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

sel, Executive Office for United States Attorneys, and Benjamin Greenberg, First Assistant U.S. Attorney, Southern District of Florida, regarding Formal Notice of Office-wide Recusal of Southern District of Florida dated August 24 and August 29, 2011 Attorney-Client Privilege No Factual Underpinnings; Fiduciary Du

06) 9/13/2006 Subpoena to Good Samaritan Hospital (return date 9/22/06) 9/21/2006 Subpoena to The Dalton School (return date 9/29/09) 9/26/2006 Acosta, Mulvihill, Sloman, Nom, Waters , Lowrie ' Stefin, Atkinson, Garcia, Brown, Boscovich, Martinez Villafana Memo regarding changes to Child Ex

avery (return date 5/29/07) 59 5/22/2007 Andrew Lourie Gerald B. Lefcourt Letter requesting to meet with Matthew Menchel and Jeffrey Sloman and Alex Acosta prior to an indictment being filed 28 5/22/2007 Matthew Menchel and Jeff Sloman; cc: A. Marie Villafaiia . Andrew Loune Email re letter recei

Jeff Sloman regarding inquiries from State Attorney's Office regarding Epstein plea to state charge and facts supporting state plea 12/21/2007 It Alexander Acosta Jay Lefkowitz Knowledge of "list" of alleged victims is limited. Proposal deprives Epstein of his opportunity to test the validity of these women'

), Robert O'Neill (U.S. Attorney, MDFL), Benjamin Greenberg (FAUSA, l)1,1.), and Lee Bentley (FAUSA, MDFL) Richard Sudder Email regarding Formal Notice of Office-wide Recusal of Southern District of Florida. Cc's David Margolis (ODAG), Jay Macklin (USAEO), Thomas Anderson (USAEO), Tapken (USAEO), and James

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

nsel, Executive Office for United States Attorneys, and Benjamin Greenberg, First Assistant U.S. Attorney, Southern District of Florida, regarding Formal Notice of Office-wide Recusal of Southern District of Florida dated August 24 and August 29, 2011 Attorney-Client Privilege Box #3 P-013252 Thru P-013253 Emai

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

sel, Executive Office for United States Attorneys, and Benjamin Greenberg, First Assistant U.S. Attorney, Southern District of Florida, regarding Formal Notice of Office-wide Recusal of Southern District of Florida dated August 24 and August 29, 2011 Attorney-Client Privilege No Factual Underpinnings; Fiduciary Du

Sloman regarding inquiries from State Attorney's Office regarding Epstein plea to state charge and facts supporting state plea 12/21/2007 11. Al Acostaer exand Jay Lefkowitz Knowledge of "list" of alleged victims is limited. Proposal deprives Epstein of his opportunity to test the validity of these

e handling of the investigation by the State Attorney's Office 1/3/2008 I :.mails between Marie Villafatia, Alex Acosta, and Jeff Sloman regarding Alex Acosta telephone conference with Jay Lefkowitz where Lefkowitz admitted that he never intended to have Epstein plead guilty to an offense that required se

ttorneys also falsely accused FAUSA Sloman (and me) of promising money to a victim in exchange for her willingness to accuse Epstein. U.S. Aftorney R. Alexander Acosta (now Secretary of the U.S. Department of Labor): USA Acosta served as the head of the U.S. Attorney's Office throughout the investigation of Jeffre

FL), Robert O'Neill (U.S. Attorney, MDFL), Benjamin Greenberg (FAUSA, SDFL), and Lee Bentley (FAUSA, MDFL) Richard Sudder Email regarding Formal Notice of Office-wide Recusal of Southern District of Florida. Cc's David MSODAG), Jay Macklin (USAEO), Thomas Anderson (USAEO), Tapken (USAEO), and James Read (US

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

nsel, Executive Office for United States Attorneys, and Benjamin Greenberg, First Assistant U.S. Attorney, Southern District of Florida, regarding Formal Notice of Office-wide Recusal of Southern District of Florida dated August 24 and August 29, 2011 Attorney-Client Privilege Box #3 P-013252 Thru P-013253 Emai

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

vilege General Counsel, Executive Office for United States Attorneys, and First Assistant U.S. Attorney, Southern District of Florida, regarding Formal Notice of Office-wide Recusal of Southern District of Florida dated `Au • ust 24 and Au• ust 29.2011 Box #3 P-013252 Thru P-013253 Emails between , Assistant

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 °

vilege General Counsel, Executive Office for United States Attorneys, and First Assistant U.S. Attorney, Southern District of Florida, regarding Formal Notice of Office-wide Recusal of Southern District of Florida dated August 24 and August 29 2011 Box #3 P-013252 Thru P-013253 Emails between , Assistant Att

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

vilege General Counsel, Executive Office for United States Attorneys, and First Assistant U.S. Attorney, Southern District of Florida, regarding Formal Notice of Office-wide Recusal of Southern District of Florida dated August 24 and Au l011 Box #3 P-013252 Thru P-013253 Emails between Assistant Attorney-Cli

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

nsel, Executive Office for United States Attorneys, and Benjamin Greenberg, First Assistant U.S. Attorney, Southern District of Florida, regarding Formal Notice of Office-wide Recusal of Southern District of Florida dated August 24 and August 29, 2011 Attorney-Client Privilege Box #3 P-013252 Thru P-013253 Emai