Epstein Secrets

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

6. The correspondence further discussed a possible plea disposition that would make it hard for a judge to see what was happening: Andy [i.e., AUSA Andrew Laurie] recommended that some of the timing issues be addressed only in the state agreement, so that it isn't obvious to the judge that we are trying to c

orney's Office has not produced any emails sent to or from any home e-mail addresses of its prosecutors. 30. On September 17, 2007, defense counsel Jay Leflcowitz responded: "[D]o you have another obstruction proffer I can review that you have drafted? Also, if we go that route, would you intend to make the d

tempted to notify or confer with the victims about the existence of the NPA. 35. On September 23, 2007, the U.S. Attorney's Office sent an email to Lefkowitz stating: "It is factually accurate that the list we are going to give you are persons we have identified as victims. If we did not think they were

6. The correspondence further discussed a possible plea disposition that would make it hard for a judge to see what was happening: Andy [i.e., AUSA Andrew Laurie] recommended that some of the timing issues be addressed only in the state agreement, so that it isn't obvious to the judge that we are trying to c

tion not only to Epstein, but also to certain co-conspirators. (DE 407 at ¶ 28.) On September 17, 2007, the line prosecutor wrote to defense counsel Jay Lefkowitz: "Please send [a document] to my home e-mail address — [redacted] and give me a call on my cell [redacted] so I can be ready for some discussions t

ss — [redacted] and give me a call on my cell [redacted] so I can be ready for some discussions tomorrow." (DE 407 at ¶ 29.) On September 17, 2007, Lefkowitz responded: "[D]o you have another obstruction proffer I can review that you have drafted? Also, if we go that route, would you intend to make the de

e Office was "not investigating Mr. Epstein [for] abusing his girlfriend." (DE 407 at 11- 25.) The correspondence further stated: Andy [i.e., AUSA Andrew Laurie] recommended that some of the timing issues be addressed only in the state agreement, so that it isn't obvious to the judge that we are tying to cr

ictims and Epswin's counsel may contact the identified victims through that Col/MCI. See droll non-prosecution agreement c-mailed from Villafana to Lelkowitz dated September 17. 2007. The inclusion of a guardian ad Mem, however. only served to complicate matters. We continued to reiterate our objections

strued as an admission of civil or criminal liability in regards to any of those who seek compensation from the Trust. See dmft proposal sent from Jay Lelkowitz to Andrew Laurie dated September 15, 2007. In response, Ms. Villafamt demanded that the Agreement contain language considering the inclusion of a g

tter have no relation to the allegations against Mr. Epstein. Notably, after we objected to these overly broad and intrusive requests. Deputy Chief Andrew Laurie denied knowledge of Ms. Villalima's actions and Mr. Laurie commendably sought to significantly narrow the list of documents requested. In a subsequ

rued as an admission or civil or criminal liability in regards to any of those who seek I. pensalion from the Trust. See draft proposal sent from Jay Lerkowitz to Andrew I.ourie doted September 15. 2007." In response, Ms. Villarana demanded that the Agreement contain language considering the inclusion of a

t of Florida DELIVERY BY ELECTRONIC MAIL Jay P. Lefkowitz, Esq. Kirkland & Ellis LLP ew York, New York 10

ter have no relation to the allegations against Mr. ISpstein. Notably. affix we objected to these overt broad and intrusive requests. Deputy Chief Andrew Laurie denied knowledge of Ms. s actions and Mr Laurie commendably so t igni tiara ly narrow the list of documen requested. In a subsequent court filin

orney's Office has not produced any emails sent to or from any home e-mail addresses of its prosecutors. 30. On September 17, 2007, defense counsel Jay Leflcowitz responded: "[D]o you have another obstruction proffer I can review that you have drafted? Also, if we go that route, would you intend to make the d

tempted to notify or confer with the victims about the existence of the NPA. 35. On September 23, 2007, the U.S. Attorney's Office sent an email to Lefkowitz stating: "It is factually accurate that the list we are going to give you are persons we have identified as victims. If we did not think they were

6. The correspondence further discussed a possible plea disposition that would make it hard for a judge to see what was happening: Andy [i.e., AUSA Andrew Laurie] recommended that some of the timing issues be addressed only in the state agreement, so that it isn't obvious to the judge that we are trying to c

tion not only to Epstein, but also to certain co-conspirators. (DE 407 at ¶ 28.) On September 17, 2007, the line prosecutor wrote to defense counsel Jay Lefkowitz: "Please send [a document] to my home e-mail address — [redacted] and give me a call on my cell [redacted] so I can be ready for some discussions t

ss — [redacted] and give me a call on my cell [redacted] so I can be ready for some discussions tomorrow." (DE 407 at ¶ 29.) On September 17, 2007, Lefkowitz responded: "[D]o you have another obstruction proffer I can review that you have drafted? Also, if we go that route, would you intend to make the de

e Office was "not investigating Mr. Epstein [for] abusing his girlfriend." (DE 407 at 11- 25.) The correspondence further stated: Andy [i.e., AUSA Andrew Laurie] recommended that some of the timing issues be addressed only in the state agreement, so that it isn't obvious to the judge that we are tying to cr