Epstein Secrets

y wanted to argue -- they, being defense 13 counsel, wanted to argue why we should not pursue this case. 14 Q And in this case, it was Starr and Lefkowitz from 15 Kirkland & Ellis, and Lilly Ann Sanchez, I believe who met 16 with you. 17 A Fair. I remember it was Starr and Lefkowitz. I 18 don't

y wanted to argue -- they, being defense 13 counsel, wanted to argue why we should not pursue this case. 14 Q And in this case, it was Starr and Lefkowitz from 15 Kirkland & Ellis, and Lilly Ann Sanchez, I believe who met 16 with you. 17 A Fair. I remember it was Starr and Lefkowitz. I 18 don't

y wanted to argue -- they, being defense 13 counsel, wanted to argue why we should not pursue this case. 14 Q And in this case, it was Starr and Lefkowitz from 15 Kirkland & Ellis, and Lilly Ann Sanchez, I believe who met 16 with you. 17 A Fair. I remember it was Starr and Lefkowitz. I 18 don't

and & Ellis, and Lilly Ann Sanchez, I believe who met 16 with you. 17 A Fair. I remember it was Starr and Lefkowitz. I 18 don't know if it was Lilly Ann. 19 Q All right, and our information is it was you, Drew 20 Oosterbaan, Sloman, , and John MacMillan. Do you -- 21 do you know John MacMillan?

and & Ellis, and Lilly Ann Sanchez, I believe who met 16 with you. 17 A Fair. I remember it was Starr and Lefkowitz. I 18 don't know if it was Lilly Ann. 19 Q All right, and our information is it was you, Drew 20 Oosterbaan, Sloman, , and John MacMillan. Do you -- 21 do you know John MacMillan?

and & Ellis, and Lilly Ann Sanchez, I believe who met 16 with you. 17 A Fair. I remember it was Starr and Lefkowitz. I 18 don't know if it was Lilly Ann. 19 Q All right, and our information is it was you, Drew 20 Oosterbaan, Sloman, , and John MacMillan. Do you -- 21 do you know John MacMillan?

ty that was going through to come up 9 with a federal plea, but eventually she and the defense 10 attorney who is most actively working on this, Jay Lefkowitz, 11 turn back to the NPA, and if you look at 17d, just to make 12 the sort of staffing clear, you know, of course 13 has left, is going on vac

ty that was going through to come up 9 with a federal plea, but eventually she and the defense 10 attorney who is most actively working on this, Jay Lefkowitz, 11 turn back to the NPA, and if you look at 17d, just to make 12 the sort of staffing clear, you know, of course 13 has left, is going on vac

ty that was going through to come up 9 with a federal plea, but eventually she and the defense 10 attorney who is most actively working on this, Jay Lefkowitz, 11 turn back to the NPA, and if you look at 17d, just to make 12 the sort of staffing clear, you know, of course 13 has left, is going on vac

ce e-mails attached Suppl. Box 3 P-013847 Thru P-013849 E-mail to and September 18, 2007, 11:43 , RE: Draft Agreements?, with e-mail from Jay Leflcowitz (September 18, 2007, 11:09 M. attached Atty work-product Suppl. Box 3 P-013850 E-mail, to Alex Acosta and September 18, 2007, 9:31 RE: Epste

torney handwritten notes Attorney-Client Privilege Work Product Suppl. Box #3 P-013334 Thru P-013337 File folder entitled "11/13/07 Sloman to Lefkowitz (was this sent?" containing draft 11/13/07 letter from responding to J. Lefkowitz's letter Attorney-Client Privilege Work Product Page 2 of 14

P-013334 Thru P-013337 File folder entitled "11/13/07 Sloman to Lefkowitz (was this sent?" containing draft 11/13/07 letter from responding to J. Lefkowitz's letter Attorney-Client Privilege Work Product Page 2 of 14 EFTA00185415 Case 9:08-cv-80736-KAM Document 216-1 Entered on FLSD Docket 07/27/20

P-013872 E-mailil and p.m., FW: Lefcourt to Sanchez a 22, to Matthew ■ Any work-product May 22, 2007, 3:11 a Mi l with e-mail from , and Lilly Ann 2007 2:05 p.m. attached Suppl. Box 3 P-013873 E-mail 2007, 10:52 . e-mail from (May 14 2007 10:38 to and May 14, Any work-product RE: Oper

ter with attached 8/15/08 emails from A. Marie Villafafla to A. Acosta, J. Sloman, R. Senior, K. Atkinson, D. Lee re Agreement; 8/15/08 email from J. Lefkowitz to A. Marie Villafana, K. Atkinson, IL Black, M. Weinberg re Agreement; 8/14/08 emails from A. Marie Villafafla to J. Lefkowitz, K. Atkinson, R.

rch 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 Alice S. Fisher, and a November 29, 2007 letter Erom Jay Lefkowitz to IL Alexande

ainst Public Prosecutor; Overriding Need; Attorney Conduct at Issue Suppl. Box #3 P413338 Thru 013341 File folder entitled "12/6/07 Sloman to Lefkowitz" containing 12/5/07 faxed letter w/ cover sheet from K. Starr and J. Lefkowitz to A. Acosta [Not considered privileged. Will be produced to oppo

(May 23, 2007, 5:00 p.m.), Andrew Lourie to Gerald Lefcourt (May 22, 2007, 6:32 p.m.), and Gerald Lefcourt to Andrew Lourie Marie Villafana, and Lilly Ann Any work-product Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Waiver, Claims Against Public Prosecutor; Overriding Need; Attorney C

to confer with your co-counsel regarding this• matter. Although the language of Paragraph 8 could be so construed, our First Assistant informed Mr. Lefkowitz some weeks ago that this was not our position. As Mr. Lefkowitz has noted, were Mr. Epstein convicted at trial, the plaintiff-victims in a subsequen

lf, Professor Dershowitz, former United States Attorney Guy Lewis, Ms. Lilly Ann Sanchez and Messrs. Roy Black, Jack Goldberger, Gerry Lefcourt and Jay Lefkowitz had the opportunity to review and raise objections to the terms of the Agreement. Again, no one raised objections to the Section 2255 language. Si

Jul 1 2007, meetin between FAUSA „ Criminal Chief West Palm Beach Chief AUSA • and two FBI agents who met with Roy Black, Gerald Lefcourt, and Lilly Ann anchez. On at ate, the prosecutors presented a written, four-bullet-point term sheet that would satisfy the federal interest in the case and discus

cy to commit an assault on I plane. I just want to make sure that we have something that is factually accurate. Just trying to plan ahead" (id.). At Jay Lefkowitz's request, MAUSA and I scheduled conference call with him for early on the morning of September 14, 2007 (id. at 25). Mr. did not attend the confere

After correspondence with Roy Black and I telephone conference with Mr. Black and Jay Leflcowitz, we were advised that USA Acosta had informed Mr. Lefkowitz31 that Epstein could be considered for any Erogram that was available to other prisoners. At that point, I was unable to press forward with I breach,

gued above, but I will try to collect them into general categories in chronological order. 1. b. I did not want to meet with counsel for Epstein (Lilly Ann and Gerald Lefcourt) prior to completi.n investigation. My co-counsel agreed with me. Our supervisor, M, overruled us. and I did not want to h

2009) 06/04/2009 41 MOTION for Limited Appearance, Consent to Designation and Request to Electronically Receive Notices of Electronic Filings for Jay P. Lefkowitz, Filing Fee $75.00, Receipt #725904. (cw) (Entered: 06/04/2009) 06/04/2009 42 REPLY to Response to Motion re (113 in 9:08-cv-80119-KAM) Plaintiff'

4 EFTA00226977 Email: [email protected] Jav P Lefkowitz [COR LD NTC] Kirkland & Ellis 655 15TH Street

Marra on 7/20/2010. (ir) (Entered: 07/20/2010) 09/02/2010 NOTICE of Attorney Appearance by Lilly Ann Sanchez on behalf of Jeffrey Epstein (Sanchez, Lilly Ann) (Entered: 09/02/2010) EFTA00226950 09/02/2010 213 Defendant's MOTION for Hearing Jeffrey Epstein's Request for Oral Argument in Connection wit

will keep the defense on a strict timeline. Before this counter-offer, I was going to propose that we include in our response to Messrs. Starr and Lefkowitz one page of the draft overt acts section. I have attached the proposed overt acts related to two of the girls, as an example. Wert acts Insert.wp

ntion a couple of things that I hoped to talk to you about. There are two things that I think might lx tricks up the sleeves of the defense. First, Lilly Ann had mentioned in our Miami meeting with all the defense attorneys that Epstein would be willing to do a split sentence of community control followe

2918 Robert Deweese Critton, Jr [COR LD NTC] Burman Critton Luttier & Coleman 303 Banyan Boulevard Suite 400 West Palm Beach, FL, USA 33401-2918 Lefkowitz, Jay P [COR LD NTC] Kirkland & Ellis 655 15TH Street NW Suite 1200 Washin•ton DC USA 20005 Shumsky, Michael D [COR LD NTC] Kirkland & Ellis Con

of Law University of Utah 332 South 1400 East Room 101 Salt Lake City, UT, USA 68333 <i>pro Hac Vice</ I> Email: DEFENDANT ATTORNEY(S): Sanchez, Lilly Ann [COR LD NTC] Fowler White Burnett 1395 Brickell Avenue 14TH Floor Miami, FL, USA 33131-3302 Fax: Email: Goodner, Helaine S [COR LD NTC] Fowler

will keep the defense on a strict timeline. Before this counter-offer, I was going to propose that we include in our response to Messrs. Starr and Lefkowitz one page of the draft overt acts section. I have attached the proposed overt acts related to two of the girls, as an example. Overt acts insert.w

ntion a couple of things that I hoped to talk to you about. There arc two things that I think might be tricks up the sleeves of the defense. First, Lilly Ann had mentioned in our Miami meeting with all the defense attorneys that Epstein would be willing to do a split sentence of community control followe

TA00009351 --- PAGE BREAK --- Page 124 1 believe you had any understanding of what amount of jail time 2 was in play at this point when tells Lilly Ann 3 Sanchez -- 4 5 6 7 8 9 A I can't pinpoint that timeline -- Q All right. A -- to that degree. Q All right. A Of accuracy. Q He als

TA00009351 --- PAGE BREAK --- Page 124 1 believe you had any understanding of what amount of jail time 2 was in play at this point when tells Lilly Ann 3 Sanchez -- 4 5 6 7 8 9 A I can't pinpoint that timeline -- Q All right. A -- to that degree. Q All right. A Of accuracy. Q He als

TA00009351 --- PAGE BREAK --- Page 124 1 believe you had any understanding of what amount of jail time 2 was in play at this point when tells Lilly Ann 3 Sanchez -- 4 5 6 7 8 9 A I can't pinpoint that timeline -- Q All right. A -- to that degree. Q All right. A Of accuracy. Q He als

tions with the defense team. 16 Q In the sense that you only met with the defense 17 team for the first time in the person of Ken Starr and Jay 18 Lefkowitz and company on the 7th of September. 19 A And it wasn't the 7th of -- yeah, the 7th of -- 20 Q The 7th of September. 21 A -- September. 22

irst time in the person of Ken Starr and Jay 18 Lefkowitz and company on the 7th of September. 19 A And

irst time in the person of Ken Starr and Jay 18 Lefkowitz and company on the 7th of September. 19 A And

tions with the defense team. 16 Q In the sense that you only met with the defense 17 team for the first time in the person of Ken Starr and Jay 18 Lefkowitz and company on the 7th of September. 19 A And it wasn't the 7th of -- yeah, the 7th of -- 20 Q The 7th of September. 21 A -- September. 22

irst time in the person of Ken Starr and Jay 18 Lefkowitz and company on the 7th of September. 19 A And

tions with the defense team. 16 Q In the sense that you only met with the defense 17 team for the first time in the person of Ken Starr and Jay 18 Lefkowitz and company on the 7th of September. 19 A And it wasn't the 7th of -- yeah, the 7th of -- 20 Q The 7th of September. 21 A -- September. 22