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

uthorized release; Material Severable Box #3 P-012171 Thru P-012173 Supplement to Ex Parte Declaration Number One in Support of United States' Response to Motion to Quash Subpoenas 6(e) Investigative Privilege Also contains information subject to privacy rights of victims who are not parties to this litigation Inadequate

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

uthorized release; Material Severable Box #3 P-012171 Thru P-012173 Supplement to Ex Parte Declaration Number One in Support of United States' Response to Motion to Quash Subpoenas 6(e) Investigative Privilege Also contains information subject to privacy rights of victims who are not parties to this litigation Inadequate

unction of the grand jury. WHEREFORE, the United States respectfully requests that the aforementioned documents be sealed. Respectfully submitted, R. ALEXANDER ACOSTA UNITED STATES ATTORNEY By: Assistant United States Attorney gusdoj.gov Florida Bar No. 500 South Australian Avenue, Suite 400 West Palm Beac

be sealed. Respectfully submitted, R. ALEXANDER ACOSTA UNITED STATES ATTORNEY By: Assistant United

rey Epstein to Intervene and to Quash Grand Jury Subpoenas and Cross-Motion to Compel, Ex Parte Declaration Number One in Support of United States' Response to Motion to Quash Subpoenas, the Declaration of and the Ex Parte Declaration Number Two in Support of United States' Response to Motion to Quash Subpoenas for the following re