A. Marie Villafana Assistant United States Attorney WPB Re Jeffrey Epstein Dear Ms Villafana Thank you for your letter of July 27, 2011 in regards to the request by the New York District Attorney for copies of the NPA and the "victim list" in regards to Mr. Epstein. We continue for the reasons stated herein to believe that any such disclosure would violate the confidentiality agreement between your Office and Mr. Epstein as well as the provisions of F.R.Crim.P 6(e). As to the NPA, you have repeatedly asserted in Doe v United States 9:08cv80736-KAM that the NPA was a confidential document. For instance, in par 6 of document 14, your own declaration, you stated that the NPA contained "an express confidentiality provision". In opposing the Motion to Unseal the NPA that was filed by Jane Doe, you stated that you had informed Judge Marra of the confidentiality provision during an earlier telephonic status conference occurring on August 14, 2008 which "the United States was obligated to honor", Doc 29, pg 1, and that "the parties who negotiated the Agreement, the United States Attorney's Office and Jeffrey Epstein, determined that the Agreement should remain confidential", Doc 29, pg 2. The New York District Attorney, Ms Morse, is representing the prosecution in an appeal regarding a sex offender registration determination and any disclosure of the NPA to her has the potential to result in its use in that appeal and the real risk that the appellate court will unseal it. Both Mr. Lefkowitz, who is co-signing this letter, and myself believe it to violate both the spirit and the most logical interpretation of the NPA, par 13, for you to disclose it absent a subpoena (which we could oppose in the jurisdiction from which it emanated), and also believe that when parol evidence supplements the text of the paragraph it is perfectly apparent from your prior submissions that you as well as we believed the NPA to contain "an express confidentiality pr