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

Invocation; Overriding Need; Claims Against Public Prosecutor; Attorney Conduct at Issue; Waiver Box #3 P-013272 Thru P-013278 Emails between Peter Mason, Executive Office for United States Attorneys, and Dexter Lee, Southern District of Florida, seeking advice regarding office-wide recusal, dat

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

2011, with attached memorandum from A. Marie Villafafia to Benjamin Greenberg summarizing Jeffrey Epstein Investigation Box #3 Emails between Peter Mason, Executive Office Attorney-Client Privilege P-013272 Thru for United States Attorneys, and Dexter Lee, Southern District of Florida, seeking adv

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

Invocation; Overriding Need; Claims Against Public Prosecutor; Attorney Conduct at Issue; Waiver Box #3 P-013272 Thru P-013278 Emails between Peter Mason, Executive Office for United States Attorneys, and Dexter Lee, Southern District of Florida, seeking advice regarding office-wide recusal, dated

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

Recusal of Southern District of Florida, dated August 24 and August 29, 2011." D.E. 212-1 at 22. Further, the privilege log detailed cmails between Peter Mason, Executive Office for United States Attorneys, and Assistant U.S. Attorney Dexter Lee, "seeking advice regarding office-wide mensal, dated December

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

2011, with attached memorandum from A. Marie Villafafia to Benjamin Greenberg summarizing Jeffrey Epstein Investigation Box #3 Emails between Peter Mason, Executive Office Attorney-Client Privilege P-013272 Thru for United States Attorneys, and Dexter Lee, Southern District of Florida, seeking adv

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

2011, with attached memorandum from A. Marie Villafafla to Benjamin Greenberg summarizing Jeffrey Epstein Investigation Box #3 Emails between Peter Mason, Executive Office Attorney-Client Privilege P-013272 Thru for United States Attorneys, and Dexter Lee, Southern District of Florida, seeking adv