Epstein Secrets

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

m to Alex Acosta, Work Product Deliberative Process and regarding state cases mentioned by Epstein's counsel P-014443 12/14/2007 email from Villafafia to Alex Acosta, , and with draft letters to State Attome 's Office and victims Work Product Deliberative Process P-014444 12/17/2007 email fr

t response to Jay Leflcowitz and victim notification letters Work Product Deliberative Process P414355 thru P-014361 12/3/2007 emails between Villafafia, Alex Acosta, and Work Product Deliberative Process regarding history of plea negotiations and drafting response to correspondence from Jay Lekow

presumed that Congress acts intentionally and purposely in the disparate inclusion or exclusion." Duncan v. Walker 533 U.S. 167, 173 (2001), citing Bates v. United States 522 U.S. 23, 29-30 (1997). Petitioners contend the government was required under § 3771(a)(5) to notify them of the negotiation o

ent and learned that Epstein's state court change of plea hearing was scheduled for 8:30 a.m., Monday, June 30, 2008. D.E. 403-19 at 21, 1 38. AUSA Villafafia called attorney Edwards, told him of the June 30, 2008 hearing, and stressed the importance of the hearing.2 Thus, the government provided petitione

o pursue and foist himself upon those victims who have never reached out and asked to confer. Neither Jane Doe 1 nor Jane Doe 2 ever contacted AUSA Villafafia or FBI Special Agent Kuyrkendall regarding the case, despite being provided their phone numbers and addresses. D.E. 403-19,915. Since the Court's s

presumed that Congress acts intentionally and purposely in the disparate inclusion or exclusion." Duncan v. Walker 533 U.S. 167, 173 (2001), citing Bates v. United States 522 U.S. 23, 29-30 (1997). Petitioners contend the government was required under § 3771(a)(5) to notify them of the negotiation o

ent and learned that Epstein's state court change of plea hearing was scheduled for 8:30 a.m., Monday, June 30, 2008. D.E. 403-19 at 21, 1 38. AUSA Villafafia called attorney Edwards, told him of the June 30, 2008 hearing, and stressed the importance of the hearing.2 Thus, the government provided petitione

o pursue and foist himself upon those victims who have never reached out and asked to confer. Neither Jane Doe 1 nor Jane Doe 2 ever contacted AUSA Villafafia or FBI Special Agent Kuyrkendall regarding the case, despite being provided their phone numbers and addresses. D.E. 403-19,915. Since the Court's s

attached as Exhibit J to the Edwards Declaration accompanying this filing (hereinafter cited as "U.S. Attorney's Correspondence" and referenced by Bates number stamp).1 Because Epstein has moved to keep these documents from the public, they are at this time filed under seal with the Court. 8. At the

49, 58. Through diligent efforts, counsel for Jane Doe #1 and Jane Doe #2 received copies of half of the e-mail correspondence (the half reflecting Villafafia's communications to defense counsel) on about June 30, 2010. See Edwards Declaration at & &20-22. 5 EFTA00206839 10. The correspondence also sh

rsigned Assistant United States Attorney, hereby gives notice of its filing of its Third Supplemental Privilege Log. The index has been marked with Bates Numbers P-014924 thru P-015267. The documents referenced in the Third Supplemental Privilege Log will be delivered tomorrow to the Chambers of U.S.

8-80736-CV-MARRA THIRD SUPPLEMENTAL PRIVILEGE LOG - BOX #5 Bates Range Description Privilege(s) Asserted P-014924 5/27/2008 emails between A.M. Villafafia and K. Atkinson regarding report of new state plea deal for J. Epstein Work Product Deliberative Process P-014925 thru P-014927 5/27/2008 emai

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

of these 39 pages is: "File folder entitled 'CORR RE GJ SUBPOENAS' containing correspondence related to various grand jury subpoenas and attorney (Villafafia) handwritten notes." 64. Another good illustration of the inadequacies of the privilege log is provided on page 20 of the first privilege log, with

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

hru summary chart, witness/victim names and Contains information and Anticipation of Litigation; Improper P-002386 contact list, attorney (Villafafia) documents subject to Invocation; Overriding Need; Claims Against handwritten notes, 302s, portions of state investigative privilege. Public Pro

e attached as Exhibit J to the Edwards Declaration accompanying this filing (hereinafter cited as "U.S. Attorney's Correspondence" and referenced by Bates number stamp).' Because Epstein has moved to keep these documents from the public, they are at this time filed under seal with the Court. Threugh-

edi-te-disesss what-I-may-diselese-to,the-gek-regarding-the-agreemenWl-U:SrAnemeyls-Cerrespondenee at-1-56: 13. On about September 26, 2007, AUSA. Villafafia sent an e-mail to Lefkowitz, a copy of which is attached hereto as Exhibit in-whielt-she-etatedailiay—Can-you-give-me-a-eall at-564-209--Enentl-th

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

of these 39 pages is: "File folder entitled 'CORR RE GJ SUBPOENAS' containing correspondence related to various grand jury subpoenas and attorney (Villafafia) handwritten notes." 64. Another good illustration of the inadequacies of the privilege log is provided on page 20 of the first privilege log, with