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

; No Factual Underpinnings; Fiduciary Duty; Court Compelled Disclosure; Factual Materials; Waiver Box #3 P-013248 Thru P-013251 Emails between Richard Sudder, Assistant General Counsel, Executive Office for United States Attorneys, and Benjamin Greenberg, First Assistant U.S. Attorney, Southern Distric

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'

Letter from Acosta re Epstein case 7/29/2011 ViIlafaria Lefkowitz Letter in response to 7/27/11 letter from Villafatia 8/1/2011 Emails between Richard Sudder, Assistant General Counsel, Executive Office for United States Attorneys, and Benjamin Greenberg, First Assistant U.S. Attorney, Southern District

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

y Sloman to Office of Professional Responsibility re Self Reporting with attachments Privacy Act Box #3 P-013248 Thru P-013251 Emails between Richard Sudder, Assistant General Counsel, Executive Office for United States Attorneys, and Benjamin Greenberg, First Assistant U.S. Attorney, Southern District

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

; No Factual Underpinnings; Fiduciary Duty; Court Compelled Disclosure; Factual Materials; Waiver Box #3 P-013248 Thru P-013251 Emails between Richard Sudder, Assistant General Counsel, Executive Office for United States Attorneys, and Benjamin Greenberg, First Assistant U.S. Attorney, Southern Distric

supplemental privilege log (DE 216-1), with regard to Suppl. Box #3 P-013342 to P-013350. The entry reads: "File folder entitled '12/05/07 Stan• to Acosta' containing drafts of 11/30/07 letters from A. Acosta to K. Starr and from J. Sloman to J. Lefkowitz re performance and victim notification with ha

arlong assault on the prosecution and the prosecutors." Shortly thereafter, Jeffrey Epstein's defense attorney Roy Black sent a responsive letter to Alexander Acost's letter to the news media in which he claimed that he did not pry into the personal lives of prosecutors but merely pointed out misconduct and over-

elephone logs, photographs, emails or statement(s) of other credible sources) about a personal or business relationship between Jeffrey Epstein and Alex Acosta. UNITED STATES RESPONSE: Denied 22. The Justice Department's Office of Professional Responsibility and/or other Government entities have collected

discussed or determined existed for the USAO SDFL...." The government's privilege log clearly references e-mails between Assistant General Counsel Richard Sudder, Executive Office for United States Attorneys, and First Assistant U.S. Attorney Benjamin Greenberg, "regarding Formal Notice of Office-wide Recusal

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

Letter from Acosta re Epstein case 7/29/2011 Villafalia Lefkowitz Letter in response to 7/27/11 letter from Villafafia 8/1/2011 Emails between Richard Sudder, Assistant General Counsel, Executive Office for United States Attorneys, and Benjamin Greenberg, First Assistant U.S. Attorney, Southern District

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

Sloman to Office of Professional Responsibility re Self Reporting with attachments Privacy Act Box #3 P-013248 Thru P-013251 Emails between Richard Sudder, Assistant General Counsel, Executive Office for United States Attorneys, and Benjamin Greenberg, First Assistant U.S. Attorney, Southern District

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

y Sloman to Office of Professional Responsibility re Self Reporting with attachments Privacy Act Box #3 P-013248 Thru P-013251 Emails between Richard Sudder, Assistant General Counsel, Executive Office for United States Attorneys, and Benjamin Greenberg, First Assistant U.S. Attorney, Southern District