Epstein Secrets

ification letter, and draft correspondence to Jay Lefkowitz." Here again, the materials at issue go to the h

. Black, Srebnick, Kornspan & Stumpf, P.A. 201 South Biscayne Boulevard, Suite 1300 Miami, FL 33131 Email: [email protected] (305) 37106421 Jay P. Lefkowitz Kirkland & Ellis, LLP 601 Lexington Avenue New York, NY 10022 Email: [email protected] (212) 446-4970 Martin G. Weinberg, P.C. 20 Park Pl

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 handwritten notes and edits by A. Marie Villafafla." Again, these materials are central to the dispute i

vilege log with its objections annotated (D.E. 224-1); (2) a motion to compel production of documents that are not privileged, numbering eight pages D.E. 225; (3) a twenty-four page, single-spaced affidavit of petitioners' counsel, addressing the EFTA00179785 Case 9:08-cv-80736-KAM Document 230 Ent

icials and Epstein's attorneys, in which Epstein sought to have the NPA overturned. See Ex. H at 1. 23. On May 15, 2008, the Chief of the CEOS sent Jay Lefkowitz, Esq., a five-page letter, explaining the inquiry it conducted of the federal criminal investigation of Epstein. Ex. H. The letter concluded that "

l letter briefs to the Deputy Attorney General. Ex. V. 25. On June 23, 2008, John Roth, Senior Associate Deputy Attorney General, wrote to Messrs. Lefkowitz and Starr, advising them that "federal prosecution of this case is appropriate." Ex. I. Mr. Roth also told Epstein's attorneys that their allegation

fficials for 8:30 a.m., Monday, June 30, 2008, AUSA Villafafia and the Palm Beach Police Department attempted to provide notice to all the victims. D.E. 14,1 11; Ex. S 1 38. AUSA Villafafia specifically called and informed Brad Edwards, the attorney who at that time was representing both Jane Doe No.

I (a)(5) is significant 3 Jane Doe No. 2's exculpatory statements regarding Epstein were not lost on his attorneys. A December 21, 2007 letter from Jay Leflcowitz, one of Epstein's attorneys, to U.S. Attorney Acosta, devoted two pages examining Jane Doe No. 2's interview testimony on April 24, 2007. Ex. D at

hts associated with the agreement entered into by the United States and Mr. Epstein in a timely fashion." Ex. N, Nov. 27, 2007 email from Sloman to Lefkowitz. Epstein's attorneys responded by citing to the Attorney General's Guidelines provision stating that there must be a charge filed in a Federal distr

ined that, after the NPA was signed in September 2007, four victims were contacted and the provision for a federal restitution remedy was discussed. D.E. 14,1 8. When Epstein's attorneys learned of this, they complained that the Government was incentivizing the victims to overstate their involvement

71(a)(5) is significant 3 Jane Doe No. 2's exculpatory statements regarding Epstein were not lost on his attorneys. A December 21, 2007 letter from Jay Lefkowitz, one of Epstein's attorneys, to U.S. Attorney Acosta, devoted two pages examining Jane Doe No. 2's interview testimony on April 24, 2007. Ex. D at

hts associated with the agreement entered into by the United States and Mr. Epstein in a timely fashion." Ex. N, Nov. 27, 2007 email from Sloman to Lefkowitz. Epstein's attorneys responded by citing to the Attorney General's Guidelines provision stating that there must be a charge filed in a Federal distr

ined that, after the NPA was signed in September 2007, four victims were contacted and the provision for a federal restitution remedy was discussed. D.E. 14,1 8. When Epstein's attorneys learned of this, they complained that the Government was incentivizing the victims to overstate their involvement

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

the person whom Petitioners refer to as "Jane Doe 5" also had been approached by the investigative team in 2007 but refused to speak with them. (See D.E. 14 at 1 3.) Regardless of the perceived strength of the corroborating evidence, it was and remains my professional opinion as an experienced prosec

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

asked solely to poison the wel1.6 The Court recently sustained Plaintiffs objections to discovery requests geared solely to alleged sexual activity (D.E. 148, 149, and 150). Accordingly, the sword and shield doctrine does not apply to the illegitimate and irrelevant questions which Plaintiff declined

2 Entered on FLSD Docket 02/04/2010 Page 3 of 14 Lefkowitz v. Turley, 414 U.S. 70, 77 (1973)). The privileg

other inquiries related to the same subject matter in this case, the related cases and those matters outlined in Epstein's in camera submissions at D.E. #s 282 and 283. Given the allegations raised in the various Complaints and the elements 5 EFTA00592195 Case 9:08-cv-80119-KAM Document 462 Enter

2 Entered on FLSD Docket 02/04/2010 Page 3 of 14 Lefkowitz I. Turley, 414 U.S. 70, 77 (1973)). The privileg

other inquiries related to the same subject matter in this case, the related cases and those matters outlined in Epstein's in camera submissions at D.E. #s 282 and 283. Given the allegations raised in the various Complaints and the elements 5 EFTA00222432 Case 9:08-cv-80119-KAM Document 462 Enter