Epstein Secrets

re victim notification Attorney-Client Privilege Work product Deliberative Process Suppl. Box #3 P-013284 7/10/08 Emails between J. Sloman and A. Marie Villafafia, K. Atkinson, and FBI re proposed response to Goldberger's letter re victim notification Attorney-Client Privilege Work Product Deliberative Pro

00001 thru P-000039 File folder entitled "CORR RE GJ SUBPOENAS" containing correspondence related to various grand jury subpoenas and attorney (Villafada) handwritten notes 6(e) Work Product Box #1 P-000040 thru P-000549 Operation Leap Year Grand Jury Log containing subpoenas OLY-01 through OLY

P-003634 Thru P-003646 File folder bearing victim name containing FBI interview report from May 2008, telephone activity report with attorney (Villafanana) handwritten notes, related grand jury material Work product Attorney-client privilege 6(e) Investigative privilege Also contains information a

g 8/15/08 e-mails from A. Marie Villafafta to A. Acosta, J. Sloman, R. Senior, K. Atkinson, D. Lee it follow up on Agreement and from A. Acosta to Ann Marie Villafana on issue of Special Master with attached 8/15/08 cmails from A. Marie Villafafta to A. Acosta, J. Sloman, R. Senior, K. Atkinson, D. Lee re Agreem

aining A. Marie Villafafta's handwritten draft notes for proposed letter to J. Lefkowitz; 5/22/07 e-mail from A. Lourie to M. Menchel, J. Sloman, A. Marie VilVana re meeting with G. Lefcourt with attached email from G. Lefcourt re solicitation for meetings Attorney-Client Privilege Work Product Suppl. Box

ege Work Product Investigative privilege Also contains information subject to privacy rights of victims who are not parties to this litigation Suppl. Box #3 P-013282 Thru P-013283 7/9/08 Email from A. Marie Villafafia to A. Acosta, J. Sloman, K. Atkinson, and FBI re proposed response to Gold

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

8/16/2013 Page 30 of 70 Bates Range Description Privilege(s) Asserted Victims' Objections Box #2 P-009114 Thru 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

5/08 email from A. Marie Villafarla to A. Acosta, J. Sloman, R. Senior, K. Atkinson re "Jeffrey Epstein Agreement" discussing 6/24/08 email from A. Marie Villafafia to R. Black and J. Goldberger concerning the binding nature of the Agreement Attorney-Client Privilege Work Product Deliberative Process No Fac

P-013865 E-mail, Marie Villafana to Matthew Menchel, July 13, 2007, 3:14 p.m., RE: 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 Atty work-product atty-client privilege Inade

fafia re negotiations with attached correspondence; ■ 9/17/07 e-mail from A. Marie Villafafia to R. Garcia A. Lourie re negotiation strategy Suppl. Box #3 P-013609 Thru P-013615 File folder entitled "0 Target Letter" containing copy of signed letter and contact info for counsel for target

t Deliberative Process Suppl. Box #3 P-13351 Thru P-013361 File folder entitled "12/21/07 Lefkowitz to Acosta" containing handwritten notes by A. Marie Villafafia, 12/21/07 letter from J. Lefkowitz to A. Acosta re performance of NPA and appeal to Washington with attorney handwritten notes Attorney-

g 8/15/08 e-mails from A. Marie Villafafia to A. Acosta, J. Sloman, R. Senior, K. Atkinson, D. Lee re follow up on Agreement and from A. Acosta to Ann Marie Villafana on issue of Special Master with attached 8/15/08 emails from A. Marie Villafafia to A. Acosta, J. Sloman, R. Senior, K. Atkinson, D. Lee re Agreem

Process Suppl. Box #3 P-013554 Thru File folder labeled "E-mails Re Plea Negotiations" containing: ■ 11/28/07 e-mail from A. Laurie to A. Marie Villafafta, A. Oosterbaan, R. Garcia re non-prosecution agreement, with attached correspondence; ■ 9/19/07 e-mail from A. Marie Villafafia to A. Lourie,

, 2007, 3:14 p.m., RE: 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 Any work-product atty-client privilege Suppl. Box 3 P-013866 E-mail, Marie Villafana to Jeff Sloman, Matthe

ege Work Product Investigative privilege Also contains information subject to privacy rights of victims who are not parties to this litigation Suppl. Box #3 P-013282 Thru P-013283 7/9/08 Email from A. Marie Villafafia to A. Acosta, J. Sloman, K. Atkinson, and FBI re proposed response to Gold

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

rials; Attorney Conduct at Issue ftom J. Leflcowitz to A. Acosta re performance of NPA and appeal to Washington with attorney handwritten notes Suppl. Box #3 P-013362 Thm P413366 File folder labeled "12/26/07 Le&owitz to Acosta" containing 2 copies of draft letter from A. Acosta to J. Lefkowi

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

to which the crime-fraud-misconduct exception applies on this basis is found on page 3 of the supplemental privilege log (DE 216-1), with regard to Suppl. Box #3 P-013342 to P-013350. The entry reads: "File folder entitled `12/05/07 Starr to Acosta' containing drafts of 11/30/07 letters from A. Acost

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

to which the crime-fraud-misconduct exception applies on this basis is found on page 3 of the supplemental privilege log (DE 216-1), with regard to Suppl. Box #3 P-013342 to P-013350. The entry reads: "File folder entitled '12/05/07 Stan• to Acosta' containing drafts of 11/30/07 letters from A. Acost

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

to which the crime-fraud-misconduct exception applies on this basis is found on page 3 of the supplemental privilege log (DE 216-1), with regard to Suppl. Box #3 P-013342 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

hts Act filed by United States of America. (previously filed as 7 sealed document) (bs) (Entered: 07/15/2008) 14 UNSEALED DECLARATION signed by : A. Marie Villafana. re 13 Response to Victim's Emergency Petition by United States of America. (previously filed as 8 sealed document) (bs) (Entered: 07/15/2008) 5

8) 14 UNSEALED DECLARATION signed by : A. Marie Villafana. re 13 Response to Victim's Emergency Petition b

09/02/2011) 09/16/2011 95 Unopposed MOTION for Extension of Time to File Response/Reply as to 93 MOTION to Intervene For Limited Intervention, 94 Suppl ment b ni tates of America. (Attachments: # 1 Text of Proposed Order) ) (Entered: 09/16/2011) 09/16/2011 96 RESPONSE in Opposition re 93 MOTIO