Epstein Secrets

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 EFTA00211410 Case 9:08-cv-8073

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.

Privilege Privacy Act P-014011 thru P-014025 7/3/2007-7/13/2007 email chain between Matt Menchel and Marie Villafafia regarding disagreement on Menchel's plea negotiations and written request for meeting between USAO management and victims 6(e) Work Product Deliberative Process Investigative Pri

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

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 (was this sent?); 11/28/07

court to Lourie; 6/18/07 to Lefcourt; 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 Slom

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 SO NY_GM_02742818 EFTA_00229467

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.

e Privilege Privac Act P-014011 thru P-014025 7/312007-7/1312007 email chain between Man Menchel and Marie Villafafia regarding disagreement on Menchel's plea negotiations and written request for meeting between USAO management and victims 6(e) Work Product Deliberative Process Investigative Pri

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 SIDNY_GM_02 742858 EFIA_0022950

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.

e Privilege Privac Act P-014011 thru P-014025 7/312007-7/1312007 email chain between Man Menchel and Marie Villafafia regarding disagreement on Menchel's plea negotiations and written request for meeting between USAO management and victims 6(e) Work Product Deliberative Process Investigative Pri

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

dmits that it has information about a personal or business relationship between Jeffrey Epstein and another prosecutor involved in the Epstein case, Matthew Menchel. Answers I0 EFTA00081125 Case 9:08-cv-80736-KAM Document 225-1 Entered on FLSD Docket 08/16/2013 Page 11 of 64 to Requests for Admission at I 2

chel has a personal or business relationship with defendant Jeffrey Epstein. Gov't Answers to RFA's ¶ 20. This could potentially show misconduct by Menchel, and also potentially a motive to violate the victims' rights as explained previously. The Government's privilege log has numerous entries showing

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

nchel has a personal or business relationship with defendant Jeffrey Epstein. Gov't Answers to RFA's 120. This could potentially show misconduct by Menchel, and also potentially a motive to violate the victims' rights as explained previously. The Government's privilege log has numerous entries showing

attached as Exhibit 2 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 under seal, they are at this time filed under seal with the Court. 9. In Septemb

n to use 'a' versus `the' and other minutiae. When you and I could not reach agreement, you repeatedly went over my head, involving Messrs. Lourie, Menchel, , and Acosta in the negotiations at various times." U.S. Attorney's Correspondence at 269. 28. The December 13, 2007, letter also reveals that th

attached as Exhibit 2 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 under seal, they are at this time filed under seal with the Court. 9. In Septemb

n to use 'a' versus `the' and other minutiae. When you and I could not reach agreement, you repeatedly went over my head, involving Messrs. Lourie, Menchel, Sloman, and Acosta in the negotiations at various times." U.S. Attorney's Correspondence at 269. 28. The December 13, 2007, letter also reveals th

months' imprisonment. Parts of the correspondence are attached as Exhibit C (hereinafter cited as "U.S. Attorney's Correspondence" and referenced by Bates number stamp). 7. Counsel for Jane Doe #1 and Jane Doe #2 received copies of half of the e-mail correspondence (the half reflecting communication

n to use 'a' versus 'the' and other minutiae. When you and I could not reach agreement, you repeatedly went over my head, involving Messrs. Lowrie, Menchel, and Acosta in the negotiations at various times." U.S. Attorney's Correspondence at 269. The letter also stated: "Three victims were notified sh

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

No Attorney-Client Relationship; Waiver; Claims Against Public Prosecutor, Overriding Need; Attorney Conduct at Issue Epstein, with e- mail from Menchel (July 5, 2007, 3:30 p.m.), Villafana to Menchel (July 4, 2007, 5:16 p.m.), and Sloman to Villafana (July 3, 2007, 1:47 p.m.), attached Suppl. Bo