4164- 5-r-Aaa are- ryorc Okla& Yht,frm fegticeN) hofvu-- V8 pyrd)--LAA.Vgatkii Itacd ihmovt heA.0 votwn

0736-CV-141.11.5 P-013504 EFTA00230409 Mw Ken Starr Ak Acos-k 34 Sfe, etper_r(nkhrt it/4'4164- 5-r

e of Defendant JEFFREY EPSTEIN prepared a written telephone message for Defendant JEFFREY EPSTEIN's review regarding a telephone call received from T.M. and Jane Doe #12 that stated: "They are available all weekend and maybe [Jane Doe #18] too". 20 Case No. 08-80736-CV-MARRA P-013469 EFTA00230374

more telephone calls to a telephone used by Jane Doe #7. (48) On or about July 5, 2004, Defendant placed a telephone call to a telephone used by T.M. 14 Case No. 08-80736-CV-MARRA P-013463 EFTA00230368 (49) In or around July 2004, Defendant JEFFREY EPSTEIN masturbated in the presence of Jan

il from Marie Villafafia to Jeff Sloman, Andrew Lourie, Drew Oosterbaan, John McMillan, and Karen Atkinson regarding press coverage of meeting with Ken Starr Work Product P-014058 9/4/2007-9/6/2007 emails between Marie Villafafia and Jeff Sloman regarding planned participation of FBI ASAIC at 9/7/2007

son regarding press coverage of meeting with Ken Starr Work Product P-014058 9/4/2007-9/6/2007 emails

t Deliberative Process P-014440 12/11/2007 email from Marie Villafafia to Jeff Sloman and Alex Acosta regarding call with lawyer for Jane Doe #2 (T.M.) Work Product Deliberative Process P-014441 12/12/2007 emails between Marie Villafafia, Frederica Devlin, and Bob Senior regarding planning indi

U.S. Department of Justice Washington, D.C. 20530 June 23, 2008 Jay Lefkowitz, Esq. Kenneth Starr, Esq. Kirkland and Ellis LLP Gentlemen: This Office has completed a thorough review of the U.S. Attorney's handling of the matter involving your

0530 June 23, 2008 Jay Lefkowitz, Esq. Kenneth Starr, Esq. Kirkland and Ellis LLP Gentlemen: This O

fied, including notification letters that were sent. DE 14. Attached to that Declaration are copies of redacted letters provided to victims "C.W.", "T.M.", and "S.R." by AUSA and the FBI's Victim-Witness Specialist Twiller Smith, DE 14. In addition, appended to the Declaration are AUSA Villafana's le

il from Marie Villafaiia to Jeff Sloman, Andrew Lourie, Drew Oosterbaan, John McMillan, and Karen Atkinson regarding press coverage of meeting with Ken Starr Work Product P-014058 9/4/2007-9/6/2007 emails between Marie Villafana and Jeff Sloman regarding planned participation of FBI ASAIC at 9/7/2007 m

son regarding press coverage of meeting with Ken Starr Work Product P-014058 9/4/2007-9/6/2007 emails

t Deliberative Process P-014440 12/11/2007 email from Marie Villafafta to Jeff Sloman and Alex Acosta regarding call with lawyer for Jane Doe #2 (T.M.) Work Product Deliberative Process P-014441 12/12/2007 emails between Marie Villafafta, Frederica Devlin, and Bob Senior regarding planning indi

il from Marie Villafalia to Jeff Sloman, Andrew Lourie, Drew Oosterbaan, John McMillan, and Karen Atkinson regarding press coverage of meeting with Ken Starr Work Product P-014058 9/4/2007-9/6/2007 emails between Marie Villafaila and Jeff Sloman regarding planned participation of FBI ASAIC at 9/7/2007

son regarding press coverage of meeting with Ken Starr Work Product P-014058 9/4/2007-9/6/2007 emails

t Deliberative Process P-014440 12/11/2007 email from Marie Villafafta to Jeff Sloman and Alex Acosta regarding call with lawyer for Jane Doe #2 (T.M.) Work Product Deliberative Process P-014441 12/12/2007 emails between Marie Villafafta, Frederica Devlin, and Bob Senior regarding planning indi

dated November 29, 2007; Author: A. Marie Villafana. Letter to R. Alexander Acosta, dated December 5, 2007, RE: Jeffrey Epstein (2 pages), Author: Kenneth W. Starr and Jay Lefkowitz, Kirkland & Ellis Letter to Jay P. Lefkowitz, Esq., Kirkland & Ellis, dated December 6, 2007, RE: Jeffrey Epstein (4 pages); Auth

E: Jeffrey Epstein (2 pages), Author: Kenneth W. Starr and Jay Lefkowitz, Kirkland & Ellis Letter to Ja

o. 2: (a) Letter to Miss C.W., dated June 7, 2007, RE: Crime Victims' and Witnesses' Rights (2 pages); Author: A. Marie Villafana. Letter to Miss T.M., dated August 11, 2006, RE: Crime Victims' and Witnesses' 1 EFTA00191186 Rights (2 pages); Author: A. Marie Villafana. Letter to C.W., dated Jan

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

with Ken Starr P-014440 12/11/2007 email from to and Alex Acosta Work Product Deliberative Process regarding call with lawyer for Jane Doe #2 (T.M.) P-014441 12/12/2007 emails between and Work Product Deliberative Process 6(e) regarding planning indictment review P-014442 12/14/2007 em