Epstein Secrets

ee, e.g., Ex. L.) In response to Mr. Leflcowitz's ruinous allegations against Jane Doe 2 and myself, on December 13, 2007, I sent a response to Mr. Lefkowitz defending myself and Jane Doe 2. (Ex. 7.) 16. During the course of the suit filed by Jane Doe 1 and Jane Doe 2, the Petitioners have alleged that

LED Docket 06/02/2017 Page 48 of 176 U.S. Department of Justice United States Attorney Southern District of Florida DELIVERY BY ELECTRONIC MAIL Jay P. Lefkowitz, Esq. Kirkland & Ellis LLP Citigroup Center 153 East 53rd Street New York, New York 10022-4675 Re: Jeffrey Epstein Dear Jay: SOO S. Australia

ce Fisher, Assistant Attorney General. (See Ex. B.) I then applied to the Court for an Order compelling Jane Doe 2's testimony. U.S. District Judge Middlebrooks granted the application on April 16, 2007. (Ex. 6.) 12. After learning of Judge Middlebrooks' Order, Mr. Eisenberg asked whether Jane Doe 2 could

led "Rsrch re Crime Victims Rights" containing attorney research, handwritten notes, draft victim notification letter, and draft correspondence to Jay Lefkowitz (Also contains a November 28 2007 letter from Kenneth Starr to , and a November 29, 2007 letter from Jay Lefkowitz to R. Alexander Acosta (P-010

Thru P-009125 12/6/2007 Letter from to Jay P. Lefkowitz re Jeffrey Epstein (victim notification) [pursua

Exhibit 1 at P-003714 thru P- 003721. 11. On April 16, 2007, the Court granted the government's Sealed Motion in a Sealed Order. Exhibit 3. Judge Middlebrooks was the judge who empaneled Federal Grand Jury 07-103. The Sealed Order states, in part, that the "Order shall be SEALED in accordance with Fed. R.

ly Grail" (Ex. F), a "journal" assertedly taken from Epstein's computer and cited by Edwards inn 16-18; correspondence between the U.S. Attorney and Jay Leflcowitz, Esq. (Exs. C and D and 9fq 6, 20, 25) and Lilly Ann Sanchez, Esq. (Ex. L andl 28); a book receipt (Ex. I and 1 22), message pads (Ex. A. 1 24) and

s. Under Florida law, there is no immunity for acts undertaken in judicial proceedings that bear no relation to those proceedings. See, e.g., Levin, Middlebrooks, Mahie, Thomas, Mayes & Mitchell, P.A. v. U.S. Fire Ins. Co., 639 So. 2d 616, 608 (1994). It is for a fact finder to determine whether Edwards' ac

's attorneys used my efforts to provide a victim notification to Jane Doe 2 as evidence of that misconduct. (See, e.g., Ex. 13.) In response to Mr. Lefkowitz's ruinous allegations against Jane Doe 2 and myself, on December 13, 2007, I sent a response to Mr. Lefkowitz defending myself and Jane Doe 2. (Ex.

orney General, approved the request. (See Ex. 10.) I then applied to the Court for an Order compelling Jane Doe 2's testimony. U.S. District Judge Middlebrooks granted the Application on April 16, 2007. (Ex. 11.) II. After receiving Judge Middlebrooks' Order, Mr. Eisenberg then asked whether Jane Doe 2 c

pstein's civil exposure. For example, on October 3, 2007, Assistant U.S. Attorney Marie Villafafia sent an email (attached hereto as Exhibit “D’’) to Jay Lefkowitz, counsel for Epstein, with attached proposed letter to special master regarding handling numerous expected civil claims against Epstein. The letter r

es Attorney's Office prepared negotiated lea agreements containing these charges. For example, in a September 18, 2007, email from AUSA Villafafia to Lefkowitz (attached hereto as Exhibit “H’), she attached the proposed plea agreement describing Epstein’s witness tampering as follows: "UNITED STATES vs. JE

or other tortious behavior, suéh as tortious interference with business relationship, so long as act has some relationship to proceeding, See Levin, Middlebrooks, Mabie, Thomas, Mayes & Mitchell, P.A. v. U.S. Fire Ins. Co., 639 So, 2d 606 (Fla. 1994). The immunity afforded to statements made during the course