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

Inherent Power to Release; Proper Victim's Petition; CVRA-authorized release; Material Severable Box #3 P-012089 Thru P-012129 United States' Response to Motion of Jeffrey Epstein to Intervene and to Quash Grand Jury Subpoenas and Cross-Motion to Compel 6(e) Inadequate Log; No Factual Underpinnings; Fiduciar

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

Esq. in Support of Motion of Jeffrey Epstein to Intervene and to Quash Grand Jury Subpoenas 6(e) Box #3 P-012089 Thru P-012129 United States' Response to Motion of Jeffrey Epstein to Intervene and to Quash Grand Jury Subpoenas and Cross-Motion to Compel 6(e) Box #3 P-012130 Thru P-012150 Declaration of J

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

rt Inherent Power to Release; Proper Victim's Petition; CVRA-authorized release; Material Severable Box #3 P-012089 Tin P412129 United States' Response to Motion of Jeffrey Epstein to Intervene and to Quash Grand Jury Subpoenas and Cross-Motion to Compel 6(e) Inadequate Log; No Factual Underpinnings; Fiduciar

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

Esq. in Support of Motion of Jeffrey Epstein to Intervene and to Quash Grand Jury Subpoenas 6(e) Box #3 P-012089 Thru P-012129 United States' Response to Motion of Jeffrey Epstein to Intervene and to Quash Grand Jury Subpoenas and Cross-Motion to Compel 6(e) Box #3 P-012130 Thru P-012150 Declaration of J

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

Esq. in Support of Motion of Jeffrey Epstein to Intervene and to Quash Grand Jury Subpoenas 6(e) Box #3 P-012089 Thru P-012129 United States' Response to Motion of Jeffrey Epstein to Intervene and to Quash Grand Jury Subpoenas and Cross-Motion to Compel 6(e) Box #3 P-012130 Thru P-012150 Declaration of J

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 °

-sq. in Support of Motion of Jeffrey Epstein to Intervene and to Quash Grand Jury Subpoenas 6(e) Box #3 P-012089 Thru P-012129 United States' Response to Motion of Jeffrey Epstein to Intervene and to Quash Grand Jury Subpoenas and Cross-Motion to Compel 6(e) Box #3 P-012130 Thru P-012150 Declaration o i

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

Esq. in Support of Motion of Jeffrey Epstein to Intervene and to Quash Grand Jury Subpoenas 6(e) Box #3 P-012089 Thru P-012129 United States' Response to Motion of Jeffrey Epstein to Intervene and to Quash Grand Jury Subpoenas and Cross-Motion to Compel 6(e) Box #3 P-012130 Thru P-012150 Declaration of J

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

Esq. in Support of Motion of Jeffrey Epstein to Intervene and to Quash Grand Jury Subpoenas 6(e) Box #3 P-012089 Thru P-012129 United States' Response to Motion of Jeffrey Epstein to Intervene and to Quash Grand Jury Subpoenas and Cross-Motion to Compel 6(e) Box #3 P-012130 "Him P-012150 Declaration of J

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

Esq. in Support of 6(e) Motion of Jeffrey Epstein to Intervene and to Quash Grand Jury Subpoenas Box #3 P-012089 Thru P-012129 United States' Response to Motion of Jeffrey Epstein to Intervene and to Quash Grand Jury Subpoenas and Cross-Motion to Compel 6(e) Box #3 P-012130 Thru P-012150 Declaration of