{"efta_number": "EFTA00191148", "page_count": 51, "url": "https://epstein-data.com/EFTA00191148", "pdf_url": "https://epstein-data.com/pdf/EFTA00191148.pdf", "pages": [{"efta_number": "EFTA00191148", "page_number": 0, "text_content": "Case 9:08•cv-80736•KAM Document 190 Entered on FLSD Docket 06/19/2013 Page 1 of 3 \nUNITED STATES DISTRICT COURT \nSOUTHERN DISTRICT OF FLORIDA \nCASE NO. 08-80736-CIV-MARRA \nJANE DOE NI and JANE DOE #2, \npetitioners, \nvs. \nUNITED STATES OF AMERICA, \nrespondent. \nFILED by \nD.C. \nJUN 1 8 2013 \nSTEVEN M LARIMORE \nCLERK U S DIST. CT \nS 0 of FLA - W PB \nOMNIBUS ORDER \nTHIS CAUSE is before the court on various motions. \nUpon consideration, it is ORDERED AND ADJUDGED: \nI. The petitioners' protective motion seeking recognition of the availability of various \nremedies attaching to the CVRA violations alleged in this proceeding [DE 128] is DENIED \nWITHOUT PREJUDICE to renew the request for any particular form of relief or remedy in \nconnection with the court's fmal disposition of petitioners' CVRA petition on the merits. \n2. The intervenors' motion to strike the petitioners' supplemental authority regarding \nprivilege claims [DE 177] is DENIED AS MOOT. \n3. The petitioners' sealed motion for the court to deny the government's motion to dismiss \nbased on existing pleadings, or alternatively, for leave to file a sur-reply [DE 152] is DENIED AS \nMOOT. \nEFTA00191148\n", "char_count": 1168}, {"efta_number": "EFTA00191148", "page_number": 1, "text_content": "Case 9:08-cv-80736-KAM Document 190 Entered on FLSD Docket 06/19/2013 Page 2 of 3 \n3. The petitioners' motion to compel discovery from the government [DE 130] is \nGRANTED. Within THIRTY (30) DAYS from the date of entry of this order, the government \nshall: \na. File answers to all outstanding requests for admissions in the open court file; \nb. Produce responsive documents in response to all outstanding requests for production of \ndocuments encompassing any documentary material exchanged by or between the federal \ngovernment and persons or entities outside the federal government (including without limitation all \ncorrespondence generated by or between the federal government and Epstein's attorneys), and \nc. Produce all other responsive documents in response to all outstanding requests for \nproduction of documents. To the extent any claim of privilege is asserted in connection with the \nproduction of any documents falling within this broader category of materials only (i.e. materials \nother than communications generated between the federal government and outside persons or \nentities), the government shall further: \n(i) contemporaneously file and serve, in the public portion of the court file, a privilege log \nclearly identifying each documents by author(s), addressee(s), recipient (s), date, and general subject \nmatter and such other identifying data as required under Fed. R. Civ. P. 26.1 (g), and \n(ii) contemporaneously submit all responsive documents withheld on claim of privilege to \nthe court for in camera inspection by submitting the same for filing with the court under seal. \nAs to any documents falling into this broader category of materials (identified in ¶3.c.), and \nas to which the government has asserted claim of privilege with accompanying privilege log, \npetitioners shall have THIRTY (30) DAYS after service of the privilege log within which to file \nmotion to compel contesting any asserted privilege claim, limited to SEVEN (7) PAGES in length, \n2 \nEFTA0019\n... [truncated, 2005 chars — for the full page use /api/corpus/document/EFTA00191148/1 or ?id=EFTA00191148&page=1]", "char_count": 2005}, {"efta_number": "EFTA00191148", "page_number": 2, "text_content": "Case 9:08-cv-80736-KAM Document 190 Entered on FLSD Docket 06/19/2013 Page 3 of 3 \nand the government shall thereafter have FIFTEEN OM DAYS after service of the petitioners's \nmotion motion to file its response, if any, limited to SEVEN (7) PAGES in length. No further \nsubmissions on asserted privilege claims shall be entertained without the express invitation of the \ncourt. \nDONE AND ORDERED in Chambers at West Palm Beach, Florida this 18'\" day of June, \n2013. \nKenneth A. Marra \nUnited States District Judge \ncc. All counsel \n3 \nI\n_ SEALED \no J0T SEALED I \nEFTA00191150\n", "char_count": 576}, {"efta_number": "EFTA00191148", "page_number": 3, "text_content": "To be Argued By: \nJAY P. LEFKOWITZ \nNew York County Clerk's Index No. 30129/2010 \nr efu I wit *grant gratrt \nAPPELLATE DIVISION \nFIRST DEPARTMENT \nPEOPLE OF THE STATE OF NEW YORK, \n—against—\nJEFFREY E. EPSTEIN, \nRespondent, \nDefendant -Appellant. \nBRIEF FOR DEFENDANT-APPELLANT \nJAY P. LEFKOWITZ \nSANDRA LYNN MUSUMECI \nKIRKLAND & ELLIS LLP \n601 Lexington Avenue \nNew York, New York 10022 \njay.leflcowitz@kirkland.com \nsandra.musumeci@kirkland.com \nAttorneys for Defendant-Appellant \nREPRODUCED ON RECYCLED PAPER \nEFTA00191151\n", "char_count": 526}, {"efta_number": "EFTA00191148", "page_number": 4, "text_content": "New York County Clerk's Index No. 30129/2010 \nettr tin Supreme Court \nAPPELLATE DIVISION-FIRST DEPARTMENT \nPEOPLE OF THE STATE OF NEW YORK, \n—against-\nJEFFREY E. EPSTEIN, \nRespondent, \nDefendant-Appellant. \nAPPENDIX \nCYRUS R. VANCE, JR. \nNE%V YORK COUNTY Mrnuer \nATTORNEY'S OFFICE \nOne Hogan Place \nNew York New York 10013 \ndanyappeals@dany.gov \nAttorneys for Respondent \nJAY P. LEFKOWITZ \nSANDRA LYNN MUSUMECI \nKIRKLAND & ELLis LLP \n601 Lexington Avenue \nNew York New York 10022 \njayleficowitz@kirkland.com \nsandra.musumeci @kirkland.com \nAttorneys for Defendant-Appellant \nREPRODUCED ON RECYCLED PAPER \nEFTA00191152\n", "char_count": 618}, {"efta_number": "EFTA00191148", "page_number": 5, "text_content": "To: \nBigJimLaw©aol.coliritaol.com]; \nSubject: \nRE: \nSent: \nTue 10/24/2006 5:51:08 PM \nFrom: \nVillafana, Ann Marie C. (USAFLS) \nHi Jim -- Thank you for the e-mail, and I will even forgive the football reference. I was \njust set for trial, so the earliest I will be able to reschedule the testimony will be after \nThanksgiving. I will give you a call to discuss theigunity issue but I am concerned \nabout other things we have talked about -- if Ms. \nis given immunity, will she be \nforthcoming and answer the questions? Or am I going to jump through hoops to get her \nimmunity and then have to worry about filing motions to compel, motions for orders to \nshow cause why she shouldn't be held in contempt, etc., etc.? \nAs always, thank you for your assistance. \nRegards, \nMarie \nA. Marie Villafaiia \nAssistant U.S. Attorney \n561 209-1047 \nFax 561 820-8777 \nann.marie.c.villafana@usdoj.gov \nFrom: BigJimLaw@aol.com [mailto:BigJimlaw@aol.conr \nSent: Tuesday, October 24, 2006 12:00 PM \nTo: Villafana, Ann M \n(USAFLS) \nSubject: Re: \nSorry I did nnot get back to you sooner. I have been out of town for several weeks. As \nto Miss \nshe still does not wish to testify in this case and has a Fifth Amendment \nbasis for her position. She wishes not to accept the \"proffer letter \" cover of immunity, \nwhich again is her right. I think it is a waste of time to have her appear Friday to just \ntake the Fifth. I suggest that you huddle with your people. (It is football season). If \nyou want to push the issue you will have to get formal imawagy. I will accept service \nnow and in the future for you so you don't have to chase =I \ndown. Jim Eisenberg \nEFTA00191153\n", "char_count": 1652}, {"efta_number": "EFTA00191148", "page_number": 6, "text_content": "To: \nVillafana, Ann Marie C. USAFLSNO=USA/OU=FLS/CN=RECIPIENTS/CN=AVILLAFANA]; \nSubject: \nRe: \nSent: \nFri 2/2/ 007 2:36:10 PM \nFrom: \nBigJimLaw@aol.com \nI just wrote you a letter confirming that Ms. \nwill be at the grand jury room with me. Please keep me \ninformed as to the time. I must warn you, my e \ncritical of your office, although not at all critical of \nyou. If you change your mind about forcing Ms \nto appear, please e-mail or call at once so she does \nnot have to make arrangements for child care to e in court. Thanks, Jim Eisenberg \nEFTA00191154\n", "char_count": 559}, {"efta_number": "EFTA00191148", "page_number": 7, "text_content": "Villafana, Ann Marie C. (USAFLS) \nFrom: \nLourie, Andrew (USAFLS) \nSent: \nTuesday, May 22, 2007 3:11 PM \nTo: \nMenchel, Matthew (USAFLS); Sloman, Jeff (USAFLS) \nCc: \nVillafana, Ann Marie C. (USAFLS) \nSubject: \nFW: Jeffrey Epstein \nAttachments: \n2007.05.22 letter to AUSA Lourie.pdf \nGentlemen, \nMarie and I have already met with Lefcourt, which is really the meeting I promised him. I spoke to him last week and he \nsaid he had more information they wanted to present. I told him he could make an appointment to come in again if he \nwanted to and that we would meet with him again, but I did not promise that we would wait to give him a meeting \n\"before\" we charged. \nSo, I think he is really ready for the next level rather than a second meeting with me. Mike Tein also mentioned to me \nat some point that they wanted to make a presentation on the law and I suggested to him that he contact Matt without \ntelling him exactly what stage of review we were at. I don't know if Tein and Lefcourt have crossed wires or not. \nIn any event, I am forwarding this letter to you. I am going to suggest to Lefcourt the same thing that I suggested to \nTein. I assume you would grant his attorneys a chance to make whatever presentation they desire. It would probably \nbe helpful to us in any event to hear their legal arguments in case we have missed something. Whether Alex would be \npresent or grant them another meeting after that is his call. \nAndy \nFrom: Gerald Lefcourt [mailto:GBL@lefcourtlaw.com] \nSent: Tuesday, May 22, 2007 2:05 PM \nTo: Lourie, Andrew (USAFLS) \nCc: Villafana, Ann Marie C. (USAFLS); Lilly Ann Sanchez \nSubject: Jeffrey Epstein \nAndy, attached is a letter seeking meetings, as discussed with you, but with others if it is not resolved. Thanks for your \nattention. Could you email back so that I know you have received this letter? \nGerald B. Lefcourt \nGerald B. Lefcourt, P.C. \n148 E. 78th Street \nNew York New York 10021 \nTel. \nFax \nableletcourtlaw com \n153 \nEFTA00191155\n", "char_count": 1986}, {"efta_number": "EFTA00191148", "page_number": 8, "text_content": "Villafana, Ann Marie C. (USAFLS) \nFrom: \nMenchel, Matthew (USAFLS) \nSent: \nMonday, May 14, 2007 10:52 AM \nTo: \nVillafana, Ann Marie C. (USAFLS); Lourie, Andrew (USAFLS) \nSubject: \nRe: Operation Leap Year \nMarie, \nYou will not have approval to go forward tomorrow with an indictment or to poceed \nby complaint. Alex has your memo and lefcourt's letter but he is out of the \ndistrict at the US Attorney's conference for the next several days. \nI'm having trouble understanding - given how long this case has been pending \nwhat the rush is. This is obviously a very significant case and alex wants to \ntake his time making sure he is comfortable before proceeding. \nSent from my BlackBerry Wireless Handheld \n \nOriginal Message \nFrom: Villafana, Ann Marie C. (USAFLS) <AVillafana@usa.doj.gov> \nTo: Lourie, Andrew (USAFLS) <ALourie@usa.doj.gov>; Menchel, Matthew (USAFLS) \n<MMenchel@usa.doj.gov> \nSent: Mon May 14 10:38:15 2007 \nSubject: Operation Leap Year \nGood morning: I just received a call that Epstein's plane is flying from the \nVirgin Islands to Newark now, so it looks like Epstein is going to show up for \nhis court appearance tomorrow. Can you let me know if the indictment is going \ntomorrow or, if not, whether we are authorized to proceed by Complaint? \nThank you. \nA. Marie Villafana \nAssistant U.S. Attorney \n500 S. Australian Ave, Suite 400 \nWest Palm Beach, FL 33401 \nPhone 561 209-1047 \nFax 561 820-8777 \n179 \nEFTA00191156\n", "char_count": 1439}, {"efta_number": "EFTA00191148", "page_number": 9, "text_content": "Villafana, Ann Marie C. (USAFLS) \nFrom: \nLaurie, Andrew (USAFLS) \nSent: \nThursday, May 24, 2007 9:25 AM \nTo: \nVillafana, Ann Marie C. (USAFLS) \nSubject: \nFW: Jeffrey Epstein \nPlease put in your file. thx \nFrom: Gerald Lefcourt (mallto:GBL@lefcourtlaw.com] \nSent: Wednesday, May 23, 2007 5:00 PM \nTo: Lourie, Andrew (USAFLS) \nSubject: RE: Jeffrey Epstein \nThanks for the email. I will get back to you as to timing of the meeting. \nGerald B. Lefcourt \nGerald B. Lefcourt, P.C. \n148 E. 78th Street \nNew \nrk 10021 \nTel. \nFax \nax\ncourtlaw.com \nFrom: Lourle, Andrew (USAFLS) [mailto:Andrew.Lourie@usdcl.gov] \nSent: Tuesday, May 22, 2007 6:32 PM \nTo: Gerald Lefcourt \nSubject: RE: Jeffrey Epstein \nI have your letter. I think we are on the same page, but to be sure I do want to clarify that we spoke the other week and \nI did say that if you want to meet with me again, I am ready to do so. The wording of your letter, however, suggests \nimplicitly that I agreed to contact you before a decision is made to seek an indictment of Mr. Epstein. If that was your \nunderstanding, then please allow me to clarify. Our investigation is ongoing and if we decide to seek an indictment, we \ndon't intend to call Mr. Epstein's representatives to let him know that. Of course, in the interim, if you would like to \nmake a presentation to us, we are willing to listen. \nAlong those lines, given the fact that we have already met once, with schedules being what they are, it makes sense for \nour criminal chief, Matt Menchel, to be included when you make another presentation, rather than working up the \nchain incrementally. I realize you were being respectful in not attempting to leapfrog over me, which I appreciate. I \nwill pass on your request to meet with the U.S. Attorney as well, but can't commit for him one way or another. When \nyou have some dates in mind, let me know and I will try to set up a meeting in Miami. \nFrom: Gerald Lefcourt [mailto:GBL@Iefcourtlaw.com) \nSent: Tuesday, May 22, 2007 2:05 PM \nTo:\n... [truncated, 2127 chars — for the full page use /api/corpus/document/EFTA00191148/9 or ?id=EFTA00191148&page=9]", "char_count": 2127}, {"efta_number": "EFTA00191148", "page_number": 10, "text_content": "Andy, attached is a letter seeking meetings, as discussed with you, but with others if it is not resolved. Thanks for your \nattention. Could you email back so that I know you have received this letter? \nGerald B. Lefcourt \nGerald B. Lefcourt, P.C. \n148 E. 78th Street \nNew York New York 10021 \nTel. \nFax \nbl \ne court aw.com \n142 \nEFTA00191158\n", "char_count": 343}, {"efta_number": "EFTA00191148", "page_number": 11, "text_content": "Villafana, Ann Marie C. (USAFLS) \nFrom: \nVillafana, Ann Marie C. (USAFLS) \nSent: \nMonday, June 18, 2007 5:04 PM \nTo: \nMenchel, Matthew (USAFLS); Sloman, Jeff (USAFLS); Lourie, Andrew (USAFLS); Atkinson, \nKaren (USAFLS) \nSubject: \nEpstein \nI just received a call from the FBI telling me that Vanity Fair is sniffing around again. The reporter is a former \ndetective. He told the FBI agent that his sources tell him \"the State has been bought off,\" and asked if our \ninvestigation had been sent to \"the circular file.\" Nesbitt responded, \"All I can tell you is that we have an open \ninvestigation.\" \nOn another note, I am going to see the grand jury tomorrow and I anticipate a number of questions regarding the \nstatus of the indictment. I'm not sure what, if anything, I can tell them. \nAnd I did not hear back regarding making changes to the indictment. Can I get some feedback on that? \nThank you. \nA. Marie Villafafia \nAssistant U.S. Attorney \n500 S. Australian Ave, Suite 400 \nWest Palm Beach, FL 33401 \nPhone 561 209-1047 \nFax 561 820-8777 \nTracking: \n128 \nEFTA00191159\n", "char_count": 1075}, {"efta_number": "EFTA00191148", "page_number": 12, "text_content": "Villafana, Ann Marie C. (USAFLS) \nFrom: \nVillafana, Ann Marie C. (USAFLS) \nSent: \nThursday, June 21, 2007 3:24 PM \nTo: \nMenchel, Matthew (USAFLS) \nSubject: \nRE: Meeting Next Week \nSounds good. I will stop by on Monday afternoon. Could you just let you assistant know that I may be \nslopping by to get a copy of whatever the defense sends over? \nThanks. \nA. Alarie Villgfitho \nAssistant U.S. Attorney \n500 S. Australian Ave. Suite 400 \nWest Palm Beach, FL 33401 \nPhone 561 209-1047 \nFax 561 820-8777 \nFrom: Menchel, Matthew (USAFLS) \nSent: Thursday, June 21, 2007 2:58 PM \nTo: Villafana, Ann Marie C. (USAFLS) \nCc: Lourie, Andrew (USAFLS) \nSubject: RE: Meeting Next Week \nMeeting on Monday is fine. I have meetings with Alex and Jeff till around 11 but after that I'm free. As for who is going \nto be at the meeting from our side, I thought you, me, Andy, and Jeff. I thought it best to leave Alex out of it at this \nventure. As for the Epstein camp, I'm not entirely sure because I don't think Lily was sure last time we spoke. Probably \nher, Lefcourt, Black and maybe Lewis. \nLily told me that they wanted to present something in writing before the meeting which was why she was pushing us for \nthe statutes. I view the meeting more as us listening and them presenting their position so I would say that you don't \nneed to prepare anything (you are quite knowledgeable on the law in any event) but if you disagree we can discuss on \nMonday. As for the documents that they have yet to produce, I'll mention it to Lily if you like or we can raise it with \nthem at the Tuesday meeting. \nFrom: Villafana, Ann Marie C. (USAFLS) \nSent: Thursday, June 21, 2007 1:37 PM \nTo: Menchel, Matthew (USAFLS) \nCc: Atkinson, Karen (USAFLS); McMillan, John (USAFLS); Lourie, Andrew (USAFLS); Sloman, Jeff (USAFLS) \nSubject: Meeting Next Week \nImportance: High \nHi Matt: I would like to prepare for next week's meeting, and I am wondering if you can tell me who will \nattend, both from our side and for Mr. Epstein. I \n... [truncated, 2186 chars — for the full page use /api/corpus/document/EFTA00191148/12 or ?id=EFTA00191148&page=12]", "char_count": 2186}, {"efta_number": "EFTA00191148", "page_number": 13, "text_content": "Also, if there are any issues that you would like me to be prepared to address — either with you on Monday or \nwith defense counsel on Tuesday — please give me a list and I will bring the appropriate items with me. \nSince Lilly has been communicating with you directly about the meeting, and I have given them the list of \nstatutes that they have requested, perhaps you could ask her to reciprocate by providing us with their written \nanalysis (or documents they want us to consider) prior to the meeting so we can address any issues then and \nthere. Also, during a previous meeting, I asked Lilly and Gerry for copies of Epstein (or his assistants') agendas \nand calendars to show that, as they claim, Epstein's travels to Florida were consciously coordinated so that he \ncould maintain his Florida residency for tax purposes. Lilly said she would try to get them to us, but has never \ndone so. I have subpoenaed all of the corporate entities with which Epstein is affiliated and they all claim that \nthey do not have any responsive documents. \nI will plan to be in Miami by around 10:00 on Monday morning, so any time after that is fine. \nThank you. \nA. Marie Villafana \nAssistant U.S. Attorney \n500 S. Australian Ave, Suite 400 \nWest Palm Beach, FL 33401 \nPhone 561 209-1047 \nFax 561 820-8777 \nTracking: \n115 \nEFTA00191161\n", "char_count": 1326}, {"efta_number": "EFTA00191148", "page_number": 14, "text_content": "Villafana, Ann Marie C. (USAFLS) \nFrom: \nVillafana, Ann Marie C. (USAFLS) \nSent: \nTuesday, July 03, 2007 6:26 AM \nTo: \nSloman, Jeff (USAFLS); Menchel, Matthew (USAFLS); Lourie, Andrew (USAFLS) \nCc: \nAtkinson, Karen (USAFLS); Ball, Shawn (USAFLS) \nSubject: \nEpstein \nImportance: \nHigh \nI have received a couple of calls and an e-mail from Lilly Ann Sanchez asking for an extension of time to \nrespond to several subpoena. She also states that they intend to provide us with a \"supplement\" to their \npresentation and what they believe will be their resolution with the state. I intend to send a response stating that \nthe subpoenas for financial documents can be put off, but we want to get the computer equipment that was \nremoved from Epstein's home prior to the state search warrant as soon as possible. I also intend to invite her to \ncall me to discuss a resolution of the federal investigation that could include concurrent time. \nIf anyone has communicated anything to any of Epstein's attorneys that is contrary to this, please contact my \nassistant, Shawn Ball, as soon as possible. I have asked Shawn to send out the e-mail while I am in trial. You \nwill all receive a copy of the e-mail when it is sent. \nThank you. \nA. Marie Villafaila \nAssistant U.S. Attorney \n500 S. Australian Ave, Suite 400 \nWest Palm Beach, FL 33401 \nPhone 561 209-1047 \nFax 561 820-8777 \nTracking: \n106 \nEFTA00191162\n", "char_count": 1400}, {"efta_number": "EFTA00191148", "page_number": 15, "text_content": "Villafana, Ann Marie C. (USAFLS) \nFrom: \nVillatana, Ann Marie C. (USAFLS) \nSent: \nFriday, July 13, 2007 3:14 PM \nTo: \nMenchel, Matthew (USAFLS) \nSubject: \nRE: Epstein \nHi Matt -- My trial is over, so I now have to time to focus back on this case and \nour e-mail exchange. There are several points in your e-mail that I would like \nto address, and I also would like to address where we are in the case. \nFirst, I wanted to address the comment about jumping the chain of command. After \nthat concern was brought to my attention several months ago, I have tried very \nhard to be cognizant of the chain of command, and, as was evident at the meeting \nwith Epstein's attorneys, Andy and I have discussed the case extensively. My \noriginal e-mail asking for everyone's input was addressed to Andy, you, and Jeff, \nand Karen Atkinson was cc'd. (Karen and I also have discussed the case in great \ndetail.) The response to your e-mail was addressed only to you because i thought \nyou would want to discuss privately our disagreement. It was addressed to Jeff \nas well because you said that you had Jeff's Blackberry and it was a holiday when \nyou would be out of the office. If there is a particular instance of violating \nthe chain of command that you would like to discuss, I would be happy to discuss \nit with you. \nSecond, the reason why I sent the original e-mail to everyone was to see if \nanyone had any objections to the proposed language. I waited several days to \nsend out the e-mail to Lilly to get everyone's response. In your response, you \ndid not raise any concerns, nor did anyone else. Given your indication that the \nU.S. Attorney would be satisfied with an agreement involving no federal \nprosecution, I certainly didn't think that an agreement involving some federal \ncomponent would be objectionable. Andy, Jeff, you, and I all have discussed the \ngreater flexibility of a pre-indictment plea. \nThe statement that I have not respected Alex's position regarding the prosecution \nof the cas\n... [truncated, 3284 chars — for the full page use /api/corpus/document/EFTA00191148/15 or ?id=EFTA00191148&page=15]", "char_count": 3284}, {"efta_number": "EFTA00191148", "page_number": 16, "text_content": "would not happen. Now I feel like there is a glass ceiling that prevents me from \nmoving forward while evidence suggests that Epstein is continuing to engage in \nthis criminal behavior. Additionally, the FBI has identified two more victims. \nIf the case is not going to go forward, I think it is unfair to give hope to more \ngirls. \nAs far as promising the FBI that an indictment was a foregone conclusion, I don't \nknow of any cases in the Office where an investigation has been opened with the \nplan NOT to indict. And I have never presented an indictment package that has \nresulted in a declination. I didn't treat this case any differently. I worked \nwith the agents to gather the evidence, and I prepared an indictment package that \nI believe establishes probable cause that a series of crimes have been committed. \nMore importantly, I believe there is proof beyond a reasonable doubt of Epstein's \ncriminal culpability. \nLastly, I was not trying to \"dictate\" a meeting with the U.S. Attorney or anyone \nelse. I stated that I \"would like\" to schedule a meeting, asking to have the \nsame courtesy that was extended to the defense attorneys extended to the FBI and \nan Assistant in the Office. With respect to your questions regarding my \njudgment, I will simply say that disagreements about strategy and raising \nconcerns about the forgotten voices of the victims in this case should not be \nclassified as a lapse in judgment. This Office should seek to foster spirited \ndebate about the law and the use of prosecutorial discretion, and I think that \nthose debates do occur with other AUSAs. I know of past instances where \ndisagreements about the application of the law to different defendants and \ndefense attorneys has resulted in a call for the resignation of the AUSA who \ndared to challenge the Executive Office's conclusions. I found that very \ndisheartening and hoped that this Administration would be different. However, my \nfirst and only concern in this case (and my other child exploi\n... [truncated, 3328 chars — for the full page use /api/corpus/document/EFTA00191148/16 or ?id=EFTA00191148&page=16]", "char_count": 3328}, {"efta_number": "EFTA00191148", "page_number": 17, "text_content": "Marie \nA. Marie Villafana \nAssistant U.S. Attorney \n500 S. Australian Ave, Suite 400 \nWest Palm Beach, FL 33401 \nPhone 561 209-1047 \nFax 561 820-8777 \n \nOriginal Message \nFrom: Menchel, Matthew (USAFLS) \nSent: Thursday, July 05, 2007 3:30 PM \nTo: Villafana, Ann Marie C. (USAFLS); Sloman, Jeff (USAFLS) \nCc: Lourie, Andrew (USAFLS) \nSubject: RE: Epstein \nMarie, \nBoth the tone and substance of your email are totally inappropriate and, in \ncombination with other matters in the past, it seriously calls your judgment into \nquestion. \nAs you well know, the US Attorney has not even decided whether to go forward with \na prosecution in this matter, thus you should have respected his position before \nengaging in plea negotiations. \nAlong that same line, despite whatever contrary representations you made to the \nagents in this matter, it was made clear to you by the US Attorney and the First \nAssistant from the time when you were first authorized to investigate Mr. Epstein \nthat the office had concerns about taking this case because of petit policy and \na number of legal issues. Despite being told these things, you prepared a pros \nmemo and indictment that included a definitive date for indictment. It has come \nto my attention that you led the agents to believe that the indictment of this \nmatter was a foregone conclusion and that our decision to put off that date and \nlisten to the defense attorneys' concerns is indicative of the office having \nsecond thoughts about indicting. As you well knew, you were never given \nauthorization by anyone to seek an indictment in this case. \nLily Sanchez called me before, not after, the June 26th meeting. It was an \ninformal discussion and not in the nature of an official plea offer but rather a \nfeeling out by both sides as to what it might take to resolve the matter. As you \nare also well aware, the only reason why this office even agreed to look into the \nEpstein matter in the first instance was because of concerns that the State had \nnot \n... [truncated, 2333 chars — for the full page use /api/corpus/document/EFTA00191148/17 or ?id=EFTA00191148&page=17]", "char_count": 2333}, {"efta_number": "EFTA00191148", "page_number": 18, "text_content": "with the US Attorney's full knowledge. Had Lily Sanchez expressed interest in \npursuing this avenue further, I certainly would have raised it with all the \ninterested individuals in this case, including you and the agents. In any event, \nI fail to see how a discussion that went nowhere has hurt our bargaining \nposition. I am also quite confident that no one on the defense team believes \nthat the federal investigation in this matter has been for show. \nNor are your arguments that I have violated the Ashcroft memo, the USAM or any \nother policy well taken. As Chief of the Criminal Division, I am the person \ndesignated by the US Attorney to exercise appropriate discretion in deciding \nwhether certain pleas are appropriate and consistent with the Ashcroft memo and \nthe USAM -- not you. \nAs for your statement that my concerns about this case hurting Project Safe \nChildhood are unfounded, I made it clear to you that those concerns were voiced \nby the US Attorney. Whether or not you are correct, matters of policy are always \nwithin his purview and any decisions in that area ultimately rest with him. \nFinally, you may not dictate the dates and people you will meet with about this \nor any other case. If the US Attorney or the First Assistant desire to meet with \nyou, they will let you know. Nor will I direct Epstein's lawyers to communicate \nonly with you. If you want to work major cases in the district you must \nunderstand and accept the fact that there is a chain of command - something you \ndisregard with great regularity. \nMatt \n \nOriginal Message \nFrom: Villafana, Ann Marie C. (USAFLS) \nSent: Wednesday, July 04, 2007 5:16 PM \nTo: Sloman, Jeff (USAFLS); Menchel, Matthew (USAFLS) \nSubject: FW: Epstein \nHi Matt -- I am in trial, so I just got your message. \nFirst, it is inappropriate for you to enter into plea negotiations without \nconsulting with me or the investigative agencies, and it is more inappropriate to \nmake a plea offer that you know is completely unacceptable to\n... [truncated, 2700 chars — for the full page use /api/corpus/document/EFTA00191148/18 or ?id=EFTA00191148&page=18]", "char_count": 2700}, {"efta_number": "EFTA00191148", "page_number": 19, "text_content": "Second, your discussion makes it appear that my investigation is for \"show\" only \nand completely undermines my ability to deal with Epstein's attorneys directly. \nIn my eight years of civil practice (before the six years that I have spent with \nthis Office), I have litigated against attorneys far more formidable than Roy \nBlack and Alan Dershowitz and have managed to convince the Eighth, Ninth, and \nFederal Circuits that my legislative interpretation was correct. Your concerns \nabout this prosecution hurting the rest of the Project Safe Childhood Program are \nunfounded. \nMy trial should end early next week. I would like to make a presentation to the \nU.S. Attorney, Jeff, Andy, and you with our side of the investigation and a \nrevised indictment. The presentation will address the points raised by Epstein's \ncounsel and will convince you all of the strength of the case. \nIn the meantime, please direct all communications from Epstein's counsel to me. \nA. Marie Villafaha \nAssistant U.S. Attorney \n500 S. Australian Ave, Suite 400 \nWest Palm Beach, FL 33401 \nPhone 561 209-1047 \nFax 561 820-8777 \n \nOriginal Message \nFrom: Sloman, Jeff (USAFLS) \nSent: Tuesday, July 03, 2007 1:47 PM \nTo: Villafana, Ann Marie C. (USAFLS) \nSubject: Epstein \nMarie, my blackberry is giving me trouble so I'm using jeff's. I told lily that \na state plea with jail time and sex offender status may satisfy the usa. It was \na non-starter for them Matt \nSent from my GoodLink synchronized handheld (www.good.com) \nTracking: \n64 \nEFTA00191167\n", "char_count": 1529}, {"efta_number": "EFTA00191148", "page_number": 20, "text_content": "Villafana, Ann Marie C. (USAFLS) \nFrom: \nGerald Lefcourt [GBL©lefcourtlaw.com] \nSent: \nWednesday, July 18, 2007 5:19 PM \nTo: \nVillafana, Ann Marie C. (USAFLS) \nCc: \nLilly Ann Sanchez; Roy BLACK \nSubject: \nRE: Jeffrey Epstein \nAttachments: \n2007-07-18 Villafana re NES subpoena.pdf \nMarie please consider this letter in response to the subpoena to NES. \nGerald B. Lefcourt \nGerald B. Lefcourt, P.C. \n148 E. 78th Street \nNew York, New York 10021 \nTel. \nFax \ngb1Plefcourtlaw.com \n \nOriginal Message \nFrom: Villafana, Ann Marie C. (USAFLS) (mailto:Ann.Marie.C.Villafana@usdoj.gov] \nSent: Wednesday, July 04, 2007 4:07 PM \nTo: Lilly Ann Sanchez \nCc: Gerald Lefcourt \nSubject: RE: Jeffrey Epstein \nDear Lilly and Gerry: Thank you for your e-mail and your message. This e-mail \nwas supposed to have gone out yesterday while I was in trial. I have no \nobjection to the two-week extension with respect to NES, New York Strategy Group, \nand Epstein Virgin Islands Foundation. \nWith respect to the subpoena to the investigator, I would like to get the \ncomputer equipment as soon as possible. If you prefer to simply turn over the \nequipment without anyone appearing before the grand jury that is fine. If we \nproceed that way, we can defer litigating the issue of the applicability of the \nattorney-client and/or work product privilege to information related to how and \nwhy the equipment was removed. I will be in trial this week, so please contact \nJason Richards at the FBI directly at 561 833-7517. \nI look forward to your July 11th submission. If you would like to discuss the \npossibility of a federal resolution of Mr. Epstein's case that could run \nconcurrently with any state resolution, please leave a message on my voicemail at \nthe office (561 209-1047) and I will get back to you after trial has ended for \nthe day. \nThank you. \nA. Marie Villafaha \nAssistant U.S. Attorney \n51 \nEFTA00191168\n", "char_count": 1894}, {"efta_number": "EFTA00191148", "page_number": 21, "text_content": "561 209-1047 \n \nOriginal Message \nFrom: Lilly Ann Sanchez [mailto:LAS@FOWLER-WHITE.COM] \nSent: Friday, June 29, 2007 4:05 PM \nTo: Villafana, Ann Marie C. (USAFLS) \nCc: Gerald Lefcourt \nSubject: Jeffrey Epstein \nMarie-\nAs i stated in my earlier voicemail today, we were calling to request a two-week \nextension on the return date of the following outstanding subpoenas: \n1. NES \n2. NY Strategy \n3. Investigator Riley \n4. Certification for St. Thomas entity \nWe will be providing an additional submission to the Office by July 11 and hope \nto be able to reach a state-based resolution shortly thereafter. \nas your voicemail to me indicted, you would not oppose a one to two-week \nextension. accordingly, we would like to extend the return date two weeks-- to \nJuly 24. \nregards \nLilly Ann Sanchez, Esq. \nFOWLER WHITE BURNETT P.A. \nEspirito Santo Plaza, 14th Floor \n1395 Brickell Avenue \nMiami, Florida 33131-3302 \nTelephone: (305) 789-9200 \nDirect Dial: (305) 789-9279 \nFacsimile: (305) 728-7579 \nlsanchez0fowler-white.com \n52 \nEFTA00191169\n", "char_count": 1039}, {"efta_number": "EFTA00191148", "page_number": 22, "text_content": "Villafana, Ann Marie C. (USAFLS) \nFrom: \nVillafana, Ann Marie C. (USAFLS) \nSent: \nThursday, September 06, 2007 9:29 AM \nTo: \nSloman, Jeff (USAFLS) \nSubject: \nRE: Meeting on Friday \nHi Jeff— The ASAIC will be there for the meeting. I think she also will be at the OLEOS. \nA. Ma•ie Villafasia \nAssistant U.S. Attorney \n561 209-1047 \nFrom: Sloman, Jeff (USAFLS) \nSent: Tuesday, September 04, 2007 11:44 AM \nTo: Villafana, Ann Marie C. (USAFLS) \nSubject: RE: Meeting on Friday \nLet's get together at 1:30. FBI is welcome but let's try to limit it to one representative. Is that o.k.? \nFrom: Villafana, Ann Marie C. (USAFLS) \nSent: Tuesday, September 04, 2007 11:29 AM \nTo: Sloman, Jeff (USAFLS) \nSubject: Meeting on Friday \nHi Jeff-1 just left you a voicemail, so you can disregard that. We had a very good meeting with Drew on Friday. No one \nwas sure whether you want an FBI presence at the meeting on Friday and Drew thought I should ask you. Could you let \nme know? And does the meeting with Epstein's team start at 2:00? Is there a plan for a pre-meeting meeting with our \nfolks? \nThanks. \nA. Marie VillafaPia \nAssistant U.S. Attorney \n561 209-1047 \nTracking: \n3250 \nEFTA00191170\n", "char_count": 1181}, {"efta_number": "EFTA00191148", "page_number": 23, "text_content": "Villafana, Ann Marie C. (USAFLS) \nFrom: \nVillafana, Ann Marie C. (USAFLS) \nSent: \nThursday, September 06, 2007 5:47 PM \nTo: \nSloman, Jeff (USAFLS) \nSubject: \nRE: Epstein \nHi Jeff— Funny you should ask. I have been wondering the same thing. Here is the term sheet and guidelines calculation \nthat we provided at the last meeting. You and Matt and I had also discussed a possible federal plea to an Infonnation \ncharging a 371 conspiracy, with a Rule II plea with a two-year cap. but I think Matt must have asked Alex about it and it \nwas nixed. Just to be prepared for tomorrow, I was just starting to draft a Rule I I plea agreement in case Alex changes \nhis mind and a formal non-prosecution agreement containing the state plea tenns. As soon as those are ready, I will e-\nmail them to you. \nConf Plea \nigotlations= \nThere are three concerns that I hope we can address tomorrow. First, that there is an absolute drop-dead date for \naccepting or rejecting because it is strategically important that we indict before the end of September, which means \npresenting the indictment on September 25th. Second, the agents and I have not reached out to the victims to get their \napproval, which as Drew politely reminded me. is required under the law. And third. I do not want to make any promises \nabout allowing Epstein to self-surrender because I still believe that we have a good chance of getting him detained. \nOn another note, Junior got a call today from the Palm Beach Police Chief because he got information that there will be an \narticle released tomorrow about our meeting and that Epstein is going to plead to a state charge and the Chief wanted to \nknow if the victims had been consulted about the deal. There has been some coverage in the New York press about Ken \nStarr, but I haven't seen anything local yet. \nA. Mork Villafirila \nAssistant U.S. Attorney \n561 209-1047 \nFrom: Sloman, Jeff (USAFLS) \nSent: Thursday, September 06, 2007 5:35 PM \nTo: Villafana, Ann Marie C. (USAFLS) \nSubject: E\n... [truncated, 2104 chars — for the full page use /api/corpus/document/EFTA00191148/23 or ?id=EFTA00191148&page=23]", "char_count": 2104}, {"efta_number": "EFTA00191148", "page_number": 24, "text_content": "Recipient \nSiornan. Jett (USAFLS) \nRead \nRead: 9/6/2007 5:58 PM \n3296 \nEFTA00191172\n", "char_count": 84}, {"efta_number": "EFTA00191148", "page_number": 25, "text_content": "Villafana, Ann Marie C. (USAFLS) \nFrom: \nVillafana, Ann Marie C. (USAFLS) \nSent: \nMonday, September 10,2007 5:24 PM \nTo: \nSloman, Jeff (USAFLS): Lourie, Andrew (USAFLS) \nSubject: \nFBI \nJeff and Andy — The agents arc asking whether Alex had a chance to talk to the SAIC. Do you know? \nA. Marie Villafana \nAssistant U.S. Attorney \n500 S. Australian Ave, Suite 400 \nWest Palm Beach, FL 33401 \nPhone 561 209-1047 \nFax 561 820-8777 \nTracking: \n3231 \nEFTA00191173\n", "char_count": 458}, {"efta_number": "EFTA00191148", "page_number": 26, "text_content": "Villafana, Ann Marie C. (USAFLS) \nFrom: \nVillafana, Ann Marie C. (USAFLS) \nSent: \nThursday, September 13, 2007 8:10 PM \nTo: \nOosterbaan, Andrew \nSubject: \nRE: Epstein \nEli Drew -- I tracked down the AUSA in Alaska and he is sending the trust agreement out to me. I will let you \nknow how things go in the morning. \nThanks. \nA. Akirk \nAssistant U.S. Attorney \n500 S. Australian Ave. Suite 400 \nWest Palm Beach, FL 33401 \nPhone 561 209-1047 \nFax 561 820-8777 \nFrom: Oosterbaan, Andrew \nSent: Thursday, September 13, 2007 7:54 PM \nTo: Villafana, Ann Marie C. (USAFLS) \nSubject: RE: Epstein \nThanks for the information, Marie. I'll get the details on the Boehm arrangements from the prosecutors and get back to \nyou tomorrow. I believe the girls agreed to the arrangement, but I'll confirm that. I should have the indictment reviewed \nby then as well. \nFrom: Villafana, Ann Marie C. (USAFLS) [mailto:Ann.Marie.C.Villafana@usdoj.gov] \nSent: Thursday, September 13, 2007 7:37 PM \nTo: Oosterbaan, Andrew \nSubject: Epstein \nHi Drew — Sorry to bother you, but the plea negotiations are getting fast and furious. Epstein's lawyers are \nfixated on this idea of a \"victim's fund\" rather than having the girls file separate 2255 actions. I know that the \nreason they want to do it is not out of the goodness of their hearts but to keep this stuff out of the public Court \nfiles, but in some ways it will help the girls, too. Do you know anything about how the fund in Alaska was \nworked out? Did all the victims consent or did the Court just do it? \nThank you for your help. I also turned in the indictment package to my immediate supervisor today, so I expect \nsome edits back from her before it goes higher up the chain. If you had any thoughts, please let me know. \nA. Marie Villafana \nAssistant U.S. Attorney \n500 S. Australian Ave, Suite 400 \nWest Palm Beach, FL 33401 \n3164 \nEFTA00191174\n", "char_count": 1881}, {"efta_number": "EFTA00191148", "page_number": 27, "text_content": "Villafana, Ann Marie C. (USAFLS) \nFrom: \nVillafana, Ann Marie C. (USAFLS) \nSent: \nMonday, September 17, 2007 10:35 AM \nTo: \nGarcia, Rolando (USAFLS): Lourie, Andrew (USAFLS) \nSubject: \nRE: Epstein \nHi Rolando • Here is the last e-mail that I sent to Jay last night. Jay talked with his client about it and reports \nthat they are leaning towards options I or 4. They are going to try to make that decision today (there seems to \nhe some dissension in the ranks because Jack Goldberger gave some incorrect information), and draft a \nproposed either Non-Prosecution Agreement or Plea Agreement. As you can see from my list below, there are a \nnumber of things in their last draft that were unacceptable. All of the loopholes that I sewed up they tried to \nopen. So. Jay is supposed to be consulting with Roy Black regarding the correct state information and then will \ngive me a call. \nI agreed to ask the Judge to take the hearing off calendar tomorrow and to postpone the grand jury appearances \nthat were scheduled from tomorrow. but I told him in no uncertain terms that I am indicting on the 25th so this \nneeds to be resolved early this week. Andy and I talked about all of this as well. Long answer to a short \nquestion, sorry. \nHi Jay -- This can wait until after the show, but my voice is going so I thought I would type it up. I \ntalked to Andy and he still doesn't like the factual basis. In his opinion, the plea should only address \nthe crimes that we were addressing, and we were not investigating Mr. Epstein abusing his girlfriend. \nSo, these are the only options that he recommended: \n1. We go back to the original agreement where Mr. Epstein pleads only to state charges and serves \nhis time in the state, except that we can agree to only 18 months imprisonment. \n2. Mr. Epstein pleads guilty to the state charges and also pleads to either two obstruction counts or to \none count of violating 47 USC 223(a)(1)(B), with a joint non-binding recommendation of 18 months, \nso that Mr. Epst\n... [truncated, 3769 chars — for the full page use /api/corpus/document/EFTA00191148/27 or ?id=EFTA00191148&page=27]", "char_count": 3769}, {"efta_number": "EFTA00191148", "page_number": 28, "text_content": "prosecution agreement, the ones I have sent you recently are plea agreements that get filed with the \ncourt. Please see if the appeal waiver language in those versions is alright. \nRe your paragraph 7: As I mentioned, we will not waive the presentence investigation. I know that \nthis will delay Mr. Epstein's sentencing by 70 days, but that will allow him to get all of his affairs in \norder. As to bail, it will be set at the time of arraignment, and we can work out a joint recommendation \nregarding the amount and its limitations. I have no objection to making a joint recommendation that \nMr. Epstein remain out on bond pending his sentencing, but I'm not sure that it belongs in a plea \nagreement, especially since I can't bind the court on that issue. However, I can assure you, and we \ncan put it on the record during the plea colloquy, that I will join in your recommendation that he remain \nout on bond pending sentencing. The same goes for the prison camp issue. As I mentioned, I have \nopposed a designation only once in a very particular case. I can assure you, and we can put it on the \nrecord at the plea colloquy that I will not oppose your recommendation for Mr. Epstein's designation. \nRe your paragraph 8: As I mentioned over the telephone, I cannot bind the girls to the Trust \nAgreement, and I don't think it is appropriate that a state court would administer a trust that seeks to \npay for federal civil claims. We both want to avoid unscrupulous attorneys and/or litigants from \ncoming forward, and I know that your client wants to keep these matters outside of public court filings, \nbut I just don't have the power to do what you ask. Here is my recommendation. During the period \nbetween Mr. Epstein's plea and sentencing, I make a motion for appointment of the Guardian Ad \nLitem. The three of us sit down and discuss things, and I will facilitate as much as I can getting the \ngirls' approval of this procedure because, as I mentioned, I think it is probably in their best\n... [truncated, 4292 chars — for the full page use /api/corpus/document/EFTA00191148/28 or ?id=EFTA00191148&page=28]", "char_count": 4292}, {"efta_number": "EFTA00191148", "page_number": 29, "text_content": "From: Garda, Rolando (USAFLS) \nSent: Monday, September 17, 2007 10:26 AM \nTo: Villafana, Ann Marie C. (USAFLS) \nSubject: Epstein \nMarie, \nWhere are we at in the plea negotiations? \nTracking: \n3142 \nEFTA00191177\n", "char_count": 211}, {"efta_number": "EFTA00191148", "page_number": 30, "text_content": "Villafana, Ann Marie C. (USAFLS) \nFrom: \nVillafana, Ann Marie C. (USAFLS) \nSent: \nTuesday, September 18, 2007 9:31 AM \nTo: \nAcosta, Alex (USAFLS); Lourie, Andrew (USAFLS); Garcia, Rolando (USAFLS) \nCc: \nAtkinson, Karen (USAFLS); McMillan, John (USAFLS) \nSubject: \nEpstein Negotiations \nImportance: \nHigh \nHi all —I think that we may be near the end of our negotiations with Mr. Epstein, and not because we have \nreached a resolution. As I mentioned yesterday, spent about 12 hours over the weekend drafting Informations, \nchanging plea agreements, and writing factual proffers. I was supposed to receive a draft agreement from them \nyesterday, which never arrived. At that time, they were leaning towards pleading only to state charges and \ndoing all of the time in state custody. \nLate last night I talked to Jay Lefkowitz who asked about Epstein pleading to two twelve-month federal charges \nwith half of his jail time being spent in home confinement pursuant to the guidelines. I told him that I had no \nobjection to that approach but, in the interest of full disclosure, I did not believe that Mr. Epstein would be \neligible because he will not be in Zone A or B. This morning Jay called and said that I was correct but, if we \ncould get Mr. Epstein down to 14 months, then he thought he would be eligible. \nMy response: have him plead to two separate Informations. On the first one he gets 12 months' imprisonment \nand on the second he gets twelve months, with six served in home confinement, to run consecutively. \nI just received an e-mail asking if Mr. Epstein could just do 12 months imprisonment instead. \nAs you can see, Mr. Epstein is having second thoughts about doing jail time. I would like to send Jay an e-mail \nstating that if we do not have a signed agreement by tomorrow at 5:00, negotiations will end. I have selected \ntomorrow at 5:00 because it gives them enough time to really negotiate an agreement if they are serious about it, \nand, if not, it gives me one day before the J\n... [truncated, 2384 chars — for the full page use /api/corpus/document/EFTA00191148/30 or ?id=EFTA00191148&page=30]", "char_count": 2384}, {"efta_number": "EFTA00191148", "page_number": 31, "text_content": "Villafana, Ann Marie C. (USAFLS) \nFrom: \nVillafana, Ann Marie C. (USAFLS) \nSent: \nTuesday, September 18, 2007 11:43 AM \nTo: \n'Lourie, Andre': Garcia, Rolando (USAFLS) \nCc: \nAtkinson, Karen (USAFLS) \nSubject: \nRE: Draft Agreements? \nHe also removed any promise to plead to a registrable offense and the promise related to the girls' damages \nclaims. \nA. Marie Villafana \nAssistant U.S. Attorney \n500 S. Australian Ave, Suite 400 \nWest Palm Beach. FL 33401 \nPhone 561 209-1047 \nFax 561 820-8777 \nFrom: Villafana, Ann Marie C. (USAFLS) \nSent: Tuesday, September 18, 2007 11:18 AM \nTo: 'Lourle, Andrew'; Garcia, Rolando (USAFLS) \nCc: Atkinson, Karen (USAFLS) \nSubject: FW: Draft Agreements? \nImportance: High \nAndy and Rolando: Please see below so you understand my frustration. This document is completely different \nfrom what Jay just told Andy they would agree to. He has it written as 16 months' imprisonment followed by 8 \nmonths federal supervised release. He wants us to recommend an improper calculation of the guidelines, and he \nwants to waive the PSI so he can keep all of his information confidential. I have already told Jay that the PSI \nlanguage and other language in this agreement was unacceptable to our office. I will send back a plea \nagreement that reads consistent with what Jay represented to Andy but I don't believe that this will be resolved \nby Tuesday unless they come down here and we have a group contract writing session with the state attorney's \noffice and the decision-makers. \nA. Marie Villafana \nAssistant U.S. Attorney \n500 S. Australian Ave. Suite 400 \nWest Palm Beach, FL 33401 \nPhone 561 209-1047 \nFax 561 820-8777 \nFrom: Jay Lefkowitz [mailto:JLefkowitz@kirkland.com] \nSent: Tuesday, September 18, 2007 11:09 AM \nTo: Villafana, Ann Marie C. (USAFLS) \nSubject: RE: Draft Agreements? \nConfidential — For Settlement purposes only. \nMarie -- Please look this over and let's see if we can identify any issues that we need to discuss in greater detail. Since \nyou can't\n... [truncated, 2249 chars — for the full page use /api/corpus/document/EFTA00191148/31 or ?id=EFTA00191148&page=31]", "char_count": 2249}, {"efta_number": "EFTA00191148", "page_number": 32, "text_content": "this with a state plea as well so he serves the additional time there. I need to see your language for proffers on the two \ncharges - (taking Nadia and Sarah out of the jurisdiction to avoid process.) \nAlternatively, at this stage, we could have just one count for 12 months and then 6 months incarceration under the state, \nfollowed by community control and probabtion. I am not sure which is more practicable. \nPlease let me know when you are free to speak. \nThanks — Jay \n\"Villafana, Ann Marie C. MUSAFLST \n<Ann.Marle.CNillafanafgusdoJ.goy> \n09/18/2007 09:14 AM \nTo \"Jay Lefkowitz\" <JLeaccnvitzekirklancl.com,\ncc \nSubject RE: Draft Agreements? \nIli Jay — I know that the U.S. Attorney will not go below 18 months of prison/jail time (and I would strongly \noppose the suggestion). \nA. Marie l'illaJaha \nAssistant U.S. Attorney \n500 S. Australian Ave. Suite 400 \nWest Palm Beach, FL 33401 \nPhone 561 209-1047 \nFax 561 820-8777 \nFrom: Jay Lefkowltz [mallto:lleflowitz@kIrtland.com] \nSent: Tuesday, September 18, 2007 8:59 AM \nTo: Villafana, Ann Marie C. (USAFL5) \nSubject: Re: Draft Agreements? \nan alternative to what we discussed just now might be to plead to one count of 1512, serve 12 months plus supervised \nrelease which would be one year of home detention (if we can make that work), followed by two years of probation in the \nstate on the state charges with the first 6 months being community control. \n\"Villafana, Ann Marie C. MUSAFLST cAnn.Maria.C.Villafana@uscloj.goy> \n09/18/2007 08'44 AM \nTo \"Jay lelkowitz\" <JLetkovntzelorklan0 corn> \ncc \nSubject Draft Agreements? \n3113 \nEFTA00191180\n", "char_count": 1600}, {"efta_number": "EFTA00191148", "page_number": 33, "text_content": "Hi Jay —I was hoping there would be things for me to read this morning, but I will try to remain patient. \nI believe there are only two types of agreements that would apply to this case: (I) a plea agreement to a federal \ncharge or charges; and (2) a non-prosecution agreement (which is really a deferred prosecution agreement \nbecause the defendant agrees that if he violates the agreement, the U.S. can prosecute him). \nA plea agreement is part of the court file. It is not accessible on-line via PACER, but someone can go to the \nClerk's Office to obtain a copy. \nA non-prosecution agreement would not be made public or filed with the Court, but it would remain part of our \ncase file. It probably would be subject to a FOIA request, but it is not something that we would distribute \nwithout compulsory process. \nOn the obstruction charges, many of the facts I included in that first proffer were hypothesized based upon our \ndiscussions and the agents' observations of Ms. Groff. We will need to interview her to confirm the accuracy of \nthose facts. On a second count, we could rely on the incident where Mr. Epstein's private investigators \nfollowed \nfather, forcing him off the road. Or, if there is something more recent related to any grand \njury subpoenas, we could consider that. \nHope that helps. \nA. Marie Villafana \nAssistant U.S. Attorney \n500 S. Australian Ave, Suite 400 \nWest Palm Beach, FL 33401 \nPhone 561 209-1047 \nFax 561 820-8777 \nTracking: \n3114 \nEFTA00191181\n", "char_count": 1484}, {"efta_number": "EFTA00191148", "page_number": 34, "text_content": "Villafana, Ann Marie C. (USAFLS) \nFrom: \nLourie, Andrew [Andrew. Lourie2@usdoj.gov) \nSent: \nWednesday, September 19, 2007 4:21 PM \nTo: \nVillafana, Ann Marie C. (USAFLS) \nSubject: \nRE: epstein \nI will reach out to Alex to discuss. \nFrom: Villafana, Ann Marie C. (USAFLS) [mallto:Ann.Made.C.Villafana@usdoj.gov] \nSent: Wednesday, September 19, 2007 4:13 PM \nTo: Villafana, Ann Marie C. (USAFLS); Lourie, Andrew \nCc: Garcia, Rolando (USAFLS) \nSubject: RE: epstein \nOh. and they took out the appeal waiver. \nA. Marie Villafatla \nAssistant U.S. Attorney \n561209-1047 \nFrom: Villafana, Ann Marie C. (USAFLS) \nSent: Wednesday, September 19, 2007 4:05 PM \nTo: 'Lourie, Andrew' \nCc: Garcia, Rolando (USAFLS) \nSubject: RE: epstein \nImportance: High \nI just got their \"red-lined\" version. I will forward it to you. Here are the issues that Rolando and I specifically discussed \nwith them and rejected. that they have re-inserted into the agreement. \nI. \nWe agree to recommend that no PSI be prepared. \n2. \nThey have converted it into an ABA plea — as though we wouldn't notice? \n3. They want us to agree to the incorrect calculation of the guidelines \n4. Instead of agreeing that the girls can sue Epstein, they cannot sue him and instead are bound to apply to a trust \nadministered by the State Court (Jay and I have addressed this at least three times and it keeps appearing in his \nversions) \n5. They changed the state charge that he has to plead guilty to to a non-registrable offense and he doesn't have to \nplead to that charge until after he has finished serving his federal sentence. \n6. They want us not to oppose a request for a prison camp designation. \n7. They have re-added paragraphs 17 through 19, all of which are addressed by paragraph 2. \nThere are other problems too, but these are the highlights. This is NOT good faith negotiations. \nA. Marie Villajafia \nAssistant U.S. Attorney \n561 209.1047 \nFrom: Lourie, Andrew [mailto:Andrew.Lourie2@usdoj.gov] \nSent: Wednesday, September 19, 2007 3:50\n... [truncated, 2114 chars — for the full page use /api/corpus/document/EFTA00191148/34 or ?id=EFTA00191148&page=34]", "char_count": 2114}, {"efta_number": "EFTA00191148", "page_number": 35, "text_content": "Good job. A few thoughts: \nI would eliminate the first sentence of pare 2. \nIs there another way to deal with the issue in para 3 without this in the plea \nagreement ? Do we need para 10? Isn't para 11 sufficient without 10? Is it our place to include para 13 in this \nagreement? I think it belongs in the state agreement and it looks out of place here. \nI think you should include Roy or another member of the FL Bar on the plea agreement so we are not slowed down at the \nlast minute by Pro Hac stuff. \nFrom: Villafana, Ann Marie C. (USAFLS) [mallto:Ann.Marie.C.Villafana@usdoi.gov] \nSent: Wednesday, September 19, 2007 2:36 PM \nTo: Lourie, Andrew \nSubject: RE: epsteln \nFYI - The Palm Beach Post reported the whole deal in today's paper and claimed to have a \"federal source\" and a \"spy\" \nin Epstein's camp. \n.4. Alark Vilkociatt \nAssistant U.S. Attorney \n561 209-1047 \nFrom: Lourie, Andrew [mailto:Andrew.Lourie2@usdoj.gov] \nSent: Wednesday, September 19, 2007 2:33 PM \nTo: Villafana, Ann Marie C. (USAFLS) \nSubject: RE: epstein \nCan you send me copy of the last thing you sent them? Thanks. \nFrom: Villafana, Ann Marie C. (USAFLS) [mallto:Ann.Marie.C.Villafana@usdoj.gov] \nSent: Wednesday, September 19, 2007 2:31 PM \nTo: Lourie, Andrew; Garda, Rolando (USAFLS) \nSubject: RE: epstein \nWe are still waiting for a \"redline\" of the agreement that they seemed happy with yesterday. Barry and 'Anna and \nEpstein's attorneys are coining to our office on Monday to finalize everything with the plan of getting him at least \narraigned on Monday afternoon. They tried to drag it into Tuesday and I said no. \nA. Marie Vint:fin-us \nAssistant U.S. Attorney \n561 209-1047 \nFrom: Lourie, Andrew [mailto:Andrew.Lourie2@usdoj.gov] \nSent: Wednesday, September 19, 2007 2:25 PM \nTo: Villafana, Ann Marie C. (USAFLS); Garda, Rolando (USAFLS) \nSubject: epstein \nWhat is the latest? \n3045 \nEFTA00191183\n", "char_count": 1887}, {"efta_number": "EFTA00191148", "page_number": 36, "text_content": "Villafana, Ann Marie C. (USAFLS) \nFrom: \nVillafana, Ann Marie C. (USAFLS) \nSent: \nWednesday, September 19, 2007 4:33 PM \nTo: \nLourie, Andrew; Garcia, Rolando (USAFLS) \nCc: \nAtkinson, Karen (USAFLS) \nSubject: \nRE: Draft Plea Agreement \nImportance: \nHigh \nAndy and Rolando -- This is my proposed response (below). I know that you keep \nsaying he is going to plead, and he will plead if we cave on everything, but I \nreally do not think that Mr. Epstein is going to engage in serious negotiations \nuntil he sees the Indictment and shows up in mag court (preferably in flip-\nflops). In reviewing the indictment package, if you would like to maintain \nflexibility for the future, we could indict Mr. Epstein just on Count 1 (the \nconspiracy charge), and, if he won't plead to 5 years at that time, supersede \nwith the remaining counts and just go to trial. But we gave them an initial \ndeadline of early August with the 24-month sentence. We are now seven weeks \nlater and we are just spinning our wheels. \nJay -- The same problems that I e-mailed you about on Sunday and discussed \nyesterday with you and Rolando and that you discussed with Andy are still in \nhere. Paragraphs 4, 7, 8, 9, and 11 have specifically been discussed and \nrejected. Paragraphs 17 through 19 have been addressed in paragraph 2 and will \nnot be repeated. You have removed our paragraphs 4 (regarding the application of \nthe Sentencing Guidelines) and 18 (appeal waiver) both of which are specifically \nrequired by the Office's Appellate Division. You have replaced Mr. Epstein's \nplea to a registrable offense, to one that does not require registration, and you \nhave again delayed the plea until after Mr. Epstein completes his federal prison \nsentence. Rolando and I specifically told you that was unacceptable, and Barry \nKrischer also has informed us that he will not keep his case open for that \nperiod. You also have inserted that this is a Rule 11(c)(1)(C) plea, which binds \nthe judge, which you know we have specificall\n... [truncated, 2467 chars — for the full page use /api/corpus/document/EFTA00191148/36 or ?id=EFTA00191148&page=36]", "char_count": 2467}, {"efta_number": "EFTA00191148", "page_number": 37, "text_content": "Confidential \nFor settlement purposes only \nMarie - I wanted to get this to you before I took off for nyc. I am landing at 7 \nand would like to speak shortly thereafter. \nI am still considering which of the options you suggested Sunday. In this email, \nI am sending you a redline of your federal resolution. I am also working on a \ndeferred prosecution agreement because it may well be that we cannot reach \nagreement here. I don't think there are that many issues left open, although \nclearly we still need to have further discussions. I also like your suggestion \nfrom Sunday that we consider a C plea. \nI know that Alex would have to sign off on it and that he has not done so as of \nnow. \nRegarding my schedule, I am available tonight to speak, all afternoon tomorrow (I \nam in fed court in nyc on another criminal matter tomorrow am), and then all day \nFriday. \nI will plan on seeing you Monday. I am confident that one of the approaches we \nhave discussed will work out. \nJay \nOriginal Message \nFrom: )ay Lefkowitz \nSent: 09/19/2007 03:35 PM EDT \nTo: )ay Lefkowitz \nSubject: Draft Plea Agreement \n(See attached file: 9.19.07 Draft Plea Agreement \n(Clean).doc) \n(See attached file: 9.19.07 Draft Plea Agreement \n(Redlined).doc) \n###*#*####******************#34c*got###*###****************## \nThe information contained in this communication is confidential, may be attorney-\nclient privileged, may constitute inside information, and is intended only for \nthe use of the addressee. It is the property of Kirkland & Ellis LLP or Kirkland \n& Ellis International LLP. \nUnauthorized use, disclosure or copying of this communication or any part thereof \nis strictly prohibited and may be unlawful. If you have received this \ncommunication in error, please notify us immediately by return e-mail or by e-\nmail to postmasterOkirkland.com, and destroy this communication and all copies \nthereof, including all attachments. \n*************###t##*##*******###*#***************M4c#***** \nTracking: \n3042 \nEFTA\n... [truncated, 2009 chars — for the full page use /api/corpus/document/EFTA00191148/37 or ?id=EFTA00191148&page=37]", "char_count": 2009}, {"efta_number": "EFTA00191148", "page_number": 38, "text_content": "UNITED STATES DISTRICT COURT \nSOUTHERN DISTRICT OF FLORIDA \nCASE NO. 08-80736-CIV-MARRA \nJANE DOE #1 and JANE DOE #2, \nPetitioners. \nvs. \nUNITED STATES OF AMERICA, \nRespondents. \n/ \nUNITED STATES OF AMERICA'S RESPONSE TO \nPE i i i LONERS' REQUEST FOR PRODUCTION \nRespondent United States of America, in response to petitioners' Request for Production, \nsubmits the following: \nRequest for Production No. 1: \n(a) \n(b) \n(c) \nFBI Case File on the Epstein case (P). \n(d) \nProsecution Memorandum, \"Operation Leap Year,\" May 1, 2007 (82 pages), \nAuthor: A. Marie Villafana. Addressees: R. Alexander Acosta, United States Attorney; Jeff \nSloman, First Assistant U.S. Attorney; Matthew Menchel, Chief, Criminal Division; Andrew \nLourie; Managing Assistant U.S. Attorney, Northern Region; and Karen Atkinson, Chief, \nNorthern Region. (P). \nDraft Indictment (54 pages)(P). \n(e) \nDraft indictments (P) \nRequest for Production No. 2: \n(a) \nLetter to Miss C.W., dated June 7, 2007, RE: Crime Victims' and Witnesses' \nRights (2 pages); Author: A. Marie Villafana. \nLetter to Miss T.M., dated August 11, 2006, RE: Crime Victims' and Witnesses' \n1 \nEFTA00191186\n", "char_count": 1146}, {"efta_number": "EFTA00191148", "page_number": 39, "text_content": "Rights (2 pages); Author: A. Marie Villafana. \nLetter to C.W., dated January 10, 2008, RE: Case Number \n (2 pages); \nAuthor: Twiller Smith, Victim Specialist, Federal Bureau of Investigation, West Palm Beach, \nFlorida. \nLetter to James Eisenberg, dated January 10, 2008; RE: \n, (2 \npages); Author: Twiller Smith, Victim Specialist, Federal Bureau of Investigation, West Palm \nBeach, Florida. \nLetter to S.R., dated May 30, 2008, RE: \n, (2 pages); \nAuthor: Twiller Smith, Victim Specialist, Federal Bureau of Investigation, West Palm Beach, \nFlorida. \nLetter to Brad Edwards, Esq., dated July 9, 2008, RE: Jeffrey Epstein/C.W.: \nNotification of Identified Victim (2 pages); Author: A. Marie Villafana. \nLetter to Brad Edwards, Esq., dated July 9, 2008, RE: Jeffrey Epstein/S.R.: \nNotification of Identified Victim (2 pages); Author: A. Marie Villafana. \n(b) \nLetter to R. Alexander Acosta, dated October 10, 2007, RE: Jeffrey Epstein (6 \npages); Author: Jay P. Lefkowitz, Kirkland & Ellis \nLetter to R. Alexander Acosta, dated November 29, 2007, RE: Jeffrey Epstein (4 \npages), Author: Jay Lefkowitz, Kirkland & Ellis, with attachment of draft Crime Victims' \nRights - Notification of Resolution of Epstein Investigation (4 pages), dated November 29, \n2007; Author: A. Marie Villafana. \nLetter to R. Alexander Acosta, dated December 5, 2007, RE: Jeffrey Epstein (2 \npages), Author: Kenneth W. Starr and Jay Lefkowitz, Kirkland & Ellis \nLetter to Jay P. Lefkowitz, Esq., Kirkland & Ellis, dated December 6, 2007, RE: \nJeffrey Epstein (4 pages); Author: Jeffrey H. Sloman, First Assistant U.S. Attorney, with \nattached draft letter RE: Crime Victims' Rights — Notification of Resolution of Epstein \nInvestigation (4 pages); Author: A. Marie Villafana. \nLetter to R. Alexander Acosta, dated December 11, 2007, RE: Jeffrey Epstein (13 \npages), Author: Jay Lefkowitz \nLetter to Lilly Ann Sanchez, dated December 19, 2007, RE: Jeffrey Epstein (3 \nPages) \nLetter to R. Alexander Acosta, dated December 21, 20\n... [truncated, 2155 chars — for the full page use /api/corpus/document/EFTA00191148/39 or ?id=EFTA00191148&page=39]", "char_count": 2155}, {"efta_number": "EFTA00191148", "page_number": 40, "text_content": "pages), Author: Jay Lefkowitz \nRequest for Production No. 3 (confidentiality provision) \nLetter to Matthew Menchel, Chief, Criminal Division, U.S. Attorney's Office, dated \nAugust 2, 2007, RE: Jeffrey Epstein (3 pages), Author: Lilly Ann Sanchez \nLetter to Lilly Ann Sanchez, Esq., dated August 3, 2007, RE: Jeffrey Epstein (2 pages), \nAuthor: Matthew Menchel \nE-mail, Marie Villafana to Gerald Lefcourt, dated September 10, 2007 5:23 p.m., RE: \nJeffrey Epstein (2 pages with 4 page draft Non-Prosecution Agreement) \nE-mail, Marie Villafana to Gerald Lefcourt, dated September 11, 2007 2:15 p.m., RE: \nRevised Agreement re Epstein (2 pages with 4 page draft Non-Prosecution Agreement attached) \nE-mail, Marie Villafana to Jay Lefkowitz, dated September 12, 2007 3:44 p.m., RE: \nJeffrey Epstein (2 pages) \nE-mail, Jay Lefkowitz to Marie Villafana and Andrew Lourie, dated September 12, 2007 \n5:55 p.m., RE: Jeffrey Epstein (2 pages) \nE-mail, Marie Villafana to Jay Letkowitz, dated September 13, 2007 7:27 p.m., RE: no \nsubject (1 page) \nE-mail, Jay Lefkowitz to Marie Villafana, dated September 13, 2007, 7:35 p.m., RE: no \nsubject (2 pages) \nE-mail, Jay Lefkowitz to Marie Villafana, dated September 14, 2007 9:40 a.m., RE: \nFollow up (1 page) \nE-mail, Marie Villafana to Jay Lefkowitz, dated September 14, 2007 9:54 a.m., RE: Plea \ndocuments (1 page with 2 page draft Information, and 7 page draft Plea Agreement, attached) \nE-mail, Marie Villafana to Jay Lefkowitz, dated September 14, 2007 9:56 a.m., RE: \nFollow up (2 pages) \nE-mail, Marie Villafana to Jay Lefkowitz, dated September 17, 2007 11:45 a.m., RE: \nNon-Prosecution Agreements (I page with 4 page draft Non-Prosecution Agreement attached) \nE-mail, Marie Villafana to Jay Lefkowitz, dated September 18, 2007 8:44 a.m., RE: \nDraft Agreements? (I page) \nE-mail, Jay Lefkowitz to Marie Villafana, dated September 18, 2007 9:18 a.m., RE Draft \nAgreements? (2 pages) \n3 \nEFTA00191188\n", "char_count": 1943}, {"efta_number": "EFTA00191148", "page_number": 41, "text_content": "E-mail, Jay Lefkowitz to Marie Villafana, dated September 18, 2007 11:09 a.m., RE: \nDraft Agreements? (2 pages, with 6 page draft Non-Prosecution Agreement) \nE-mail, Jay Leflcowitz to Marie Villafana, dated September IS, 2007 11:52 a.m., RE: \nDraft Agreements? (2 pages, with 5 page draft Non-Prosecution Agreement) \nE-mail, Marie Villafana to Jay Lefkowitz, dated September 18, 2007 12:44 p.m., RE: \nDraft Agreements? (3 pages) \nE-mail, Marie Villafana to Jay Lefkowitiz, dated September 18, 2007 1:22 p.m., RE: \nDraft Agreements? (4 pages, with 9 page draft Plea Agreement) \nE-mail, Marie Villafana to Jay Lefkowitz, dated September 18, 2007 2:53 p.m., RE: \nFactual Proffer (1 page) \nE-mail, Marie Villafana to Jay Lefkowitz, dated September 19, 2007 10:39 a.m. RE: \nDraft Agreements? (I page) \nE-mail, Jay Lefkowitz to Marie Villafana, dated September 19, 2007 10:45 a.m., RE: \nDraft Agreements? (1 page) \nE-mail, Marie Villafana to Jay Leflcowitiz, dated September 19, 2007 11:18 a.m., RE: \nDraft Agreements? (1 page) \nE-mail, Jay Leflcowitz to Marie Villafana, dated September 19, 2007 11:36 a.m., RE: \nDraft Agreements? (2 pages) \nE-mail, Marie Villafana to Jay Lefkowitz, dated September 19, 2007 11:46 a.m., RE: \nDraft Agreements? (3 pages) \nE-mail, Jay Leflcowitz to Marie Villafana, dated September 19, 2007 3:44 p.m., RE: FW \nDraft Plea Agreement (1 page, with 12 page draft Plea Agreement) \nE-mail, Marie Villafana to Jay Leflcowitz, dated September 20, 2007 3:52 p.m., RE: \nFinal version of Plea Agreement — Epstein (2 pages, with 8 page draft Plea Agreement) \nE-mail, Marie Villafana to Jay Lefkowitz, dated September 20, 2007 3:54 p.m., RE \nEpstein Plea Agreement (1 page, with 8 page draft Plea Agreement) \nE-mail, Marie Villafana to Jay Lefkowitz, dated September 20, 2007 5:33 p.m., RE: \nFinal version of Plea Agreement — Epstein (2 pages) \nE-mail, Jay Lefkowitz to Marie Villafana, dated September 20, 2007 6:12 p.m., RE: Plea \nAgreement — Epstein (1 page) \nE-mail, Marie Villafana\n... [truncated, 2081 chars — for the full page use /api/corpus/document/EFTA00191148/41 or ?id=EFTA00191148&page=41]", "char_count": 2081}, {"efta_number": "EFTA00191148", "page_number": 42, "text_content": "Agreement — Epstein (2 pages) \nE-mail, Jay Lefkowitz to Marie Villafana, dated September 21, 2007 10:44 a.m., RE: \nPlea Agreement — Epstein (2 pages, with 4 page draft Non-Prosecution Agreement) \nE-mail, Marie Villafana to Jay Lefkowitz, dated September 21, 2007 10:57 a.m., RE: \nPlea Agreement — Epstein (3 pages) \nE-mail, Barry Krischer, State Attorney to Marie Villafana, dated September 21, 2007 \n12:03 p.m., RE: Meeting with Epstein's attorneys (1 page) \nE-mail, Jay Lefkowitz to Marie Villafana, dated September 21, 2007 2:46 p.m., RE: \nReminder (1 page, with 1 page Plea in the Circuit Court Form 005 attached) \nE-mail, Marie Villafana to Jay Lefkowitz, dated September 21, 2007 2:54 p.m., RE: \nReminder (2 pages) \nE-mail, Marie Villafana to Jay Lefkowitz, dated September 21, 2007 2:55 p.m., RE: \nImmigration Question (1 page) \nE-mail, Jay Lefkowitz to Alex Acosta, dated September 23, 2007 11:58 a.m., RE: Jeffrey \nEpstein — confidential (2 pages) \nE-mail, Jay Lefkowitz to Marie Villafana, dated September 23, 2007 1:42 p.m., No \nSubject (1 page) \nE-mail, Ami Sheth, Kirkland & Ellis to Marie Villafana, dated September 23, 2007 1:57 \np.m., RE: FW: Draft Agreement (I page with 6 page draft Non-Prosecution Agreement) \nE-mail, Marie Villafana to Jay Lefdowitz, dated September 23, 2007 4:03 p.m., RE: \nDraft Agreement (2 pages with 6 page draft Non-Prosecution Agreement attached) \nE-mail, Alex Acosta to Jay Lefkowitz, dated September 23, 2007 4:31 p.m., RE: (no \nsubject) (2 pages) \nE-mail, Marie Villafana to Jay Lefkowtiz, dated September 23, 2007 8:01 p.m., RE: \nRevised agreement (1 page) \nE-mail, Jay Lefkowitz to Marie Villafana, dated September 23, 2007 8:31 p.m., RE: Fw \n(1 page with 7 page draft Non-Prosecution Agreement attached) \nE-mail, Jay Lefkowitiz to Marie Villafana, dated September 23, 2007 8:35 p.m., RE: no \nsubject (1 page) \nE-mail, Marie Villafana to Jay Lefkowitz, dated September 23, 2007 8:37 p.m., RE: no \nsubject (1 page) \n5 \nEFTA00191190\n", "char_count": 1980}, {"efta_number": "EFTA00191148", "page_number": 43, "text_content": "E-mail, Jay Lefkowitz to Marie Villafana, dated September 23, 2007 8:39 p.m., RE: no \nsubject (2 pages) \nE-mail, Marie Villafana to Jay Lefkowitz, dated September 23, 2007 8:58 p.m., RE: \nEpstein Agreement (1 page with 6 page draft Non-Prosecution Agreement attached) \nE-mail, Jay Letkowitz to Marie Villafana, dated September 24, 2007 7:54 a.m., RE: \nEpstein (I page) \nE-mail, Marie Villafana to Jay Letkowitz, dated September 24, 2007 10:14 a.m., RE: \nEpstein agreement as reviewed by the U.S. Attorney (I page with 6 page draft Non-Prosecution \nAgreement attached) \nE-mail, Jay Lefkowitz to Marie Villafana, dated September 24, 2007 11:46 a.m., RE: \nEpstein agreement as reviewed by the U.S. Attorney (1 page with 6 page Non-Prosecution \nAgreement, and 8 page Non-Prosecution Agreement, attached) \nE-mail, Marie Villafana to Jay Lefkowitz, dated September 24, 2007 1:28 p.m., RE: \nEpstein agreement as reviewed by the U.S. Attorney (3 pages with 7 page draft Non-Prosecution \nAgreement attached) \nE-mail, Marie Villafana to Jay Lefkowitz, dated September 24, 2007 2:16 p.m., RE: The \nfinal final (1 page with 7 page Non-Prosecution Agreement attached) \nE-mail, Marie Villafana to Jay Lefkowitz, dated September 24, 2007 4:03 p.m., RE: Do \nyou have a signed copy? (1 page) \nE-mail, Jay Lefkowitz to Marie Villafana, dated September 24, 2007 4:06 p.m., RE: Do \nyou have a signed copy? (1 page with 9 page Non-Prosecution Agreement attached) \nE-mail, Marie Villafana to Jay Lefkowitz, dated September 24, 2007 4:32 p.m., RE: Do \nyou have a signed copy? (1 page) \nRequest for Production No. 5 (legal representation of victims) \nE-mail, Marie Villafana to Jay Lefkowitz, dated September 25, 2007 8:37 p.m., RE: \nOther attorneys (1 page) \nE-mail, Marie Villafana to Jay Lefkowitz, dated September 26, 2007 11:01 a.m., RE: \nOther attorneys (2 pages) \nE-mail, Marie Villafana to Jay Lefkowitz, dated September 26, 2007 11:49 a.m., RE: \nOne more thing (2 pages) \nE-mail, Marie Villafana to Jay Lefkowitz, d\n... [truncated, 2099 chars — for the full page use /api/corpus/document/EFTA00191148/43 or ?id=EFTA00191148&page=43]", "char_count": 2099}, {"efta_number": "EFTA00191148", "page_number": 44, "text_content": "E-mail, Jay Leflcowitz to Marie Villafana, dated September 27, 2007 10:57 a.m., RE: \nConference call with Bert Ocariz (2 pages) \nE-mail, Marie Villafana to Jay Lefkowtiz, dated September 27, 2007 11:08 a.m., RE: \nConference Call with Bert Ocariz (2 pages) \nE-mail, Marie Villafana to Jay Lefkowitz, dated September 27, 2007 3:06 p.m., RE: \nConference Call with Bert Ocariz (3 pages) \nE-mail, Marie Villafana to Jay Lefkowitz, dated October 3, 2007 3:15 p.m., RE: no \nsubject (2 pages, with 1 page Special Master Proposal attached) \nE-mail, Marie Villafana to Jay Lefkowitz, dated October 3, 2007 3:38 p.m., RE: no \nsubject (2 pages) \nE-mail, Marie Villafana to Jay Lefkowitz, dated October 3, 2007 4:23 p.m., RE: \nProposed Letter to Special Master (2 pages with 2 page Proposed Letter to the Special Master \nattached) \nE-mail, Marie Villafana to Jay Lefkowitz, dated October 3, 2007 7:30 p.m., RE: \nProposed Letter to Special Master (1 page) \nE-mail, Marie Villafana to Jay Leflcowitz, dated October 5, 2007 7:49 p.m., RE: \nProposed Letter to Special Master (2 pages) \nE-mail, Jay Lefkowitz to Marie Villafana, dated October 5, 2007 11:04 a.m., RE: \nProposed Letter to Special Master (3 pages with 4 page letter from Jay Leflcowitz to Marie \nVillafana attached) \nLetter to Jeffrey Sloman, dated October 8, 2007, RE: Jeffrey Epstein (3 pages), Author: \nLilly Ann Sanchez \nE-mail, Marie Villafana to Lilly Ann Sanchez, October 9, 2007 5:09 p.m., RE: Jeffrey \nEpstein (1 page with two page letter to Lilly Ann Sanchez attached) \nE-mail, Jeff Sloman to Jay Lefkowitz, dated\n 22, 2007 4:41 p.m., RE: Epstein (3 \npages with 4 page draft letter to Hon. Edward B. \nand 2 page Addendum to the Non-\nProsecution Agreement, attached) \nE-mail, Jay Lefkowitz to Jeff Sloman, dated October 22, 2007 5:10 p.m., RE: Epstein (3 \npages) \nE-mail, Jeff Sloman to Ja Lefkowitz, dated October 24, 2007 3:45 p.m., RE: Epstein —\nAddendum and Letter to Judge \n(2 pig 1/2.ddendum to the Non-Prosecution Agreement, \nand 4 page d\n... [truncated, 2060 chars — for the full page use /api/corpus/document/EFTA00191148/44 or ?id=EFTA00191148&page=44]", "char_count": 2060}, {"efta_number": "EFTA00191148", "page_number": 45, "text_content": "E-mail, Jeff Sloman to Jay Lefkowitz, dated October 24, 2007 5:30 p.m., RE: Epstein —\nLetter to Judge \n(I page with 4 page letter to Hon. Edward B. \nattached) \nLetter to Hon. Edward B. M, Akerman Senterfitt, dated October 25, 2007, RE: \nService as a Special Master (4 pages); Author: Jeff Sloman \nE-mail, Jeff Sloman to Jay Lefkowitz, dated October 31, 2007 11:51 a.m., RE: Epstein \n(2 pages) \nE-mail, Jay Lefkowitz to Jeff Sloman, dated November 8, 2007 1:24 p.m., RE: No \nsubject (1 page) \nE-mail, Jay Lefkowitz to Jeff Sloman, dated November 16, 2007 2:00 p.m., RE: No \nsubject (1 page) \nE-mail, Jeff Sloman to Jay Lefkowitz, dated November 27, 2007 1:55 p.m., RE: Epstein \n(1 page) \nLetter to Jeffrey Sloman, dated December 7, 2007, RE: Jeffrey Epstein, Author: Lilly \nAnn Sanchez (1 page Affirmation signed by Jeffrey E. Epstein, 1 page Notice of Hearing, and 1 \npage fax transmittal sheet, attached) \nE-mail, Marie Villafana to Jack Goldberger, dated June 28, 2008 11:31 a.m., RE: Notice \nof Non-Compliance (1 page) \nRequest for Production No. 8 (Lobbying efforts at DOJ) \nE-mail, Jeff Sloman to Jay Lefkowitz, dated February 25, 2008 7:43 p.m., RE: Epstein (1 \npage) \nE-mail, Jeff Sloman to Jay Lefkowitz, dated February 27, 2008 9:45 p.m., RE: Fw: \nEpstein (2 pages) \nLetter to Jay Lefkowitz, Esq., dated May 15, 2008, RE: Investigation of Jeffery Epstein \n(5 pages), Author: Andrew G. Oosterbaan, Chief, Child Exploitation and Obscenity Section, \nCriminal Division, U.S. Department of Justice \nE-mail, Jay Lefkowitz to Alex Acosta, dated May 19, 2008 10:54 a.m., RE: confidential \ncommunication (3 pages) \nLetter to Honorable Mark Filip, Deputy Attorney General, dated May 19, 2008, No \nSubject (8 pages), Authors: Kenneth W. Starr, Kirkland & Ellis, and Joe D. Whitley, Alston & \nBird \n8 \nEFTA00191193\n", "char_count": 1812}, {"efta_number": "EFTA00191148", "page_number": 46, "text_content": "Letter to Honorable Mark Filip, Deputy Attorney General, dated May 27, 2008, No \nSubject (2 pages), Authors: Kenneth W. Starr, Kirkland & Ellis, and Joe D. Whitley, Alston & \nBird \nE-mail, Jeff Sloman to Jay Lefkowtiz, dated May 28, 2008 4:51 p.m., RE: Jeffrey \nEpstein (1 page) \nLetter to Kenneth Starr and Joe D. Whitley, dated June 3, 2008, No Subject (1 page), \nAuthor: John Roth, Senior Associate Deputy Attorney General \nLetter to John Roth, Senior Associate Deputy Attorney General, dated June 19, 2008, No \nSubject (14 pages Author: Stephanie D. Thacker, Allen Guthrie McHugh & Thomas, \nCharleston, West \nLetter to Jay Lefkowitz and Kennth Stan, dated June 23, 2008, No Subject (1 page), \nAuthor: John Roth, Senior Associate Deputy Attorney General \nRearrest for Production No. 19:  (prosecutor misconduct) \nLetter to IL Alexander Acosta, dated December 11, 2007, RE: Jeffrey Epstein (20 \npages); Author: Jay Lefkowitz \nLetter to Jay P. Lefkowitz, Esq., dated December 13, 2007, RE: Jeffrey Epstein (5 \npages); Author: A. Marie Villafana. \nE-mail, Jay Lefkowitz to Alex Acosta, dated February 29, 2008 3:11 p.m., RE: Fw \nEpstein (1 page) \nLetter to Office of Professional Responsibility, U.S. Department of Justice, dated April \n21, 2008, RE: Self Reporting — Jeffrey H. Sloman, FAUSA S.D.F.L. (3 pages, with 5 pages of \nattachments); Author: Jeffrey H. Sloman (P) \nLetter to Office of Professional Responsibility, U.S. Department of Justice, dated April \n22, 2008, RE: Self-Report of Allegation of Conflict of Interest (9 pages); Author: A. Marie \nVillafana (P) \nMemorandum to Office of Professional Responsibility, dated April 23, 2008, Subject: \nSelf Reporting — Jeffrey H. Sloman, Corrected Version of the previously submitted April 21, \n2008 letter to OPR (1 page, with 3 page letter attached); Author: Jeffrey H. Sloman (P) \nLetter to Deputy Attorney General Mark Filip, dated May 19, 2008, No Subject, Authors: \nKenneth W. Starr and Joe D. Whitley, attachment entitled \"Summary of Misc\n... [truncated, 2066 chars — for the full page use /api/corpus/document/EFTA00191148/46 or ?id=EFTA00191148&page=46]", "char_count": 2066}, {"efta_number": "EFTA00191148", "page_number": 47, "text_content": "An \"attorney for the government\" did not confer with Jane Doe #1 or Jane Doe #2 about the \nspecific terms of the Non-Prosecution Agreement prior to: \n(a) \n(b) \nits execution on September 24, 2007; \nthe execution of the Addendum to the Non-Prosecution Agreement on October \n29, 2007; and \n(c) \nthe commencement of the performance of the Non-Prosecution Agreement on \nJune 30, 2008. \nEFTA00191195\n", "char_count": 395}, {"efta_number": "EFTA00191148", "page_number": 48, "text_content": "Villafana, Ann Marie C. (USAFLS) \nFrom: \nVillafana, Ann Marie C. (USAFLS) \nSent: \nTuesday, July 16, 2013 4:03 PM \nTo: \nSanchez, Eduardo (USAFLS) \nCc: \nLee, Dexter (USAFLS) \nSubject: \nRE: Responses to REM \nTracking: \nRsdplent \nRoad \nSanchez Eduardo (USAFLS) \nRead: 7/16/2013 4:17 PM \nLee, Dexter (USAFLS) \nRead: 746/2013 5:49 PM \nEli Ed — There are some issues that I think you want to include in the RFA's: \nOverall — you need to change \"the government\" to \"the USAO\" \nNo. 2(a): My contact with JD#2's attorney, Jim Eisenberg, to ask him whether we should send the letter to him \nor directly to JD#2, is what started the firestorm regarding victim notifications. I think that is significant \nbecause she is one of the petitioners in this case. \nNo. 2(c): Remove \"and her then-attorney\" \nNo. 2(d): The USAO denies that the language in its 2006 and 2007 victim notification letters to Jane Doe #1 \nand Jane Doe #2 were affected in any way by contact with counsel for Jeffrey Epstein. The USAO also denies \nthat the language in the FBI's letters to Jane Doe #1 and Jane Doe #2 were affected in any way by contact with \ncounsel for Jeffrey Epstein. The language of the July 9, 2008 letter to Jane Doe #1 in care of Bradley Edwards \nwas altered after receiving objections to victim notifications from counsel for Jeffrey Epstein and reevaluation \nof the victim notification obligations by the USAO. \nNo. 2(e): You need to make clear that Jane Doe #2 was never officially notified about the NM because it was \ndetermined that she was not a person whom the USAO was prepared to name in an indictment. \nNo. 7: You need to make clear that the FBI was still actively investigating the case as of that time, including \ninterviewing additional victims. We did grand jury appearances in March and April 2008. \nNo. 9(e): You can make clear that the FBI notified Jane Doe #1 at the request of the USAO because they met \nwith her at my request. You again need to reiterate that Jane Doe #2 was never officially notif\n... [truncated, 2680 chars — for the full page use /api/corpus/document/EFTA00191148/48 or ?id=EFTA00191148&page=48]", "char_count": 2680}, {"efta_number": "EFTA00191148", "page_number": 49, "text_content": "No. 13(b): I recommend adding: During interviews with Jane Doe #1 and Jane Doe #2 prior to entering into \nthe Non-Prosecution Agreement. both were asked their opinions about prosecution by an \"attorney for the \ngovernment\" and Jane Doe #1 was asked about her willingness to serve as a witness at trial by an \"attorney for \nthe government.\" Both were provided with contact information for an \"attorney for the government\" and \ninvited to contact that attorney at any time. At no time prior to the signing of the Non-Prosecution Agreement \nor Jeffrey Epstein's June 30.2008 guilty plea did Jane Doe #1 or Jane Doe #2 ask to confer with an attorney for \nthe government. \nNo. 13(c): You may want to say something about the USAO's knowledge that JD#2 was represented by \ncounsel paid for by Epstein. \nNo. 13(d): No, other than the confidentiality provision that appears in the agreement, there was nothing \nspecifically aimed at talking to the victims. \nNo. 16 — Wait until I finish. I need to go back and double-check. Just keep this highlighted for now. \nNo. 23 — Do you want to add something about —\"provided that Epstein does not breach the agreement\" \nNo. 26 — Do you want to add something about the information being covered by other privileges? (investigative \nprivilege)? \nThank you for all of your help with these! \nA. Marie Villafaga \nAssistant U.S. Attorney \nSouthern District of Florida \n500 S. Australian Ave, Suite 400 \nWest Palm Beach, FL 33401 \nann.marie.c.villafana®usdoj.gov \n561-209-1047 \nFrom: Sanchez, Eduardo (USAFLS) \nSent: Monday, July 15, 2013 7:59 PM \nTo: Villafana, Ann Made C. (USAFLS); Lee, Dexter (USAFLS) \nSubject: RE: Responses to RFAs \nAttached are my suggested edits and thoughts. \nFrom: Villafana, Ann Marie C. (USAFLS) \nSent: Monday, June 24, 2013 9:56 PM \nTo: Lee, Dexter (USAFLS); Sanchez, Eduardo (USAFLS) \nSubject: Responses to RFAs \nHi Dexter and Ed — Here is my stab at a response. There are a number that I cannot answer. \n2 \nEFTA00191197\n", "char_count": 1977}, {"efta_number": "EFTA00191148", "page_number": 50, "text_content": "Isn't the only real factual issue whether or not we conferred with the victims PRIOR TO SIGNING the NPA? \nThe closest that they come to asking that is 13(b) and even that isn't quite right. Should we suggest that they \nsend a revised RFA asking simply: \n\"An attorney for the government did not confer with Jane Doe #1 or Jane Doe #2 prior to entering into the \nNPA.\" \n« File: Response to Requests for Admissions.docx » \nA. Marie Villafana \nAssistant U.S. Attorney \nSouthern District of Florida \n500 S. Australian Ave, Suite 400 \nWest Palm Beach, FL 33401 \nann.marie.c.vi Ilafana(4)usdoj .gov \n561-209-1047 \n3 \nEFTA00191198\n", "char_count": 623}]}