Epstein Secrets

ana to request for conference call prior to call with Roy Black B-76 8/13/2008 Email from Bob Senior to Karen Atkinson, Alex Acosta, Jeff Montan, Dexter Lee, and Marie Villalatla regarding Epstein and call with Jay' Lefkowitz B-77 8/13/2008 Email response from Alex Acosta to Karen Atkinson, Bob Senior,

respondence and telephone conference with J. Lefkowitz B-79 8/14/2008 Villafana -;enior Email response to 8/14/08 email from Villafaiia advising Dexter disagrees with strategy 8/14/2008 Villafana, cc: Atkinson Lefkowitz Email re Follow up point regarding victims B-80 8/14/2008 Status Conf be

e Dalton School (return date 9/29/09) 9/26/2006 Acosta, Mulvihill, Sloman, Noto, Waters, L°urie' Stefin, Atkinson, Garcia, Brown, Boscovich, Martinez Villafaila Memo regarding changes to Child Explotation Statutes in Tide 18 16 10/19/2006 Subpoena to Individual #28 (return date 10/27/06) 10/2

the following using the Court's CM/ECF system: Dexter Lee A. Marie Villafafia Assistant U.S. Attorneys 5

4 WL 1773207, at *14 (S.D.Fla. July 20, 2004); Plante v. USF & G Speciality Ins. Co., No. 03-23517-Civ, 2004 WL 741382, at *5 n. 3 (S.D. Fla. 2004); Martinez v. Weyerhaeuser Mortgage Co., 959 F.Supp. 1511, 1515-16 (S.D.Fla.1996)." Felicia v. Celebrity Cruises, Inc., 2012 WL 6869829 at *2 (S.D. Fla. Nov.

ent and Cross-Motion for Summary Judgment was filed with the Clerk of the Court and served on counsel on the attached service list using CM/ECF. Is/Dexter A. Lee Dexter A. Lee Assistant United States Attorney 31 EFTA00799855 Case 9:08-cv-80736-KAM Document 408 Entered on FLSD Docket 06/06/2017 Page 32 of 3

Q. 6 "A judicial admission is a formal concession in the pleadings or stipulations by a party or counsel that is binding on the party making them." Martinez v. Bally's Louisiana. Inc. 244 F.3d 474, 476-77 (5th Cir. 2001). 23 EFTA00799847 Case 9:08-cv-80736-KAM Document 408 Entered on FLSD Docket 06/0

ent and Cross-Motion for Summary Judgment was filed with the Clerk of the Court and served on counsel on the attached service list using CM/ECF. Is/Dexter A. Lee Dexter A. Lee Assistant United States Attorney 31 EFTA00591492 Case 9:08-cv-80736-KAM Document 401-2 Entered on FLSD Docket 06/02/2017 Page 33 of

Q. 6 "A judicial admission is a formal concession in the pleadings or stipulations by a party or counsel that is binding on the party making them." Martinez v. Bally's Louisiana. Inc. 244 F.3d 474, 476-77 (5th Cir. 2001). 23 EFTA00591484 Case 9:08-cv-80736-KAM Document 401-2 Entered on FLSD Docket 06

. 12. I never learned any confidential, non-public information about the Epstein matter. 13. In late December 2007, I had an "exit meeting" with Dexter Lee, the Office's ethics officer. As part of that meeting, Mr. Lee reviewed with me the Department of Justice's post-employment restrictions. Based on

re "merely a statement of assertion or concession made for some independent purpose," and may be controverted or explained by the party who made it. Martinez v. Bally's Louisiana, Inc., 244 F.3d 474, 476-77 (V' Cir. 2001), citing McNamara v. Miller, 269 F.2d 511, 515 (D.C. Cir. 1959). In contrast, a judi

r. 12. I never teamed any confidential, non-public information about the Epstein matter. 13. In late December 2007, I had an "exit meeting" with Dexter Lee, the Office's ethics officer. As part of that meeting, Mr. Lee reviewed with me the Department of Justice's post-employment restrictions. Based on

re "merely a statement of assertion or concession made for some independent purpose," and may be controverted or explained by the party who made it. Martinez I. Bally's Louisiana, Inc., 244 F.3d 474, 476-77 (V' Cir. 2001), citing McNamara'. Miller, 269 F.2d 511, 515 (D.C. Cir. 1959). In contrast, a judic