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

A-authorized analysis charts, victim/witness who are not parties to this release; Material Severable; Redaction; No photographs, DAVID records, NCICs, and related materials for persons identified as litigation Assertion by Victims Jane Does #15, 16, 17, 18, 19, Past Em lo ees, Misc. Witnesses

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

typed notes, relevant pieces of grand jury materials, telephone records/flight records analysis charts, victim/witness photographs, DAVID records, NCICs, and related materials for persons identified as Jane Does #15, 16, 17, 18, 19, Past Employees, Misc. Witnesses Work product 6(e) Contains infor

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

VRA-authorized analysis charts, victim/witness who are not parties to this release; Material Severable; Redaction; No photographs, DAVID records, NCICs, and related materials for persons identified as litigation Assertion by Victims Jane Does #15, 16, 17, 18, 19, Past Employees, Misc. Witnesses

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

typed notes, relevant pieces of grand jury materials, telephone records/flight records analysis charts, victim/witness photographs, DAVID records, NCICs, and related materials for persons identified as Jane Does #15, 16, 17, 18, 19, Past Employees, Misc. Witnesses Work product 6(e) Contains infor

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

typed notes, relevant pieces of grand jury materials, telephone records/flight records analysis charts, victim/witness photographs, DAVID records, NCICs, and related materials for persons identified as Jane Does #15, 16, 17, 18, 19, Past Employees, Misc. Witnesses Work product 6(e) Contains infor

ates respectfully requests that the Application and any Order related to the Application be sealed. Dated: April 16, 2007 Respectfully submitted, R. ALEXANDER ACOSTA ASSISTANT UNITED STA1 ES A ORNEY Florida Bar No. 500 South Australian Ave, Suite 400 West Palm Beach, Florida 33401 Tel: Fax: Case No. 08-8073

rida West Palm Beach, Florida 33401 Attention: Asstetantlinited States Attorney Re: Grand Jury Investigpuion, terfrey Epstein, et al. Dcar Mr. Acosta: Pursuant to the authority vested in me by 18 U.S.C. § 6003(h) and 28 C.P.R., § 0.175(a), I hereby approve ycur request for authority to apply to °

typed notes, relevant pieces of grand jury materials, telephone records/flight records analysis charts, victim/witness photographs, DAVID records, NCICs, and related materials for persons identified as Jane Does #15, 16, 17, 18, 19, Past Employees, Misc. Witnesses Work product 6(e) Contains infor

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

typed notes, relevant pieces of grand jury materials, telephone records/flight records analysis charts, victim/witness photographs, DAVID records, NCICs, and related materials for persons identified as Jane Does #15, 16, 17, 18, 19, Past Employees, Misc. Witnesses Work product 6(e) Contains infor

tion subject to privacy rights of victims who are not rties to this liti ation Suppl. Box #3 P-013282 Thru P-013283 7/9/08 Email from to A. Acosta, and FBI re proposed response to Goldberger letter re victim notification Attorney-Client Privilege Work product Deliberative Process Suppl. B

status of plea negotiations, draft agreements, and need to confer with victims P-014062 thru P-014068 9/10/2007-9/14/2007 emails between I and Alex Acosta regarding final plea negotiations, finalizing details with State Attorney's Office and final revisions to indictment pack: a Work Product Delibera

typed notes, relevant pieces of grand jury materials, telephone records/flight records analysis charts, victim/witness photographs, DAVID records, NCICs, and related materials for persons identified as Jane Does #9, 10, 11, 12, 13, 14 Work Product Deliberative Process 6(e) Also contains documents

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

typed notes, relevant pieces of grand jury materials, telephone records/flight records analysis charts, victim/witness photographs, DAVID records, NCICs, and related materials for persons identified as Jane Does #15, 16, 17, 18, 19, Past Employees, Misc. Witnesses Work product 6(e) Contains infor

opposing counsel]); subfolder entitled "12/19/07 Acosta-Sanchez Ltr" containing unredacted copies of tha

typed notes, relevant pieces of grand jury materials, telephone records/flight records analysis charts, victim/witness photographs, DAVID records, NCICs, and related materials for persons identified as Jane Does #15, 16, 17, 18, 19, Past Employees, Misc. Witnesses Work product 6(e) Contains infor