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P-003634 Thru P-003646 File folder bearing victim name containing FBI interview report from May 2008, telephone activity report with attorney (Villafanafia) handwritten notes, related grand jury material Work product Attorney-client privilege 6(e) Investigative privilege Also contains information
08/16/2013 Page 30 of 70 Bates Range Description Privilege(s) Asserted Victims' Objections Box #2 P409114 Tint P-009115 7/3/2008 Email from A. Marie Villafafia to Col. M. Gauger at PBSO re Epstein work release with attachment [not being withheld as privileged — produced to opposing counsel] N/A Box
Underpinnings; Fiduciary Duty; Court Compelled Disclosure; Factual Materials; Waiver Box #3 P-013231 Thai P-013239 April 22, 2008 Letter from A. Marie Villafafia to Office of Professional Responsibility re Self-Report of Allegation of Conflict of Interest Privacy Act Inadequate Log; No Factual Underpinni
aiver; Claims Against Public Prosecutor, Overriding Need; Attorney Conduct at Issue Epstein, with e- mail from Menchel (July 5, 2007, 3:30 p.m.), Villafana to Menchel (July 4, 2007, 5:16 p.m.), and Sloman to Villafana (July 3, 2007, 1:47 p.m.), attached Suppl. Box 3 P-013866 E-mail, Marie Villafana
07 letter from Gerald Public Prosecutor, Attorney Conduct at Issue; Lefeourt to Jeffrey Sloman, Matt Factual Materials; Court Authorized Under Menchal, Andrew Lourie, and 6(e)(3)(E); Court Inherent Power to Release; Marie Vi Ilafarla with handwritten attorney (Villafarla) notes; Proper Victim's
ental box No. 3 (P-013504 to P-013507). The entry here reads: "File folder labeled `Mtg w/ Ken Starr, RAA, JS, Drew' containing handwritten notes by A. Marie Villafaiia." Kenn Staff, of course, is a defense attorney who represented defendant Epstein. Recording information provided by a defense attorney is not part o
mails) that were sent to. conied to, or sent by Reinhart in which the word "Epstein," _ ' "Morrison," "Visoki," "Rogers," "Hammond," Roxburgh," "Villafana, " "Florida Science Foundation," "Starr," "Black," "Goldberger," "Jeffrey," "Australian," "Lewis," "Sanchez," "358 El Brillo Way" appears and which
prosecutors working on the case (including, but not limited to, federal prosecutors Alexander Acosta, Jeffrey H. Sloman, Matt Menchel, Andy Lourie, Ann Marie Villafana, Dexter Lee, and Bruce Reinhart and state prosecutors Dahlia Weiss, Lana Belolovek, and others involved in the Epstein investigation) and defense a
also potentially a motive to violate the victims' rights as explained previously. The Government's privilege log has numerous entries showing that Menchal was substantially and personally involved in making decisions related to the Epstein prosecution. See, e.g., page 19 of the first privilege log (DE
n agreement. At this point it is clear that AUSA Villafana was restricted in what she was being permitted to
/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 Villafafla." Again, these materials are central to the dispute in this case, as they involve discussions between the U.S. Attorney's Office and defense attorne
prosecutors working on the case (including, but not limited to, federal prosecutors Alexander Acosta, Jeffrey H. Sloman, Matt Menchel, Andy Lourie, Ann Marie Villafana, Dexter Lee, and Bruce Reinhart and state prosecutors Dahlia Weiss, Lana Belolovek, and others involved in the Epstein investigation) and defense a
also potentially a motive to violate the victims' rights as explained previously. The Government's privilege log has numerous entries showing that Menchal was substantially and personally involved in making decisions related to the Epstein prosecution. See, e.g., page 19 of the first privilege log (DE
Negotiations" containing 9/17/07 e-mail from A. Villafana to J. N. it status update; undated and typed ha
f this Non- Prosecution Agreement and agrees to comply with them. R. ALEXANDER UNITED STATES ATTORNEY Dated: By: Dated: 77a, Dated: Dated: VILLAFARA ASSISTANT U.S. ATTORNEY GERALD LEFCOURT, ESQ. COUNSEL TO JEFFREY EPSTEIN LILLY ANN SANCHEZ, ESQ. ATTORNEY FOR JEFFREY EPSTEIN Page 7 of 7 EFTA
o supplemental box No. 3 (P-013644 through P-013653). The entry here "File folder e ' I "Notes Re Plea Negotiations" containing 9/17/07 e-mail from A. Villafana to J. N. it status update; undated and typed handwritten notes by A. Villafafia re items to be completed on case, strength of case, victim interv
also potentially a motive to violate the victims' rights as explained previously. The Government's privilege log has numerous entries showing that Menchal was substantially and personally involved in makingslecisions related to the Epstein prosecution. See, e.g., page 19 of the first privilege log (DE
Entities connected to both A. Marie Villafana and Menchal

Jeffrey Epstein
PERSON
Alexander Acosta
PERSON
Kenneth Marra
PERSON
Dexter Lee
PERSON
Karen Atkinson
PERSON
Bradley Edwards
PERSONJack Goldberger
PERSONJane Doe
PERSON
Jay Lefkowitz
PERSONLeon Black
PERSON
United States
LOCATIONRoy Black
PERSON
Prince Andrew
PERSON
Department of Justice
ORGANIZATIONthe Southern District
LOCATION
Bill Richardson
PERSON
Paul Cassell
PERSON
Alan Dershowitz
PERSONGerald Lefcourt
PERSONFBI
ORGANIZATION