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as 1 through 182. We have an additional set of documents that are 183 through 215, that I do not believe are responsive to your notice. They are Bates-numbered emails. I don't know if you want to have these produced and made available to everyone or not. MR. SCAROLA: Are those the documents that
ing to Farmer Jaffe. Q And when you talk about a copy, are you talking about a hard copy? A A hard copy of the contents of the disc after being Bates stamped. Q Why were the discs delivered to the Miami office? A We had the facilities in the Miami office to do this job. Q What happened to t
as the law clerk to whom you spoke? A Chris Hewitt. Q Who among those individuals is still a Fowler White employee? A Everybody except for Ms. Sanchez. Q Did you ever speak to Judge Carney with respect to any matters relating to this disc or these discs? A I myself have not. Q Did any agent
signed Assistant United States Attorney, hereby gives notice of its filing of its Second Supplemental Privilege Log. The index has been marked with Bates Numbers P-013970' thru P-014923. The documents referenced in the Second Supplemental Privilege Log will be delivered today to the Chambers of U.S.
l Privilege Log, the undersigned discovered an error on the Supplemental Privilege Log, that is, the last entry states that the last document bears Bates Numbers P-013956 thru P-013846. The correct Bates range for that document is P-013956 thru P-013969 [14 pages]. 1 EFTA00185428 Case 9:08-cv-8073
fcourt to and Lilly Ann Sanchez (May 22, 2007, 2:05 p.m. attached Any work-product Suppl. Box 3 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-01387
the Government (Bates 0001-04), court pleadings filed by the victims themselves or other victims, by Epstein, or by news media organizations (e.g., Bates 00142-88, 00229-31, 281-311, 00668-69), public court rulings on Epstein related matters (e.g., Bates 0008-10, 0012-14. 0036-86, 00190-228), public
cuments apply to which of the victims' document production requests. Instead, the Government has simply taken more than 13,000 pages of documents, Bates stamped them in no particular order (or at least no order that the victims can discern), and then asserted that they are all privileged for various
rison," "Visoki," "Rogers," "Hammond," Roxburgh,' r afana, " "Florida SS Foundation," "Starr," "Black," "Goldberger," "Jeffrey," "Australian,"' "Sanchez," "358 El Brillo Way" appears and which are connected to or related to Jeffrey Epstein, Jack Goldberger, or the Jeffrey Epstein investigation or pr
he privilege logs that the Government has produced that OPR generated a great deal of correspondence (at least 46 pages) regarding this request. See Bates P- 013909 to P-013955. Of course, improper influences being brought to bear on the Epstein prosecution would support the victims' allegations that t
," "Visoki," "Rogers," "Hammond," Roxburgh," S, " "Florida Science Foundation," "Starr," "Black," "Goldberger," "Jeffrey," "Australian," "Lewis," "Sanchez," "358 El Brillo Way" appears and which are connected to or related to Jeffrey Epstein, Jack Goldberger, or the Jeffrey Epstein investigation or pr
tein, who had agreed to pay directly all such fees and costs. It was then determined that the number of documents that would need to be printed and Bates stamped exceeded 27,000, which would have resulted in significant costs to the Farmer Jaffe law firm. Consequently, Farmer Jaffe requested the Cour
t filed by a sex offender billionaire, to come into the possession of privileged documents. On November 11, 2010, to aid in satisfying concerns, Ms. Sanchez specifically warranted that, "I am speaking to my IT department and they believe that the storing of 3 EFTA00793670 any documents can be bypasse
d Victims' Services Info Clean Copies of Agreement without App D & E (file folder) Relevant Privileged Docs (brown redwell) — 2 copies clipped with Bates Numbers P-003713-P-003746; P- 008516; P-009105-P-009111; P-012624-P-012642; P-012646; P-014011-P-014025; P-014059-P-014061; P-014440; P-014444; P-01
court; 6/25/07 Lefcourt to Sloman & Lourie; 7/6/07 Lefcourt & Dershowitz to Sloman; 7/25/07 Lefcourt & Dershowitz to Menchel; 8/2/07 EFTA00066350 Sanchez to Menchel; 8/3/07 Menchel to Sanchez; 9/17/07 to Lekowitz; 10/25/07 Sloman Itr to Davis; 11/8/07 Lefkowitz to Sloman; 11/13/07 Sloman to Lefkowitz
he privilege logs that the Government has produced that OPR generated a great deal of correspondence (at least 46 pages) regarding this request. See Bates P- 013909 to P-013955. Of course, improper influences being brought to bear on the Epstein prosecution would support the victims' allegations that t
n," "Visoki," "Rogers," "Hammond," Roxburgh," " "Florida Science Foundation," "Starr... " "Black" "Goldberger," "Jeffrey," "Australian," "Lewis," "Sanchez," appears and which are connected to or related to Jeffrey Epstein, Jack Goldberger, or the Jeffrey Epstein investigation or prosecution; e) All d
he privilege logs that the Government has produced that OPR generated a great deal of correspondence (at least 46 pages) regarding this request. See Bates P- 013909 to P-013955. Of course, improper influences being brought to bear on the Epstein prosecution would support the victims' allegations that t
ki," "Rogers," "Hammond," Roxburgh," "Villafana, " "Florida Science Foundation," "Starr," "Black," "Goldberger," "Jeffrey," "Australian," "Lewis," "Sanchez," "358 El Brillo Way" appears and which are connected to or related to Jeffrey Epstein, Jack Goldberger, or the Jeffrey Epstein investigation or pr
he privilege logs that the Government has produced that OPR generated a great deal of correspondence (at least 46 pages) regarding this request. See Bates P- 013909 to P-013955. Of course, improper influences being brought to bear on the Epstein prosecution would support the victims' allegations that t
ocess Crime-Fraud-Misconduct; Crime-Fraud- Thru ■ 7/13/2007 letter from Lilly Ann 6(e) Misconduct; Not in Anticipation of Litigation; P-011966 Sanchez to Andrew Lourie with handwritten attorney (Lourie) notes; Attorney-Client Privilege Ordinary Government Communication; No Attorney-Client Re
Entities connected to both Bates and Sanchez

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSONLeon Black
PERSON
Jay Lefkowitz
PERSON
Prince Andrew
PERSONJack Goldberger
PERSON
Department of Justice
ORGANIZATION
United States
LOCATIONSouthern District
LOCATION
Bradley Edwards
PERSON
Alexander Acosta
PERSONJane Doe
PERSONJeffrey Pagliuca
PERSONRoy Black
PERSON
Alan Dershowitz
PERSONthe Southern District
LOCATION
A. Marie Villafana
PERSON
Kenneth Marra
PERSON
Michael Cohen
PERSONGerald Lefcourt
PERSON