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led "Rsrch 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 , and a November 29, 2007 letter from Jay Lefkowitz to R. Alexander Acosta (P-010
Thru P-009125 12/6/2007 Letter from to Jay P. Lefkowitz re Jeffrey Epstein (victim notification) [pursua
cipation of either in the instant litigation. ° The Government asserts that the work-product doctrine applies to documents prepared by attorneys in the Department of Justice's Office of Professional Responsibility (OPR) in response to Petitioners' counsel's request for an investigation into the Government's handling of the Epstein case. (DE 216-1 at 12-14). A
Discovery has revealed that during these negotiations, several drafts of the NPA were exchanged. See, e.g., Exh. C (9/17/07 email from Villafana to Lefkowitz attaching draft NPA); Exh. D (9/21/07 email from Villafana to Lefkowitz attaching draft NPA). In addition, the parties exchanged several drafts of
is understandable that the current regime may wish the government had not entered into the NPA, or that it had negotiated different terms. Indeed, the Department of Justice's Office of Professional Responsibility ("OPR") found that Acosta exercised "poor judgment" and "agreed to several unusual and problematic terms in the NPA," which OPR characterized as a
Discovery has revealed that during these negotiations, several drafts of the NPA were exchanged. See, e.g., Exh. C (9/17/07 email from Villafana to Lefkowitz attaching draft NPA); Exh. D (9/21/07 email from Villafana to Lefkowitz attaching draft NPA). In addition, the parties exchanged several drafts of
is understandable that the current regime may wish the government had not entered into the NPA, or that it had negotiated different terms. Indeed, the Department of Justice's Office of Professional Responsibility ("OPR") found that Acosta exercised "poor judgment" and "agreed to several unusual and problematic terms in the NPA," which OPR characterized as I
Entities connected to both Jay Lefkowitz and the Department of Justice's Office of Professional Responsibility

Jeffrey Epstein
PERSON
Alexander Acosta
PERSON
A. Marie Villafana
PERSON
Kenneth Marra
PERSON
United States
LOCATION
Department of Justice
ORGANIZATIONJane Doe
PERSONthe Southern District
LOCATION
George W. Bush
PERSON
Prince Andrew
PERSONFBI
ORGANIZATION
Scarlett Johansson
PERSON
Ghislaine Maxwell
PERSON
Virginia Giuffre
PERSON
Southern District of New York
ORGANIZATION
Harvey Weinstein
PERSON
New York
LOCATION
Donald Trump
PERSON
Julie K. Brown
PERSON
Supreme Court
ORGANIZATION