Epstein Secrets

rivileged — have been produced to opposing counsel]); signed Non- Prosecution Agreement, Addendum, and operative portion of 12/19/2007 Sanchez- Acosta letter (P-008328-P-008343 [not being withheld as privileged — have been produced to opposing counsel]); subfolder entitled "12/19/07 Acosta-Sanche

y Lefkowitz (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). Pursuant to the Court's Order, these will be produced to opposing counsel upon lift of stay

Duty; Claims Against Public Prosecutor; Overriding Need; Attorney Conduct at Issue Waiver Suppl. Box 3 P-013850 E-mail, Marie Villafana to Alex Acosta, Andrew Lourie, Rolando Garcia, Karen Atkinson, and John McMillan, September 18, 2007, 9:31 a.m., RE: Epstein Negotiations Atty work-product

itigation; Claims Against Public Prosecutor; Overriding Need; Attorney Conduct at Issue Box #1 P-003681 Thru P-003687 File folder entitled "Dr. Anna Salter" containing attorney (Villafafia) memo to expert witness and handwritten attorney notes Work product Investigative privilege Inadequate Log; No

09111 File folder entitled "Meeting Timeline" containing Villafafia typed notes summarizing meetings with opposing counsel prepared at request of R. Alexander Acosta, with handwritten correction and typed guideline estimate Work product Deliberative process Box #2 P-009112 Thru P-009113 11/26/2008 Email fr

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-Client Privilege 30 3/19/

ween Alex Acosta, Jeff Sloman, Marie Villafafta, Nesbitt Kuyrkendall, Cyndee Campos, and Annette Castillo about drafting and sending the 12/4/2007 Acosta letter to Ken Starr Work Product Deliberative Process 6(e) Attorney-Client Privilege Page 6 of 12 EFTA00191243 Bates Range Description Pri

rene 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 expert witness and handwritten attorney notes Work product Investigative privilege Box #1 P-003688 T

rivileged — have been produced to opposing counsel]); signed Non- Prosecution Agreement, Addendum, and operative portion of 12/19/2007 Sanchez- Acosta letter (P-008328-P-008343 [not being withheld as privileged — have been produced to opposing counsel]); subfolder entitled "12/19/07 Acosta-Sanche

older entitled "Meeting Timeline" containing Villafaria typed notes summarizing meetings with opposing counsel prepared at request of R. Alexander Acosta, with handwritten correction and typed guideline estimate Work product Deliberative process Inadequate Log; No Factual Underpinnings; Fiduciar

ry Duty; Claims Against Public Prosecutor, Overriding Need; Attorney Conduct at Issue Waiver Suppl. Box 3 P-013850 E-mail, Marie Villafana to Alex Acosta, Andrew Lourie, Rolando Garcia, Karen Atkinson, and John McMillan, September 18, 2007, 9:31 a.m., RE: Epstein Negotiations Atty work-product

itigation; Claims Against Public Prosecutor; Overriding Need; Attorney Conduct at Issue Box #1 P-003681 Thru P-003687 File folder entitled "Dr. Anna Salter" containing attorney (Villafafla) memo to expert witness and handwritten attorney notes Work product Investigative privilege Inadequate Log; No

dum, and operative portion of 12/19/2007 Sanchez-Acosta letter (P-008328-P- 008343 [not being withheld as

09111 File folder entitled "Meeting Timeline" containing Villafafia typed notes summarizing meetings with opposing counsel prepared at request of R. Alexander Acosta, with handwritten correction and t d uideline estimate Work product Deliberative process Box #2 P-009112 Thru P-009113 11/26/2008 Email from

rene Cano (N.Y. AUSA)" containing attorney (Villafafia) handwritten notes Work product Box #1 P-003681 Thru P-003687 File folder entitled "Dr. Anna Salter" containing attorney (Villafafia) memo to expert witness and handwritten attorney notes Work product Investigative privilege Box #1 P-003688 T

Thru P-009111 File folder entitled "Meeting Timeline" containing typed notes summarizing meetings with opposing counsel prepared at request of R. Alexander Acosta, with handwritten correction and typed guideline estimate Work product Deliberative process Box #2 P-009112 Thru P-009113 11/26/2008 Email fr

dum, and operative portion of 12/19/2007 Sanchez-Acosta letter (P-008328-P- 008343 [not being withheld as

"Serene Cano (N.Y. AUSA)" containing attorney (IIIIII) handwritten notes Work product Box #1 P-003681 Thru P-003687 File folder entitled "Dr. Anna Salter" containing attorney ( ) memo to expert witness and handwritten attorney notes Work product Investigative privilege Box #1 P-003688 Thru P-00

erns. I also would appreciate it if you would send me your e-mail address so that I can send the updated victim log to you via e- mail. Sincerely, R. Alexander Acosta United States Attorney By: Enclosures Assistant United States Attorney Please note that three victims have moved recently. As soon as we have co

log to you via e- mail. Sincerely, R. Alexander Acosta United States Attorney By: Enclosures Assista

d by the Palm Beach Police Department. In light of our discussion, I also have enclosed some information that I found on the internet regarding Dr. Anna Salter, who is an expert in the area of the grooming of sexual abuse victims and "compliant victims"; she also writes on the issue of victims' reluctance t

s terms. I! GOVERNMENT EXHIBIT 1 EFTA00185326 JAMES EISENBERG, ESQ. • JANUARY 24, 2007 PAGE 2 I look forward to your response. Sincerely, R. Alexander Acosta By: Assistant United States Attorney EFTA00185327 United States District Court SOUTHERN DISTRICT OF FLORIDA TO: SUBPOENA TO TESTIFY SUBPOENA

4, 2006 N O approval of 18 U.S.C. § 6001 Immunity for TM i sNAbril 24, 2007 TM Interview Transcript N i31 cember 21, 2007 letter from Lefkowitz to Acosta N gust 11, 2006 victim letter to TM gust 11, 2006 victim letter to CW Epstein appeal letters to CEOS • May 15, 2008 letter from Oosterbaan to Lef

folder entitled (N.Y. AUSA)" containing attorney 1 I handwritten notes Work product Box #1 P-003681 Thru P-003687 File folder entitled "Dr. Anna Salter" containing attorney ( ) memo to expert witness and handwritten attorney notes Work product Investigative privilege Box #1 P-003688 Thru P-00

erns. I also would appreciate it if you would send me your e-mail address so that I can send the updated victim log to you via e-mail. Sincerely, R. Alexander Acosta Enclosures Assistant United States Attorney EFTA00177460 FINAL VICTIM NOTIFICATION LOG Victim Name and Contact Info Attorney Name and Contact

log to you via e-mail. Sincerely, R. Alexander Acosta Enclosures Assistant United States Attorney EF

d by the Palm Beach Police Department. In light of our discussion, I also have enclosed some information that I found on the internee regarding Dr. Anna Salter, who is an expert in the area of the grooming of sexual 'Please note that three victims have moved recently. As soon as we have correct contact inf

09111 File folder entitled "Meeting Timeline" containing Villafafia typed notes summarizing meetings with opposing counsel prepared at request of R. Alexander Acosta, with handwritten correction and typed guideline estimate Work product Deliberative process Box #2 P-009112 Thru P-009113 11/26/2008 Email fr

dum, and operative portion of 12/19/2007 Sanchez-Acosta letter (P-008328-P- 008343 [not being withheld as

erene Cano (N.Y. AUSA)" containing attorney (Villafana) handwritten notes Work product Box #1 P-003681 Thru P-003687 File folder entitled "Dr. Anna Salter" containing attorney (Villafana) memo to expert witness and handwritten attorney notes Work product Investigative privilege Box #1 P-003688 Th

/25/07 Sloman Itr to Davis; 11/8/07 Lefkowitz to Sloman; 11/13/07 Sloman to Lefkowitz (was this sent?); 11/28/07 Starr to Fisher; 11/29/07 Starr to Acosta; 11/30/07 Acosta to Lefkowitz; 12/4/07 Acosta to Starr; 12/5/07 Starr to Acosta; 12/6/07 Sloman to Lefkowitz; 12/7/07 Sanchez to Sloman; 12/7/07 Sta

berger OLY-46 & 0LY-47 (file folder) Box 19: Research re JE websites (file folder) Victim Civil Suits (file folder) NY AUSA) - (file folder) Dr. Anna Salter (file folder) Interview (file folder) Research re Travel for Prostitution (file folder) Transcript (empty file folder) (green file folder) PBPD