Epstein Secrets

led "Rsrch re Crime Victims Rights" containing attorney research, handwritten notes, draft victim notification letter, and draft correspondence to Jay Leflcowitz (Also contains a November 28, 2007 letter from Kenneth Starr to Alice S. Fisher; and a November 29, 2007 letter from Jay Lefkowitz to R. Alexande

telephone Work Product 6(e) 57 11/28/2007 correspondence between Marie Villafafta, Andrew Lourie, Drew Oosterbaan, and Rolando Garcia regarding Lefkowitz 11/27/2007 email discussing presentation to DAAG Work Product Deliberative Process 58 11/19/2007-11/28/2007 emails between Marie Villafafla, N

u P-013337 File folder entitled "I 1/13/07 Sloman to Lefkowitz (was this sent?)" containing draft 11/13/07 letter from J. Sloman responding to J. Lefkowitz's letter Attorney-Client Privilege Work Product Page 2 of 14 EFTA00191251 Bates Range Description Privilege(s) Asserted Suppl. Box #3 P-013

M. Weinberg re Agreement; 8/14/08 emails from A. Marie Villafana to J. Lefkowitz, K. Atkinson, R. Black m interpretation of Agreement; email from J. Lefkowitz to A. Marie Villafana, K. Atkinson re questions it Agreement; email from A. Marie Villafana to J. Lefkowitz, K. Atkinson re production of Agreemen

aration binder containing meta- analysis charts of telephone/flight/grand jury information for a number of victim/witnesses, Nadia Marcinkova, and Adriana Mucinska Work product 6(e) Contains information and documents subject to investigative privilege. Also contains information and documents subject to pr

llafafia Nathan Z. Dershowitz Ms. Groff will proceed by interview. 9/12/2007 Meeting (US: Andy Laurie, Rolando Garcia and Marie Villafatia, DEF: Jay Lefkowitz, Gerald Lefcourt and Jack Goldberger, STATE OF FLORIDA: Barry Krisher and Lanna Belohlavek) 9/12/2007 A. Marie Villafalia; cc: Andrew Laurie Ja

age with attached Epstein Plea Offer 49 9/16/2007 Villafatia Lefkowitz Email with attached 5 page Agreement 49 9/16/2007 Email chain between Lefkowitz and Villafana regarding changing the documents to 1512 and language in the plea agreement 46 9/16/2007 12:00 pm draft Information 9/16/2007 12:

Material EFTA00224968 EPSTEIN INVESTIGATION TIMELINE Date To From Re: Exhibit # 12/11/2007 R. Alexander Acosta Kenneth Starr d Jay an Lefkowitz 2 separate letters to address problems with case. Letter 1 - Federal Investigators relied upon tainted evidence. Improper involvement and conduct of

o Larry Visoski (pilot)(retum date 12/1/06) 11/13/2006 Subpoena to Janusz Banasiak (property manager)(return date 12/1/06) 11/13/2006 Subpoena to Adriana Mucinska (former assistant) (return date 12/1/06) 15 11/15/2006 A. Marie Villafafia Lilly Ann Sanchez Gerald Lefcourt from New York and Lilly Ann Sanch

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

igation; Improper P-003545 a number of victim/witnesses, Nadia documents subject to Invocation; Overriding Need; Claims Against Marcinkova, and Adriana Mucinska investigative privilege. Public Prosecutor, Attorney Conduct at Issue; Also contains information and documents subject to privacy rights of vict

acy to commit an assault on a plane. I just want to make sure that we have something that is factually accurate. Just trying to plan ahead" (id). At Jay Lefkowitz's request, MAUSA Lourie and I scheduled a conference call with him for early on the morning of September 14, 2007 (id. at 25). Mr. Lourie did not att

Villafana letter to Lclkowitz, Black, and Goldberger regarding history of Epstein's performance under the NPA 89 6/17(2009 Villafaila letter to Lelkowitz regarding monitoring future performance under the NPA 90 9/1/2009 Black letter to Montan seeking approval for Epstein to transfer community contr

draft Plea Agreement 9/18/2007 1:37pm draft Information 9/18/2007 Garcia, Villafaiia Lourie Email stating new terms that Louric negotiated with Lefkowitz 9/19/2007 A. Laurie, R. Garcia, K. A. Marie Villafana Email re negotiating strategy with attached correspondence l6 9/19/2007 A. A. Marie Vi

o Larry Visoski (pilot)(return date 12/1/06) 11/13/2006 Subpoena to Janusz Banasiak (property manager)(retum date 12/1/06) 11/13/2006 Subpoena to Adriana Mucinska (former assistant) (return date 12/1/06) 15 I 1/15/2006 A. Marie Villafalia Lilly Ann Sanchez Gerald Lefcourt from New York and Lilly Ann Sanc

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 Alice S. Fisher; and a November 29, 2007 letter from Jay Lefkowitz to R. Alexande

12/6/2007 Letter from Jeffrey Sloman to Jay P. Lefkowitz re Jeffrey Epstein (victim notification) [pursua

aration binder containing meta- analysis charts of telephone/flight/grand jury information for a number of victim/witnesses, Nadia Marcinkova, and Adriana Mucinska Work product 6(e) Contains information and documents subject to investigative privilege. Also contains information and documents subject to pr

ered to join the trial team and provide additional support from CEOS. On September 7, 2007, U.S. Attorney Acosta met with Kirkland & Ellis partners Jay Lefkowitz and former Solicitor General Ken Starr and Ms. Sanchez, along with Chief Oosterbahn and AUSAs Villafana, John McMillan, and FAUSA Sloman, Messrs. St

. We discussed those legal arguments and the unanimous opinion of all of the attorneys present was in favor of prosecution. During that meeting, Mr. Lefkowitz also offered a plea resolution. His offer, in essence, was that Epstein be subjected to home confinement at his Palm Beach home, using private secu

described in the forfeiture section of this indictment, as a result of any act or omission of the defendants JEFFREY EPSTEIN, SARAH ADRIANA a/k/a "Adriana Mucinska," and NADIA (a) cannot be located upon the exercisezof due diligence; (b) has been transferred or sold to, or deposited with, a third person; (c

flights with Ghislaine Maxwell, Sarah Kellen, and Adriana Mucinska, - all employees and/or co-conspirators of Epstei

Epstein's civil exposure. For example, on October 3, 2007, Assistant U.S. Attorney Marie Villafafia sent an email (attached hereto as Exhibit “D”) to Jay Lefkowitz, counsel for Epstein, with attached proposed letter to special master regarding handling numerous expected civil claims against Epstein. The letter r

s Attorney's Office prepared negotiated plea agreements containing these charges. For example, in a September 18, 2007, email from AUSA Villafafia to Lefkowitz (attached hereto as Exhibit “H”), she attached the proposed plea agreement describing Epstein’s witness tampering as follows: "UNITED STATES vs. JE

pstein's civil exposure. For example, on October 3, 2007, Assistant U.S. Attorney Marie Villafafia sent an email (attached hereto as Exhibit “D’’) to Jay Lefkowitz, counsel for Epstein, with attached proposed letter to special master regarding handling numerous expected civil claims against Epstein. The letter r

es Attorney's Office prepared negotiated lea agreements containing these charges. For example, in a September 18, 2007, email from AUSA Villafafia to Lefkowitz (attached hereto as Exhibit “H’), she attached the proposed plea agreement describing Epstein’s witness tampering as follows: "UNITED STATES vs. JE

n 2002 and 2005. See Flight logs attached hereto as Exhibit “MM.” Clinton traveled on many of those flights with Ghislaine Maxwell, Sarah Kellen, and Adriana Mucinska, - all employees and/or co-conspirators of Epstein’s that were closely connected to Epstein’s child exploitation and sexual abuse. The documents clea