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

reement Thrown Out," with attorney's notes written on margin Ally work-product Suppl. Box 3 P-013838 Thru P-013841 Letter from Paul Cassell to Wifrcdo A. Ferrer, December 10, 2010, Subject: Request for Investigation of Jeffrey Epstein Prosecution, with underlines, written notes, and comments by DOJ attor

/2011 Page 10 of 10 CERTIFICATE OF SERVICE The foregoing document was served on March 21, 2011, on the following using the Court's CM/ECF system: A. Marie Villafafla Assistant U.S. Attorney 500 S. Australian Ave., Suite 400 West Palm Beach, FL 33401 (561) 820-8711 Fax: (561) 820-8777 E mail: ann.marie.c.vill

office file a corrected declaration and accompanying explanation. The first statement is found at page 3 to 4 of the July 9th, 2008 declaration of Marie Villafafia. There a provision in a plea agreement with Mr. Jeffrey Epstein is recounted. As we understand the Government's current position in this case, it is

n been convicted at trial." Declaration of Marie Villafana, July 9, 2008 (doe. #14) at 3-4. The affidavit

se. 6 08-80736-CV-MARRA 000879 EFTA00230703 1 • Case 9:08-cv-80736-KAM Document 49 Entered on FLSD Docket 03/21/2011 Page 7 of 10 Letter from Wifrcdo A. Ferrer to Paul G. Cassell (March 15, 2011).3 Accordingly, the victims were left with no choice but to file a motion without stipulated facts. Contemporaneo

13) (citing Declaration of Asst. U.S. 5 EFTA00230177 Case 9:08-cv-80736-KAM Document 51 Entered on FLSD Docket 03/21/2011 Page 6 of 10 Attorney Marie Villafafia). These same subjects were also discussed at length at the Court's July 11, 2008, hearing on the matter. See, e.g., Tr. July 11, 2008, at 3-4, 18-1

n been convicted at trial." Declaration of Marie Villafana, July 9, 2008 (doe. #14) at 3-4. The affidavit

rly viewed as a "civil" case. 6 EFTA00230125 1 Case 9:08-cv-80736-KAM Document 49 Entered on FLSD Docket 03/21/2011 Page 7 of 10 • Letter from Wifrcdo A. Ferrer to Paul G. Cassell (March 15, 2011).3 Accordingly, the victims were left with no choice but to file a motion without stipulated facts. Contemporaneo