EFTA00185206

Case 9:08-cv-80736-KAM Document 
Entered on FLSD Docket 07/19/2013 Page 19 of 
23 
Bates Range 
Description 
Privilege(s) Asserted 
Box #3 
P-011923 
Thru 
P-011966 
Folder entitled "Responses to Arguments from JE 
Counsel" containing: 
II 7/13/2007 letter from Lilly Ann Sanchez 
to 
with handwritten 
attorney 
notes; 
• 
6/25/2007 letter from Gerald Lefcourt to 
a
Sloman, 
Menchal 
, and 
with 
handwritten attorney I 
I notes 
ml 6/25/2007 email from 
to 
and 
entitled "Thoughts on Lefcourt's letter" 
Handwritten and typed attorney (
) notes 
regarding main themes raised by Epstein counsel 
Work product 
Deliberative process 
6(e) 
Attorney-Client Privilege 
Box #3 
P-011967 
Thru 
P-012016 
Composition book entitled "Operation Leap 
Year" containing attorney handwritten notes 
regarding investigation and case strategy 
Work product 
Investigative privilege 
6(e) 
Contains information subject 
to privacy rights of victims 
who are not parties to this 
litigation 
Box #3 
P-012017 
Thru 
P-012055 
Motion of Jeffrey Epstein to Intervene and to 
Quash Grand Jury Subpoenas and Incorporated 
Memorandum of Law 
6(e) 
Box #3 
P-012056 
Thru 
P-012088 
Affidavit of Roy Black, Esq. in Support of 
Motion of Jeffrey Epstein to Intervene and to 
Quash Grand Jury Subpoenas 
6(e) 
Box #3 
P-012089 
Thru 
P-012129 
United States' Response to Motion of Jeffrey 
Epstein to Intervene and to Quash Grand Jury 
Subpoenas and Cross-Motion to Compel 
6(e) 
Box #3 
P-012130 
Thru 
P-012150 
Declaration of Joseph Recarey 
6(e) 
Box #3 
P-012151 
Thru 
PM 12167 
Ex Parte Declaration Number One in Support of 
United States' Response to Motion to Quash 
Subpoenas 
6(e) 
Investigative Privilege 
Also contains information 
subject to privacy rights of 
victims who are not parties to 
this litigation 
Page 19 of 23 
EFTA00185406

Case 9:08-cv-80736-KAM Document M-1 Entered on FLSD Docket 07/19/2013 Page 20 of 
23 
Bates Ran e 
Description 
Privil e s Asserted 
Box #3 
P-012168 
Thru 
P-012170 
Ex Parte Declaration Number Two in Support of 
United States' Response to Motion to Quash 
Subpoenas 
6(e) 
Investigative Privilege 
Box #3 
P-012171 
Thru 
P-012173 
Supplement to Ex Parte Declaration Number One 
in Support of United States' Response to Motion 
to Quash Subpoenas 
6(e) 
Investigative Privilege 
Also contains information 
subject to privacy rights of 
victims who are not parties to 
this litigation 
Box #3 
P-012174 
Thru 
P-012176 
Draft of September 2009 letter from 
Work Product 
Attorney-Client Privilege 
Deliberative Process 
to Roy Black regarding breach of Non 
Prosecution Agreement with handwritten attorney 
notes 
Box #3 
P-012177 
Thru 
P-012178 
Undated handwritten attorney 
notes 
regarding negotiations and allegations 
Work Product 
Attorney-Client Privilege 
Deliberative Process 
Box #3 
P-012179 
Thru 
P-012188 
File Folder entitled "FBI G.J. Log" containing 
copy of FBI
 jury subpoena log with 
attorney 
handwritten notes 
6(e) 
Work Product 
Investigative Privilege 
Also contains information 
subject to privacy rights of 
victims who are not parties to 
this litigation 
Box #3 
P-012362 
Thru 
P-012451 
File folder entitled "Key Documents" containing 
correspondence between AUSA and case agent 
regarding indictment prep questions, victim 
identification information, corrections to draft 
indictment, indictment preparation timeline, key 
grand jury material 
6(e) 
Work Product 
Attorney-Client privilege 
Investigative Privilege 
Also contains information 
subject to privacy rights of 
victims who are not parties to 
this litigation 
Box #3 
P-012451 
Thru 
P-012452 
File folder entitled "Victim List" containing list 
of victims with dates of birth and age information 
Work Product 
Investigative Privilege 
Also contains information 
subject to privacy rights of 
victims who are not parties to 
this litigation 
Page 20 of 23 
EFTA00185407

Case 9 08-cv-80736-KAM Document M-1 Entered on FLSD Docket 07/19/2013 Page 21 of 
23 
Bates Range 
Description 
Privilege(s) Asserted 
Box #3 
P-012453 
Thru 
P-012623 
Complete indictment package marked "Originals 
12/12/07" 
Work-product 
Deliberative process 
6(e) 
Also contains documents 
subject to investigative 
privilege 
Also contains documents 
subject to privacy rights of 
victims who are not parties to 
this litigation 
Box #3 
P-012624 
Thru 
P-012653 
Folder entitled "(Victims) Additional 302's" 
containing reports of interviews conducted in 
June 2007, October 2007, and March 2008. 
Investigative Privilege 
Also contains documents 
subject to privacy rights of 
victims who are not parties to 
this litigation 
Box #3 
P-012654 
Thru 
P-012864 
3-ring binder entitled "Child Molesters: A 
Behavioral Analysis" with attorney (;
) 
handwritten notes 
Work-product 
Box #3 
P-012865 
Thru 
P-013226 
Indictment preparation binder containing: 
witness/victim list with identifying information, 
sexual activity suragephone call summary 
chart, attorney 
handwritten notes, 
3ak
tions of state investigative file, attorney 
typed notes, relevant pieces of grand 
jury materials, telephone records/flight records 
analysis charts, victim/witness photographs, 
DAVID records, NCICs, and related materials for 
persons identified as Jane Does #9, 10, 11, 12, 13, 
14 
Work Product 
Deliberative Process 
6(e)
Also contains documents 
subject to investigative 
privilege 
Also contains documents 
subject to privacy rights of 
victims who are not parties to 
this litigation 
Box #3 
P-013227 
April 23, 2008 Memo from Jeffrey Sloman to 
Office of Professional Responsibility re Self 
Reporting, Corrected Version of the previously 
submitted April 21, 2008 Letter to OPR 
Privacy Act 
Box #3 
P-013226 
Thru 
P-013230 
April 21, 2008 Letter from Jeffrey Sloman to 
Office of Professional Responsibility re Self 
Reporting 
Privacy Act 
Box #3 
P-013231 
Thru 
P-013239 
April 22, 2008 Letter from A. 
to 
Privacy Act 
Office of Professional Responsibility re Self-
Report of Allegation of Conflict of Interest 
Page 21 of 23 
EFTA00185408

Case 9:08-cv-80736-KAM Document •1 
Entered on FLSD Docket 07/19/2013 Page 22 of 
23 
Bates Range 
Description 
Privilege(s) Asserted 
Box #3 
P-013240 
Thru 
P-013247 
April 21, 2008 Letter from Jeffrey Sloman to 
Office of Professional Responsibility re Self 
Reporting with attachments 
Privacy Act 
Box #3 
P-013248 
Thru 
P-013251 
Emails between 
Assistant 
Attorney-Client Privilege 
General Counsel, Executive Office for United 
States Attorneys, and 
First 
Assistant U.S. Attorney, Southern District of 
Florida, regarding Formal Notice of Office-wide 
Recusal of Southern District of Florida dated 
August 24 and Au
l011 
Box #3 
P-013252 
Thru 
P-013253 
Emails between 
Assistant 
Attorney-Client Privilege 
General Counsel, Executive Office for United 
States Attorneys, and 
, First 
Assistant U.S. Attorney, Southern District of 
Florida, regarding Recusal matter, dated July 28, 
Au ust 3 and Au ust 24 2011 
Box #3 
P-013254 
Thru 
P-013257 
Emails between 
Assistant 
Attorney-Client Privilege 
General Counsel, Executive Office for United 
States Attorneys, and 
, First 
Assistant U.S. Attorney, Southern District of 
Florida, regarding Formal Notice of Office-wide 
Recusal of Southern District of Florida dated 
August 24 and August 29 2011 
Box #3 
P-013258 
Thru 
P-013259 
Emails between 
Ma 
Assistant 
General Counsel, Executive Office for United 
States Attorneys, and 
, First 
Assistant U.S. Attorney, Southern District of 
Florida, regarding Formal Notice of Office-wide 
Recusal of Southern District of Florida dated July 
28 and August 3 2011 
Attorney-Client Privilege 
Box #3 
P-013260 
Thru 
P-013262 
Email from 
Assistant General 
Attorney-Client Privilege 
Counsel, Executive Office for United States 
Attorneys, to 
N.S. Attorney, 
SDFL Robert O'Neill (U.S. Attorney, MDFL
(FAUSA, SDFL), and
(FAUSA, MDFL) regarding Formal 
Notice of Office-wide Recusal of Southern 
District of Florida dated Au st 24 2011. CC's 
ODAG), 
USAEO 
SAEO), 
USAEO 
(USAEO) 
Page 22 of 23 
EFTA00185409

Case 9:08-cv-80736-KAM Document 212-1 Entered on FLSD Docket 07/19/2013 Page 23 of 
23 
Bates Range 
Deal lion 
Privilege(s) Asserted 
Box #3 
Emails between 
_, 
Assistant 
Attorney-Client Privilege 
P-013263 
General Counsel, Executive Office for United 
Deliberative Process 
Thru 
States Attorneys, and 
First 
Work Product 
P-013271 
Assistant U.S. Attorney, Southern District of 
Florida, regarding recusal of Southern District of 
Florida, dated July 29 2011 with attached 
memorandum from 
to 
summarizing 
Jeffrey 
Epstein Invest". ation 
Box #3 
Emails between 
Executive Office 
Attorney-Client Privilege 
P-013272 
Thru 
for United States Attorneys, and 
, 
Southern District of Florida, seeking advice 
P-013278 
regarding office-wide recusal, dated December 16 
and 17, 2010 with attached letter from 
to 
dated December 10, 
2010 
Page 23 of 23 
EFTA00185410

EFTA00185411

, 
Case 9:08-cv-80736-KAM Document 216 Entered on FLSD Docket 07/27/2013 Page 1 of 2 
UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
Case No. 08-80736-Civ-MarraMatthewman 
JANE DOES #1 AND #2, 
Petitioners, 
UNITED STATES OF AMERICA, 
Respondent. 
UNITED STATES' NOTICE OF FILING SUPPLEMENTAL PRIVILEGE LOG 
Pursuant to the Court's June 18, 2013 Omnibus Order (DE 190), the Respondent, United 
States of America, by and through the undersigned Assistant United States Attorney, hereby gives 
notice of its filing of its Privilege Log, which is attached hereto. 
The documents referenced in the Privilege Log are being delivered today to the Chambers 
of U.S. District Judge Kenneth A. Marra for ex parte in camera review, pursuant to the Court's 
Omnibus Order. 
Respectfully submitted, 
UNITED STATES ATTORNEY 
By: 
Assistant United States Attorney 
Florida Bar No. 0018255 
500 South Australian Ave, Suite 400 
West Palm Beach, FL 33401 
Telephone: 
Facsimile: 
EFTA00185412

Case 9:08-cv-80736-KAM Document 216 Entered on FLSD Docket 07/27/2013 Page 2 of 2 
CERTIFICATE OF SERVICE 
I HEREBY CERTIFY that on July 26, 2013, I electronically filed the foregoing document 
with the Clerk of the Court using CM/ECF. According to the Court's website, counsel for all parties 
are able to receive notice via the CM/ECF system. 
Assistant United States Attorney 
SERVICE LIST 
Jane Does 1 and 2'. United States, 
Case No. 08-80736-CIV-MARRA/MATTHEWMAN 
United States District Court, Southern District of Florida 
Brad Edwards, Esq., 
Farmer Jaffe Weissing Edwards Fistos Lehrman 
425 N Andrews Ave Ste 2 
Fort Lauderdale, FL 33301-3268 
brad@pathtojustice.com 
954-524-2820 
Fax: 954-524-2822 
Paul G. Cassell 
S.J. Quinney College of Law at the 
University of Utah 
332 S. 1400 E. 
Salt Lake City, Utah 84112 
(801) 585-5202 
Fax: (801) 585-6833 
E-mail: casselp®law.utah.edu 
Attorneys for Jane Doe # 1 and Jane Doe # 2 
2 
EFTA00185413

Case 9:08-cv-80736-KAM Document 216-1 Entered on FLSD Docket 07/27/2013 Page 1 of 14 
SUPPLEMENTAL PRIVILEGE LOG 
Bates Range 
Description 
Privilege(s) Asserted 
Suppl. Box #3 
P-013279 
Tluu 
P-013280 
8/15/08 Emails between A. Acosta and 
and 
re 
proposed correspondence to Jay Lefkowitz 
Attorney-Client Privilege 
Work Product 
Suppl. Box #3 
P-013281 
Handwritten note re Epstein investigation 
Attorney-Client Privilege 
Work Product 
Investigative privilege 
Also contains information 
subject to privacy rights of 
victims who are not 
rties to this liti ation 
Suppl. Box #3 
P-013282 
Thru 
P-013283 
7/9/08 Email from 
to A. 
Acosta, 
and FBI re 
proposed response to Goldberger letter re victim 
notification 
Attorney-Client Privilege 
Work product 
Deliberative Process 
Suppl. Box #3 
P-013284 
7/10/08 Emails between 
and A. 
and FBI re proposed 
response to Goldberger's letter re victim 
notification 
Attorney-Client Privilege 
Work Product 
Deliberative Process 
Suppl. Box #3 
P-013285 
Thru 
P-013289 
File folder entitled "8/5/08 AMCV e-mail re 
correct a 
t" containing 8/5/08 email from A. 
to A. Acosta, 
a 
re "Jeffrey 
Epstein 
Agreement" discussing 6/24/08 email from 
to R. Black and J. Goldberger 
concerning the binding nature of the Agreement 
Attorney-Client Privilege 
Work Product 
Deliberative Process 
Suppl. Box #3 
P-013290 
Thru 
P-013292 
File folder entitled "8/14/08 E-mail from Lefk to 
AMCV" containing undated entails from A. 
to 
A. 
Acosta, 
re draft response to 
8/14/08 email from J. Leflcowitz regarding "the 
December 2007 proposal" 
Attorney-Client Privilege 
Work Product 
Page 1 of 14 
EFTA00185414

Case 9:08-cv-80736-KAM Document 216-1 Entered on FLSD Docket 07/27/2013 Page 2 of 14 
Bates Range 
Description 
Privilege(s) Asserted 
Suppl. Box #3 
P-013293 
Mil 
P-013299 
File folder entitled "8/15/08 AMCV e-mail re 
A 
t" containing 8/15/08 e-mails from A. 
to A. Acosta, 
, 
re follow s oailment and 
from A. Acosta to Ann = 
on issue 
of Special Master with attached 8/15/08 emails 
from 
to A. Acosta, 
re A 
ei
f
i
terit• 
8/15/08 email from J. Lefkowitz to 
R. Black, M. Weinber 1 re 
lis
nent; 8/14/08 emails from 
to J. Lefkowitz, 
R. Black 
re interpretation of A 
ment• email from J. 
Lefkowitz to 
re 
itSms re Agreement; email from 
to J. Lefkowitz, 
re 
production of Agreement to victims 
Attorney-Client Privilege 
Work Product 
Deliberative Process 
Suppl. Box #3 
P-013300 
Thru 
P-0133303 
File folder entitled "8/18/08 Lefkowitz Ltr to 
AMCV" containing 
handwritten draft notes for proposed letter to J. 
Lefkowitz; 5/22/07 e-mail from 
to M. 
re 
meeting with G. Lefcourt with attached email 
from G. Lefcourt re solicitation for meetings 
Attorney-Client Privilege 
Work Product 
Suppl. Box #3 
P-013304 
Thru 
P-013325 
File folder entitled "6/25/07 Lefcourt to Sloman 
& 
containin 
6/25/07 letter (with 
handwritten notes b 
from G. 
Lefcourt to 
M. 
addressing reasons for not 
prosecuting E stein; handwritten outline by 
of possible response to letter 
Attorney-Client Privilege 
Work Product 
Suppl. Box #3 
P-013326 
Thru 
P-013329 
File folder entitled "9/17/07 
to 
Attorney-Client Privilege 
Work Product 
Lefkowitz contai ' 
9/17/07 e-mail from 
to 
and from 
to A. 
concerning status 
of plea negotiations 
Suppl. Box #3 
P-013330 
Thru 
P-013333 
File folder entitled "11/8/07 Lefkowitz to 
Sloman" containing 11/8/07 letter from J. 
Lefkowitz re issues arising during pendency of 
matter with attorney handwritten notes 
Attorney-Client Privilege 
Work Product 
Suppl. Box #3 
P-013334 
Thru 
P-013337 
File folder entitled "11/13/07 Sloman to 
Lefkowitz (was this sent?" containing draft 
11/13/07 letter from 
responding to J. 
Lefkowitz's letter 
Attorney-Client Privilege 
Work Product 
Page 2 of 14 
EFTA00185415

Case 9:08-cv-80736-KAM Document 216-1 Entered on FLSD Docket 07/27/2013 Page 3 of 14 
Bates Range 
Description 
Privilege(s) Asserted 
Suppl. Box #3 
P-013338 
Thru 
013341 
File 
folder 
entitled 
"12/6/07 
Sloman 
to 
Lefkowitz" containing 12/5/07 faxed letter w/ 
cover sheet from K. Starr and J. Leflcowitz to A. 
Acosta 
(Not considered 
privileged. Will be 
produced to opposing 
counsel upon lifting of 
stay] 
Suppl. Box #3 
P-013342 
Thru 
P-013350 
File folder entitled "12/05/07 Starr to Acosta" 
containing drafts of 11/30/07 letters from A. 
Acosta to K. Starr and from 
to J. 
Leflcowitz re performance and victim notification 
with handwritten notes and edits by A. 
Attorney-Client Privilege 
Work Product 
Deliberative Process 
Suppl. Box #3 
P-13351 
Thru 
P-013361 
File folder entitled "12/21/07 Lefkowitz to 
Acosta" containing handwritten notes by 
12/21/07 
letter 
from 
J. 
Lefkowitz to A. Acosta re performance of NPA 
and appeal to 
Washington 
with attorney 
handwritten notes 
Attorney-Client Privilege 
Work Product 
Suppl. Box #3 
P-013362 
Thru 
P-013366 
File folder labeled "12/26/07 Lefkowitz to 
Acosta" containing 2 copies of draft letter from 
A. Acosta to J. Lefkowitz (with 12/28/07 fax 
header) 
Attorney-Client Privilege 
Work Product 
Deliberative Process 
Suppl. Box #3 
P-013367 
Thru 
P-013372 
File folder labeled "Draft Itr from Sloman to 
Lefkowitz re termination" containin: draft letter 
dated "April , 2008" from 
to J. 
Lefkowitz concerning the compliance with the 
Agreement 
Attorney-Client Privilege 
Work Product 
Suppl. Box #3 
PM 13373 
Thru 
P-013503 
File folder labeled "6/3/08 Sloman Submission to 
the DAG" containing 6/3/08 letter from 
to 
Office of the DAG cc'd to 
re 
Jeffrey Epstein, detailing events concerning the 
Agreement and thereafter and with relevant 
attachments 
Attorney-Client Privilege 
Deliberative Process 
Work Product 
Investigative privilege 
Suppl. Box #3 
P-013504 
Thru 
P-013507 
File folder labeled "Mtg w/ Ken Starr, RAA_I_La
S 
Drew" containing handwritten notes by A. = 
Attorney-Client Privilege 
Work Product 
Suppl. Box #3 
P-013508 
Thru 
P-013514 
File folder labeled "Internal Corr." cont
i niii
11/28/07 e-mails from 
to 
re respondin: to 11/28/07 e-mail from 
J. Lefkowitz to 
regarding victim 
notification with attachments 
Attorney-Client Privilege 
Work Product 
Page 3 of 14 
EFTA00185416

Case 9:08-cv-80736-KAM Document 216-1 Entered on FLSD Docket 07/27/2013 Page 4 of 14 
Bates Range 
Description 
Privilege(s) Asserted 
Suppl. Box #3 
P-013515 
Thru 
P-013525 
Draft 11/30/07 letter from A. Acosta to K. Starr 
cc'd to 
and A. 
re 
compliance with Agreement and internal emails 
from 
A. Acosta, and 
re 
items to address in letter 
Attorney-Client Privilege 
Work Product 
Deliberative Process 
Suppl. Box #3 
P-013526 
Thru 
P-013527 
5/23/07 e-mail from A. 
to 
Attorney-Client Privilege 
Work Product 
Deliberative Process 
re draft proposed internal e-mail about 
handling 
of 
case 
and 
attached 
email 
correspondence between 
and G. 
Lefcourt 
Suppl. Box #3 
P-013528 
Thru 
P-013530 
P-013532 
Thru 
P-013537 
Handwritten notes by 
dated 
Work Product 
9/21 re telephone conference with possible victim 
representative, conflict check with names and 
email listed, list of names of potential victim 
representatives, 
payment 
discussion, 
and 
guideline calculation, email containing contact 
info for potential victim representative, draft Non 
Prosecution Agreement dated 9/10/07 4:17 pm 
Suppl. Box #3 
P-013531 
Typed note addressed to "Dear David" re 
response to grand jury subpoena 
6(e) 
Investigative privilege 
Suppl. Box #3 
P-013538 
Thru 
P-013553 
File folder labeled "Notes Re Post-Agreement 
Communications" containing handwritten notes 
by A. 
Work Product 
Deliberative Process 
Suppl. Box #3 
P-013554 
Thru 
File 
folder 
labeled 
"E-mails 
Re 
Plea 
Negotiations" containing: 
■ 11/28/07 e-mail from 
to A. 
re 
non-prosecution 
agreement, 
wi 
attached correspondence• 
■ 9/19/07 e-mail from A. 
to 
re 
negotiating 
strategy, 
with 
attached 
correspondence; 
■ 9/18/07 e-mail from A. 
to 
A. Acosta, 
re negotiating 
strategy; 
■ 9/17/07 e-mail from A. 
to 
A. Acosta re negotiation• 
■ 9/17/07 e-mail from A. 
to 
A. Acosta, 
re ne otiations• 
■ 9/17/07 e-mail from A. 
to 
Attorney-Client Privilege 
Work Product 
Deliberative Process 
Investigative Privilege 
Page 4 of 14 
EFTA00185417

Case 9:08-cv-80736-KAM Document 216-1 Entered on FLSD Docket 07/27/2013 Page 5 of 14 
Bates Ranee 
Description 
strategy; 
• 
9/14/07 e-mail from A. 
A. Acosta 
plea agreement and 
• 
9/14/07 e-mail from A. 
A. Acosta 
re plea negotiations; 
• 
9/13/07 e-mail from A. 
Privilege(s) Asserted 
re negotiation 
re proposed 
ormation.
indictment package; 
• 
9/13/07 e-mail from A. 
to 
re trust agreement with 
attached correspondencea_. 
• 
9/13/07 e-mail from A. =I 
to 
re trust aanent• 
• 
9/13/07 e-mail from A. 
to 
re conference call 
with J. Lefkowitz; 
• 
9/13/07 e-mail from A. 
to 
re plea negotiations with 
attached correspondence• 
• 
9/13/07 e-mail from A. 
to 
re charging strategy with 
attached correspondence.
• 
9/13/07 e-mail from A. 
to 
to 
re 
indictment package; 
• 
9/13/07 e-mail from A. 
to 
A. Acosta 
re plea ne otiations; 
• 
9/11/07 e-mail from A. 
to 
re meeting w/ G. Le court with 
attached correspondence.
• 
9/11/07 e-mail from 
to 
re revised Agreement with 
attached correspondencs_ 
• 
9/11/07 e-mail from A. 
to 
re non-prosecution agreement 
edits with attached correspondence.
• 
9/11/07 e-mail from A. 
to 
re status of negotiations 
with attached correspondence; 
Page 5 of 14 
EFTA00185418

Case 9:08-cv-80736-KAM Document 216-1 Entered on FLSD Docket 07/27/2013 Page 6 of 14 
Bates Range 
Description 
Privilege(s) Asserted 
• 
9/10/07 e-mail from 
to 
re ne ofiations; 9 10 07 e-mail 
from 
to 
I 
re state gran, jury proceedin s• 
• 
9/17/07 e-mail from A. Acosta to 
re draft Agreement 
wi attache correspondence. 
• 
9/14/07 e-mail from 
A. Acos 
re nalizing 
documents; 
IN 9/14/07 e-mail from 
to A. 
re charging strategy with 
attached correspondence. 
IN 9/13/07 e-mail from 
to A. 
re settin u trust fund; 
l• 9/13/07 e-mail from 
to 
re final negotiations with 
attached correspondence. 
• 
9/11/07 e-mail from 
to 
re 
scheduling a 
meeting 
regarding finalizing the agreement with 
attached correspondence. 
• 
9/11/07 e-mail from 
to 
re 
non-prosecution 
agreement 
edits 
with 
attached 
correspondence; 
M 9/11/07 e-mail from 
to 
re 
non-prosecution 
agreement 
edits 
with 
attached 
correspondence; 
II 9/11/07 e-mail from 
to 
re negotiations with 
attached correspondence. 
• 
9/17/07 e-mail from A. 
to 
re negotiation 
strategy 
Suppl. Box #3 
File folder entitled "[] Target Letter" containing 
6(e) 
P-013609 
copy of signed letter and contact info for counsel 
Investigative Privilege 
Thru 
for target 
P-013615 
Page 6 of 14 
EFTA00185419

Case 9:08-cv-80736-KAM Document 216-1 Entered on FLSD Docket 07/27/2013 Page 7 of 14 
Bates Range 
Description 
Privilege(s) Asserted 
Suppl. Box #3 
P-013616 
Thru 
P-013621 
File folder entitled "Atty Notes re Revised 
Indictment" containing handwritten notes by A. 
Attorney-Client Privilege 
Deliberative Process 
Work Product 
Investigative Privilege 
Also contains information 
subject to privacy rights of 
victims who are not 
parties to this litigation 
Suppl. Box #3 
P-013622 
Thru 
P-013643 
File folder entitled "Research Re Possible 
Misdemeanors" containing attorney research 
Work product 
Suppl. Box #3 
P-013644 
Thru 
P-013653 
File folder entitled "Notes Re Plea Negotiations" 
tinin 
9/17/07 e-mail from A. 
to 
re status 
update• undated and typed handwritten notes by 
A. 
re items to be completed on 
case, strength of case, victim interviews, 
summary of evidence, guidelines calculations 
Attorney-Client Privilege 
Work Product 
Deliberative Process 
Investigative privilege 
Also contains information 
subject to privacy rights of 
victims who are not 
parties to this litigation 
Suppl. Box #3 
P-013654 
Thm 
P-013745 
File folder entitled "Plea Agreement Drafts" 
containing several draft plea asents 
some 
with handwritten notes by A. 
copies of draft non-prosecution iiiement some 
with handwritten notes by A. 
copy of a draft Information 
Attorney-Client Privilege 
Work Product 
Deliberative Process 
Suppl. Box #3 
P-0013747 
Thru 
P-013810 
File folder entitled "Draft Non-Prosecution 
Agreements" containing several draft non- 
prosecution a reements some with handwritten 
notes by 
plea sheet State 
Circuit Court; copies of draft Information; draft 
plea proffer; draft motion and order to seal; draft 
penalty sheet; draft plea agreement 
Attorney-Client Privilege 
Work Product 
Deliberative Process 
Suppl. Box 3 
P-013811 
Thru 
P-013833 
File folder entitled "Information Packet Drafts" 
containing several drafts of Informations, and 
complete draft Information packet 
Attorney-Client Privilege 
Work Product 
Deliberative Process 
Suppl. Box 3 
P-013834 
Through 
P-013835 
Two pages of filed document, D.E. 62, page 2 of 
54 and page 6 of 54, containing handwritten 
attorney notes 
atty work-product 
Page 7 of 14 
EFTA00185420

Case 9:08-cv-80736-KAM Document 216-1 Entered on FLSD Docket 07/27/2013 Page 8 of 14 
Bates Range 
Description 
Privilege(s) Asserted 
Suppl. Box 3 
P-013836 
Thru 
P-013837 
Palm Beach Daily News Article, "Attorneys want 
Jeffrey Epstein Agreement Thrown Out," with 
attorney's notes written on margin 
Atty work-product 
Suppl. Box 3 
P-013838 
Thru 
P-013841 
Letter from 
to 
Atty work-product 
December 10, 2010, Subject: 
Request for 
Investigation of Jeffrey Epstein Prosecution, with 
underlines, written notes, and comments by DOJ 
Worm 
Suppl. Box 3 
P-013842 
Email from 
to 
Any work-product 
Atty-client privilege 
(OPR), February 25, 2011, 4:31 p.m., Re: 
Request for OPR Investigation — Jeffrey Epstein 
Non-Prosecution Alreement 
Suppl. Box 3 
P-013843 
Thru 
P-013844 
E-mail 
to 
and 
September 
19, 2007, 4:33 p.m., RE: Plea Agreement 
Atty work-product 
atty-client privilege 
Suppl. Box 3 
P-013845 
Thru 
P-013846 
E-mail, 
to 
Atty work-product 
September 19, 2007, 4:21 p.m., RE: Epstein, 
with internal U.S. Attorney's Office e-mails 
attached 
Suppl. Box 3 
P-013847 
Thru 
P-013849 
E-mail 
to 
and 
September 
18, 2007, 11:43 
, RE: Draft Agreements?, 
with e-mail from Jay Leflcowitz (September 18, 
2007, 11:09 M. attached 
Atty work-product 
Suppl. Box 3 
P-013850 
E-mail, 
to Alex Acosta 
and 
September 18, 2007, 9:31 
RE: Epstein Ne otiations 
Atty work-product 
Suppl. Box 3 
P-013851 
Thru 
P-013853 
E-mail 
to 
and 
September 17, 2007, 10:35 
, 
Atty work-product 
RE: 
Epstein [providing update re plea 
negotiations 
Suppl. Box 3 
P-013854 
E-mail, 
to 
Atty work-product 
September 13, 2007 8:10 .m. RE: Epstein, 
with e-mail from 
(September 
;1
rat
.nilached 
Suppl. Box 3 
P-013855 
E-mail 
to 
and 
Atty work-product 
Atty-client privilege 
September 10, 2007, 5:24 p.m., 
RE: FBI 
Suppl. Box 3 
P-013856 
Thru 
P-013857 
E-mail, 
to 
Any work-product 
Atty-client privilege 
September 6, 2007 5:47 .m., RE: Epstein, with 
e-mail from 
(September 6, 2007, 
5:35 p.m.), attached 
Page 8 of 14 
EFTA00185421

Case 9:08-cv-80736-KAM Document 216-1 Entered on FLSD Docket 07/27/2013 Page 9 of 14 
Bates Range 
Descri tion 
Privilege(s) Asserted 
Suppl. Box 3 
P-013858 
Email, 
to 
atty work-product 
September 6, 2007, 
Friday 
9:29 
, Re: Meeting on 
Suppl. Box 3 
P-013859 
Through 
P-013860 
Email, Gerald Lefcourt 
Ann Sanchez, Roy 
to 
Lilly 
[Not considered 
privileged. Will be 
produced to opposing 
counsel upon lifting of 
stay] 
Black, re: Jeffrey Epstein 
Suppl. Box 3 
P-013861 
Thru 
P-013865 
E-mail, 
to Matthew 
Any work-product 
atty-client privilege 
July 13, 2007 3:14 p.m., RE: Epstein, with e- 
mail from 
(July 5, 2007, 3:30 p.m.), 
to 
Jul
4, 2007, 5:16 p.m.), 
and Sloman to 
(July 3, 2007, 1:47 
p.m.), attached 
Suppl. Box 3 
P-013866 
E-mail 
to 
Matthew 
and 
Jul 3 2007 6:26 
., RE: E stein 
Atty work-product 
Suppl. Box 3 
P-013867 
Thru 
P-013868 
E-mail, 
to Matthew 
Any work-product 
June 21, 2007, 3:24 p.m., RE: Meetin Next 
Week, with e-mails from 
to 
June 21, 2007, 2:58 p.m.), and 
to 
June 21 2007 1:37 p.m.), attached 
Suppl. Box 3 
P-013869 
E-mail 
June 18 
to Matthew 
and 
2007, 5:(14_2O.RIS, stein 
Any work-product 
Suppl. Box 3 
P-013870 
Thru 
P-013871 
E-mail, 
to = 
May 
24, 2007, 9:25 
., FW: Jeffrey Epstein with e-
mail from Gerald Lefcourt to 
(May 23, 2007, 5:00 p.m.), 
to 
Gerald Lefcourt (May 22 2007 6:32 p.m.),
Gerald Lefcourt 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-013873 
E-mail 
2007, 10:52 
. 
e-mail from 
(May 14 2007 10:38 
to 
and 
May 14, 
Any work-product 
RE: Operation Leap Year with 
to 
and 
.), attached 
Page 9 of 14 
EFTA00185422

Case 9:08-cv-80736-KAM Document 216-1 Entered on FLSD Docket 07/27/2013 Page 10 of 
14 
Bates Range 
Description 
Privilege(s) Asserted 
Suppl. Box 3 
P-013874 
Through 
P413875 
Inadvertently marked as privileged, will be 
produced 
Suppl. Box 3 
P413876 
Thru 
P413877 
E-mail 
to = 
and 
Any work-product 
, September 19, 2007, 4:33 p.m., RE: 
Draft Plea 
J11 a- nent, with e-mail 
from 
Lefkowitz to 
(Se .tember 19, 2007, 3:44 
p.m.), and Lefkowitz to 
(September 19, 
2007, 3:35 m.) attached 
Suppl. Box 3 
P-013878 
Thru 
P-013879 
E-mail, 
to 
September 19, 2007, 
Atty work-product 
4:21 ..m., RE: 
Epstein with e-mails from 
to 
and 
Se tember 19 
2007, 4:13 p.m.), 
to 
and 
Se tember 19 2007, 4:05 p.m.), and 
to 
and 
Se tember 19, 2007, 3:50 
p.m.), 
to 
Se tember 19 2007, 
2:36 p.m.), 
to 
(September 19, 
2007 2:33 p.m.), and 
to 
and 
(Se• ?tember 19, 2007 2:31 p.m. attached 
Suppl. Box 3
E
P-013880 
Thru 
P-013882 
-mail 
to 
and 
Any work-product 
September 18, 2007, 11:43 
., RE: 
DraltSreements?, with e-mails from 
to =I, 
and 
(September 18 
2007, 11:18 
), Lefkowitz to 
(September 18, 2007, 11:09 
.), and 
to Lefkowitz (September 18 2007, 9:14 
.), 
ande Lefkowitz to 
(September 18, 
2007, 8:59 
attached 
Suppl. Box 3 
P-013883 
E-mail 
to Acosta, 
, 
Any work-product 
and McMillan, September 18, 2007, 
9:31 
., RE: 
tein Ne otiations 
Suppl. Box 3 
P-013884 
Thru 
P413886 
E-mail, 
to 
and l=, 
September 17, 2007 10:35 
., RE: Epstein, 
with e-mail from 
(September 17, 2007, 
10:26 
attached 
Any work-product 
Suppl. Box 3 
P413887 
E-mail, 
to 
Atty work-product 
September 13, 2007 8:10 ..m. RE: Epstein, 
with e-mail from 
(September 
13, 2007, 7:54 p.m. attached 
Suppl. Box 3 
P-013888 
E-mail 
to 
and 
Atty work-product 
Atty-client privilege 
September 10, 2007, 5:24 p.m., 
RE: FBI 
Page 10 of 14 
EFTA00185423

Case 9:08-cv-80736-KAM Document 216-1 Entered on FLSD Docket 07/27/2013 Page 11 of 
14 
Bates Range 
Besets' i tion 
Privilege(s) Asserted 
Suppl. Box 3 
P-013889 
Thru 
P-013890 
E-mail, 
to 
Atty work-product 
Atty-client privilege 
September 6, 2007 5:47 .m., RE: Epstein, with 
e-mail from 
(September 6, 2007, 
5:35 p.m. attached 
Suppl. Box 3 
P-013891 
Email, 
to 
atty work-product 
September 6, 2007, 9:29 
., Re: Meeting on 
Friday 
Suppl. Box 3 
P-013892 
Through 
P-013893 
Email, Gerald Lefcourt to 
Lilly 
[Not considered 
privileged. Will be 
produced to opposing 
counsel upon lifting of 
stay) 
Ann Sanchez, Roy Black, re: Jeffrey Epstein 
Suppl. Box 3 
P-013894 
Thru 
P-013898 
E-mail, 
to Matthew 
Atty work-product 
atty-client privilege 
July 13, 2007 3:14 p.m., RE: Epstein, with e- 
mail from 
(July 5, 2007, 3:30 p.m.), 
to 
Jul 4, 2007, 5:16 p.m.), 
and Sloman to 
(July 3, 2007, 1:47 
p.m.) attached 
Suppl. Box 3 
P-013899 
E-mail 
Matthew 
, and 
Jul 3 2007 6:26 
., RE: E .stein 
Atty work-product 
Suppl. Box 3 
P-013900 
Thru 
P-013901 
E-mail, 
to Matthew 
Atty work-product 
June 21, 2007, 3:24 p.m., RE: Meetin 1 Next 
Week, with e-mails from 
to 
June 21, 2007, 2:58 p.m.), and 
to 
June 21 2007 1:37 p.m.), attached 
Suppl. Box 3 
P-013902 
E-mail 
to Matthew 
and 
June 18 2007, 5:04.2±a.RSistein 
Atty work-product 
Suppl. Box 3 
P-013903 
Thru 
P-013904 
E-mail, 
to = 
May 
24, 2007, 9:25 
., FW: Jeffrey Epstein with e-
mail from Gerald Lefcourt to 
(May 23, 2007, 5:00 p.m.), 
to 
Gerald Lefcourt (May 22 2007 6:32 .m.i.nd 
Gerald Lefcourt to 
and Lilly Ann Sanchez (May 22, 2007, 
2:05 p.m. attached 
Atty work-product 
Suppl. Box 3 
P-013905 
E-mail, 
to Matthew 
Atty work-product 
, and 
May 22, 2007, 3:11 
p.m., FW: ae 
, E.,Hi with e-mail from 
Lefcourt to 
and Lilly Ann 
Sanchez (May 22, 2007, 2:05 p.m.), attached 
Page 11 of 14 
EFTA00185424

Case 9:08-cv-80736-KAM Document 216-1 Entered on FLED Docket 07/27/2013 Page 12 of 
14 
Bates Range 
Descri . tion 
I 
Privilege(s) Asserted 
Suppl. Box 3 
P-013906 
E-mail 
to 
and 
May 14, 
Atty work-product 
2007, 10:52 
RE: Operation Leap Year with 
e-mail from 
to 
and 
(May 14, 2007, 10:38 
), attached 
Suppl. Box 3 
P-013907 
Through 
P-013908 
Inadvertently marked as privileged, will be 
produced 
Suppl. Box 3 
P-013909 
Thru 
P-013911 
Memorandum, 
Assistant Counsel, 
U.S. 
Department 
of 
Justice, 
Office 
of 
Professional Responsibility (OPR), to 
Acting Associate Counsel, OPR, 
undated, Suliect: Recommendation 
Deliberative Process 
Privilege; atty work-
product 
Suppl. Box 3 
P-013912 
Thru 
P-013914 
Memorandum 
, Assistant Counsel, 
OPR, to 
Acting Associate 
Counsel, OPR, Subject: Recommendation, with 
handwritten note dated 5/4/11 
Deliberative Process 
Privilege, atty work-
product 
Suppl. Box 3 
P-013915 
Thru 
P-013918 
Memorand 
Assistant Counsel, 
OPR, to 
Acting Associate 
Counsel, OPR, Subject: Recommendation, with 
two post-it notes attached with handwritten 
attorney notations, and handwritten notations, 
underlines, and circled text throughout the body 
of the two page memorandum 
Deliberative Process 
Privilege; atty work-
product 
Suppl. Box 3 
P-013919 
Thru 
P-013921 
Draft letter marked "Confidential", from 
Deliberative Process 
Privilege 
Attorney Work Product 
, Counsel 
Office of Professional 
Responsibility to 
United 
States Attorney, with handwritten corrections, 
strikethrou hs and added text 
Suppl. Box 3 
P-013922 
Thru 
P-013924 
Draft Letter marked "Confidential" from 
Deliberative Process 
Privilege 
Attorney Work Product 
to 
, with 
handwritten corrections 
Suppl. Box 3 
P-013925 
Thru 
P-013927 
Draft Letter, from 
to Professor 
Deliberative Process 
Privilege 
Attorney Work Product 
Paul G. Cassell, with handwritten correction 
Suppl. Box 3 
P-013928 
Thru 
P-013930 
Draft Letter, from 
to Professor 
Deliberative Process 
Privilege 
Attorney Work Product 
Paul G. Cassell, with handwritten corrections 
Suppl. Box 3 
P-013931 
Thru 
P-013933 
Draft Letter, from 
to Professor 
Deliberative Process 
Privilege 
Attorney Work Product 
Paul G. Cassell, with handwritten corrections, 
circled text, strikethroughs, and additional text 
Page 12 of 14 
EFTA00185425