Epstein Secrets

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

llafafia regarding letter received from Lilly Ann Sanchez Work Product Deliberative Process 49 3/19/2008-3/27/2008 emails between Jeff Sloman, Bob Senior, Karen Atkinson, Rolando Garcia, Nesbitt Kurykendall, and Jason Richards regarding waiting for DC's decision regarding Epstein's challenges to NP

lead until the Deputy Attorney General's Office (DAG) completed its review. See Exhibit 9, May 28, 2008 Email from Assistant U.S. Attorney Sloman to J. Lefkowitz. EFTA00234494 Ms. A. Maric Villafana, Esq. June 19, 2009 Page 4 • A final letter of determination was not issued by the Department of Justice

KIRKLAND & ELLIS LLP AND AIIILIATLD PAItTNERSHIPS Jay P. Lefkowitz, P.C. To ail iictly: [email protected] VIA FEDERAL EXPRESS Citigroup Center 153 East 53rd Street New York. New York 10022-4811 Ms. A. Ma

& ELLIS LLP AND AIIILIATLD PAItTNERSHIPS Jay P. Lefkowitz, P.C. To ail iictly: [email protected] V

reviewed this very matter with you and other individuals in your Office in November 2008. At that time, Mr. Roy Black met with you, Karen Atkinson, Bob Senior, and Jeffrey Sloman in Miami to review the work release issue. Among other significant documents shown to you, we presented you with your own email

on P-014277 thru P-014282 11/2/2007-11/5/2007 emails between Marie Villafafia and Jeff Sloman regarding drafting 11/5/2007 letter from Sloman to Lefkowitz Work Product Deliberative Process P-014283 thru P-014284 11/5/2007-11/7/2007 emails from Marie Villafaila to Jeff Sloman inquiring about statu

14354 11/29/2007-12/1/2007 emails between Marie Villafafia, Alex Acosta, Jeff Sloman, Cyndee Campos, and Andrew Lourie regarding draft response to Jay Leflcowitz and victim notification letters Work Product Deliberative Process P-014355 thru P-014361 12/3/2007 emails between Marie Villafaila, Alex Acosta

7 emails between Marie Villafaila, Alex Acosta, and Jeff Sloman regarding history of plea negotiations and drafting response to correspondence from Jay Lekowitz and Ken Starr Work Product Deliberative Process P-014362 thru P-014402 12/3/2007-12/5/2007 correspondence between Alex Acosta, Jeff Sloman, Ma

estions Work Product 6(e) Deliberative Process Investigative Privilege P-014781 thru P-014800 3/19/2008-3/27/2008 emails between Jeff Sloman, Bob Senior, Karen Atkinson, Rolando Garcia, Nesbitt Kurykendall, and Jason Richards regarding waiting for DC's decision regarding Epstein's challenges to NPA

on P-014277 thru P-014282 11/2/2007-11/5/2007 emails between Marie Villafafia and Jeff Sloman regarding drafting 11/5/2007 letter from Sloman to Lefkowitz Work Product Deliberative Process P-014283 thru P-014284 11/5/2007-11/7/2007 emails from Marie Villafaila to Jeff Sloman inquiring about statu

14354 11/29/2007-12/1/2007 emails between Marie Villafafia, Alex Acosta, Jeff Sloman, Cyndee Campos, and Andrew Lourie regarding draft response to Jay Leflcowitz and victim notification letters Work Product Deliberative Process P-014355 thru P-014361 12/3/2007 emails between Marie Villafaila, Alex Acosta

7 emails between Marie Villafaila, Alex Acosta, and Jeff Sloman regarding history of plea negotiations and drafting response to correspondence from Jay Lekowitz and Ken Starr Work Product Deliberative Process P-014362 thru P-014402 12/3/2007-12/5/2007 correspondence between Alex Acosta, Jeff Sloman, Ma

estions Work Product 6(e) Deliberative Process Investigative Privilege P-014781 thru P-014800 3/19/2008-3/27/2008 emails between Jeff Sloman, Bob Senior, Karen Atkinson, Rolando Garcia, Nesbitt Kurykendall, and Jason Richards regarding waiting for DC's decision regarding Epstein's challenges to NPA

efforts to communicate with you about any potential problems and hope, in the interest of fairness, you will do the same. Sincerely, 9 :74/1 Jay . Lefkowitz, P.C. Enclosures EFTA00194729 LEOPOLD-KUVIN„ CONSUMER JUSTICE ATTORNEYS July 6, 2009 A. Maria Villafana, Esq. Assistant U.S. Attorney Southe

to your response. Cordially y rs, Robe, D. Critton, Jr. RDC/clz cc by pdf: Jack A. Goldberger, Esq. Martin G. Weinberg, Esq. Roy Black, Esq. Jay Lefkowitz, Esq. EFTA00194734 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 09-CV-80802-MARRA-JOHNSON JANE DOE NO. 8 Plaintiff, JE

lead until the Deputy Attorney General's Office (DAG) completed its review. See Exhibit 9, May 28, 2008 Email from Assistant U.S. Attorney Sloman to J. Lefkowitz. EFTA00194722 • Ms. A. Marie Villafana, Esq. June 19, 2009 Page 4 • A final letter of determination was not issued by the Department of Justic

reviewed this very matter with you and other individuals in your Office in November 2008. At that time, Mr. Roy Black met with you, Karen Atkinson, Bob Senior, and Jeffrey Sloman in Miami to review the work release issue. Among other significant documents shown to you, we presented you with your own email

ive Process P-014206 thru P-014216 9/24/2007-9/25/2007 emails between Alex Acosta, Marie Villafafia, Andrew Lourie, and Rolanda Garcia regarding Lefkowitz email about keeping agreement from becoming public and confidentiality provision in agreement Work Product Deliberative Process P-014217 thru

nterstate commerce" Work Product 6(e) P-014486 12/21/2007 email from Marie Villafafia to Jeff Sloman with thoughts on recent correspondence from Jay Leflcowitz raising concerns about interpretation of the Non prosecution Agreement Work Product Deliberative Process P-014487 12/27/2007 email from Marie Vi

estions Work Product 6(e) Deliberative Process Investigative Privilege P-014781 thru P-014800 3/19/2008-3/27/2008 emails between Jeff Sloman, Bob Senior, Karen Atkinson, Rolando Garcia, Nesbitt Kurykendall, and Jason Richards regarding waiting for DC's decision regarding Epstein's challenges to NPA

eys Starr and Lefkowitz stating their finding that there was no abuse of discretion and no misconduct (Exhibit B-44). I immediately sent an email to Jay Lefkowitz in accordance with Mr. Senior's instructions (Ex. B-49). The following day, Roy Black and Jack Goldberger, as local counsel for Epstein, contacted m

2007, Jay Lefkowitz, counsel for Epstein, objected to the victim notification letter in a letter to USA Acosta. (Exhibit B-9). USA Acosta asked Mr. Lefkowitz to discuss the matter with Jeff Sloman and me. (Exhibit B-10). On December 5, 2007, Kenneth Starr and Jay Lefkowitz wrote a letter to USA Acosta re

line to enter his guilty plea would be extended again, and we continued preparing for indictment (Exhibits B-34 through B-37). So, on May 27, 2008, Bob Senior, who took Matt Menchel's place as Criminal Chief, Jeff Sloman, who had taken over for USA Acosta due to his recusal from the Epstein matter, Karen

ur modifications we-suggested-to resolve problems raised by the draft notification letter. See December 6, 2007 Letter from U.S. Attorney Acosta to J. Lefkowitz. Thine fact that-MfrAsesta-eventually-adepted-eeetain-ef-the-suggested-ntedifteatiens in-tespeese-te-euF-ebjeetiens-confirms both the good-faith nat

eviewed this very matter with you and other individuals in your office in November 2008. At that time, Mr. Roy Black met with you, Karen Atkinson, Bob Senior, and Jeffrey Sloman in Miami to review the work release issue. Among other significant documents, we presented you with your EFTA00731119 Ms. A.

ive Process P-014206 thru P-014216 9/24/2007-9/25/2007 emails between Alex Acosta, Marie Villafafia, Andrew Lourie, and Rolanda Garcia regarding Lefkowitz email about keeping agreement from becoming public and confidentiality provision in agreement Work Product Deliberative Process P-014217 thru

14354 11/29/2007-12/1/2007 emails between Marie Villafafia, Alex Acosta, Jeff Sloman, Cyndee Campos, and Andrew Lourie regarding draft response to Jay Lefkowitz and victim notification letters Work Product Deliberative Process P-014355 thrn P-014361 12/3/2007 emails between Marie Villafafia, Alex Acosta

estions Work Product 6(e) Deliberative Process Investigative Privilege P-014781 thru P-014800 3/19/2008-3/27/2008 emails between Jeff Sloman, Bob Senior, Karen Atkinson, Rolando Garcia, Nesbitt Kurykendall, and Jason Richards regarding waiting for DC's decision regarding Epstein's challenges to NPA