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

57 than confer with the victims about the fact that resolution by NPA was ever being considered— or even tell them that it was already a signed deal—the Office and Epstein inserted a "confidentiality" provision into the agreement barring its disclosure to anyone, including the victims. There is no dispute that the Gov

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

57 than confer with the victims about the fact that resolution by NPA was ever being considered— or even tell them that it was already a signed deal—the Office and Epstein inserted a "confidentiality" provision into the agreement barring its disclosure to anyone, including the victims. There is no dispute that the Gov

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

57 than confer with the victims about the fact that resolution by NPA was ever being considered— or even tell them that it was already a signed deal—the Office and Epstein inserted a "confidentiality" provision into the agreement barring its disclosure to anyone, including the victims. There is no dispute that the Gov

that arises out of the ongoing federal investigation as described above."41 29. 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

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

57 than confer with the victims about the fact that resolution by NPA was ever being considered— or even tell them that it was already a signed deal—the Office and Epstein inserted a "confidentiality" provision into the agreement barring its disclosure to anyone, including the victims. There is no dispute that the Gov