EFTA01125419Set 9
2012-01-03101p22,011w
further this scheme to defraud, Wegelin and other Swiss banks
used Wegelin's correspondent bank account in the United States to
launder undeclared funds from Switzerland to U.S. taxpayer-
clients ... volume of other
transactions and other funds moving in and out of Wegelin's
correspondent account contemporaneously with the laundering of
these undeclared assets helped to facilitate these money
laundering ... United
States, but it directly accessed the U.S. banking system through
a correspondent bank account, Account No. 101-WA-358967-000, held
-3-
EFTA01125421
at UBS AG ("UBS") in Stamford
https://www.justice.gov/epstein/files/DataSet%209/EFTA01125419.pdf
EFTA00205884Set 9
2011-09-2613p5,481w
that needed "further factual development." DE 99 at 2 n.2. Please provide all
documents, correspondence, and other information that supports these victims' allegations,
including:
(a) the FBI case file ... Epstein case;
(b) all documents, correspondence, witness statements, FBI 302s, and other
similar information, that the Government collected as part of its case against
and/or investigation of Epstein, including ... part of "discovery" or exchange of information
concerning the case;
(c) all documents, correspondence, witness statements, and other similar
information that the Government received from any federal, state, local
https://www.justice.gov/epstein/files/DataSet%209/EFTA00205884.pdf
EFTA00205116Set 9
2011-09-2613p5,431w
that needed "further factual development." DE 99 at 2 n.2. Please provide all
documents, correspondence, and other information that supports these victims' allegations,
including:
(a) the FBI case file ... Epstein case;
(b) all documents, correspondence, witness statements, FBI 302s, and other
similar information, that the Government collected as part of its case against
and/or investigation of Epstein, including ... part of "discovery" or exchange of information
concerning the case;
(c) all documents, correspondence, witness statements, and other similar
information that the Government received from any federal, state, local
https://www.justice.gov/epstein/files/DataSet%209/EFTA00205116.pdf
EFTA00206695Set 9
2007-06-0719p6,035w
prepared a 53-page indictment
for numerous federal offenses. U.S. Attorney's Correspondence at 4.
8. In and around September 2007, plea discussions took place between Jeffrey Epstein,
represented ... negotiations are
reflected in e-mails between Lefkowitz and Copies of the correspondence are attached as
Exhibit 2 to the Edwards Declaration accompanying this filing (hereinafter cited as "U.S. Attorney ... 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
https://www.justice.gov/epstein/files/DataSet%209/EFTA00206695.pdf
EFTA00229916Set 9
2011-04-26277p86,795w
this filing (hereinafter
the case. See generally U.S. Attorney's Correspondence, Exhibi
by Bates page number stamp).
cited as "U.S. Attorney's Correspondence" and referenced
Jane Doe #2 were victims ... presented information to
nce at 47-55.
prosecution, See Exhibit "B"; U.S. Attorney's Corresponde
Doe #1 a standard CVRA
6. On about June 7, 2007, FBI agents hand-delivered ... criminal sexual assault prosecution by
operation of Fed. R. Evid. 414. U.S. Attorney's Correspondence at 4.
interested in
12. The correspondence also shows that the U.S. Attorney's Office
https://www.justice.gov/epstein/files/DataSet%209/EFTA00229916.pdf
EFTA00209534Set 9
2013-07-1225p5,708w
Disinterested Third Party 15
III. INTERVENORS WILL SUFFER INJURY IF THE
PRIVILEGED AND CONFIDENTIAL CORRESPONDENCE
IS DISCLOSED TO PLAINTIFFS 17
CONCLUSION 20
EFTA00209535
Case: 13-12923 Date Filed: 07/12/2013 Page ... civil litigation, "Epstein's counsel produced to the victims' counsel
significant parts of the correspondence by his attorneys concerning the NPA," Motion
at 6, is misleading, as only correspondence from ... government to Mr. Epstein's
attorneys was produced to plaintiffs, not correspondence authored by Mr. Epstein's
counsel during the course of the negotiations. See United States' Response to
Supplemental
https://www.justice.gov/epstein/files/DataSet%209/EFTA00209534.pdf
EFTA00213912Set 9
2010-09-025p1,166w
JANE DOE and Defendant, JEFFREY EPSTEIN ("Epstein"), hereby file their
Joint Stipulation Regarding Certain Correspondence Obtained By Jane Doe's attorneys during
discovery, and each state:
I. In July ... Finn"), Paul G. Cassell, Esq. and Jay Howell, Esq. ("Counsel")
received through discovery certain correspondence and documents (including content thereof)
between Epstein's attomeys/agents and federal prosecutors (the "Correspondence ... Counsel for Jane Doe and Counsel for Epstein disagree whether the
Correspondence is confidential.
3. Without in any way altering the obligations set forth in the Addenda to Settlement
Agreements
https://www.justice.gov/epstein/files/DataSet%209/EFTA00213912.pdf
EFTA01072076Set 9
2013-07-1512p2,731w
case. Absent a stay there will be
irreparable injury to the intervenor/appellants, as the correspondence which they seek
to have remain confidential will have been disclosed. Given the common
understanding ... others.
Second, plaintiffs' statement that they have already seen "significant parts of
the correspondence," Opposition at 15 n.7, is misleading, as only correspondence
from the government to Mr. Epstein ... order in Jane Doe #2 v. Epstein, No. 08-80119-MARRA, Doc. 462;
correspondence authored by Mr. Epstein's counsel during the course of the
negotiations has not been disclosed
https://www.justice.gov/epstein/files/DataSet%209/EFTA01072076.pdf
EFTA00223850Set 9
2013-06-1816p4,116w
Acosta and Attorney-Client Privilege
P-013279 , and re Work Product
Thru proposed correspondence to Jay Leflcowitz
P-013280
Suppl. Box #3 Handwritten note re Epstein investigation Attorney-Client Privilege ... about Work Product
Thru handling of case and attached email Deliberative Process
P-013527 correspondence between and G.
Lefcourt
Suppl. Box #3 Handwritten notes by dated Work Product ... mail from to Deliberative Process
Investigative Privilege
re non-prosecution agreement, with
attached correspondence;
• 9/19/07 e-mail from to
re
negotiating strategy, with attached
correspondence;
• 9/18/07 e-mail from
https://www.justice.gov/epstein/files/DataSet%209/EFTA00223850.pdf
EFTA00820386Set 9
2016-08-253p704w
registered trademark of IMAX Corporation.
IMPORTANT NOTICE********************************
Information contained in this e-mail correspondence and any attachments is confidential information
intended only for the use of the individual or entity ... above.
Any reader of this message who is not the intended recipient of this correspondence is hereby notified that
any dissemination, distribution, copying
or communication of the contents of this ... correspondence is strictly prohibited. If this e-mail was not
addressed to you , please immediately notify us
by phone in Canada at (905) 403-6500 (collect calls will be accepted
https://www.justice.gov/epstein/files/DataSet%209/EFTA00820386.pdf
EFTA01206074Set 9
2008-06-3012p4,141w
regarding whether
there was a sanctionable violation of the CVRA, the portion of the correspondence authored by
Epstein's counsel to the government, foreseeably, is irrelevant to the resolution ... evidence that there was a "deliberate" conspiracy
that would begin to make relevant the correspondence at issue. For these reasons, and because
the correspondence of Epstein's counsel ... parties and intervenors
concerning the public dissemination at this point in time of the correspondence between
Epstein's various counsel and the government that memorializes the negotiations relating
https://www.justice.gov/epstein/files/DataSet%209/EFTA01206074.pdf