Epstein Secrets

. Weinberg re Agreement; 8/14/08 emails from A. Marie Villafafia to J. Lefkowitz, K. Atkinson, R. Black re interpretation of Agreement; email from J. Lefkowitz to A. Marie Villafafia, K. Atkinson re questions re Agreement; email from A. Marie Villafafia to J. Lefkowitz, K. Atkinson re production of Agreem

P-013279 Thru P-013280 8/15108 Emails between A. Acosta and A. Marie Villafafia, R. Senior, D. Lee and K. Atkinson re proposed correspondence to Jay Lefkowitz Attorney-Client Privilege Work Product Suppl. Box #3 P-013281 Handwritten note re Epstein investigation Attorney-Client Privilege Work Product

response to letter Attorney-Client Privilege Work Product Suppl. Box #3 P-013326 Thru P-013329 File folder entitled "9/17/07 Villafafia to Lefkowitz containing 9/17/07 e-mail from A. Marie Villafafia to R. Garcia, A. Lourie and from R. Garcia to A. Marie Villafafia concerning status of plea neg

hru P-013337 File folder entitled "11/13/07 Sloman to Lefkowitz (was this sent?)" containing draft 11/13/07 letter from J. Sloman responding to J. Lefkowitz's letter Attorney-Client Privilege Work Product Page 2 of 14 EFTA00209309 Case 9:08-cv-80736-KAM Document 216-1 Entered on FLSD Docket 07/27/20

ts of victims who are not parties to this litigation Suppl. Box #3 P-013282 Thru P-013283 7/9/08 Email from A. Marie Villafafia to A. Acosta, J. Sloman, K. Atkinson, and FBI re proposed response to Goldberger letter re victim notification Attorney-Client Privilege Work product Deliberative Proce

led "Rsrch re Crime Victims Rights" containing attorney research, handwritten notes, draft victim notification letter, and draft correspondence to Jay Leflcowitz (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. Alexande

telephone Work Product 6(e) 57 11/28/2007 correspondence between Marie Villafafta, Andrew Lourie, Drew Oosterbaan, and Rolando Garcia regarding Lefkowitz 11/27/2007 email discussing presentation to DAAG Work Product Deliberative Process 58 11/19/2007-11/28/2007 emails between Marie Villafafla, N

u P-013337 File folder entitled "I 1/13/07 Sloman to Lefkowitz (was this sent?)" containing draft 11/13/07 letter from J. Sloman responding to J. Lefkowitz's letter Attorney-Client Privilege Work Product Page 2 of 14 EFTA00191251 Bates Range Description Privilege(s) Asserted Suppl. Box #3 P-013

M. Weinberg re Agreement; 8/14/08 emails from A. Marie Villafana to J. Lefkowitz, K. Atkinson, R. Black m interpretation of Agreement; email from J. Lefkowitz to A. Marie Villafana, K. Atkinson re questions it Agreement; email from A. Marie Villafana to J. Lefkowitz, K. Atkinson re production of Agreemen

ts of victims who are not parties to this litigation Suppl. Box #3 P-013282 Thru P-013283 7/9/08 Email from A. Marie Villafafia to A. Acosta, J. Sloman, K. Atkinson, and FBI re proposed response to Goldberger letter re victim notification Attorney-Client Privilege Work product Deliberative Proce

U.S. Department of Justice Washington, D.C. 2053U June 23, 2008 Jay Lefkowitz, Esq. Kenneth Starr, Esq. Kirkland and Ellis LLP Gentlemen: This Office has completed a thorough review of the U.S. Attorney's handling of the ma

stice Washington, D.C. 2053U June 23, 2008 Jay Lefkowitz, Esq. Kenneth Starr, Esq. Kirkland and Ellis LL

novo review of the investigation and facilitated such review at the highest levels of the Department of Justice. " Tab 1, May 19, 2008 Letter from J. Sloman, p. 5,1 3. The Truth: • CEOS' review, concluded in May 2008, was neither independent nor de nova o CEOS' review was not "independent:" • who co

ct that Bert Ocariz is a friend of my boyfriend and that I have a "longstanding relationship" with Mr. Ocariz. RFP MIA 000464 EFTA00208945 • • JAY P. LEFKOWITZ, ESQ. DECEMBER 13, 2007 PAGE 2 OF 5 I informed you that I selected Mr. Ocariz because he was a friend and classmate of two people whom I respecte

es." See Tab 37, February 27, 2008 Email from J. Again, that claim was utterly false; Mr. Thomas's contemporaneous hand-written notes, reviewed by Jay Lefkowitz, confirm that the USAO had violated settled Department policy and ethical rules by providing case-specific information about the Department's legal

n's attorneys stating that "I intend to notify the victims by letter after COB Thursday [two days later]." See Tab 34, November 27, 2007 Email from J. Sloman to J. Lelkowitz. 42. The morning of November 28, attorneys for Mr. Epstein faxed a letter to Assistant Attorney General Alice Fisher, requesting a

U.S. Department of Justice United States Attorney Southern District of Florida DELIVERY BY FACSIMILE Jay P. Lefkowitz, Esq. Kirkland & Ellis LLP Citigroup Center 153 East 53rd Street New York, New York 10022-4675 Re: Jeffrey Epstein Dear Jay: 300 S. Australia

istrict of Florida DELIVERY BY FACSIMILE Jay P. Lefkowitz, Esq. Kirkland & Ellis LLP Citigroup Center 15

the Government's previously made representation that it is not vouching for the veracity of any claim by any identified individual. See Letter from J. Sloman to E. Davis (10/25/07). Second, please note also that we do not understand your request that Mr. Epstein and his attorneys execute the rider / ackn

oman. Each of Mr. Epstein's attorneys, including Roy Black, Gerald Lefcourt, Alan Dershowitz, Alan Dershowitz's brother, Nat Dershowitz, Ken Starr, Jay Lefkowitz, Lilly Sanchez, Jack Goldberger, Bruce Lyons, Martin Weinberg, Stephanie Thacker, Guy Lewis, Mike Tein, Joe Whitley and Herb Rosen, have expressed

howitz's brother, Nat Dershowitz, Ken Starr, Jay Lefkowitz, Lilly Sanchez, Jack Goldberger, Bruce Lyons, Ma

sel, confirming that "I understand that the plea and sentence will occur on or before the January 4th [2008] date." See October 31, 2007 Email from J. Sloman to J. Lefkowitz (emphasis added). On November 5, 2007, despite Mr. Sloman's having sent the October 31 email only a week earlier, after learning th

U.S. Department of Justice United States Attorney Southern District of Florida DELIVERY BY FACSIMILE Jay P. Lefkowitz, Esq. Kirkland & Ellis LLP Citigroup Center 153 East 53rd Street New York, New York 10022-4675 Re: Jeffrey Epstein Dear Jay: 500 S. Australia

istrict of Florida DELIVERY BY FACSIMILE Jay P. Lefkowitz, Esq. Kirkland & Ellis LLP Citigroup Center 15

the Government's previously made representation that it is not vouching for the veracity of any claim by any identified individual. See Letter from J. Sloman to E. Davis (10/25/07). Second, please note also that we do not understand your request that Mr. Epstein and his attorneys execute the rider / ackn

ey's December letter. Messrs. Goldberger and Tein are aware of this Declaration and have filed copies of it in connection with their EFTA00183452 JAY P. LEFKOWITZ, ESQ. AUGUST 13, 2008 PAGE 2 OF 2 efforts to stay all of the civil litigation. Again, neither of them ever expressed to me — or to the Court — th

nse. Dear Jay: Assistant U.S. Attome From: Jay Lefkowitz [mailto Sent: Thursda Au ust 14, 2008 2:39 PM

the Government's previously made representation that it is not vouching for the veracity of any claim by any identified individual. See Letter from J. Sloman to E. (10/25/07). Second, please note also that we do not understand your request that Mr. Epstein and his attorneys execute the rider / acknowled

avene the government's commitment to take no position regarding potential claims of government witnesses. See Tab 39, November 28, 2008 Email from J. Lefkowitz to J. Sloman. o The letter cited to an inapplicable statute (the Justice for All Act of 2004) as its justification for being sent. Id. AUSA Acosta

hearing." 2 RFP MIA 000432 EFTA00225659 KIRKLAND & ELLIS LLP Response to Letter by FAUSA Sloman Dated May 19, 2008 In a May 19, 2008 letter to Jay Lelkowitz (See Tab I), SDFL First Assistant U.S. Attorney Jeffrey Sloman provided what purported to be a summary of the events that have occurred during the

ts responsibility to select the attorney representative for the alleged victims to an independent third-party." See Tab I, May 19, 2008 Letter from J. Sloman, p. 4, f.3. The Truth: • That such an assignment was the SDFL's "unilateral" decision is false. Before the SDFL decided to assign selection of th

ent representation that “/T]he SDFL indicated a willingness to defer to the State the length of incarceration...” See Tab 1, May 19, 2008 Letter from J. Sloman, p. 2. This statement is simply not true. Contrary to Mr. Sloman’s assertion, federal prosecutors refused to accept what the State believed to be app

See Tab 37, February 27, 2008 Email from J. Sloman. Again, that claim was utterly false; Mr. Thomas’s contemporaneous hand-written notes, reviewed by Jay Lefkowitz, confirm that the USAO had violated settled Department policy and ethical rules by providing case-specific information about the Department’s legal t