Epstein Secrets

itled 'Rsrch re Crime Victims Rights' containing attorney research, handwritten notes, draft victim notification letter, and draft correspondence to Jay Leflcowitz." Here again, the materials at issue go to the heart of this case — what kind of notifications were made to the victims and how did the defense att

ich involves "File folder entitled `12/05/07 Starr to Acosta' containing drafts of 11/30/07 letters from A. Acost to K. Starr and from J. Sloman to J. Lefkowitz re performance and victim notification with handwritten notes and edits by A. Marie Villafafia." This information goes very directly to the issues i

entry reads: "File folder entitled `12/05/07 Starr 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 Villafaiia." Again, these materials are central to the dispute i

il to meet this requirement. 63. A good illustration of the inadequacies of the privilege log comes from the very first entry in the log, covering Box No. 1 (P-000001 through P-000039), some 39 pages of documents. DE 212-1. Yet the only description of these 39 pages is: "File folder entitled 'CORR RE G

letters from A. to K. Starr and from J. to J. Lefkowitz re performance and victim notification with handw

itled 'Rsrch re Crime Victims Rights' containing attorney research, handwritten notes, draft victim notification letter, and draft correspondence to Jay Leflcowitz." Here again, the materials at issue go to the heart of this case — what kind of notifications were made to the victims and how did the defense att

42 to P-013350. The entry reads: "File folder entitled `12/05/07 Starr to containing drafts of 11/30/07 letters from A. to K. Starr and from J. to J. Lefkowitz re performance and victim notification with handwritten notes and edits by NEB" Again, these materials are central to the dispute in this case, as t

il to meet this requirement. 63. A good illustration of the inadequacies of the privilege log comes from the very first entry in the log, covering Box No. 1 (P-000001 through P-000039), some 39 pages of documents. DE Si. Yet the only description of these 39 pages is: "File folder entitled 'CORR RE GJ

ter with attached 8/15/08 emails from A. Marie Villafafla to A. Acosta, J. Sloman, R. Senior, K. Atkinson, D. Lee re Agreement; 8/15/08 email from J. Lefkowitz to A. Marie Villafana, K. Atkinson, IL Black, M. Weinberg re Agreement; 8/14/08 emails from A. Marie Villafafla to J. Lefkowitz, K. Atkinson, R.

rch 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 Alice S. Fisher, and a November 29, 2007 letter Erom Jay Lefkowitz to IL Alexande

ainst Public Prosecutor; Overriding Need; Attorney Conduct at Issue Suppl. Box #3 P413338 Thru 013341 File folder entitled "12/6/07 Sloman to Lefkowitz" containing 12/5/07 faxed letter w/ cover sheet from K. Starr and J. Lefkowitz to A. Acosta [Not considered privileged. Will be produced to oppo

en notes." 64. Another good illustration of the inadequacies of the privilege log is provided on page 20 of the first privilege log, with regard to Box No. 3 (P-012362 through P-012451). The Government asserts privilege here regarding 90 pages of documents. Yet the only description of these 90 pages is

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

Starr; Admitted. (e) Lillian Sanchez; Admitted to the extent that the reference to "Lillian Sanchez" was meant to refer to Lilly Ann Sanchez. (f) Jay Leflcowitz; Admitted and (g) Roy Black. Admitted EFTA00208659 Case 9:08-cv-80736-KAM Document 225-1 Entered on FLSD Docket 08/16/2013 Page 53 of 64 7. On

il to meet this requirement. 63. A good illustration of the inadequacies of the privilege log comes from the very first entry in the log, covering Box No. 1 (P-000001 through P-000039), some 39 pages of documents. DE 212-1. Yet the only description of these 39 pages is: "File folder entitled 'CORR RE G

Starr; Admitted. (e) Lillian Sanchez; Admitted to the extent that the reference to "Lillian Sanchez" was meant to refer to Lilly Ann Sanchez. (f) Jay Leflcowitz; Admitted and (g) Roy Black. Admitted EFTA00615920 Case 9:08-cv-80736-KAM Document 265-1 Entered on FLSD Docket 10/20/2014 Page 53 of 64 7. On

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

il to meet this requirement. 63. A good illustration of the inadequacies of the privilege log comes from the very first entry in the log, covering Box No. 1 (P-000001 through P-000039), some 39 pages of documents. DE 212-1. Yet the only description of these 39 pages is: "File folder entitled 'CORR RE G

ment 361-60 Entered on FLSD Docket 02/10/2016 Page 2 of 2 (USAFLS) rom: (USAFLS) Il ibject: nt: 'A I hursday, September 20, 2007 6:42 PM 'Jay Lefkowitz' RE: Plea Agreement -- EPSTEIN Jay -- The 18 and 12 has already been agreed to by our office, so that is not a problem. On the issue about 18 USC 2

P-013350, which involves "File folder entitled `12/05/07 Starr to containing drafts of 11/30/07 letters from A. Acost to K. Starr and from J. to J. Lefkowitz re performance and victim notification with handwritten notes and edits by A. Villafafia." This information goes very directly to the issues involve

il to meet this requirement. 63. A good illustration of the inadequacies of the privilege log comes from the very first entry in the log, covering Box No. 1 (P-000001 through P-000039), some 39 pages of documents. DE M-1. Yet the only description of these 39 pages is: "File folder entitled 'CORR RE GJ