Epstein Secrets

ilege Log, which is attached hereto. The documents referenced in the Privilege Log are being delivered today to the Chambers of U.S. District Judge Kenneth A. Marra for ex parte in camera review, pursuant to the Court's Omnibus Order. Respectfully submitted, UNITED STATES ATTORNEY By: Assistant United States

18, 2008, attorney Katherine Ezell representing some of Epstein's victims emailed the line prosecutor, asking whether the NPA was "blessed" by Judge Marra. The line prosecutor emailed back: "As far as I know, Judge Man has not ever seen the agreement or these notification letters.... 1 don't know if t

osecutor, asking whether the NPA was "blessed" by Judge Marra. The line prosecutor emailed back: "As far as I

P-013872 E-mailil and p.m., FW: Lefcourt to Sanchez a 22, to Matthew ■ Any work-product May 22, 2007, 3:11 a Mi l with e-mail from , and Lilly Ann 2007 2:05 p.m. attached Suppl. Box 3 P-013873 E-mail 2007, 10:52 . e-mail from (May 14 2007 10:38 to and May 14, Any work-product RE: Oper

t relate to multiple cases shall be styled with all of the case names and numbers and shall be filed in Case No. 08-80119-CIV-MARRA. Signed by Judge Kenneth A. Marra_on 5/14/2009. EFTA00226850 05/14/2009 15 05/15/2009 16 05/19/2009 17 05/20/2009 18 05/20/2009 19 05/22/2009 20 05/27/2009 21 05/28/2009

chments: # 1 Exhibit Letter Dated December 6. 2007 from US Attorney's Office to Defendant's Counsel, # 2 Exhibit Transcript of Hearing before Judge Marra, Dated June 17. 2009)(Prieto, Peter) (Entered: 05/26/2010) NOTICE of Attorney Appearance by Michael James Pike on behalf of Jeffrey Epstein (Pike. M

ounsel, # 2 Exhibit Transcript of Hearing before Judge Marra, Dated June 17. 2009)(Prieto, Peter) (Entered: 05

ON to Quash Service of Process and Supporting Memorandum of Law by Jeffrey Epstein. (Attachments: # 1 Exhibit Affidavit of Richard Barnett)(Sanchez, Lilly Ann) (Entered: 10/29/2010) Clerks Notice to Filer re 6 Certificate of Service. 5 Certificate of Service. Document Not Captioned ; CORRECTIVE ACTION REQ

of the agents and myself the matter was, in fact, "currently under investigation." The NPA was signed on September 24, 2007. The letters that Judge Marra referred to in his order were dated January 10, 2008 and May 30, 2008. During the period that the letters were sent, Epstein was asserting that: (I

as signed on September 24, 2007. The letters that Judge Marra referred to in his order were dated January 10,

gued above, but I will try to collect them into general categories in chronological order. 1. b. I did not want to meet with counsel for Epstein (Lilly Ann and Gerald Lefcourt) prior to completi.n investigation. My co-counsel agreed with me. Our supervisor, M, overruled us. and I did not want to h

pstein PLAINTIFF: L, C DEFENDANT: Epstein, Jeffrey DOCKET CASE NUMBER: 9:10cv80447 FILING DATE: 3/31/2010 JURISDICTION: Federal Question JUDGE: Marra, Kenneth A REFERRED TO: Magistrate Judge Johnson, Linnea R NATURE OF SUIT: 320 Assault, Libel & Slander FILING TYPE: Civil CAUSE: Fed. Question:

tates of America Material Witness: Jean Luc Bruhnel DOCKET CASE NUMBER: 9:08cv80893 FILING DATE: 8/13/2008 JURISDICTION: Federal Question JUDGE: Kenneth A. Marra REFERRED TO: Magistrate Judge Linnea R. Johnson NATURE OF SUIT: 360 Personal Injury FILING TYPE: Civil CAUSE: no cause specified JURY DEMAND: Pl

of Law University of Utah 332 South 1400 East Room 101 Salt Lake City, UT, USA 68333 <i>pro Hac Vice</ I> Email: DEFENDANT ATTORNEY(S): Sanchez, Lilly Ann [COR LD NTC] Fowler White Burnett 1395 Brickell Avenue 14TH Floor Miami, FL, USA 33131-3302 Fax: Email: Goodner, Helaine S [COR LD NTC] Fowler

n (Pike. Michael) (Entered: 06/30/2010) 06/30/2010 180 ORDER granting 161 Motion for open trial and to identify Jane Doe at trial. Signed by Judge Kenneth A. Marra on 6/30/2010. (mkz) (Entered: 06/30/2010) 06/30/2010 181 *Endorsed Order requiring expedited response. Response to (DE 175) Plaintiff's Motion for

ntry for proceedings held before Judge Kenneth A. Marra: Telephonic Status Conference held on 6/16/2010.

Marra on 7/20/2010. (ir) (Entered: 07/20/2010) 09/02/2010 NOTICE of Attorney Appearance by Lilly Ann Sanchez on behalf of Jeffrey Epstein (Sanchez, Lilly Ann) (Entered: 09/02/2010) EFTA00226950 09/02/2010 213 Defendant's MOTION for Hearing Jeffrey Epstein's Request for Oral Argument in Connection wit

THERN DISTRICT OF FLORIDA Case No. 08-80736-Mise-Marra/MatthrA mari JANE DOE #1 and JANE DOE #2, Petit

ommunication or influence" is so vague and potentially broad that a denial is problematic. I also have never seen all of the emails between Guy and Lilly Ann and Alex, Jeff, Matt, Andy, and Rolando (and any others in DC).] 19. [Again, I don't know how to answer this. The RFA does not use the word "former

THERN DISTRICT OF FLORIDA Case No. 08-80736-Mise-Marra/MatthrA mari JANE DOE #1 and JANE DOE #2, Petit

ommunication or influence" is so vague and potentially broad that a denial is problematic. I also have never seen all of the emails between Guy and Lilly Ann and Alex, ' cS ",\ . I " ' b (and any others in DC).] 19. [Again, I don't know how to answer this. The RFA does not use the word "former," so

UTHERN DISTRICT OF FLORIDA Case No. 08-80736-Civ-Marra/Johnson JANE DOE #1 and JANE DOE #2 v. UNITED

(May 23, 2007, 5:00 p.m.), Andrew Lourie to Gerald Lefcourt (May 22, 2007, 6:32 p.m.), and Gerald Lefcourt to Andrew Lourie Marie Villafana, and Lilly Ann Any work-product Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Waiver, Claims Against Public Prosecutor; Overriding Need; Attorney C

r-white.com) Subject: Your letter Hi Lilly — I did get a copy of your letter, thanks. I will see you tomorrow morning. Regards, 113 08-80736-CV MARRA 002145 EFTA00227259

• C. (USAFLS) From: C. (USAFLS) Sent: Monday, June 25, 2007 4:54 PM To: Sanchez, Lilly Ann ([email protected]) Subject: Your letter Hi Lilly — I did get a copy of your letter, thanks. I will see you tomorrow morning. Regards, 1

TA00009351 --- PAGE BREAK --- Page 124 1 believe you had any understanding of what amount of jail time 2 was in play at this point when tells Lilly Ann 3 Sanchez -- 4 5 6 7 8 9 A I can't pinpoint that timeline -- Q All right. A -- to that degree. Q All right. A Of accuracy. Q He als

TA00009351 --- PAGE BREAK --- Page 124 1 believe you had any understanding of what amount of jail time 2 was in play at this point when tells Lilly Ann 3 Sanchez -- 4 5 6 7 8 9 A I can't pinpoint that timeline -- Q All right. A -- to that degree. Q All right. A Of accuracy. Q He als

TA00009351 --- PAGE BREAK --- Page 124 1 believe you had any understanding of what amount of jail time 2 was in play at this point when tells Lilly Ann 3 Sanchez -- 4 5 6 7 8 9 A I can't pinpoint that timeline -- Q All right. A -- to that degree. Q All right. A Of accuracy. Q He als

ay, and what would your response be though to -- 4 are you -- are you aware of the CVRA litigation that went on? 5 6 7 8 A Yes. Q From Judge Marra? A Yes. Q So, one of the issues that comes up in Judge 9 Marra's decision is, he made a finding that the government 10 violated the CVRA beca

ation that went on? 5 6 7 8 A Yes. Q From Judge Marra? A Yes. Q So, one of the issues that comes up

ation that went on? 5 6 7 8 A Yes. Q From Judge Marra? A Yes. Q So, one of the issues that comes up

ay, and what would your response be though to -- 4 are you -- are you aware of the CVRA litigation that went on? 5 6 7 8 A Yes. Q From Judge Marra? A Yes. Q So, one of the issues that comes up in Judge 9 Marra's decision is, he made a finding that the government 10 violated the CVRA beca

ation that went on? 5 6 7 8 A Yes. Q From Judge Marra? A Yes. Q So, one of the issues that comes up

ay, and what would your response be though to -- 4 are you -- are you aware of the CVRA litigation that went on? 5 6 7 8 A Yes. Q From Judge Marra? A Yes. Q So, one of the issues that comes up in Judge 9 Marra's decision is, he made a finding that the government 10 violated the CVRA beca