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

f Litigation; Claims Against Public Prosecutor; Overriding Need; Attorney Conduct at Issue Box #1 P-003679 Thru P-003680 File folder entitled "Serene Cano (N.Y. AUSA)" containing attorney (Villafafia) handwritten notes Work product Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Not in An

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

File folder entitled "Research re JE Websites" containing attorney research Work product Box #1 P-003679 Thru P-003680 File folder entitled "Serene Cano (N.Y. AUSA)" containing attorney (Villafafla) handwritten notes Work product Box #1 P-003681 Thru P-003687 File folder entitled "Dr. Anna Salt

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

f Litigation; Claims Against Public Prosecutor; Overriding Need; Attorney Conduct at Issue Box #1 P-003679 Thru P-003680 File folder entitled "Serene Cano (N.Y. AUSA)" containing attorney (Villafafia) handwritten notes Work product Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Not in An

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

File folder entitled "Research re JE Websites" containing attorney research Work product Box #1 P-003679 Thru P-003680 File folder entitled "Serene Cano (N.Y. AUSA)" containing attorney (Villafafia) handwritten notes Work product Box #1 P-003681 Thru P-003687 File folder entitled "Dr. Anna Salt

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

File folder entitled "Research re JE Websites" containing attorney research Work product Box #1 P-003679 Thru P-003680 File folder entitled "Serene Cano (N.Y. AUSA)" containing attorney (IIIIII) handwritten notes Work product Box #1 P-003681 Thru P-003687 File folder entitled "Dr. Anna Salter"

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

File folder entitled "Research re JE Websites" containing attorney research Work product Box #1 P-003679 Thru P-003680 File folder entitled "Serene Cano (N.Y. AUSA)" containing attorney (Villafana) handwritten notes Work product Box #1 P-003681 Thru P-003687 File folder entitled "Dr. Anna Salte