Epstein Secrets

e Also contains documents subject to privacy rights of victims who are not parties to this litigation Box #3 P-013227 April 23, 2008 Memo from Jeffrey Sloman to Office of Professional Responsibility re Self Reporting, Corrected Version of the previously submitted April 21, 2008 Letter to OPR Privacy Ac

ter with attorney handwritten notes Attorney-Client Privilege Work Product Suppl. Box #3 P-013334 Thru P-013337 File folder entitled "11/13/07 Sloman to Lefkowitz (was this sent?" containing draft 11/13/07 letter from responding to J. Lefkowitz's letter Attorney-Client Privilege Work Product

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

orized release; Material Severable; Redaction; No Assertion by Victims Box #2 P-008517 Thru P-008535 6/25/2007 Letter from Gerald Lefcourt to Jeffrey Sloman and Andrew Lourie [pursuant to Court's Order, not being withheld as privileged — will be produced to opposing counsel upon lift of stay by 11th C

onship; Claims Against Public Prosecutor; Overriding Need; Attorney Conduct at Issue Suppl. Box #3 P-013334 Thru File folder entitled "11/13/07 Sloman to Leflcowitz (was this sent?)" containing draft 11/13/07 letter from J. Sloman Attorney-Client Privilege Inadequate Log; No Factual Underpinning

(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

] 20. Admit. [I know that Menchel now has a business relationship with Epstein. I don't have any documentary evidence, but I have been told this by Jeff Sloman.] 21. [I don't know.] 22. [OPR needs to answer these.] 23. Admit. 24. [I don't know what "valuable consideration" means. I had heard a rumor that

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

Villafana, Ann Marie C. (USAFLS) From: Villa/one, Ann Marie C. (USAFLS) Sent: Monday. September 10, 2007 3:52 PM To: Sloman, Jeff (USAFLS) Subject: Plea Hi Jeff—Just talked with Andy. I am sure that he communicated these thoughts, but I wanted to mention a couple of th

ntion a couple of things that I hoped to talk to you about. There are two things that I think might lx tricks up the sleeves of the defense. First, Lilly Ann had mentioned in our Miami meeting with all the defense attorneys that Epstein would be willing to do a split sentence of community control followe

Villafana, Ann Marie C. (USAFLS) From: Villafana, Ann Marie C. (USAFLS) Sent: Monday. September 10. 2007 3:52 PM To: Sloman, Jeff (USAFLS) Subject: Plea Hi Jeff — Just talked with Andy. I am sure that he communicated these thoughts, but I wanted to mention a couple of

ntion a couple of things that I hoped to talk to you about. There arc two things that I think might be tricks up the sleeves of the defense. First, Lilly Ann had mentioned in our Miami meeting with all the defense attorneys that Epstein would be willing to do a split sentence of community control followe