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

secutor; Attorney Conduct at Issue; Final Decision; Waiver Suppl. Box 3 P-013947 E-mail, Paul Cassell to Plagenhoef, May 3, 2011,12:23 p.m., RE: OPR Inquiry — request for information, with post-it note attached with handwritten attorney notes on telephone call between Plagenhoef and Howard with Dexter

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

cord, atty work product; deliberative process privilege Suppl. Box 3 P-013947 E-mail, Paul Cassell to Plagenhoef, May 3, 2011, 12:23 p.m., RE: OPR Inquiry — request for infonnation, with post-it note attached with handwritten attorney notes on telephone call between Plagenhoef and Howard with Dexter

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

secutor; Attorney Conduct at Issue; Final Decision; Waiver Suppl. Box 3 P-013947 E-mail, Paul Cassell to Plagenhoef, May 3, 2011,12:23 pan., RE: OPR Inquiry — request for information, with post-it note attached with handwritten attorney notes on telephone call between Plagenhoef and Howard with Dexter

P-013292 File folder entitled "8/14/08 E-mail from Lefk to AMCV" containing (undated) emails from A. Marie Villafafia to R. Senior, J. Sloman, A. Acosta, K. Atkinson, D. Lee re draft response to 8/14/08 email from J. Lefkowitz regarding "the December 2007 proposal" Attorney-Client Privilege Work P

s?, with e-mail from Jay Lefkowitz (September 18, 2007, 11:09 a.m.) attached Atty work-product 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 Sup

cord, atty work product; deliberative process privilege Suppl. Box 3 P-013947 E-mail, Paul Cassell to Plagenhoef, May 3, 2011, 12:23 p.m., RE: OPR Inquiry — request for information, with post-it note attached with handwritten attorney notes on telephone call between Plagenhoef and Howard with Dexter

ion subject to privacy rights of victims who are not arties 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

07, 11:43 a.m., RE: Draft Agreements?, with e-mail from Jay Lefkowitz (September 18, 2007, 11:09 a.m. attached Suppl. Box 3 P-013850 E-mail, to Alex Acosta, , , and September 18, 2007, 9:31 a.m., RE: E stein Ne otiations Atty work-product Suppl. Box 3 P-013851 Thru P-013853 E-mail, to and A

aul 12:23 p.m., information, handwritten between and Cassell to May 3, 2011, atty work product; law enforcement investigatiory record RE: OPR Inquiry — request for with post-it note attached with attorney notes on telephone call and Howard with Suppl. Box 3 P-013948 Thru P-013951 E-mail, t

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

Florida matter Suppl. Box 3 P-013947 E-mail, to May 3, 2011, for atty work product; law enforcement investigatiory record 12:23 p.m., RE: OPR Inquiry — request information, with post-it note attached with handwritten attorney notes on tele 'hone call between and with and Suppl. Box 3 P-0139