Epstein Secrets

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

" 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

States Attorney's Office Hon. R. Alexander Acosta (305) 530-6444 Southern District of Florida Pages From: Date; Fax It: Direct Si: arintir Kenneth W. Starr December 5, 2007 3 (213) 680-8500 Message: Case No. 08-80736-CV-MARRA P-013339 EFTA00230244 12/05/07 WED 15:24 FAX 1 213 880 8500 KIRKLAND&

ent e-mails and letters regarding victim notification and other issues. Some of these issues also are addressed in the U.S. Attorney's letter to Mr. Starr, but in light of our discussions, I believe a separate response is needed. In a recent e-mail, you write that you were surprised at the tone of my

r. See October 9, 2007 New York Post article attached at Tab C. Prior to signing the Non-Prosecution Agreement, Mr. Epstein's defense team included Ken Starr, Jay Lefkowitz, , Alan Dershowitz, Gerald Lefcourt, Roy Black, Guy Lewis, Martin Weinberg, Jack Goldberger, Stephanie Thacker", and the associates

er. See October 9, 2007 New York Post article attached at Tab C. Prior to signir the Non-Prosec tion Agreement, Mr. Epstein's defense team included Ken Start, Jay Lefkowitz, , Alan Dershowitz, Gerald Lefcourt, Roy Black, Guy Lewis, Martin Weinberg, Jack Goldberger, Stephanie Thacker', and the associates

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

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

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

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

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