former President Bill Clinton, Andrew Albert Christian Edward (aAda Prince Andrew, Duke of York), Harvard Law Professor Alan Dershowitz, Ken Starr, Lillian Sanchez, Jay Lefkowitz, and Roy Black on his behalf. EFTA00081144 Case 9:08-cv-80736-KAM Document 225-1 Entered on FLSD Docket 08/16/2013 Page 30 of 64

ve process privilege. 3 EFTA00191201 6. (a) Denied. (b) Denied. (c) Admitted. (d) Admitted. (e) Admitted to the extent that the reference to "Lillian Sanchez" was meant to refer to Lilly Ann Sanchez. (0 Admitted. (g) Admitted. 7. The government admits that, on about January 10, 2008, when Jane Doe # I

ormer President Bill Clinton, Andrew Albert Christian Edward (a/k/a Prince Andrew, Duke of York), Harvard Law Professor Alan Dershowitz, Ken Starr, Lillian Sanchez, Jay Lefkowitz, and Roy Black on his behalf. EFTA00204882 9. On January 10, 2008, Jane Doe #1 and Jane Doe #2 received letters from the FBI advi

ll Clinton; (b) Andrew Albert Christian Edward (a/k/a Prince Andrew, Duke of York); (c) Harvard Law Professor Alan Dershowitz; (d) Ken Starr; (e) Lillian Sanchez; (0 Jay Leflcowitz; and (g) Roy Black. 7. On about January 10, 2008, when Jane Doe #1 and Jane Doe #2 were sent letters advising them that "this

ormer President Bill Clinton, Andrew Albert Christian Edward (a/k/a Prince Andrew, Duke of York), Harvard Law Professor Alan Dershowitz, Ken Starr, Lillian Sanchez, Jay Lefkowitz, and Roy Black on his behalf. EFTA00205119 9. On January 10, 2008, Jane Doe #1 and Jane Doe #2 received letters from the FBI advi

ormer President Bill Clinton, Andrew Albert Christian Edward (a/k/a Prince Andrew, Duke of York), Harvard Law Professor Alan Dershowitz, Ken Starr, Lillian Sanchez, Jay Lefkowitz, and Roy Black on his behalf. EFTA00205257 9. On January 10, 2008, Jane Doe #1 and Jane Doe #2 received letters from the FBI advi

ormer President Bill Clinton, Andrew Albert Christian Edward (a/k/a Prince Andrew, Duke of York), Harvard Law Professor Alan Dershowitz, Ken Starr, Lillian Sanchez, Jay Lefkowitz, and Roy Black on his behalf. EFTA00205383 9. On January 10, 2008, Jane Doe #1 and Jane Doe #2 received letters from the FBI advi

ormer President Bill Clinton, Andrew Albert Christian Edward (a/k/a Prince Andrew, Duke of York), Harvard Law Professor Alan Dershowitz, Ken Starr, Lillian Sanchez, Jay Lefkowitz, and Roy Black on his behalf. EFTA00205296 9. On January 10, 2008, Jane Doe #1 and Jane Doe #2 received letters from the FBI advi

ll Clinton; (b) Andrew Albert Christian Edward (a/k/a Prince Andrew, Duke of York); (c) Harvard Law Professor Alan Dershowitz; (d) Ken Starr; (e) Lillian Sanchez; (0 Jay Leflcowitz; and (g) Roy Black. 7. On about January 10, 2008, when Jane Doe #1 and Jane Doe #2 were sent letters advising them that "this

ll Clinton; (b) Andrew Albert Christian Edward (a/k/a Prince Andrew, Duke of York); (c) Harvard Law Professor Alan Dershowitz; (d) Ken Starr; (e) Lillian Sanchez; (0 Jay Leflcowitz; and (g) Roy Black. 7. On about January 10, 2008, when Jane Doe #1 and Jane Doe #2 were sent letters advising them that "this

munications but not Epstein's for a number of the emails. (Epstein improperly withheld some of the e-mails without telling us, such as e-mails from Lillian Sanchez.) So turning over what Epstein said certainly can't be regarded as privileged. And the e- mails regarding the NPA are clearly within the scope of dis

munications but not Epstein's for a number of the emails. (Epstein improperly withheld some of the e-mails without telling us, such as e-mails from Lillian Sanchez.) So turning over what Epstein said certainly can't be regarded as privileged. And the e- mails regarding the NPA are clearly within the scope of dis

ry orders, Epstein's attorneys secretly withheld significant correspondence involving plea discussions by several of Epstein's attorneys, including Lillian Sanchez, Jay Lefkowitz, and Ken Starr. If this is true, as part of any privilege log they file, the defense attorneys should explain why they secretly and

ormer President Bill Clinton, Andrew Albert Christian Edward (a/k/a Prince Andrew, Duke of York), Harvard Law Professor Alan Dershowitz, Ken Starr, Lillian Sanchez, Jay Lefkowitz, and Roy Black on his behalf. EFTA00205870 9. On January 10, 2008, Jane Doe #1 and Jane Doe #2 received letters from the FBI advi

ormer President Bill Clinton, Andrew Albert Christian Edward (a/k/a Prince Andrew, Duke of York), Harvard Law Professor Alan Dershowitz, Ken Starr, Lillian Sanchez, Jay Lefkowitz, and Roy Black on his behalf. EFTA00205887 9. On January 10, 2008, Jane Doe #1 and Jane Doe #2 received letters from the FBI advi

ormer President Bill Clinton, Andrew Albert Christian Edward (a/k/a Prince Andrew, Duke of York), Harvard Law Professor Alan Dershowitz, Ken Starr, Lillian Sanchez, Jay Lefkowitz, and Roy Black on his behalf. EFTA00205920 9. On January 10, 2008, Jane Doe #1 and Jane Doe #2 received letters from the FBI advi

ormer President Bill Clinton, Andrew Albert Christian Edward (a/k/a Prince Andrew, Duke of York), Harvard Law Professor Alan Dershowitz, Ken Starr, Lillian Sanchez, Jay Lefkowitz, and Roy Black on his behalf. EFTA00207798 9. On January 10, 2008, Jane Doe #1 and Jane Doe #2 received letters from the FBI advi

ke the position that you can withhold the other half of the U.S. Attorney's correspondence, correspondence between the Department and Ken Starr and Lillian Sanchez on behalf of Epstein, and information about role in the Epstein case. In short, we understand you to be asserting a blanket position that you can w

ke the position that you can withhold the other half of the U.S. Attorney's correspondence, correspondence between the Department and Ken Starr and Lillian Sanchez on behalf of Epstein, and information about role in the Epstein case. In short, we understand you to be asserting a blanket position that you can w

erstand you to take the position that you can withhold the other half of the U.S. Attorney's correspondence, correspondence ment and Ken Starr and Lillian Sanchez on behalf of Epstein, and information about role in the Epstein case. In short, we understand you to be asserting a blanket position a you can with