{"efta_number": "EFTA00225378", "page_count": 294, "url": "https://epstein-data.com/EFTA00225378", "pdf_url": "https://epstein-data.com/pdf/EFTA00225378.pdf", "pages": [{"efta_number": "EFTA00225378", "page_number": 0, "text_content": "Memorandum \nSubject \nMemorandum seeking Travel Authorization \nOperation Leap Year \nDote \nJune 20, 2008 \nTO \nRolando Garcia, Deputy Chief \nCriminal Division \nKaren Atkinson, Chic \nNorthern Division \nFrom \nA. Marie Villaf \nAssistant U.S. A \nI. \nINTRODUCTION \nThis memorandum seeks travel authorization to travel to New York from June 19 to June 20, \n2008, in connection with Operation Leap Year. \nII. \nTHE PROPOSED TRAVEL AND ITS PURPOSE \nAs you know, we plan to present a final indictment to the grand jury in approximately two \nweeks. Since our original planned indictment, we have learned about a series of victims in New \nYork and the \nssible involvement of Epstein's two New York-based assistants, \nand \nThe inclusion of New York victims would be a great benefit to the indictment, and \nwe would like to interview some key people in New York in order to include that evidence in the \nindictment. \nAccordingly, I propose to travel to New York on the afternoon of Thursday, June 19 to \nconduct interviews on Friday, June 20, 2008.' FBI Special Agents Nesbitt Kuyrkendall and Jason \nRichards also will be traveling, although they may stay longer. \nFirst, we would like to interview \nShe has been identified by two victims \nas someone who recruited numerous others to Epstein's New York residence. We know that Lacerda \nwas going to Epstein's home when she was 14, and it is possible that she was going there as early \nas 13. This trip is contingent upon approval from the Justice Department of our immunity request \nfor Lacerda. Yesterday I spoke with someone at the Witness Immunity Unit who stated that we \n'I may decide to stay in New York on Friday night in order to see a college friend. If I do, \nI will pay for the hotel room on Friday night and any difference in the airfares. \nEXHIBIT B-132 \nCase No. 08-80736-CV-MARRA \nP-008379 \nEFTA00225378\n", "char_count": 1852}, {"efta_number": "EFTA00225378", "page_number": 1, "text_content": "should have the approval by early next week.' \nIn addition, a witness here in the Palm Beach area came forward recently to inform the FBI \nabout a link between Epstein and the MC Modeling Agency. The witness stated that Epstein and \nthe head of MC2, Jean Luc Brunel, worked together to obtain fraudulent visas to bring potential \nmodels to the United States. The witness stated that Epstein selected some of the underage girls to \ncome to the United States even though Brunel never intended to use them as models so that Epstein \ncould engage in sexual activity with them. Brunel's name appears on several of the message pads \nrecovered during the search of Epstein's home. Some of the messages describe young girls that he \nwould like Epstein to meet (including a I6-year-old who would \"teach Russian\" to Epstein). The \nFBI previously tried to interview Brunel, but he refused to speak with them. The Palm Beach \nwitness has told the FBI that a former MC2 employee is willing to speak with the FBI about the \nfraud. \nYesterday, the FBI in New York arrested two Bear Steams employees for securities fraud \nrelated to Bear Steams hedge funds involved in the subprime loan crisis. Epstein has been reported \nas one of the creators of those hedge funds in financial news sources. The agents here are contacting \nthe New York agents to determine if Epstein is a target/subject of the New York investigation and \nalso to find out whether the two employees are cooperating and would be willing to speak with us. \nFor the foregoing reasons, I recommend that the Office approve the costs of a hotel room and \na flight for my travel to New York. \n'-Travel plans will not be made until the immunity is confirmed. \n-2-\nCase No. 08-80736-CV-MARRA \nP-008380 \nEFTA00225379\n", "char_count": 1759}, {"efta_number": "EFTA00225378", "page_number": 2, "text_content": "‘A0/10 (Ho 04/07)Suboxra Co Testify Before Grand Any \nUNITED STATES DISTRICT COURT \nSOUTHERN DISTRICT OF FLORIDA \nTO: \nSUBPOENA TO TESTIFY \nBEFORE GRAND JURY \n01.1031MPB1-Tues. No. OLY-05/2 \nSUBPOENA FOR: \ne PERSON \nI DOCUMENT(S) OR OBJECTS) \nYOU ARE HEREBY COMMANDED to appear and terrify before the Grand Jury of the United States District \nCourt at the place, date, and lime specified below, \nPLACE \nUnited States District Court \n701 Clematis Street \nWest Palm Beach. Florida 33401 \nCOURTROOM \nGrand Jury Room \nDATE AND TIME \n71112008 10:30 am \nYOU ARE ALSO COMMANDED to bring with you the following document(s) or object(s):* \nALL DOCUMENTS AND INFORMATION REFERENCED IN THE ATTACHMENT TO THIS SUBPOENA. \nU Please see additional information on rei • \nThis subpoena shall remain in elf \nbehalf of the court. \nThis subpoena is issued on application \nor the \nof A \n• Ilea applicable. eat 'none\" \nIn by the cowl or by an officer acting on \nNAME ADDRESS AND PHONE NUMBER OF ASSISTANT U S ATTORNEY\nAnnMarie C. Villaf aria , Assistant U.S. Attorney \n500 South Australian Avenue, Suite 400 \nWest Palm Beach, Florida 33401-6235 \nTel (561) 820.8711, ext 3047 \nCase No. 08-80736-CV-MARRA \nP-008381 \nEFTA00225380\n", "char_count": 1205}, {"efta_number": "EFTA00225378", "page_number": 3, "text_content": "ATTACHMENT TO GRAND JURY SLBPOENA OLY-85/I \nADDRESSED TO \nPLEASE BRINGTHE. FOLLOWING DOCUM ENTS, FILMS, AND INFORMATION WITH YOU \nTO YOUR GRAND JURY APPEARANCE: \n1. \nAny and all notes, letters, cards, ifts, a ments, hoto ra hs, or other items that \nu \n\"'\nreceived from Jeffrey Epstein, \nLesley Groff, Ghislaine Maxwell. and/or any other employee or associate o Je rey Epstein. \n2. \nAn and all hot \na hs, whether printed or di ital, ofJeffrey Epstein, \n. Cecilia Steen,\n Ghislaine Maxwell, and/or any \nother employee or associate o Jeffrey Epstein. \n3. \nAny and all e-mails, instant messages, chats, text messages, voiccmails or tele hone \n10111\nt\nreceived from Jeffrey Epstein. \n. \nLesley Groff, Ghislaine Maxwe a \nor any of r \nemployee or associate o Je rey Epstein. \n4. \nA list of all telephone numbers (cellular and \"land line\"), c-mail addresses, screen \nnames, addresses, and any other contact information that you have for the following persons during \nthe period of January I, 2003 to the present: \na. \nyourself; \nb. \nJeffrey Epstein; \nc. \nd. \ne. \nf. \ng. \nh. \nGhislaine Maxwell; \ni. \nany person(s) who introduced you to Jeffrey Epstein and/or Ghislaine \nMaxwell; \nany person(s) whom you introduced to Jeffrey Epstein and/or Ghislaine \nMaxwell; \nk. \nany person(s) who communicated with you to arrange appointments to meet \nwith Jeffrey Epstein and/or Ghislaine Maxwell. \n5. \nAny billing statements for telephone service (cellular and \"land line\") for any \ntelephone you used during the period of January I, 2003 to the present. \nCase No. 08-80736-CV-MARRA \nP-008382 \nEFTA00225381\n", "char_count": 1586}, {"efta_number": "EFTA00225378", "page_number": 4, "text_content": "Villafana, Ann Marie C. (USAFLS) \nFrom: \nFernandez, Aida I. (USAFLS) \nSent: \nMonday, June 23, 2008 9:23 AM \nTo: \nVillafana, Ann Marie C. (USAFLS) \nSubject: \nRE: Grand Jury on 6/26 and 7/1 \nOk - got it - thx \nFrom: Villafana, Ann Marie C. (USAFLS) \nSent: Monday, June 23, 2008 9:19 AM \nTo: Fernandez, Aida I. (USAFLS) \nSubject: RE: Grand Jury on 6/26 and 7/1 \nHi Aida. Thank you for asking. We will be presenting the witness testimony after the indictment. (I would like \nto do the indictment in the morning and the witness in the afternoon, if possible.) \nA. Marie Villafaiia \nAssistant U.S. Attorney \n500 S. Australian Ave, Suite 400 \nWest Palm Beach, FL 33401 \nPhone 561 209-1047 \nFax 561 820-8777 \nFrom: Fernandez, Alda I. (USAFLS) \nSent: Monday, June 23, 2008 9:18 AM \nTo: Villafana, Ann Marie C. (USAFLS) \nCc: Ball, Shawn (USAFLS) \nSubject: RE: Grand Jury on 6/26 and 7/1 \nI assume you will be presenting your witness testimony first? Pls advise so that I know the order in which to \npresent them next week. \nPls advise. \nThx. \nFrom: Villafana, Ann Marie C. (USAFLS) \nSent: Monday, June 23, 2008 9:09 AM \nTo: Fernandez, Aida I. (USAFLS) \nCc: Ball, Shawn (USAFLS) \nSubject: Grand Jury on 6/26 and 7/1 \nEXHIBIT B-133 \n08-80736-CV-MARRA \nP-014979 \n6 \nEFTA00225382\n", "char_count": 1291}, {"efta_number": "EFTA00225378", "page_number": 5, "text_content": "Hi Aida — I think you already have this, but, if not: \nCan you put me down for a half-hour on Thursday, 6/26, in the morning, for an indictmen-\nAnd, on 7/1 can I have 2 hours in the morning for an indictment on Operation Leap Year. Witness will be \nNesbitt Kuyrkendall, FBI. It will be sealed. \nAlso on 7/1, I will need 2 hours for witness testimony on Operation Leap Year. Witness will be \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 \n08-80736-CV-MARRA \nP-014980 \n7 \nEFTA00225383\n", "char_count": 593}, {"efta_number": "EFTA00225378", "page_number": 6, "text_content": "Villafana, Ann Marie C. (USAFLS) \nFrom: \nSenior, Robert (USAFLS) \nSent: \nMonday, June 23, 2008 1. 11 \nTo: \nVillafana, Ann Marie C. (USAFLS); Kuyrkendall, E N. (MM) (FBI); Richards, Jason R. (MM) \n(FBI) \nCc: \nAtkinson, Karen (USAFLS) \nSubject: \nRE: Trip to New York, etc. \nOk. Marie, hoping to hear from DAG's office today giving the green light. Let's talk when that decision is \nmade. \nFrom: Villafana, Ann Marie C. (USAFLS) \nSent: Monday, June 23, 2008 9:15 AM \nTo: Kuyrkendall, E N. (FBI); Richards, Jason R. (FBI) \nCc: Atkinson, Karen (USAFLS); Senior, Robert (USAFLS) \nSubject: Trip to New York, etc. \nWe will not be interviewing \nin New York. Her attorney gave a copy of the grand jury subpoena to \nEpstein's lawyers. They, in turn, promptly sent it on to Washington complaining, yet again, about me. So, I do \nnot want to do an interview with him present, and we will have to put her in the grand jury. \nGiven that, let's take the New York section out of the indictment so we can present the indictment Tuesday \nmorning. Then we can do \ninterview in the afternoon with plans to supersede. It probably makes sense \nto wait on the rest of the interviews until we hear whadMI has to say, so let's plan to do the New York trip \nin a few weeks. \nBob — I will revise everything accordingly and send it down to you. We have another girl from Florida, so I \nwill replace our New York Jane Doe with her. \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 \n08-80736-CV-MARRA \nP-014981 \n78 \nEFTA00225384\n", "char_count": 1593}, {"efta_number": "EFTA00225378", "page_number": 7, "text_content": "Villafana, Ann Marie C. (USAFLS) \nFrom: \nBrendan White \nSent: \nThursday, June 26, 2008 10:38 AM \nTo: \nVillafana, Ann Marie C. (USAFLS) \nSubject: \nRe: Grand Jury Appearance \nDear Ms. Villafana: \nI understand that there has been a recent development with respect to Mr. Epstein in that he intends to plead guilty in \nFlorida state court on Monday pursuant to a deferred prosecution agreement with your office that has already been \nexecuted. Since this would seem to obviate any need for Ms. Lacerda to testify, please let me know what is going on with \nrespect to this Tuesday. Do we still need to come down there and, if so, will she receive court-ordered \nimmunity? Thanks. \nBrendan White \n--- Original Message --\nFrom: Vilfacana. Ahn Marie C. (USAFLS) \nTo: Brendan White \nSent: Monday, June 23, 2008 2:09 PM \nSubject: RE: Grand Jury Appearance \nDear Mr. White: \nPlease feel free to make your own travel arrangements, but if you would like Ms. Lacerda's travel costs to be \nreimbursed, they must be made through the government's approved agency on the approved carriers. \nRegarding the immunity, at this point, without a written proffer from you regarding the substance of her \nanticipated testimony, I believe that the more prudent course will be to question Ms. Lacerda to determine the \nlimits of her Fifth Amendment exposure and, if necessary, to apply to the Court at that time. If you provide me \nwith a written proffer that summarizes her anticipated testimony and explains how she will be exposed to \ncriminal liability, then I can make the motion ahead of time. Your written statement would be treated as an \nattorney statement made in the course of confidential plea discussions and related negotiations, and would be \ngoverned by Fed. R. Crim. P. 11(0 and Fed. R. Evid. 410. \nA. Marie Wolin \nAssistant U.S. Attorney \n500 S. Australian Ave, Suite 400 \nWest Palm Beach, FL 3340] \nPhone 561 209-1047 \nFax 561 820-8777 \nFrom: Brendan White [mailto:brendan@whiwhl.com] \nSe\n... [truncated, 2424 chars — for the full page use /api/corpus/document/EFTA00225378/7 or ?id=EFTA00225378&page=7]", "char_count": 2424}, {"efta_number": "EFTA00225378", "page_number": 8, "text_content": "— Original Message ---\nFrom: Villafana. Arm Marie C. (USAFLS1 \nTo: Brendan White \nCc: Ball Shawn (USARSI \nSent: Monday, June 23, 2008 11:27 AM \nSubject: Grand Jury Appearance \nDear Mr. White: \nMs. Lacerda will need to appear before the grand jury on July 1m to give testimony. Please contact my \nassistant, Shawn Ball, at 561 820-8711, ext. 3037, to make travel arrangements. I expect that Ms. Lacerda's \ntestimony will begin either in the late morning or early afternoon, but she should be available for the whole \nday. \nThank you. \nA. Marie Villafaiia \nAssistant U.S. Attorney \n500 S. Australian Ave, Suite 400 \nWest Palm Beach, FL 33401 \nPhone 561 209-1047 \nFax 561 820-8777 \n08-80736-CV-MARRA \nP-014992 \nl's \nEFTA00225386\n", "char_count": 726}, {"efta_number": "EFTA00225378", "page_number": 9, "text_content": "Villafana, Ann Marie C. (USAFLS) \nFrom: \nVillafana, Ann Marie C. (USAFLS) \nSent: \nThursday, June 26, 2008 10:55 AM \nTo: \nBrendan White \nSubject: \nRE: Grand Jury Appearance \nDear Mr. White: \nIf Mr. Epstein enters a guilty plea in accordance with that agreement on Monday, then the subpoena will be \nwithdrawn. At this point, I have not received confirmation that the change of plea is going to occur, nor have I \nreceived information confirming that the plea will be in conformance with our agreement. As such, at this time, \n1 still intend to present Ms. Lacerda's testimony to the grand jury on Tuesday. With respect to the immunity \nquestion, I refer you to my e-mail of June 2314, which is shown below. \nIf the situation changes, I will contact you. \nThank you. \nA. Marie Villafaiia \nAssistant U.S. Attorney \n500 S. Australian Ave, Suite 400 \nWest Palm Beach, FL 33401 \nPhone 561 209-1047 \nFax 561 820-8777 \nFrom: Brendan White [mailto:brendan@whiwhl.com] \nSent: Thursday, June 26, 2008 10:38 AM \nTo: Villafana, Ann Marie C. (USAFLS) \nSubject: Re: Grand Jury Appearance \nDear Ms. Villafana: \nI understand that there has been a recent development with respect to Mr. Epstein in that he intends to plead guilty in \nFlorida state court on Monday pursuant to a deferred prosecution agreement with your office that has already been \nexecuted. Since this would seem to obviate any need for Ms. Lacerda to testify, please let me know what is going on with \nrespect to this Tuesday. Do we still need to come down there and, if so, will she receive court-ordered \nimmunity? Thanks. \nBrendan White \n--- Original Message ---\nFrom: Villafana. AM Marie C. (USAFLS). \nTo: Brendan White \nSent: Monday, June 23, 2008 2:09 PM \nSubject: RE: Grand Jury Appearance \nDear Mr. White: \nPlease feel free to make your own travel arrangements, but if you would like Ms. Lacerda's travel costs to be \nreimbursed, they must be made through the government's approved agency on the approved carriers. \n\n... [truncated, 2047 chars — for the full page use /api/corpus/document/EFTA00225378/9 or ?id=EFTA00225378&page=9]", "char_count": 2047}, {"efta_number": "EFTA00225378", "page_number": 10, "text_content": "Regarding the immunity, at this point, without a written proffer from you regarding the substance of her \nanticipated testimony, I believe that the more prudent course will be to question Ms. Lacerda to determine the \nlimits of her Fifth Amendment exposure and, if necessary, to apply to the Court at that time. If you provide me \nwith a written proffer that summarizes her anticipated testimony and explains how she will be exposed to \ncriminal liability, then f can make the motion ahead of time. Your written statement would be treated as an \nattorney statement made in the course of confidential plea discussions and related negotiations, and would be \ngoverned by Fed. R. Crim. P. 11(0 and Fed. R. Evid. 410. \nA. Marie Villafalla \nAssistant U.S. Attorney \n500 S. Australian Ave, Suite 400 \nWest Palm Beach, FL 33401 \nPhone 561 209-1047 \nFax 561 820-8777 \nFrom: Brendan White [rnailto:brendan@whiwhl.com] \nSent: Monday, June 23, 2008 1:45 PM \nTo: Villafana, Ann Made C. (USAFIS) \nCc: Ball, Shawn (USAFLS) \nSubject: Re: Grand Jury Appearance \nWe will be there, and I will make the travel arrangements. I am assuming that this will be done in connection with an \norder of immunity. Please let me know if that is correct so I can advise Ms. Lacerda. Thanks. \nBrendan White \n \n Original Message --\nFrom: Villifena. Ann Mane C. (USAFLS) \nTo: Brendan White \nCc: Ball, Shawn (USAFLS) \nSent: Monday, June 23, 2008 11:27 AM \nSubject: Grand Jury Appearance \nDear Mr. White: \nN \nt \nMs. Lacerda will need to appear before the grand jury on July In to give testimony. Please contact my \nassistant, Shawn Ball, at 561 820-8711, ext. 3037, to make travel arrangements. I expect that Ms. Lacerda's \ntestimony will begin either in the late morning or early afternoon, but she should be available for the whole \nday. \nThank you. \nA. Marie Villafafia \nAssistant U.S. Attorney \n500 S. Australian Ave, Suite 400 \nWest Palm Beach, FL 33401 \nPhone 561 209-1047 \n08-80736-CV-MARRA \nP-014994 \n102 \nEFTA00225388\n", "char_count": 1990}, {"efta_number": "EFTA00225378", "page_number": 11, "text_content": "I I Fax 561 820-8777 \n08-80736-CV-MARRA \nP-014995 \n103 \nEFTA00225389\n", "char_count": 69}, {"efta_number": "EFTA00225378", "page_number": 12, "text_content": "Villafana, Ann Marie C. (USAFLS) \nFrom: \nBrendan White \nSent: \nThursday, June 26, 2008 11:26 AM \nTo: \nVillafana, Ann Marie C. (USAFLS) \nSubject: \nRe: Grand Jury Appearance \nThanks. \n---- Original Message ---\nFrom: Villafana. Anny.Matie C. (USAFLS) \nTo: Brendan White \nSent: Thursday, June 26, 2008 10:55 AM \nSubject: RE: Grand Jury Appearance \nDear Mr. White: \n• \nIf Mr. Epstein enters a guilty plea in accordance with that agreement on Monday, then the subpoena will be \nwithdrawn. At this point, 1 have not received confirmation that the change of plea is going to occur, nor have I \nreceived information confirming that the plea will be in conformance with our agreement. As such, at this \ntime, I still intend to present Ms. Lacerda's testimony to the grand jury on Tuesday. With respect to the \nimmunity question, I refer you to my e-mail of June 23rd, which is shown below. \nIf the situation changes, I will contact you. \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 \nFrom: Brendan White [mailto:brendan@whiwhi.com] \nSent: Thursday, June 26, 2008 10:38 AM \nTo: Villafana, Ann Marie C. (USAFLS) \nSubject: Re: Grand Jury Appearance \nDear Ms. Villafana: \nI understand that there has been a recent development with respect to Mr. Epstein in that he intends to plead guilty in \nFlorida state court on Monday pursuant to a deferred prosecution agreement with your office that has already been \nexecuted. Since this would seem to obviate any need for Ms. Lacerda to testify, please let me know what is going on \nwith respect to this Tuesday. Do we still need to come down there and, if so, will she receive court-ordered \nimmunity? Thanks. \nBrendan White \n-- Original Message --\nFrom: Villafana, Ann Marie C. (USAFLS1 \nTo: Brendan White \nSent: Monday, June 23, 2008 2:09 PM \nSubject: RE: Grand Jury Appearance \n08-80736-CV-MARRA \nP-014996 \n104 \nEFTA00225390\n", "char_count": 1988}, {"efta_number": "EFTA00225378", "page_number": 13, "text_content": "Dear Mr. White: \nPlease feel free to make your own travel arrangements, but if you would like Ms. Lacerda's travel costs to be \nreimbursed, they must be made through the government's approved agency on the approved carriers. \nRegarding the immunity, at this point, without a written proffer from you regarding the substance of her \nanticipated testimony, I believe that the more prudent course will be to question Ms. Lacerda to determine the \nlimits of her Fifth Amendment exposure and, if necessary, to apply to the Court at that time. If you provide \nme with a written proffer that summarizes her anticipated testimony and explains how she will be exposed to \ncriminal liability, then I can make the motion ahead of time. Your written statement would be treated as an \nattorney statement made in the course of confidential plea discussions and related negotiations, and would be \ngoverned by Fed. R. Crim. P. 11(1) and Fed. R. Evid. 410. \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: Brendan White [mallto:brendan@whiwhi.com) \nSent: Monday, June 23, 2008 1:45 PM \nTo: VIllafana, Ann Marie C. (USAFLS) \nCc: Ball, Shawn (USAFLS) \nSubject: Re: Grand Jury Appearance \nWe will be there, and I will make the travel arrangements. I am assuming that this will be done in connection with an \norder of immunity. Please let me know if that is correct so I can advise Ms. Lacerda. Thanks. \nBrendan White \n— Original Message ---\nVillarana, Ann Marie C. (USAFLS) \nTo: Brendan White \nCc: Ball. Shawn (USAFLS) \nSent: Monday, June 23, 2008 11:27 AM \nSubject: Grand Jury Appearance \nDear Mr. White: \nA*. \nMs. Lacerda will need to appear before the grand jury on July 1St to give testimony. Please contact my \nassistant, Shawn Ball, at 561 820-8711, ext. 3037, to make travel arrangements. I expect that Ms. Lacerda's \ntestimony will begin either in the late morning or early afternoon, but she should be availa\n... [truncated, 2130 chars — for the full page use /api/corpus/document/EFTA00225378/13 or ?id=EFTA00225378&page=13]", "char_count": 2130}, {"efta_number": "EFTA00225378", "page_number": 14, "text_content": "500 S. Australian Ave, Suite 400 \nWest Palm Beach, FL 33401 \nPhone 561 209-1047 \nFax 561 820-8777 \n08-80736-CV-MARRA \nP-014998 \n106 \nEFTA00225392\n", "char_count": 146}, {"efta_number": "EFTA00225378", "page_number": 15, "text_content": "Villafana, Ann Marie C. (USAFLS) \nFrom: \nBrendan White \nSent: \nThursday, June 26, 2008 3:00 PM \nTo: \nVillafana, Ann Marie C. (USAFLS) \nSubject: \nRe: Grand Jury Appearance \nI've learned from Mr. Epstein's attorney that the plea is scheduled to take place on Monday morning. In understand, of \ncourse, that you need confirmation of this before withdrawing the subpoena, but it might make logistical sense to consider \nputting the contingent appearance off for another week at this point, to avoid our having to make an unnecessary trip to \nFlorida. Although I am confident that things will proceed as scheduled, should there be a problem, we would then be able \nto appear at a later date. \nBrendan White \nOriginal Message ---\nFrcimiVillafand: ArineMorie,C. tUSAR.S1.4. . \nTo: Brendan White \nSent: Thursday, June 26, 2008 10:55 AM \nSubject: RE: Grand Jury Appearance \nDear Mr. White: \nIf Mr. Epstein enters a guilty plea in accordance with that agreement on Monday, then the subpoena will be \nwithdrawn. At this point, I have not received confirmation that the change of plea is going to occur, nor have I \nreceived information confirming that the plea will be in conformance with our agreement. As such, at this \ntime, 1 still intend to present Ms. Lacerda's testimony to the grand jury on Tuesday. With respect to the \nimmunity question, I refer you to my e-mail of June 23Id, which is shown below. \nIf the situation changes, I will contact you. \nThank you. \nA. Marie Villafafla \nAssistant U.S. Attorney \n500 S. Australian Ave, Suite 400 \nWest Palm Beach, FL 33401 \nPhone 561 209-1047 \nFax 561 820-8777 \nFrom: Brendan White (mallto:brendan@whiwhi.com) \nSent: Thursday, June 26, 2008 10:38 AM \nTo: Villafana, Ann Marie C. (USAFLS) \nSubject: Re: Grand Jury Appearance \nDear Ms. Villafana: \nI understand that there has been a recent development with respect to Mr. Epstein in that he intends to plead guilty in \nFlorida state court on Monday pursuant to a deferred prosecution agreem\n... [truncated, 2337 chars — for the full page use /api/corpus/document/EFTA00225378/15 or ?id=EFTA00225378&page=15]", "char_count": 2337}, {"efta_number": "EFTA00225378", "page_number": 16, "text_content": "Brendan White \n-- Original Message --\n;From: Villafana, Ann Marie.C. fUSAFLSI \nTo: prendan White \nSent: Monday, June 23, 2008 2:09 PM \nSubject: RE: Grand Jury Appearance \nDear Mr. White: \nPlease feel free to make your own travel arrangements, but if you would like Ms. Lacerda's travel costs to be \nreimbursed, they must be made through the government's approved agency on the approved carriers. \nRegarding the immunity, at this point, without a written proffer from you regarding the substance of her \nanticipated testimony, I believe that the more prudent course will be to question Ms. Lacerda to determine the \nlimits of her Fifth Amendment exposure and, if necessary, to apply to the Court at that time. If you provide \nme with a written proffer that summarizes her anticipated testimony and explains how she will be exposed to \ncriminal liability, then 1 can make the motion ahead of time. Your written statement would be treated as an \nattorney statement made in the course of confidential plea discussions and related negotiations, and would be \ngoverned by Fed. R. Crim. P. 11(0 and Fed. R. Evid. 410. \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: Brendan White imallto:brendanOwhlwhl.com] \nSent: Monday, June 23, 2008 1:45 PM \nTo: Villafana, Ann Marie C. (USAFLS) \nCc: Ball, Shawn (USAFLS) \nSubject: Re: Grand Jury Appearance \nWe will be there, and I will make the travel arrangements. I am assuming that this will be done in connection with an \norder of immunity. Please let me knoie if that is correct so I can advise Ms. Lacerda. Thanks. \nBrendan White \n-- Original Message - \nFrom: Villeanie. Ann Mile C. (USAFISI \nTo: Brendan White \nCc: Ball. Shawn fUSAFLS) \nSent: Monday, June 23, 2008 11:27 AM \nSubject: Grand Jury Appearance \nDear Mr. White: \nk t • \nMs. Lacerda will need to appear before the grand jury on July 1st to give testimony. Please contact my \nassistant, Shawn Ball, \n... [truncated, 2262 chars — for the full page use /api/corpus/document/EFTA00225378/16 or ?id=EFTA00225378&page=16]", "char_count": 2262}, {"efta_number": "EFTA00225378", "page_number": 17, "text_content": "A. 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 \n4+, \n08-80736-CV-MARRA \nP-015001 \n111 \nEFTA00225395\n", "char_count": 196}, {"efta_number": "EFTA00225378", "page_number": 18, "text_content": "Villafana, Ann Marie C. (USAFLS) \nFrom: \nVillafana, Ann Marie C. (USAFLS) \nSent: \nThursday, June 26, 2008 6:41 PM \nTo: \nBrendan White \nSubject: \nRE: Grand Jury Appearance \nDear Mr. White: \nI have not received any such confirmation. At this time, we are still on for July 1m. I recommend that you make \nyour travel plans for Monday afternoon or evening and if things change, I will call you right away. \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 \nFrom: Brendan White [mailto:brendan@whiwhi.com] \nSent: Thursday, June 26, 2008 3:00 PM \nTo: Villafana, Ann Marie C. (USAFLS) \nSubject: Re: Grand Jury Appearance \nI've learned from Mr. Epstein's attorney that the plea is scheduled to take place on Monday morning. In understand, of \ncourse, that you need confirmation of this before withdrawing the subpoena, but it might make logistical sense to consider \npulling the contingent appearance off for another week at this point, to avoid our having to make an unnecessary trip to \nFlorida. Although I am confident that things will proceed as scheduled, should there be a problem, we would then be able \nto appear at a later date. \nBrendan White \n---- Original Message ----\nFrormtVillefina, Aim Marie C. (USAE.LSr:.: \nTo: Brendan White \nSent: Thursday, June 26, 200810:55 AM \nSubject: RE: Grand Jury Appearance \nDear Mr. White: \nIf Mr. Epstein enters a guilty plea in accordance with that agreement on Monday, then the subpoena will be \nwithdrawn. At this point, I have not received confirmation that the change of plea is going to occur, nor have I \nreceived information confirming that the plea will be in conformance with our agreement. As such, at this \ntime, I still intend to present Ms. Lacerda's testimony to the grand jury on Tuesday. With respect to the \nimmunity question, I refer you to my e-mail of June 23id, which is shown below. \nIf the situation changes\n... [truncated, 2082 chars — for the full page use /api/corpus/document/EFTA00225378/18 or ?id=EFTA00225378&page=18]", "char_count": 2082}, {"efta_number": "EFTA00225378", "page_number": 19, "text_content": "A. Marie Villain& \nAssistant U.S. Attorney \n500 S. Australian Ave, Suite 400 \nWest Palm Beach, FL 33401 \nPhone 561 209-1047 \nFax 561 820-8777 \nFrom: Brendan White [malito:brendan@whlwhl.com] \nSent: Thursday, June 26, 2008 10:38 AM \nTo: Vlllafana, Ann Marie C. (USAFLS) \nSubject: Re: Grand Jury Appearance \nDear Ms. Villafana: \nI understand that there has been a recent development with respect to Mr. Epstein in that he intends to plead guilty in \nFlorida state court on Monday pursuant to a deferred prosecution agreement with your office that has already been \nexecuted. Since this would seem to obviate any need for Ms. Lacerda to testify, please let me know what is going on \nwith respect to this Tuesday. Do we still need to come down there and, if so, will she receive court-ordered \nimmunity? Thanks. \nBrendan White \nOriginal Message --\nFreim: Vil \nAna &Wert (USAFLS) \nTo: Brendan White \nSent: Monday, June 23, 2008 2:09 PM \nSubject: RE: Grand Jury Appearance \nDear Mr. White: \nPlease feel free to make your own travel arrangements, but if you would like Ms. Lacerda's travel costs to be \nreimbursed, they must be made through the government's approved agency on the approved carriers. \nRegarding the immunity, at this point, without a written proffer from you regarding the substance of her \nanticipated testimony, I believe that the more prudent course will be to question Ms. Lacerda to determine the \nlimits of her Fifth Amendment exposure and, if necessary, to apply to the Court at that time. If you provide \nme with a written proffer that summarizes her anticipated testimony and explains how she will be exposed to \ncriminal liability, then I can make tte motion ahead of time. Your written statement would be treated as an \nattorney statement made in the course of confidential plea discussions and related negotiations, and would be \ngoverned by Fed. R. Crim. P. 11(0 and Fed. R. Evid. 410. \nA. Marie Villafafia \nAssistant U.S. Attorney \n500 S. Australian Ave, Suite 400 \nWest Palm B\n... [truncated, 2287 chars — for the full page use /api/corpus/document/EFTA00225378/19 or ?id=EFTA00225378&page=19]", "char_count": 2287}, {"efta_number": "EFTA00225378", "page_number": 20, "text_content": "We will be there, and I will make the travel arrangements. I am assuming that this will be done in connection with an \norder of immunity. Please let me know if that is correct so I can advise Ms. Lacerda. Thanks. \nBrendan White \n---- Original Message ---\nFrom: Villafana, Ann Marie C. (USAFLS) \nTo: Brendan White \nCc: Ball, Shawn (USAFLS) \nSent: Monday, June 23, 200811:27 AM \nSubject: Grand Jury Appearance \nDear Mr. White: \nMs. Lacerda will need to appear before the grand jury on July l g to give testimony. Please contact my \nassistant, Shawn Ball, at 561 820-8711, ext. 3037, to make travel arrangements. 1 expect that Ms. Lacerda's \ntestimony will begin either in the late morning or early afternoon, but she should be available for the whole \nday. \nThank you. \nA. Marie Villajaiia \nAssistant U.S. Attorney \n500 S. Australian Ave, Suite 400 \nWest Palm Beach, FL 33401 \nPhone 561 209-1047 \nFax 561 820-8777 \n08-80736-CV-MARRA \nP-015004 \n114 \nEFTA00225398\n", "char_count": 960}, {"efta_number": "EFTA00225378", "page_number": 21, "text_content": "Villafana, Ann Marie C. (USAFLS) \nFrom: \nBrendan White [brendan@whiwhi.com) \nSent: \nMonday. June 30. 2008 11:20 AM \nTo: \nVillafana, Ann Marie C. (USAFLS) \nSubject: \nRe: Cancellation of Grand Jury Appearance \nThank you for letting me know. I will inform Ms. Lacerda. \nBrendan \n-- Original Message ---\nFrom: Villafana. Ann Marie C. (USAFLS) \nTo: Brendan White \nCc: Ball. Shawn (USAFLS) \nSent: Monday, June 30, 2008 10:59 AM \nSubject: Cancellation of Grand Jury Appearance \nDear Mr. White: At this time, the subpoena of Ms. Lacerda is withdrawn. If that should change, I will contact \nyou. \nA. Mark Villafana \nAssistant U.S. Attorney \n500 S. Australian Ave, Suite 400 \nWest Palm Beach, FL 33401 \nPhone 561 209-1047 \nFax 561 820-8777 \nEXHIBIT B-135 \n753 \nEFTA00225399\n", "char_count": 764}, {"efta_number": "EFTA00225378", "page_number": 22, "text_content": "Villafana, Ann Marie C. (USAFLS) \nFrom: \nVillafana, Ann Marie C. (USAFLS) \nSent: \nThursday, January 31, 2008 7:33 PM \nTo: \nSloman, Jeff (USAFLS); Acosta, Alex (USAFLS) \nSubject: \nEpstein \nHi Jeff and Alex — We just finished interviewing three of the girls. I wish you could have been there to see how \nmuch this has affected them. \nOne girl broke down sobbing so that we had to stop the interview twice within a 20 minute span. She regained \nher composure enough to continue a short time, but she said that she was having nightmares about Epstein \ncoming after her and she started to break down again, so we stopped the interview. \nThe second girl, who has a baby girl of her own, told us that she was very upset about the 18 month deal she \nhad read about in the paper. She said that 18 months was nothing and that she had heard that the girls could get \nrestitution, but she would rather not get any money and have Epstein spend a significant time in jail. \nThe FBI's victim-witness coordinator attended and she has arranged for counseling for several of the girls. \nPlease reach out to Alice to make her decision. These girls deserve so much better than they have received so \nfar, and I hate feeling that there is nothing I can do to help them. \nWe have four more girls coming in tomorrow. Can I persuade you to attend? \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: \nEXHIBIT \n1779 \n08-80736-CV-MARRA \nP-014573 \nEFTA00225400\n", "char_count": 1537}, {"efta_number": "EFTA00225378", "page_number": 23, "text_content": "Villafana, Ann Marie C. (USAFLS) \nFrom: \nVillafana, Ann Marie C. (USAFLS) \nSent: \nWednesday, March 19. 2008 2:30 PM \nTo: \nWeinstein, David (USAFLS) \nSubject: \nRE: Epstein update \nWhy is this allowed to continue? Al least put us out of our misery quickly if that is what is going to happen! \nA. Marie lillaleala \nAssistant 11.5. Attorney \n500 S. Australian Ave. Suite 400 \nWest Palm Beach. FL 33401 \nPhone 56 I 209-I 047 \nFax 561 820-8777 \nFrom: Weinstein, David (USAFLS) \nSent: Wednesday, March 19, 2008 2:29 PM \nTo: Villafana, Ann Marie C. (USAFLS) \nSubject: RE: Epstein update \nThank you for silently keeping me in the loop. \nOutrageous. \nFrom: Villafana, Ann Marie C. (USAFLS) \nSent: Wednesday, March 19, 2008 2:16 PM \nTo: Sloman, Jeff (USAFLS); Senior, Robert (USAFLS) \nCc: Atkinson, Karen (USAFLS); Garcia, Rolando (USAFLS) \nSubject: Epstein update \nHi Jeff and Bob — I am hoping that you have an update from Drew. I wanted to fill you in on recent events. \nYesterday we did the first half of the grand jury presentation on the indictment. Many of the grand jurors \nexpressed thanks for our return. After a break as 1 walked into the room, I overheard one juror telling another \nthat he had been concerned that we were going to \"whitewash\" this case and not charge it. \nEpstein's lawyers arc using the civil lawsuits as an excuse to harass a number of the victims. One girl, who is a \nscholarship student at a local university, was hauled into the Dean of Students office to be served with a \nsubpoena for a deposition. It is scheduled for Monday. \nA national crime victims service organization has received a grant from the Justice Department to provide legal \nrepresentation to victims. They have agreed to provide counsel for our victims. The only problem is that the \nlawyers are located in Maryland. But they will try to find pro bono lawyers here to help out. \nI also told Bob that one of our victims tried to commit suicide last week. The FBI's victim-witness coordinator \nis doing her be\n... [truncated, 2167 chars — for the full page use /api/corpus/document/EFTA00225378/23 or ?id=EFTA00225378&page=23]", "char_count": 2167}, {"efta_number": "EFTA00225378", "page_number": 24, "text_content": "for these girls to have a resolution in this case. The \"please be patient\" answer is really wearing thin, especially \nwhen Epstein's group is still on the attack while we are forced to wait on the sidelines. \nYour guidance is needed. \nThank you. \nA. Marie Yillafalia \nAssistant U.S. Attorney \n500 S. Australian Ave, Suite 400 \nWest Palm Beach, FL. 33401 \nPhone 561 209-1047 \nFax 561 820-8777 \n1316 \n08-80736-CV-MARRA \nP-014782 \nEFTA00225402\n", "char_count": 441}, {"efta_number": "EFTA00225378", "page_number": 25, "text_content": "Villafana, Ann Marie C. (USAFLS) \nFrom: \nVillafana, Ann Marie C. (USAFLS) \nSent: \nWednesday, March 19, 2008 4:34 PM \nTo: \nSloman, Jeff (USAFLS); Senior, Robert (USAFLS); Atkinson, Karen (USAFLS); Garcia, \nRolando (USAFLS) \nCc: \nKuyrkendall, E N. \nSubject: \nVictim Subpoena \nIli everyone — I just spoke with the subpoenaed victim. The subpoena was issued in connection with the state \ncriminal case, which, as you know, doesn't involve most of the victims in our case (including the girl who was \nsubpoenaed). The state attorney's office told us from the beginning that their case has been resolved. He is \ngoing to plead to the solicitation of adults for prostitution charge, so this seems to be a clear effort to find out \nabout our case through the state case. \nA. Marie Villain \nAssistant U.S. Attorney \n500 S. Australian Ave, Suite 400 \nWest Palm Beach, FL 33401 \nPhone 561 209-1047 \nFax 561 820-8777 \nTracking: \n1313 \nEXHIBIT C-3 \n08-80736-CV-MARRA \nP-014783 \nEFTA00225403\n", "char_count": 978}, {"efta_number": "EFTA00225378", "page_number": 26, "text_content": "Villafana, Ann Marie C. (USAFLS) \nFrom: \nVillafana, Ann Marie C. (USAFLS) \nSent: \nSaturday, March 22, 2008 8:51 PM \nTo: \nSloman, Jeff (USAFLS); Senior, Robert (USAFLS) \nCc: \nAtkinson, Karen (USAFLS); Garcia, Rolando (USAFLS) \nSubject: \nEpstein \nHi all - So sorry to bother you on a Saturday, but I am hoping that I can persuade you to reach out to Drew \nabout Epstein's investigators harassing the girls. Nesbitt received a frantic call today about Epstein's \ninvestigators bothering the parents of one of the victims. According to the victim, he demanded to see the \nvictim and when he saw her, he told the victim that they had video of the girl and were planning to put it on the \ninternet. We don't believe that Epstein actually has video of any of the girls, and Nesbitt has calmed the girl \ndown, but this activity seems to be getting more aggressive. Remember also that Epstein is using the state \ncriminal case to subpoena depositions of victims in the federal case (who are not part of the state indictment) to \nget information about our investigation. These actions do not seem consistent with what Epstein's attorneys are \nsupposed to be trying to work out with Drew in DC. Any chance Drew will ask Epstein's people to call off \ntheir dogs until he makes his decision? \n4. Marie Villafana \nAssistant U.S. Attorney \n561 209-1047 \nFax 561 820-8777 \nTracking: \n1256 \n08-80736-CV-MARRA \nP-014790 \nEFTA00225404\n", "char_count": 1416}, {"efta_number": "EFTA00225378", "page_number": 27, "text_content": "Villafana, Ann Marie C. (USAFLS) \nFrom: \nVillafana, Ann Marie C. (USAFLS) \nSent: \nSaturday, March 22, 2008 9:43 PM \nTo: \nKuyrkendall, E N. \nSubject: \nMessage from Jeff \nHi Nesbitt — I contacted Jeff and Bob about the harassment issue and Jeff also recommended calling the police. \nWhen Twiler calls on Monday can she provide the non-emergency police numbers for the local police \ndepartments where the girls are located and ask them to call the police directly if they are getting harassed? I \nthink we should be documenting this stuff with someone other than you. \nThank you. \nA. Marie Mal-aft \nAssistant U.S. Attorney \n561 209-1047 \nFax 561 820-8777 \n1248 \n08-80736-CV-MARRA \nP-014795 \nEFTA00225405\n", "char_count": 701}, {"efta_number": "EFTA00225378", "page_number": 28, "text_content": "Villafana, Ann Marie C. (USAFLS) \nFrom: \nAtkinson, Karen (USAFLS) \nSent: \nWednesday, May 23, 2007 4:20 PM \nTo: \nVillafana, Ann Marie C. (USAFLS) \nSubject: \nRE: Jeffrey Epstein \nLet's talk before this is sent, please. \nFrom: Villafana, Ann Marie C. (USAFLS) \nSent: Wednesday, May 23, 2007 3:45 PM \nTo: Atkinson, Karen (USAFLS) \nSubject: FW: Jeffrey Epstein \nKaren — What do you think? \nHi Jeff and Mau — I just want to again voice my disagreement with promising to have a meeting or having a \nmeeting with Lefcourt or any other of Epstein's attorneys. As I mentioned, this is not a case where we will be \nsitting down to negotiate whether a defendant will serve one year versus two years of probation. This is a case \nwhere the defendant is facing the possibility of dozens of years of prison time. Just as the defense will defend a \ncase like that differently than they would handle a probation-type case, we need to handle this case \ndifferently. Part of our prosecution strategy was already disclosed at the last meeting, and I am concerned that \nmore will be disclosed at a future meeting. \nMy co-chair, John McMillan, who has prosecuted more of these cases than the rest of us combined and who \nactually worked on the drafting of some of the child exploitation statutes, also opposes a meeting. We have \nbeen accused of not being \"strategic thinkers\" because of our opposition to these meetings, but we are simply \nlooking at this case as a violent crime prosecution involving stiff penalties rather than as a white collar or public \ncorruption case where the parties can amicably work out a light sentence. \nWith respect to the \"policy reasons\" that Lefcourt wants to discuss, those were already raised in his letter \n(which is part of the indictment package) and during his meeting with Andy and myself. Those reasons are: (1) \nhe wants the Petit policy to trump our ability to prosecute Epstein, (2) this shouldn't be a federal offense, and \n(3) the victims were willing participants so the cr\n... [truncated, 3118 chars — for the full page use /api/corpus/document/EFTA00225378/28 or ?id=EFTA00225378&page=28]", "char_count": 3118}, {"efta_number": "EFTA00225378", "page_number": 29, "text_content": "500 S. Australian Ave, Suite 400 \nWest Palm Beach, FL 33401 \nPhone 561 209-1047 \nFax 561 820-8777 \nFrom: Lourie, Andrew (USAFLS) \nSent: Tuesday, May 22, 2007 6:33 PM \nTo: Villafana, Ann Marie C. (USAFLS) \nSubject: FW: Jeffrey Epstein \nfyi \nFrom: Lourie, Andrew (USAFLS) \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@lefcourtlaw.com] \nSent: Tuesday, May 22, 2007 2:05 PM \nTo: Lourle, 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\n... [truncated, 2124 chars — for the full page use /api/corpus/document/EFTA00225378/29 or ?id=EFTA00225378&page=29]", "char_count": 2124}, {"efta_number": "EFTA00225378", "page_number": 30, "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 by complaint. Alex has your memo \nand lefcourt's letter but he is out of the district at the US Attorney's conference for the next several days. \nI'm having trouble understanding - given how long this case has been pending - what the rush is. This is obviously a very \nsignificant case and alex wants to take his time making sure he is comfortable before proceeding. \nSent from my BlackBerry Wireless Handheld \n \nOriginal Message \nFrom: Villafana, Ann Marie C. (USAFLS) \nTo: Lourie, Andrew (USAFLS) ; Menchel, Matthew (USAFLS) \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 Virgin Islands to Newark now, so it looks like \nEpstein is going to show up for his 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 Villafaha \nAssistant U.S. Attorney \n500 S. Australian Ave, Suite 400 \nWest Palm Beach, FL 33401 \nPhone 561 209-1047 \nFax 561 820-8777 \nEXHIBIT C-5 \nEFTA00225408\n", "char_count": 1445}, {"efta_number": "EFTA00225378", "page_number": 31, "text_content": "Villafana, Ann Marie C. (USAFLS) \nFrom: \nVIHelena. Ann Marie C. (USAFLS) \nSent: \nFriday, October 05, 2007 4:48 PM \nTo: \nSloman, Jeff (USAFLS) \nSubject: \nFW: Proposed Letter to Special Master \nAttachments: \nPROPOSED Letter to Special Master.pdf; Special Master Proposal.pdf; Ltr from Lefkowitz to \nVillafana (Oct. 5, 2007)212135690_4)1)OC \nlii Jeff Can I please just indict him? Can you give me a call on my cell phone? 561 601-2301. Since they \nobject to using a Special Master. we have two options — we can just choose the lawyer ourselves or as part of \nour selection process. we can deal with the Special Master ourselves and, upon receiving the Special Master's \nchoice. provide that name to the defense, understanding that they may then reject the selection. \nThe other issues, regarding paying the attorney, clearly violate the terms of the agreement, which specifically \nstate \"if any of the individuals elects to file suit.\" \nA. Mark Villafafta \nAssistant U.S. Attorney \n561 209-1047 \nFax 561 820-8777 \nFrom: Jay Lefkowitz [mailto:Reficowit@kirkland.com] \nSent: Fri 10/5/2007 11:03 AM \nTo: Villafana, Ann Marie C. (USAFLS) \nCc: Lourie, Andrew; owlmgw@worldnet.att.net; glewis@lewistein.com \nSubject: RE: Proposed Letter to Special Master \nMarie. \nAttached is a letter responding to your latest proposals. For your convenience, I've also attached your prior e-mails and \nattachments regarding this matter so that you can easily see what I am responding to (see the chain below). If you are \navailable, I'm free to talk at 5:30 this evening. We can use my usual call-in number at (866) 462-0164. The code is \n'4464970'. \nThanks, \nJay \n\"Villatana, Ann Marie C. (USAFLSr \ncAnn.Marie.C.Vifialaniausdoi.00v>\n10/05/2007 07 48 AM \nTo -Jay Letkormts\" clletkomMakirkland corny \ncc \nSubject RE. Proposed Letter to Special Master \nEXHIBIT C-6 \n2767 \nEFTA00225409\n", "char_count": 1859}, {"efta_number": "EFTA00225378", "page_number": 32, "text_content": "Good morning, Jay. We need to resolve the attorney issue today. It has been weeks since \nexecution of the contract, and there is no need for further delay. \nAs far as the five attorney names that we will be providing, I propose Bert Ocariz, \nKatherine Ezell at Podhurst Orseck, Stuart Grossman, Ed Rogers, and Walter Cobath. \nIf you would like to use the same Special Master to resolve fees disputes as well as to \nhandle the selection of the attorney, I \nrecommend that w \ntired 11th Circuit \nJudge Joseph Hatchett instead of Judge \nbecause of Judge \nillie \nhealth problems. \n:No one has contacted Judge Hatchett yet, but one of the District udges in Miami \nmentioned him as a good choice.) \nI am available for a conference call between 9:00 and 10:00, and between 3:15 and 6:00. \nPlease call me on my cell (561 601-2301) and let me know which of those times works best \nfor you. \nThank you. \nFrom: Jay Lefkowitz (mailto:JLefkowitz@kirkland.com) \nSent: Wed 10/3/2007 4:26 PM \nTo: Villafana, Ann Marie C. (USAFLS) \nSubject: Re: Proposed Letter tc Special Master \nMarie - I, too, am interested in speed. But I really need to go over this and then \ndiscuss with Jeffrey. So please do not send this to any Special Master before we discuss \nthe next steps. \nThanks -- Jay \n\"Villafana, Ann Marie C. (USAFLS)\" \n10/03/2007 04:24 PM \nTo \n\"Jay Lefkowitz\" \ncc \nSubject \nProposed Letter to Special Master \nHi Jay - To move things along, I also have enclosed the proposed text of a letter to the \nSpecial Master. \n<\n10/03/2007 04 24 PM \nTo \"Jay lentowaz ciLefltovnizattkirkiand corn,\ncc \nSubject Proposed Letter to Special Master \nHi Jay — To move things along. I also have enclosed the proposed text of a letter to the Special Master. \n«PROPOSED Letter to Special Master pdf» \nA. Mark Villafaik \nAssistant U.S. Attorney \n561 209-1047 \nFax 561 820-8777 \n\"Vilialana, Ann Marie C. (USAFLS)\" \n4Ann,Mario.C.Villaranalausdoickur>\n10/03/2007 03 18 PM \nTo \"Jay Lefkowitz\" \ncc \n&beset Memo in POF lomat \nHi Jay — In case you can't open the other version, here it is in pdf. \n< \nSent: Mon Oct 22 17:23:30 2007 \nSubject: Re: Epstein \nI\nl\nI have not spoken to him b \n' was our intention to assign the decision to \nselect a lawyer to Judge \nnot for him to represent the girls. We do not \nwant to select the lawyer w o \nl represents the girls. I don't know who said he'd do \nit but it wasn't us. \nSent from my BlackBerry Wireless Handheld \n \n Original Message \nFrom: Jay Lefkowitz \nTo: Sloman, Jeff (USAFLS) \nCc: Acosta, Alex (USAFLS); Villafana, Ann Marie C. (USAFLS) \nSent: Mon Oct 22 17:10:00 2007 \nSubject: Re: Epstein \nJeff -- I will review these materials this evening and be in touch with you \ntomorrow with the expectation of wrapping this up by \nnd of the day. One \nquestion I have, however, is why you say that Judge \nis a non-starter. I \nunderstood that he was ready, willing and able to serve as the attorney \nrepresentative. If you have had conversations with him and that is not the case, \nplease let me know. \nI will go over the other issues you raise in your email and will look forward to \nspeaking tomorrow. \nThanks -- Jay \n\"Sloman, Jeff (USAFLS)\" <]eff.Sloman@usdoj.gov> \n2691 \nEFTA00225414\n", "char_count": 1500}, {"efta_number": "EFTA00225378", "page_number": 37, "text_content": "10/22/2007 04:40 PM \nTo \n\"Jay Lefkowitz\" cc \n\"Acosta, Alex (USAFLS)\" cAlex.Acosta@usdoj.gov>, \"Villafana, Ann Marie C. \n(USAFLS)\" Subject \nEpstein \nJay, \nThe Judge \nissue is a non-starter. We've beaten that horse to death. \nRegarding your contention that \"the attorney representative be told clearly that \nMr. Epstein has agreed to pay the lawyer's hourly rate only for the time he or \nshe spends working to effectuate settlements for the identified women,\" Alex and \nI agree that paragraph 7C is sufficient, Regarding the other points, we have \nmade the following concessions: \n1. \nRegarding the language concerning a lawyer whose firm is \nsizeable enough to litigate multiple trials simultaneously, I have removed \nparagraph 4 on page 3 of the letter. \n2. \nRegarding the 150k statutory limit language, I have included a \nfootnote which should satisfy your concern. \n3. \nRegarding language there may be discovery to test the claims \nof alleged \"victims\", please see new paragraph 4 on page 3 which now states as \ncriteria that the firm should have \"Experience litigating against large law firms \nand high profile attorneys who may test the veracity of the victims' claims.\" \nI have attached the Addendum and the revised letter to Judge \nJay, this \nneeds to be concluded. Alex and I believe that this is as far \nw can go. \nTherefore, please advise me whether we have a deal no later than COB tomorrow, \nTuesday, October 23, 2007. Thanks, \nJeff \n \nOriginal Message \nFrom: Jay Lefkowitz [mailto:]Lefkowitz@kirkland.com] \nSent: Friday, October 19, 2007 4:05 PM \nTo: Sloman, Jeff (USAFLS) \nSubject: Re: \nJeff - \n2692 \nEFTA00225415\n", "char_count": 1687}, {"efta_number": "EFTA00225378", "page_number": 38, "text_content": "I have reviewed your proposed language and wanted to raise a few areas of \nconcern. \nFirst, I am not sure why we are not just asking Judge \nto represent these \nwomen. If he is available, that would save us a whole a itional layer of \nprocess. \nI had thought that was initially the idea. I am not sure why you seem \nto be moving in another direction. \nI also cannot understand why the draft affirmatively requests that J \nselect \na lawyer whose firm is sizeable enough to litigate multiple trials \nsimultaneously. That seems to be directly at odds with the purpose of the \nagreement, which is to facilitate out of court settlements. \nIndeed, to the \nextent any woman were to elect to bring an action against Mr. Epstein, she would \nnot only be free to select any lawyer of her choice, but would be restricted from \nusing the lawyer representative in this capacity due to the conflicts of \ninterests that would cause. \nThis part of your proposed language is of \nsignficiant concern to me. \nYour letter also indicates the 150k statutory limit without reference to the \npre-existing 50G limit. To be sure, any of the women are free to seek whatever \nsettlement they want, but given the question that exists about the statutory \namount, the letter should not state definitely that it will be 150k. \nIn addition \nhave omitted a few important items from your proposal. Given \nthat Judge \nor any other potential attorney representative should understand \nthe scope o \ne work, the language should make clear that there may be discovery \nto test the claims of alleged \"victims.\" \nFinally, I think it is important that the attorney representative be told clearly \nthat Mr. Epstein has agreed to pay the lawyer's hourly rate only for the time he \nor she spends working to effectuate settlements for the identified women. \nJay \n \n Original Message \nFrom: \"Sloman, Jeff (USAFLS)\" [Jeff.Sloman@usdoj.gov] \nSent: 10/17/2007 01:58 PM AST \nTo: Jay Lefkowitz \nSubject: RE: \n<<071015 Special Master Letter2.wpd» Jay, \nH\n... [truncated, 2149 chars — for the full page use /api/corpus/document/EFTA00225378/38 or ?id=EFTA00225378&page=38]", "char_count": 2149}, {"efta_number": "EFTA00225378", "page_number": 39, "text_content": "Sent: Tuesday, October 16, 2007 9:26 AM \nTo: Sloman, Jeff (USAFLS) \nSubject: \nJeff - is there a time today we can speak? \nHow about 430 pm? \n*********************************************************** \nThe information contained in this communication is \nconfidential, may be attorney-client privileged, may \nconstitute inside information, and is intended only for \nthe use of the addressee. It is the property of \nKirkland & Ellis LLP or Kirkland & Ellis International LLP. \nUnauthorized use, disclosure or copying of this \ncommunication or any part thereof is strictly prohibited \nand may be unlawful. If you have received this \ncommunication in error, please notify us immediately by \nreturn e-mail or by e-mail to postmaster@kirkland.com, and \ndestroy this communication and all copies thereof, \nincluding all attachments. \n#4********#4\n, ###tt4c#4***********####*********************### \n#********####4\n, 4, **************###*t#ti,*#*#44\n, *********4.44.44\n2k# \nThe information contained in this communication is \nconfidential, may be attorney-client privileged, may \nconstitute inside information, and is intended only for \nthe use of the addressee. It is the property of \nKirkland & Ellis LLP or Kirkland & Ellis International LLP. \nUnauthorized use, disclosure or copying of this \ncommunication or any part thereof is strictly prohibited \nand may be unlawful. If you have received this \ncommunication in error, please notify us immediately by \nreturn e-mail or by e-mail to postmaster@kirkland.com, and \ndestroy this communication and all copies thereof, \nincluding all attachments. \n2694 \nEFTA00225417\n", "char_count": 1610}, {"efta_number": "EFTA00225378", "page_number": 40, "text_content": "EXHIBITS TO WRITTEN RESPONSE OF A. MARIE VILLAFANA \nExhibit # \nDate \nDescription \nI \n5/1/2006 Letter from Chief Rcitcr to State Attorney Krischer \n2 \n5/23/2006 File Opening Documents \n3 \n7/3/2007- \n7/13/2007 \nEmails between Criminal Chief Matt Menchel and AUSA Villafaiia regarding plea \nnegotiations. \n4 \n7/31/2007 Tenn Sheet for Epstein Non-Prosecution Agreement \n5 \nUndated \nFile folder entitled 'Meeting Timeline' with contents \n6 \n7/24/2006 Letter from Chief Reiter to victims informing them of FBI investigation \n7 \n7/26/2006 South Florida Sun-Sentinel Article Regarding Chief Reiter's referral of case to FBI \n8 \n8/2/2007 \nLilly Ann Sanchez email to Matt Menchel with attached letter containing counter-\nproposal for plea to two years of 'supenised custody.' \n9 \n8/24/2006-\n10/24/2006 Entails betweenJim Eisenberg and Marie Villafana regarding #28 \n10 \n10/30/2006- \n10/31-2006 \nEmails between Marie Vitt:liana and Guy Lewis regarding Lewis respresentation \nof Epstein \nII \n11/8/2006- \nI/8/2007 \nEmails between Marie Villatana and Lilly Ann Sanchez regarding Sanchets \nrepresentation of Epstein \n12 \n8/4/2006 \nVictim Notification Letters \n13 \nWI1/2006 Victim Notification Letters \n14 \n1/17/07- \n2/1/07 \nCorrespondence between Lilly Ann Sanchez, Gerald Lelcourt, Andrew Laurie, \nA. Marie Villafrina, and John McMillan regarding 2/1/2007 Meeting \n15 \n11/13/06-\n1/22/07 \nSubpoenas to Adrian Mucinska and research re 6001 immunity \n16 \n9/26/2006 Memo regarding Changes to Child Exploitation Statutes in Tide 18 \n17 \n2/6/2007 \nTranscript of Kuyrkendall Testimony \n18 \n2/27/2007 Transcript of Kuyrkendall Testimony \n19 \n3/15/2007 Victim Notification Letter \n20 \n3/20/2007 Transcript of Kuyrkendall Testimony \n21 \n4/24/2007 Transcript of Kiwrkendall Testimony \n22 \n4/24/2007 ' I 't a irseript of #37 Testimony \n23 \n5/8/2007 \nPresentation Materials \n24 \n5/8/2007 Transcript of Kuyrkendall Testimony \n25 \n5/8/2007 Transcript of Richards Testimony \n26 \n5/14/07-\n5/21/07 \nEmats between Andrew Laurie, Mau \n... [truncated, 2859 chars — for the full page use /api/corpus/document/EFTA00225378/40 or ?id=EFTA00225378&page=40]", "char_count": 2859}, {"efta_number": "EFTA00225378", "page_number": 41, "text_content": "EXHIBITS TO WRITTEN RESPONSE OF A. MARIE VILLAFANA \nExhibit 41 \nDate \nDescription \n33 \n7/6/2007 \nLetter from Gerald l.efcourt and Alan Dershonia toJeffrey Sloman and Andrei \nLonde arguing against federal prosecution. \n34 \n7/13/2007 Letter from Roy Black to Marie Villa' la with handwritten attorney Lourie notes \n35 \n7/25/2007 \nlatter from Gerald l.efrourt and Alan Dershowia to Matthew Menchel arguing \nthat no charge can or should be made under 18 U.S.C. S 2422(b). \n36 \n7/26/2007 \nEmail from Marie ViIlafaria to Matt Menchel and Andrew Lourie regarding \nproposed changes to indictment. \n37 \n7/27/2007 -\n8/8/2007 \nResearch regarding 18 U.S.C. S 2255 \n38 \n7/81/2007 \nEmail from Marie ViKaiak toJeff Molnar], Man Menchel, and Andrew Lourie \nsummarizing proposed plea terms as per Menchel recommendation \n39 \n7/81/07- \n8/3/07 \n7/31/2007.8/3/2007 Entails between Jeff Montan, Matt Moretti, Andrew Louric, \nand Marie VilLafaria regarding plea negotiations, including draft response to \nNutter counsel regarding proposed agreement \n40 \n8/2/2007 \nLetter front Lilly Ann Sanchez to Matthew Menchel containing counter-proposal \nof 2 years' supervised custody with two additional years of probation and internal \ncorrespondence regarding same. \nI I \n8/3/2007 \nLetter from Matthew Menchel to Lilly Ann Sanchez rejecting counterproposal, \nsetting a deadline of 8/17/2007, and advising that LISA Acosta was not inclined to \nmeet with counsel for Epstein, and internal entails regarding same. \nI.? \n8/6/2007 \nEntails from Marie Villafaila to Cyndee Campos, Frederica Devlin, and Jeff \nSloman to determine whether Malt Matchers 8/3/2007 letter went out before he \nresigned from the U.S. Attorney's Office. \n43 \n8/7/2007 \nEntails between Drew Oosterbaan, Andrew Laurie, Marie Villafafia, Alex Acosta, \nJeff Slontan, and Cyndee Campos regarding request front Epstein's counsel for \nmeeting with CEOS and background of case \nl 1. \n9/4/07- \n9/6/07 \nEntails betweenJeff Molnar', Marie Villafak, Andrew Laurie, Drew Oos\n... [truncated, 3050 chars — for the full page use /api/corpus/document/EFTA00225378/41 or ?id=EFTA00225378&page=41]", "char_count": 3050}, {"efta_number": "EFTA00225378", "page_number": 42, "text_content": "EXHIBITS TO WRITTEN RESPONSE OF A. MARIE VILLAFANA \nExhibit (t\nDate \nDescription \n52 \n9/24/2007 Signed non-prosecution agreement \n53 \n6/18/2007 Letter to Gerald Lefcourt re subpoena to NES, LLC and Jute 26, 2007 meeting \n54 \n5/21/2007 Email regarding guidance on grand jury presentation \n55 \n12/3/2007 \nEntails from Marie VillafaLfia to Alex Acosta regarding research on proposed trust \nfund. \n56 \n3/22/2007 \nEntails between Marie Villafafia and IRS supervisor regarding money laundering \nresearch \n57 \nCase regarding nunicy laundering and aiding & abetting \n58 \n2/12/2007 \nEntails between l'illafafia and Lilly Ann Sanchez regarding employee \nrepresentation with Lourie and Villafafia handwritten notes \n59 \n5/21/2007 Subpoena to Paul A. Lavery \n60 \n6/18/2007 Subpoena to Witham Riley \n61 \n«18/2007 Subpoena to Riley Kiraly \n62 \n7/18/2007 \nEmail from Villafaita to Matt Menthe! regarding Roy Black objection to \nsubpoenas addressed to William Riley and Riley Kiraly \n63 \n7/19/2007 Entails between A/Malaita, Menthe!, and Loire regarding service of target letters. \n64 \n7/26/2007 \nEmail from Villarafia to Man Menthe) and Andrew Londe regarding \nreconunended revisions to indictment \n65 \n8/1/2007-\n8/2/2007 \nEntails between Menthe! and Villakdre regarding plea negotiations \n66 \n9/10/2007 \nProposed Non-Prosecution Agreement provided to Gerald Leleourt on \n9/10/2007 \n67 \n9/11/2007 \nProposed Non-Prosecution Agreement incorporating Acosta edits provided to \nGerald Lefeourt on 9/11/2007 \n68 \n6/18/2008- \n6/19/2008 \nEntails between Villafafia, Krischer, Atkinson, Senior, Acosta, Sloman. and \nGarcia regarding Epstein's case with state court and how it might breach the NPA \n69 \n12/14/2007 Draft letter to Kriseher front Acosta regarding Epstein filing as sex oftender \n70 \n9/16/2008- \n9/17/2008 \nEntails between Villarafia, Krischer, Belohlavek, Garcia, Sloman, and Atkinson \nregarding Palm Beach Daily News requesting copy of the NPA and discussion \n71 \n«30/2008 Entail front Drew Oosterbaan rc Epst\n... [truncated, 2999 chars — for the full page use /api/corpus/document/EFTA00225378/42 or ?id=EFTA00225378&page=42]", "char_count": 2999}, {"efta_number": "EFTA00225378", "page_number": 43, "text_content": "EXHIBITS TO WRITTEN RESPONSE OF A. MARIE VILLAFANA \n&hint # \nDate \nDescription \n79 \n6/27/2008 \nEntail from 3rillafaita to Montan summarizing conversation with Goldberger that \nEpstein would serve sentence in confinement '24-bouts-a-day \n80 \n6/29/2008 Email from Kuyrkendall to Villafana regarding work release \n81 \n7/3/2008 \nEmail from Villafiula to Sloman providing update on meeting with Col Gauger at \nPBSO regarding work release \n82 \n11/20/2008. \n1 iip2 mow \nEntails between Villafafia, Senior, Acosta, Slontan, Atkinson, and Garcia \nregarding Epstein work release \n83 \n12/9/2008 Research materials regarding Epstein's work release application \n84 \n12/11/2008 \nVilLiana letter to Capt. Sleeth, Palm Beach Sheriffs Office, mganling Epstein's \nwork release application \n85 \n6/9/2009 \nVadatla Memorandum to Sloman, Senior, Garcia, awl Atkinson seeking \npermission to declare breach with attachments awl proposal breach letter \n86 \n6/9/2009 Signed indictment package \n87 \n6/12/2009 Villafaiia letter to Goldberger providing notice of breach of NPA \n88 \n6/15/2009 \nVillafana letter to Lclkowitz, Black, and Goldberger regarding history of Epstein's \nperformance under the NPA \n89 \n6/17(2009 \nVillafaila letter to Lelkowitz regarding monitoring future performance under the \nNPA \n90 \n9/1/2009 \nBlack letter to Montan seeking approval for Epstein to transfer community control \nto the Virgin Islands \n91 \n9/18/2009 \nVillafaila letter to Black explaining Olfwe's concerns about Epstein's application \nfor transfer to the Virgin Islands \nA-1 \nTimeline of Events \nB-1 \nChart addressing Question B.2 \n11-2 \n11/19/2007 Plea notification letter datal 11/19/2007 \nB-3 \n11/27/2007 \nPlea notification letter dated 11/27/2007 at 7:11 pm (formatting problem \nconvening from Word Perfect) \nB-4 \n11/28/2007 Victim notification letter prepared II/28/2007 at 9:42 pm \nB-5 \n12/1/2007 Victim notification letter prepared 12/1/2007 at 7:50 pm \n1.6 \n12/7(2007 Victim notification letter prepared 12/7/2007 at 9:10 pm (form\n... [truncated, 2733 chars — for the full page use /api/corpus/document/EFTA00225378/43 or ?id=EFTA00225378&page=43]", "char_count": 2733}, {"efta_number": "EFTA00225378", "page_number": 44, "text_content": "EXHIBITS TO WRITTEN RESPONSE OF A. MANE VILLAFAHA \nExhibit # \nDale \nDescription \nB-14 \n12/7/2007 Victim notification letters and envelopes that were never sent \n13-15 \n12/7/2007 Letter from Lilly Ann Sanchez with 1/4/2008 plea date \n13-16 \n12/14/2007 \nDraft Victim Notification Letter prepared I WI4/2007 at 9:57 pm (formatting \nproblem) \n13-17 \n12/14/2007 \nEmail from Marie Villafana to Alex Acostadcff Sloman, Rolando Garcia, and \nKaren Atkinson with victim letter attached \nB-18 \n12/17/2007 \nEmail from Marie Villafana to Jeff Sloman reiterating concerns about failure to \nnotify victims \n13.19 \n12/19/2007 \nEntails between Alex Acosta,JeffSloman, and Marie Villafafta with draft and final \nletter to Lilly Ann Sanchez, including promise not to provide victims with notice \nof state change of plea hearing. \n13-20 \n19/11/2007 \nEmail from Marie Villafana toJeff Sloman and Alex Acosta regarding call with \nJim Eisenberg \n13.21 \n12/21/2007 Letter from Jay Lefkowitz to Alex Acosta re wanting to sec victim list \nB.22 \n12/26/2007 \nLetter from Jay Lelkowitz. to Alex Acosta re right to review victim notification \nletter and belief that it should come from State Attorney's Office \n13.23 \n3/10/2008. \n3/12/2008 \nEntails regarding Epstein attempts to contact victims and finding counsel for \nvictims \n13-24 \n5/15/2008 \nLetter from Drew Oosterbaan toJay Lelkowitz denying challenge to federal \nprosecution \n13.25 \n3/14/2008 Revised indictment package \nB-26 \n3/18/2008 Grand jury presentation materials and transcript \n13-27 \n3/14/2008 \nEntails between Marie Villafana, Rolando Garcia, Karen Atkinson, Frederica \nDevlin, and Shawn Ball rc complete indictment package for Robert Senior review \nB-28 \n3/28/2008 Letter from Ken Starr to DAAG SW Mandelker with additional objections \nB-29 \n4/29/2008 Summary chart and outline for grand jury presentation \nB-30 \n4/29/2008 Draft Indictment \n15-31 \n10/9/2007- \n3/25/2008 \nFBI Interview Reports of— (10/05/2007, 3/20/2008, and 3/25/2008), #2 \n(10/10/2007), #14 (\n... [truncated, 3168 chars — for the full page use /api/corpus/document/EFTA00225378/44 or ?id=EFTA00225378&page=44]", "char_count": 3168}, {"efta_number": "EFTA00225378", "page_number": 45, "text_content": "EXHIBITS TO WRITTEN RESPONSE OF A. MARIE V1LLAFANA \n&Wait # \nDate \nDescription \nB-40 \n5/29/2008 \nEmail from Jell Sloman to Marie Villafafta, Bob Senior, Karen Atkinson, E. \nNesbitt KtnTkendaII, and Jason Richards informing them that l)AG Filip agreed \nto review matter and that grand jury presentation was canceled \n13-41 \n8/28/2008 \nLetter front Michael Danchuk to Marie Villafaila regarding victim representation \nand filing suit against Epstein in state court \n13-42 \n4/9/2008 Mai is Villafana letter to Richard II. Willits (formatting problem) \n13-43 \n6/18/2008 Marie Villalana handwritten notes re calls with Brad Ed wards and Roy Black \nB-44 \n6/23/2008 John Roth letter to Kan Starr and Jay Lelkowitt \n13-45 \n6/24/2008 Em.ias between Roy Black, Jack Goldberger, and Marie Villafaiia re wrap up \n13-46 \n6/25/2008 \nEmail from Jcff Montan to Marie Villafafia regarding conversation about 225.5 \nissue and enui of guilt' plea \n1147 \n6/25/2008 \nEmail from Jeff Sloman to Marie %Adana with attached revised victim \nnotification letter \n13-48 \n6/25/2008 \nEntails between Marie Villafaila,JcITSIontan, Bob Senior, Karen Atkinson, and \nAlex Acosta regarding draft of notification of victim list for Jeffrey Epstein counsel \nwith attached drafts \n13-49 \n6/23/2008 \nEntails betweenJeff Sloman, Bob Senior, and Marie Vitt& instructing Marie \nVillafana to inform Epstein's attorneys that lie had untiLlune 30 to enter a guilty \nplea and Villafaita email to Lelkowitz re same. \n13-50 \n6/26/2008 Fax from FBI with final victim list \nB-51 \n6/27/2008 Confirmation from police and Epstein's counsel of plea on 6/30/2008 \n13-52 \n6/27/2008 Email from Villafaiia to Sloman inquiring about conversation with Chief Reiter. \n13-53 \n6/28/2008 \nEntails between Villafafm andJeff Montan regarding Chief Reiter providing \nnotifications to victims. \nB-54 \n1W7 /2007 \nEmail fmmJeff Montan to Marie Villafana instructing her not to send victim \nnotification letter \n13-55 \n6/30/2008 \nNotes from calls with attonwys M. Danchuk\n... [truncated, 2984 chars — for the full page use /api/corpus/document/EFTA00225378/45 or ?id=EFTA00225378&page=45]", "char_count": 2984}, {"efta_number": "EFTA00225378", "page_number": 46, "text_content": "EXHIBITS TO WRITTEN RESPONSE OF A. MARIE VILLAFANA \nExhibit # \nDate \nDescription \n11-61 \n7/10/2008 Letter fromJack Goldberger to Marie Villafana requesting list of all victims \n11-65 \n7/10/2008 \nEmail from Jeff Sloman to Marie Villafafta, Alex Acosta, Karen Atkinson, E \nNesbitt Kuyrkendall, and Jason Richards regarding proposed response to Jack \nGoldberger \n15-66 \n7/9/2008 \nVictim Notification Letters to inditiduals #35 and 43 \n13-67 \n7/10/2008 Victim Notification Letters to individuals #3, 8, 17, 25, 26, 37, and I I \nB-68 \n7/14/2008- \n7/15/2008 \nEmails between Marie Villafana, E. Nesbitt Kuyrkendall,Jason Richards. and \nTwiler Smith re FBI victim notifications \n15-69 \n7/18/2008- \n7/21/2008 \nEmails between Marie Villafana, Jeff Montan, E. Nesbitt Kuyrkendall, Jason \nRichards, Dexter Lee, and Karen Atkinson rc preparation of victim notificatiot I \nletters and victim contact list and victims that Miler still needs to make contact \nwith \n13-70 \n7/21/2008 Victim Notification Letters to individuals NI, 2, 4, 9, IS, 14, 21, 23, 30, 32, and 38 \nB-71 \n8/5/2008 \nEmail from Marie Villafaffa to Alex Acostajeff Montan, Bob Senior, and Karen \nAtkinson regarding analysis ofJeffrey Epstein agreement, with attached 6/24/2008 \nemail from A. M. Villafafia to R. Black midi. Goldberger and attached Epstein \nagreement \n13-72 \n8/5/2008 \nEmail from Alex Acosta to Marie Villafatla, Bob Senior, Jeff Simian, Dexter Lee, \nand Karen Atkinson with attached suggestions to Superseding Non-Prosecution \nAgreement \n13-73 \n8/7/2008 \nEmail from Roy Black to Marie Villafana responding to 8/7/08 email providing \nnotification of possible compelled disclosure of the Non-Prosecution Agreement \nB-74 \n8/6/2008 \nEmail response from Bob Senior to Marie Villafaila regarding Roy Black's \nresponse to email \nB-75 \n8/12/2008 \nEmail response from Bob Senior to Marie Villafana to request for conference call \nprior to call with Roy Black \nB-76 \n8/13/2008 \nEmail from Bob Senior to Karen Atkinson, Alex Acosta, Jeff Mont\n... [truncated, 3196 chars — for the full page use /api/corpus/document/EFTA00225378/46 or ?id=EFTA00225378&page=46]", "char_count": 3196}, {"efta_number": "EFTA00225378", "page_number": 47, "text_content": "EXHIBITS TO WRITTEN RESPONSE OF A. MARIE VILLAFANA \nExhibit # \nDate \nDescription \nB-83 \n8/15/2008 Letter from Marie Villafaiia to Jay Lelkowitz and Roy Black re terms of NPA \n8-84 \n8/18/2008 Letter fromJay tellowitz to Marie Villafana regarding restitution \nB-85 \n8/21/2008 \nLetter from Marie Villafaila to Jay I elkowilz and Roy Black re Special Master and \ndraft Notification of Identified Victim \nB-86 \n8/22/2008 \nLetter from lay Lelkowitz to Marie Villafana regarding misstatements in 8/21/08 \nVilliditIR letter \nB-87 \n8/26/2008 Letter from Marie Villafaila to Jay Lelkowitz and Roy Black re victim's list \n8-88 \n9/2/2008 \nLetter from Jay Lclkowitz to Marie Villafana agreeing that Goldberger should be \nlisted as the contact person for civil suits and re victim representativeJosefsberes \nfees \nB-89 \n9/2/2008 \nMailed Amended Victim Notification letters to #1 )12, #3 (via Richard H. Willits), \n#4, #13, #8 friaJeffrey Herman), #9, #10, #11, #14, #16, #I7 (via Theodore \nLeopold), #20, #21, #23, #24, #25 (viaJelfrey Herman), #26 biaJellity Herman), \n#30, #31, #32, #33, #37 (via Michael E. Dutko), #38, #44 biaJeffni Herman) \n8-90 \n9/W2008 \nVictim notification letters to #36, #35 (via Brad Edwards), #42, #43 (via Brad \nEdwards) \nB-9I \n9/12/2008 Notification of Identified Victim letter #39 \nB-92 \n9/15/2008 Mailed victim notification letters for #I8 and #32 \n15-93 \n9/17/2008-\n11/4/2008 Entails and coorespondence with 'Ilie Florida Bar re victim notifications \nB-94 \n11/14/2008 Notification of Identified Victim letters to #20, #40 \n13-95 \n12/4/2008 \nEmail from Karen Atkinson to Marie Villafaila in response to draft letter notifying \nvictims of Epstein's work release \nB-96 \n12/5/2008 \nEmail from Marie Villafaila to victim's attorneys with attached Work Release \nNotice \n15-97 \n12/8/2008 \nNotification of NVotk Release letters to Spencer Kuvin,Jack Scuola, Michael \nDutko, #11,1439 and #40 \nB-98 \n12/9/2008 \nNotification of Work Release letters to #4, #10, #16, #I8, #23, #24, #33, #38, #\n... [truncated, 3210 chars — for the full page use /api/corpus/document/EFTA00225378/47 or ?id=EFTA00225378&page=47]", "char_count": 3210}, {"efta_number": "EFTA00225378", "page_number": 48, "text_content": "EXHIBITS TO WRITTEN RESPONSE OF A. MARIE VILLAFANA \nExhibit It \nDate \nDescription \nB-106 \n1/I7/2008 Agents compile evidence for Bob Senior indictment review \nB-107 \n1/25/2008 \nEmail chain between Myesha Braden and Marie Villafafia regarding victim's \nnames in indictment \nB-108 \n1/31/2008 Additional grand jury subpoenas \nB-109 \n1/28/2008• \n2/1/2008 \nEntails between Marie Villafana,Jeff Sloman, Alex Acosta, Nesbit Kuyrkendall, \nJason Richards, and Alan Santiago regarding results of additional victim-witness \ninterviews and requesting intervention with CEOS to move review process along \nB-I 10 \n2/12/2008- \n2/22/2008 \nEntails between Marie Villafana, E. Nesbitt Kuyrkendall, Jason Richards, and \nMyesha Braden re information for indictment/ongoing investigation \nB-111 \n2/20/2008- \nW21/2008 \nEntails between Drew Oosterbaan, Marie Villatana, Robert Senior,Jeff Montan, \nSigal Mandelker, Karen Atkinson, Alex Acosta, Rolando Garcia and Myesha \nBraden regarding status of CEOS plans to meet with counsel for Epstein and \nstatus of indictment review \nB-112 \n245/2008 \nEmail chain between Marie Villafana and Caroline \nregarding use of Grand \nJury \nB-113 \n2/25/2008 \nEmail from Marie Villafafia toJeffSlontan, Bob Senior, Rolando Garcia, Karen \nAtkinson, and Myesha Braden re staying with same grand jury or present to a \ndifferent gnmd jury \n13-114 \n2/26/2008 \nEmail front Marie Villatana to Myesha Braden re CEOS independent review and \nconcern about victim's mulles being released \nB-115 \n2/26/2008 \nEmail response from Marie Villatalia to Jeff Sloman and Bob Senior with \nconcerns regarding allowing Epstein to keep the same deal as before \n13-116 \n2/27/2008 \nEmail chain between Marie Villatana, David Weinstein, and Bob Senior re email \nto the Civil Rights Chief \nB-117 \n2/2W2008 \nEmail chain between Marie Villatanajason Richards, and E. Nesbitt Kuyrkendall \nregarding further investigation \nB-118 \n2/29/2008 \nEntails betweenJeff Montan, Marie Villatafia, Robert Senior, and David \nWeinstein r\n... [truncated, 3171 chars — for the full page use /api/corpus/document/EFTA00225378/48 or ?id=EFTA00225378&page=48]", "char_count": 3171}, {"efta_number": "EFTA00225378", "page_number": 49, "text_content": "EXHIBITS TO WRITTEN RESPONSE OF A. MARIE VILLAFASA \nExhibit N \nDate \nDescription \n5/15/2008- Entails between Marie Villafana, Karen Atkinson. Bob Sentor,JeliSloman. am I \n13-125 \n5/27/2008 agents regarding indictment review and status of investigation \n13-126 \n5/30/2008 FBI-302 of 5/28/08 Interview of Individual #35 \n6/2/2008 4:25 pm Draft letter from Jeff Sloman to Deputy Attorney General \n13-127 \n6/2/2008 Mark Hip \n6/3/2008 10:40 am Draft letter fromJcff Sloman to Deputy Attorney General \nB-128 \n6/3/2008 Mark Hip \nEntails between Villafana and Kuyrkendall re subpoena issued to victimfwitness \n13-129 \n6/6/2008 \nand need for additional subpoenas \n13-130 \n6/17/2008 Application for 6001 immunity for grand jury witness \nLetter from Matthew W. Friedrich, Acting Assistant Attorney General. \nB-131 \n6/24/2008 authorizing application for a court order granting 6001 int:marl \nB-B2 \n6/20/2008 Request to travel to \nYork for witness interviews in June 2008 and subpoena \nEntails between A. Marie Villafaria, E. Nesbitt Kuyrkendall, J. Richards, K. \nAtkinson, and R. Senior regarding grand jury time, witness subpoena, and \nB-133 \n6/23/2008 indictment \n6/23/2008- Entails between Marie Villalirna and attorney for grand jury witness regarding \n1 t-I34 \n6/26/2008 immunity and travel for grand jury appearance \nEntails between Marie Villafana and attorney for grand jury witness withdrawing \n13-135 \n6/30/2008 subpoena \nc'- i \n1/31/2008 Email from Marie Villafana to Jeff Mon tan and Alex Acosta regarding victims \nEmail chain between Marie Villafana, David Weinstein,Jeff Montan, Bob Senior, \nKaren Atkinson, and Rolando Garcia with Epstein update from grand jury \npresentation and grant front theJustice Department to provide legal \nC-2 \n3/19/2008 representation to victims \n3/19/2008-\nC-3 \n3/22/2008 rattails regarding victims being harassed by Epstein's investigators \nDraft of entail to be sent to Jeff and Matt stating that Villalana disagrees with \npromising to have a meeting with Lel-court o\n... [truncated, 2809 chars — for the full page use /api/corpus/document/EFTA00225378/49 or ?id=EFTA00225378&page=49]", "char_count": 2809}, {"efta_number": "EFTA00225378", "page_number": 50, "text_content": "EPSTEIN INVESTIGATION TIMELINE \nDate \nTo \nFrom \nRe: \nExhibit # \n5/1/2006 \nState Attorney \n• \nga y E \nB \n' \nKrischer \nMichael S. \n Reiter, Chief of \n Police for Town \nof Palm Beach \nLetter urging State Attorney to proceed with probable cause affidavits and cast \nfiling packages or to recuse himself \ni\n5/23/2006 \nFile Opening Documents for Operation Leap Year \n2 \n7/24/2006 \nMichael S. \nReiter, Chief of \nPolice for Town \nof Palm Beach \nLetter noting that Palm Beach Police Chief was unhappy with State Attorney's \nhandling of case and was referring matter to the FBI for investigation \n6\n7/26/2006 \nSouth Florida Sun-Sentinel Article Regarding Chief Reiter's referral of case to \nFBI \n_ \n8/2/2006 \nSubpoena to Colonial Bank (return date 8/18/06) \n8/2/2006 \nSubpoena to Washington Mutual (return date 8/18/06) \n8/2/2006 \nSubpoena to Capital One (return date 8/18/06) \n8/2/2006 \nSubpoena to Chase (return date 8/18/06) \n8/2/2006 \nSubpoena to Hyperion Air, Inc. (return date 8/18/06) \n8/2/2006 \nSubpoena to JEGE, Inc. (return date 8/18/06) \n8/2/2006 \nSubpoena to David Neville Rodgers (return date 8/18/06) \n8/2/2006 \nSubpoena to DTG Operations d/b/a Dollar Rent-a-car (return date 8/18/06) \n8/2/2006 \nSubpoena to Royal Palm Beach Community High School (return date \n8/18/06) \n8/2/2006 \nSubpoena to Custodian of Records 15th Judicial District (return date 8/18/06) \n8/4/2006 \nVictim Notification letters to Individuals #6, #9, #10, #11, #13, #15, #17, \n#18, #20, #23, #24, #25, #26, #27, #28, #29, #30, #31, #32, #38, #39, \n#41, #42, and #44 \n1 :! \n8/11/2006 \nVictim Notification letters to Individuals #4, #5, #6, #9, #12, #13, #15, #19. \n#26, #28, #29, #31, #32, #34, #38, #39, #43, and #44 \n8/15/2006 \nSubpoena to \n(withdrawn) (return date 8/25/06) \nPrivileged Confidential \nPage 1 of SI \nContains 6(e) Material \nCVUIDIT \nA 1 \nEFTA00225428\n", "char_count": 1841}, {"efta_number": "EFTA00225378", "page_number": 51, "text_content": "EPSTEIN INVESTIGATION TIMELINE \nDate \nTo \nFrom \nRe: \nExhibit # \n8/15/2006 \nSubpoena to Individual #4 (return date 8/25/06) \n8/15/2006 \nSubpoena to Individual #28 (return date 8/25/06) \n8/15/2006 \nSubpoena to Individual #44 (withdrawn) (return date 8/25/06) \n8/23/2006 \nSubpoena to Individual #4 (return date 9/1/06) \n8/23/2006 \nSubpoena to Individual #28 (return date 9/1/06) \n8/23/2006 \nSubpoena to Reimer Employment Agency (return date 9/1/06) \n8/23/2006 \nSubpoena to Evidence Custodian Palm Beach Police Department (return date \n9/1/06) \n8/24/2006 \nVillafalia \nJim Eisenberg Email re Individual #28 \n9 \n8/28/2006 \nSubpoena to Custodian of Records State Attorney's Office (return date \n9/15/06) \n8/28/2006 \nSubpoena to Custodian of Records 15th Judicial District (return date 9/15/06) \n9/13/2006 \nSubpoena to Good Samaritan Hospital (return date 9/22/06) \n9/21/2006 \nSubpoena to The Dalton School (return date 9/29/09) \n9/26/2006 \nAcosta, \nMulvihill, \nSloman, Noto, \nWaters, L°urie' \nStefin, Atkinson, \nGarcia, Brown, \nBoscovich, \nMartinez \nVillafaila \nMemo regarding changes to Child Explotation Statutes in Tide 18 \n16 \n10/19/2006 \nSubpoena to Individual #28 (return date 10/27/06) \n10/24/2006 \nEmail chain between Villafaiia and Jim Eisenberg discussing Individual #28 \n9 \n10/30/2006 \nVillafatia \nGuy Lewis \nEmail re representation of Jeffrey Epstein \n10 \n10/31/2006 \nVillafatia \nGuy Lewis \nEmail chain to set up call \n10 \n11/8/2006 \nLourie, Villafana ' \ncc: Menchel \nSloman \nEmail re Lilly Ann Sanchez/representation of Jeffrey Epstein\nPrivileged Confidential \nPage 2 of 51 \nContains 6(e) Material \nEFTA00225429\n", "char_count": 1618}, {"efta_number": "EFTA00225378", "page_number": 52, "text_content": "EPSTEIN INVESTIGATION TIMELINE \nDate \nTo \nFrom \nRe: \nExhibit # \n11/13/2006 \nSubpoena to Bill Hammond (pilot) (return date 12/1/06) \n11/13/2006 \nSubpoena to Larry Visoski (pilot)(return date 12/1/06) \n11/13/2006 \nSubpoena to Janusz Banasiak (property manager)(retum date 12/1/06) \n11/13/2006 \nSubpoena to Adriana Mucinska (former assistant) (return date 12/1/06) \n15 \nI 1/15/2006 \nA. Marie \nVillafalia \nLilly Ann \nSanchez \nGerald Lefcourt from New York and Lilly Ann Sanchez will be dealing with \nthe U.S. Attorney's Office in the Jeffrey Epstein matter \n1 1 \n11/16/2006 \nLilly Ann \nSanchez \nA. Marie \nViilafan_a \nRequest for documents and information necessary to the investigation \n11/17/2006 \nSubpoena to Extra Touch Flowers (return date 2/6/07) \n11/21/2006 \nLilly Ann \nSanchez \nA. Marie \nVillafaria \nRequesting a meeting to discuss 11/16/06 letter \n11 \n11/29/2006 \nLilly Ann \nSanchez \nA. Marie \nVillafafia \nAUSA Villafatia will be out of district and will not be available for meeting \nduring the proposed dates, but will schedule the meeting when she returns. \n1 1 \nI 2/1/2006 \nA. Marie \nVillafalia \nLilly Ann \nSanchez \nWill check on the document requests and will schedule the meeting in the new \nyear. \n11 \n12/18/2006 \nSubpoena to Janusz Banasiak (property manager) (return date 1/12/07) \n12/18/2006 \nSubpoena to \n(former assistant) (return date 1/12/07) \n15 \n12/18/2006 \nSubpoena to Anthony Figueroa (return date 1/12/07) \n1/5/2007 \nA. Marie \nVillafatia \nLilly Ann \ncl. inchez \nRequest for dates and times to schedule meeting \n11 \n1/8/2007 \nLilly Ann \nSanchez \nA. Marie \nVaifan_a \nRequest for documents prior to setting meeting \n1 \n1/17/200-\nLilly Ann \nSanchez \nAndrew Lourie \nClient wants to cooperate with the investigation, but requests for documents \nwere overly broad. Provided shortened and narrowed list and request for \ndocuments to be provided by 1/25/07, so they could be reviewed prior to \n2/1/07 meeting. \n14 \nPrivileged Confidential \nPage 3 of 51 \nContains 6(e) Material \nEFTA0022\n... [truncated, 2005 chars — for the full page use /api/corpus/document/EFTA00225378/52 or ?id=EFTA00225378&page=52]", "char_count": 2005}, {"efta_number": "EFTA00225378", "page_number": 53, "text_content": "EPSTEIN INVESTIGATION TIMELINE \nDate \nTo \nFrom \nRe: \nExhibit # \n1/18/2007 \nA. Marie \nVillafaiia \nLilly Ann \nSanchez \nBecause of the Palm Beach Police Department and the State Attorney's \n. \ninvestigation for almost two years, Epstein hired counsel for all employees so \ncontact Ms. Sanchez for contact information for the attorneys. \n14 \nI /22/2007 \nAndrew Lourie \nSanchez \nLooking forward to the 2/1/07 meeting and expect to send documents \npreviously provided to the Palm Beach County State Attorney's Office by \n1/25/07. \nI I \n1/22/2007 \nResearch re NPAs and 6001 immunity \nI c \n1/23/2007 \nLilly Ann \nSanchez \nA. Marie \nNrillafafia \nRequest for a list of the individuals who have accepted Epstein's offer of \npayment for representation and the names of their attorneys. \n2/1/2007 \nA. Marie \nVillafafia \nGerald B. \nLefcourt \nTalking points and documents for 2/1/07 meeting \n4 \n2/5/2007 \nA. Marie \nVillafatia \nGerald B. \nLefcourt \nProduction of debit/credit card statement regarding Epstein's birthday and a \npurchase at Guys and Dolls made by Individual #18. \n2/6/2007 \nGrand Jury Testimony of E. Nesbitt Kuyrkendall \nI - \n2/12/2007 \nA. Marie \nVillafana \nLilly Ann \nSanchez \nEmails between Villafana and Lilly Ann Sanchez regarding employee \nrepresentation with Laurie and Villafana handwritten notes \n58 \n2/14/2007 \nSubpoena to Colonial Bank (return date 3/6/07) \n2/14/2007 \nSubpoena to Palm Beach National Bank (return date 3/6/07) \n2/14/2007\nSubpoena to Western Union (return date 3/6/07) \n2/14/2007 \nSubpoena to Western Union (return date 3/6/07) \n2/14/2007 \nSubpoena to JP Morgan Chase (return date 3/6/07) \n2/20/2007 \nMeeting (US: Andy Laurie, Marie Villafana, and Junior Ortiz, DEF: Lilly \nSanchez and Gerald Lefcourt) \n2/23/2007 \nA. Marie \nVillafaiia \nGerald B. \nLefcourt \nExcerpts of drafts of transcripts from recorded interviews of various witnesses \ntaken during state's investigation. \n2/27/2007 \nGrand Jury Testimony of E. Nesbitt Kuyrkendall \n18 \n3/2/2007 \nSubpoena to Thomas Rofrano\n... [truncated, 2352 chars — for the full page use /api/corpus/document/EFTA00225378/53 or ?id=EFTA00225378&page=53]", "char_count": 2352}, {"efta_number": "EFTA00225378", "page_number": 54, "text_content": "EPSTEIN INVESTIGATION TIMELINE \nDate \nTo \nFrom \nRe: \nExhibit # \n3/15/2007 \nVictim Notification letter to Individual #4 \n19 \n3/16/2007 \nSubpoena to Individual #29 (return date 3/27/07) \n3/20/2007 \nGrand Jury Testimony of E. Nesbitt Kuyrkendall \n20 \n3/20/2007 \nSubpoena to Individual #32 (return date 4/3/07) \n3/22/2007 \nVillafatia \nStefan Cassella Email re money laundering question \n56 \n4/4/2007 \nSubpoena to Individual #37 (return date 4/17/07) \n4/16/2007 \nSubpoena to Chase Bank USA, NA Atm: Jeff Sehr (return date 4/24/07) \n4/16/2007 \nSubpoena to Adult Video Warehouse (return date 5/1/07) \n4/16/2007 \nSubpoena to Eve's Garden (return date 5/1/07) \n4/17/2007 \nSubpoena to Individual #28 (return date 5/1/07) \n4/20/2007 \nSubpoena to Adult Video Warehouse (return date 5/1/07) \n4/24/2007 \nGrand Jury Testimony of Special Agent E. Nesbitt Kuyrkendall \n21 \n4/24/2007 \nGrand Jury Testimony of Individual #37 \n22 \n4/24/2007 \nSubpoena to New York Strategy Group, LLC Custodian of Records (return \ndate 5/8/07) \n4/24/2007 \nSubpoena to Hyperion Air, Inc. Custodian of Records (return date 5/8/07) \n4/24/2007 \nSubpoena to JEGE, Inc. (return date 5/8/07) \n5/8/2007 \nGrand Jury presentation materials \n23 \n5/8/2007 \nGrand Jury Testimony of E. Nesbitt Kuyrkendall \n24 \n5/8/2007 \nGrand Jury Testimony of Jason Richards \n25 \n5/10/2007 \nA. Marie \nVillafatia \nJack A. \nGoldberger \nResponse to subpoenas JEGE, Inc. and Hyperion Air, Inc.. \n5/14/2007 \nMarie Villafatia \nand Andrew \nLourie \nMatthew \nMenchel \nEmail re Operation Leap Year with email from Villafatia to Lourie and \nMenchel (5/14/07) attached \n26/C-5 \n5/15/2007 \nGrand Jury Testimony of Special Agent E. Nesbitt Kuyrkendall \n27 \n5/16/2007 \nSubpoena to American Express TRS Co., Inc. (return date 5/29/07) \n5/17/2007 \nA. Marie \nVillafafia \nJack A. \nGoldberger \nExtension of compliance deadlines until 5/29/07 for subpoena responses for \nJEGE, Inc. and Hyperion Air, Inc. \nPrivileged Confidential \nPage 5 of 51 \nContains 6(e) Material \nEFTA00225432\n", "char_count": 1994}, {"efta_number": "EFTA00225378", "page_number": 55, "text_content": "EPSTEIN INVESTIGATION TIMELINE \nDate \nTo \nFrom \nRe: \nExhibit # \n5/18/2007 \nMatthew \nMenchel \nA. Marie \nVillafatia \nEmail informing Menchel of intent to subpoena Roy Black's private \ninvestigator and steps taken to obtain DOJ authorization \n26 \n5/21/2007 \nMatthew \nMenchel and Jeff \nSloman \nA. Marie \nVillafatia\nEmail seeking guidance on grand jury presentation \n26/54 \n5/21/2007 \nSubpoena to Paul A. Lavery (return date 5/29/07) \n59 \n5/22/2007 \nAndrew Cootie \nGerald B. \nLefcourt \nLetter requesting to meet with Matthew Menchel and Jeffrey Sloman and \\ lc\\ \nAcosta prior to an indictment being filed \n28 \n5/22/2007 \nMatthew \nMenchel and Jeff \nSloman; cc: A. \nMarie Villafalia \nAndrew Laurie Email re letter received from Gerald Lefcourt discussing a meeting to discuss \nEpstein investigation \n5/22/2007 \nGrand Jury Testimony of Special Agent E. Nesbitt Kuyrkendall \n'() \n5/23/2007 \nKaren Atkinson \nA. Marie \nVillafaila \nDraft of email to be sent to Sloman and Menchel stating that Villafatia \ndisagrees with promising to have a meeting with Lefcourt or any of Epstein's \nother attorneys. Believes the prior meeting disclosed prosecution strategy and \nholding another meeting will disclose even more. If meeting is held, Villafaiii \nwill ask to have the case reassigned. Attached email correspondence between \nAndrew Laurie and G. Lefcourt \n28/C-4 \n5/31/2007 \nSubpoena to J. Epstein Virgin Islands Foundation, Inc. (return date 6/21/07) \n5/31/2007 \nSubpoena to J. Epstein & Company, Inc. (return date 6/21/07) \n5/31/2007 \nSubpoena to Epstein Interests (return date 6/21/07) \n5/31/2007 \nSub_poena to Financial Trust Company, Inc. (return date 6/12/07) \n5/31/2007 \nSubpoena to Royal Palm Beach Community High School (return date \n6/12/07) \n6/1/2007 \nGerald B. \nLefcourt \nA. Marie \nVillafaiia \nSubpoenas for J. Epstein Virgin Islands Foundation, Inc., J. Epstein & Co., \nInc., Epstein Interests, and Financial Trust Company, Inc. \n6/1/2007 \nFolder entitled \"(Victims) Additional 302's\" containing reports\n... [truncated, 2146 chars — for the full page use /api/corpus/document/EFTA00225378/55 or ?id=EFTA00225378&page=55]", "char_count": 2146}, {"efta_number": "EFTA00225378", "page_number": 56, "text_content": "EPSTEIN INVESTIGATION TIMELINE \nDate \nTo \nFrom \nRe: \nExhibit # \n6/7/2007 \nVictim Notification letters to Individuals #3, #9, #31, #38, #40, and #43 \n30 \n6/7/2007 \nSubpoena to Park A. Cadillac Limo Service (return date 6/26/07) \n6/11/2007 \nSubpoena to Individual #40 (return date 6/26/07) \n6/11/2007 \nSubpoena to All Star Taxi and Limo Service (return date 6/26/07) \n6/11/2007 \nSubpoena to Airport Executive Towncar Service Dan Tischler (return date \n6/26/07) \n6/12/2007 \nA. Marie \nVillafafia \nGerald Lefcourt \nProduction response to 5/31/07 subpoenas to J. Epstein Virgin Islands \nFoundation, Inc., J. Epstein & Co., Inc., Epstein Interests, and Financial Trust \nCompany, Inc. \n6/13/2007 \nSubpoena to Majestic Theatre (return date 6/06/07) \n6/13/2007 \nSubpoena to Broward Center for the Performing Arts (return date 6/26/07) \n6/13/2007 \nSubpoena to Kravis Center for the Performing Arts (return date 6/26/07) \n6/14/2007\n31 \n6/14/2007-6/21/2007 Emails between Marie Villafaiia, Karen Atkinson, \nAndrew Lourie, Matt Menchel, and Jeff Sloman regarding addendum to Pros \nMemo, grand jury presentation and changes to indictment, and meeting with \ncounsel for Epstein \n6/18/2007 \nGerald B. \nLefcourt \nA. Marie \nVillafaiia \ntt\n. \nLeer thanking Lefcourt for accepting service of subpoena addressed to the \nCustodian of Records of NES, LLC and requesting acceptance of subpoena \nissued to New York Strategy Group, Inc. \n53 \n6/18/2007 \nSubpoena to William Riley (return date 7/10/07) \n60 \n6/18/2007 \nSubpoena to Riley Kiraly (return date 7/10/07) \n6I \n6/18/2007 \nSubpoena to NES, LLC (return date 7/10/07) \n6/21/2007 \nMatthew \nMenchel \nA. Marie \nVillafafia \nEmail re Meeting next week with emails from Menchel to Villafaiia (6/21/07) \nand Viliafaiia to Menchel (6/21/07) attached \n, \n6/22/2007 \nSubpoena to Guys and Dolls (return date 7/10/07) \n6/25/2007 \nJeffrey Sloman \nand Andrew \n_ \nLourie \nGerald B. \n12fcourt \nLetter containing overview of position of Epstein's counsel and the materials \nplanned to pres\n... [truncated, 2150 chars — for the full page use /api/corpus/document/EFTA00225378/56 or ?id=EFTA00225378&page=56]", "char_count": 2150}, {"efta_number": "EFTA00225378", "page_number": 57, "text_content": "EPSTEIN INVESTIGATION TIMELINE \nDate \nTo \nFrom \nRe: \nExhibit # \n6/25/2007 \nMan Mcnchel \nand Marie \nVillafatia \nAndrew Lourie Email entitled \"Thoughts on Lefcourt's letter\" \n32 \n6 /26/2007 \nMeeting (US: Jeff Slotnan, Matt Manche', Marie Villafaila, Junior Ortiz, \nNesbitt Kuyrkendall, DEF: Alan Dershowitz, Roy Black, Gerald Lefcourt and \nLilly Sanchez) \n6 2- 2007 \nSubpoena to Live Nation Theatrical/Broadway Across America (return date \n7/10/07) \n7/1/2007 \nSanchez, \nLefcourt \nVillafana \nEmail re oustanding subpoenas and planned meeting for 7/11/07 \n7/3/2007 \n7/3/2007-7/13/2007 Email chain between Matt Menchel and Marie Villafalia \nregarding disagreement on Menchel's plea negotiations and written request for \nmeeting between USAO management and victims \n3 \n7/3/2007 \n7/3/2007-7/4/2007 Emails between Marie Villafaiia and Andrew Lourie \nregarding extension of time to respond to subpoenas requested by Lilly Ann \nSanchez and possible resolution of case \n7/6/2007 \nJeffrey Sloman \nand Andrew \nLourie \nGerald B. \nLefcourt and \nAlan \nDershowitz \nFollow-up letter to 6/26/07 meeting including facts, law, and policy that \nshould inform any decision made on how and whether to proceed \n33 \n7/13/2007 \nVillafaila \nRoy Black \nLetter with handwritten attorney (Lourie) notes \n34 \n7/13/2007 \nMatthew \nMenchel \nA. Marie \nVillafana \nEmail re Epstein with email from Menchel (7/5/07), Villafana to Marche' \n(7/4/07) and Sloman to Villafana (7/3/07) attached \n3 \n7/16/ 2007\nBlack \nVillafatia \nResponse to letter regarding subpoena to Paul Lavery for computer equipment \nremoved from Epstein's residence \n7/16/2007 \nMatt Menchel \nand Andrew \nLourie \nA. Marie \nVillafatia \nEmail regarding correspondence from Roy Black and Motion to Quash Lavery \nsubpoena \n7/17/2007 \nMotion of Jeffrey Epstein to Intervene and Quash Grand Jury Subpoenas and \nIncorporated Memorandum of Law \nPrivileged Confidential \nPage 8 of 51 \nContains 6(e) Material \nEFTA00225435\n", "char_count": 1942}, {"efta_number": "EFTA00225378", "page_number": 58, "text_content": "EPSTEIN INVESTIGATION TIMELINE \nDate \nTo \nFrom \nRe: \nExhibit # \n7/17/2007 \nAffidavit of Roy Black, Esq., in Support of Motion of Jeffrey Epstein to \nIntervene and to Quash Grand Jury Subpoenas and Incorporated \nMemorandum of Law \n7/18/2007 \nAndrew Laurie \nand Matt \nMenchel \nMarie Villafana Email from Villafafia to Matt Menchel regarding Roy Black objection to \nsubpoenas \nsubpoenas addressed to William Riley and Riley Kiraly \n7/19/2007 \nVillafana \nMille Levy \n(USAPAE) \nEmail regarding comments to Rule 16 about disclosing identifying information \nabout victims \n7/19/2007 \nEmail chain between Marie Villafaiia, Andrew Lourie, Matt Menchel, S/A \nJason Richards and S/A Eliasib Ortiz regarding potential service of target \nletters \n63 \n7/19/2007 \nPreparing Motion for Post-indictment protective order \n7/24/2007 \nSubpoena to Rachel Eve Lockwood (return date 8/14/07) \n7/25/2007 \nMatthew \nMenchel \nGerald B. \nLefcourt and \nAlan \nDershowitz \nDocument entitled: \"Data that strongly supports the arguments made that no\ncharge can or should be made under 18 U.S.C. § 2422(b)\" \n35\n7/26/2007 \nMatt Menchel \nand Andrew \nLaurie \nMarie Villafatia Email regarding proposed changes to indictment \n3e 6 I \n7/26/2007 \nMeeting where Criminal Chief Menchel announces that USA Acosta will offer \na two-year state plea. Present: Matt Menchel, Marie Villafafia, Andy Lowrie \n(phone), Valerie Parlave, Junior Ortiz, Nesbitt Kuyrkendall, and Jason \nRichards \n7/27/2007 \nResearch re 18 U.S.C. § 2255 \n37 \n7/31/2007 \nJeff Sloman, \nMatt Menchel, \nand Andrew \nLaurie \nMarie Villafafia Email summarizing proposed plea terms as per Menchel recommendation \n4 and 38 \n7/31/2007 \nMeeting (US: Jeff Sloman, Matt Menchel, Marie Villafatia, Andy Laurie, \nNesbitt Kuyrkendall and Jason Richards, DEF: Roy Black, Gerald Lefcourt \nand Lilly Sanchez) \nPrivileged Confidential \nPage 9 of 51 \nContains 6(e) Material \nEFTA00225436\n", "char_count": 1893}, {"efta_number": "EFTA00225378", "page_number": 59, "text_content": "EPSTEIN INVESTIGATION TIMELINE \nDate \nTo \nFrom \nRe: \nExhibit # \n7/31/2007 \nU.S. Response to Motion of Jeffrey Epstein to Intervene and to Quash Grand \nJury Subpoenas and Cross-Motion to Compel and Sealed Document Tracking \nForm with Sealed, Ex Parte Declarations \n7/31/2007 \n7/31/2007-8/3/2007 Email chain between Jeff Sloman, Matt Menchel, \nAndrew Lourie, and Marie Villafaiia regarding plea negotiations \n39 \n8/1/2007 \n8/1/2007-8/2/2007 Emails between Menchel and Villafaiia regarding plea \nnegotiations \n65 \n8/2/2007 \nMatthew \nMenchel \nLilly Ann \nSanchez \nAs discussed at meeting, Epstein is prepared to resolve the matter via state \nforum. Proposal of 2 years supervised custody with two additional years of \nreporting to probation \n8 and 40 \n8/2/2007 \nEmails between Matt Menthe', Jeff Sloman, Andy Louric, and Marie Villafana \nregarding letter received from Lilly Ann Sanchez \n40 \n8/3/2007 \nLilly Ann \nSanchez \nMatthew \nMenchel \n2 year term of incarceration is a non-negotiable minimum and U.S.Attomey \nAcosta is not inclined to meet with counsel for Epstein. Epstein must advise \nof his decision by 8/17/07. \n41 \n8/3/2007 \nMatt Menchel, \nAndrew Louie, \nJeff Sloman, \nKaren Atkinson \nMarie Villafaria Email regarding draft response to correspondence from Epstein counsel and \nplanned investigative steps if agreement cannot be reached \ni I \n8/6/2007 \nCyndee Campos, \nFrederica Devlin \nand Jeff Sloman \nMarie Villa feta Emails regarding Matt Menchel's correspondence prior to his departure \n; , \n8/6/2007 \nSubpoena to Individual #3 (return date 8/21/07) \n8/6/2007 \nSubpoena to Individual #43 (return date 8/12/07) \n8/7/2007 \nAndy Lourie \nMarie Villafana Email regarding deadline set for Epstein plea and Epstein's plan to demand a \nmeeting with CEOS \nI 1\n8/7/2007 \nEmail chain between Marie Villafalia, Cyndee Campos, and Alex Acosta \nregarding meeting to discuss Epstein matter \n41, \nPrivileged Confidential \nPage 10 of 51 \nContains 6(e) Material \nEFTA00225437\n", "char_count": 1967}, {"efta_number": "EFTA00225378", "page_number": 60, "text_content": "EPSTEIN INVESTIGATION TIMELINE \nDate \nTo \nFrom \nRe: \nExhibit # \n8/7/2007 \nEmail chain from Jeff Sloman to Andrew Oosterbaan, Marie Villafaiia, and \nAlex Acosta regarding Epstein meeting \n43 \n8/7/2007 \nReply of Jeffrey Epstein to United States' Response to His Motion to \nIntervene and to Quash Grand Jury Subpoenas and Cross-Motion to Compel \nand Sealed Document Tracking Form \n8/8/2007 \nAndrew \nOosterbaan \nMarie Villafaiia Email regarding plea negotiations, guideline calculations, and assistance in \npreparing case for trial \n43 \n8/8/2007 \nResearch re 18 U.S.C. § 2255 \n37 \n8/15/2007 \nSubpoena to Bear Stearns (return date 9/4/07) \n8/16/2007 \nSubpoena to Adam Perrylang (return date 9/4/07) \n8/16/2007 \nSubpoena to Lesley Groff (return date 9/4/07) \n8/16/2007 \nSubpoena to Jean-Luc Brunel (return date 9/4/07) \n8/16/2007 \nSubpoena to Harry Beller (return date 9/11/07) \n8/16/2007 \nSubpoena to Eric Gany (return date 9/11/07) \n8/17/2007 \nMotion of William Riley and Riley Kiraly for an Extension of Time Nunc Pro \nTunc to File Their Reply and Proposed Order \n8/17/2007 \nReply of William Riley and Riley Kiraly to the Government's Response to the \nMotion to Intervene and to Quash Grand Jury Subpoenas and Cross Motion \nto Compel \n8/23/2007 \nA. Made \nVillafaiia \nGerald Lefcourt Letter that he cannot accept service for Eric Gany \n8/28/2007 \nA. Marie \nVillafaiia \nNathan Z. \nDershowitz \nLeft messages with Sarah Kellen and \nto request if he can \naccept service on their behalf \n8/30/2007 \nJeff Sloman, \nAndrew Laurie, \nDrew \nOosterbaan, \nJohn McMillan, \nKaren Atkinson \nMarie Villa fana I imail regarding press coverage of meeting with Ken Starr \nPrivileged Confidential \nPage I I of 51 \nContains 6(e) Material \nEFTA00225438\n", "char_count": 1726}, {"efta_number": "EFTA00225378", "page_number": 61, "text_content": "EPSTEIN INVESTIGATION TIMELINE \nDate \nTo \nFrom \nRe: \nExhibit # \n8/30/2007 \nUnited States Surreply to Replies filed by Witness William Riley and \nIntervenor Jeffrey Epstein re Motion to Quash Grand Jury Subpoenas and \nScaled Document Tracking Form and Supplemental Ex Parte Declaration \n8/31/2007 \nMeeting (US: Drew Oosterbaan, Marie Villafalia, Nesbitt Kuyrkendall and \nJason Richards) \n9/4/2007 \nJeff Sloman \nMarie Villafaiia \n9/4/2007-9/6/2007 Emails between Jeff Sloman and Marie Villafalia \nregarding planned participation of FBI ASAIC at 9/7/07 meeting with \nEpstein defense team \n44 \n9/6/2007 \nA. Marie \nVillafaiia \nGerald 121Court Beller and Gany are represented by Nat Dershowitz. NES is working on\ngetting the extra documents requested and the certification. \n9/6/2007 \nNathan Z. \nDershowitz \nA. Marie \nVillafana \nQuestioning representation of Sarah Kellen and \n9/6/2007 \nNathan Z. \nDershowitz \nA. Marie \nVillafaiia \nSubpoena for Leslie Groff to appear for Grand Jury on 9/18/07 and \nanticipated topics \n9/6/2007 \nNathan Z. \nDershowitz \nA. Marie \nvigafana \nSubpoenas for Harry Beller and Eric Gany to appear before GJ on 9/11/07. \n9/7/2007 \n9:31 am draft Plea Agreement \n9/7/2007 \n9:43 am draft Non-Prosecution Agreement \n9/7/2007 \n1:15 pm draft Non-Prosecution Agreement \n9/7/2007 \n1:17 pm draft Plea Agreement \n9/7/2007 \nMeeting (US: Alexander Acosta, Drew Oosterbaan, Jeff Sloman, Marie \nVillafalia, and John McMillan, DFF: Kenneth Starr, Jay Lefkowitz, and Lilly \nSanchez) \n9/10/2007 \n5:17 pm draft Non-Prosecution Agreement \n9/10/2007 \nJ. Sloman \nA. Marie \nVillafaila \nEmail re negotiations \n46 \n9/10/2007 \nJ. Sloman, J. \nMcMillan \nA. Marie \nVillafaiia \nEmail re state grand jury proceedings \n45 \n9/10/2007 \nJeff Sloman, \nAndrew Laurie \nA. Marie \nVillafatia \nEmail re FBI \n45 \n9/10/2007 \nLefcourt \nVillafafia \nEmail with 4 page NPA attached (RFP3) \n47 \nPrivileged Confidential \nPage 12 of 51 \nContains 6(e) Material \nEFTA00225439\n", "char_count": 1944}, {"efta_number": "EFTA00225378", "page_number": 62, "text_content": "EPSTEIN INVESTIGATION TIMELINE \nDate \nTo \nFrom \nRe: \nExhibit # \n9/10/2007 \nProposed Non-Prosecution Agreement provided to Gerald Lefcourt on \n9/10/2007 \n66 \n9/10/2007 \n9/10/2007-9/11/2007 Emails between Marie Villafidia, Alex Acosta, and Jeff \nSloman regarding modifications to the proposed Non-Prosecution Agreement \n46 \n9/10/2007 \n9/10/2007-9/14/2007 Emails between Marie Villafatia, Andrew Lourie, Jeff \nSloman, Karen Atkinson, Rolando Garcia, Shawn Ball, and Alex Acosta \nregarding final plea negotiations, finalizing details with State Attorney's Office \nand final revisions to indictment package \n46 \n9/11/2007 \nA. Lourie \nA. Marie \nVillafatia \nEmail re meeting with G. Lefcourt with attached correspondence \n46 \n9/11/2007 \nA. Lourie \nA. Marie \nVillafaiia \nEmail re revised Agreement with attached correspondence \n46 \n9/11/2007 \nA. Marie \nVillafalia \n. \nA Lourie \nEmail re scheduling a meeting regarding finalizing the agreement with attached \ncorresondcnce \n46 \n9/11/2007 \nA. Marie \nVillafatla \nA. Oosterbaan Email re negotiations with attached correspondence \n48 \n9/11/2007 \nA. Marie \nVillafatia \nAndrew Lourie \nEmail regarding revised agreement - Plea to the 3 specified charges, a 30 \nmonth sentence, split 20 in jail and 10 in \"community control,\" and agree that \nthe girls are victims for purposes of damages. Also includes deadlines for a \nplea and sentencing date \n46 \n9/11/2007 \nA. Oosterbaan \nA. Marie \nVillafaiia \nEmail re status of negotiations with attached correspondence \n48 \n9/11/2007 \nLefcourt \nVillafatia \nEmail with 4 page NPA attached \n.1-\n9/11/2007 \nProposed Non-Prosecution Agreement incorporating Acosta edits provided to \nGerald Lefcourt on 9/11/2007 \n67 \n9/11/2007 \nEmails between Marie Villafatia, John McMillan, Drew Oosterbaan, Nesbitt \nKuyrkendall, and Jason Richards regarding changes to the draft indictment and \nstatus of plea negotiations \n46 \n9/11/2007 \n2:13 pm draft Non-Prosecution Agreement \nPrivileged Confidential \nPage 13 of 51 \nContains 6(e) Material \nE\n... [truncated, 2012 chars — for the full page use /api/corpus/document/EFTA00225378/62 or ?id=EFTA00225378&page=62]", "char_count": 2012}, {"efta_number": "EFTA00225378", "page_number": 63, "text_content": "EPSTEIN INVESTIGATION TIMELINE \nDate \nTo \nFrom \nRe: \nExhibit # \n9/12/2007 \nA. Marie \nVillafatia \nNathan Z. \nDershowitz \nMs. Groff will proceed by interview. \n9/12/2007 \nMeeting (US: Andy Lourie, Rolando Garcia and Marie Villafafia, DEF: Jay \nLefkowitz, Gerald Lefcourt and Jack Goldberger, STATE OF FLORIDA: \nBarry !Casket and Latina Belohlavek) \n9/12/2007 \nA. Marie \nVillafalia; cc: \nAndrew Lowrie \nJay Lefkowitz \nEmail in response to A. Marie Villafafia's email stating that the Office is \nsatisfied in principle with the agreement, but uncomfortable with the \nrecommended federal charge due to jurisdiction. Response states that defense \nunderstands the concerns and will work to come up with a mutually acceptable \nsolution. \n49 \n9/13/2007 \nA. Acosta, J. \nSloman, R. \nGarcia, K. \nAtkinson, A. \nLourie \nA. Marie \nVillafafia \nEmail re plea negotiations \n46 \n9/13/2007 \nA. Lourie \nA. Marie \nVillafatia \nEmail re plea negotiations with attached correspondence \ni6 \n9/13/2007 \nA. Lourie \nA. Marie \nVillafafia \nEmail re charging strategy with attached correspondence \n46 \n9/13/2007 \nA. Marie \nVillafatia \nA. Lourie \nEmail re final negotiations with attached correspondence \n46 \n9/13/2007 \nA. Marie \nVillafafia \nA. Oosterbaan Email re setting up trust fund \nk.< \n9/13/2007 \nA. Marie \nVillafaila \nJay Lefkowitz Misdemeanors 403, 1512(d) and 47 U S.0 223(a)(1)(B) \n4') \n9/13/2007 \nA. Marie \nVillafaiia \nLourie \nAssault on the plane or conspiracy \n46 \n9/13/2007 \nA. Oosterbaan \nA. Marie \nVillafaiia \nEmail re trust agreement with attached correspondence \n4S \nPrivileged Confidential \nPage 14 of 51 \nContains 6(e) Material \nEFTA00225441\n", "char_count": 1630}, {"efta_number": "EFTA00225378", "page_number": 64, "text_content": "EPSTEIN INVESTIGATION TIMELINE \nDate \nTo \nFrom \nRe: \nExhibit # \n9/13/2007 \nAndrew Lourie, \nAlex Acosta, Jeff \nSloman, Rolando \nGarcia, Karen \nAtkinson \nManic vfflafitha\nin\n1. ails regarding plea to federal charges recommending 18 U.S.C. 403 or \n1512g, or 47 U.S.C. 223(a)(1)(B); response that Epstein was only willing to \nplead to assault on the plane; and rejection of facts supporting assault on the \nplane charge \n46 \n9/13/2007 \nK. Atkinson, S. \nBak). McMillan \nA. Marie \nVillafatia \nEmail re indictment package \nIn \n9/13/2007 \nR. Garcia, J. \nslornan \nA. Marie \nVillafaria \nEmail re conference call with J. Lefkowitz \n46 \n9/13/2007 \nSubpoena to Wolf Camera (return date 9/25/07) \n9/13/2007 \n6:36pm draft Plea Agreement \n9/13/2007 \n6:55pm draft Information \n9/13/2007 \n9/13/2007-9/14/2007 Entails regarding Marie Villafaria research regarding \nvictim trust fund set up in Alaska child exploitation case \nt•-• \n9/13/2007 \nAdditions to pros memo/indictment - Individuals #3, #43, #38, #26, and \n#39 \n9/14/2007 \nA. Marie \nVillafaiia \nA. Loupe \nEmail re charging strategy with attached correspondence \n;6 \n9/14/2007 \nA. Marie\nviihfaria\nJay Lefkowitz requesting draft to include 403 in lieu of 1512 \n.1() \n9/14/2007 \nA. Marie \nVillafatia, A. \nAcosta , R. \nGarcia, A. \nLowrie, K. \nAtkinson, S. Ball \nJ. Sloman \nEmail re finalizing documents \n46 \nPrivileged Confidential \nPage 15 of 51 \nContains 6(e) Material \nEFTA00225442\n", "char_count": 1419}, {"efta_number": "EFTA00225378", "page_number": 65, "text_content": "EPSTEIN INVESTIGATION TIMELINE \nDate \nTo \nFrom \nRe: \nExhibit # \n9/14/2007\nJ. Sloman, A. \nAcosta, A. \nLourie, It. \nGarcia, K. \nAtkinson, J. \nMcMillan, S. Ball \nA. Marie \nVillafafia \nEmail re plea negotiations \nIn \n9/14/2007 \nLefkowitz \nVillafatia \nEmail - 1 page with two plea agreements attached, nine pages total \n;9 \n9/14/2007 \nVillafafia, \nAcosta, Garcia, \nLaurie \nSloman \nProposed plea agreement and information - Lourie will help finalize \n.16 \n9/14/2007 \n8:47 am draft Information \n9/14/2007 \n8:53 am draft Plea Agreement \n9/14/2007 \n9:38 am draft Information \n9/14/2007 \n9:48 am draft Plea Agreement \n9/15/2007 \n2:29 pm draft Information \n9/15/2007 \n2:46 pm draft Plea Agreement \n9/15/2007 \nLefkowitz \nVillafafia \nEmail with attached Information and Plea Agreement \n49 \n9/16/2007 \nLefkowitz \nVillafaila \nEmail re 11th Circuit cases on simple assault and found language with attached \nEpstein Plea Offer \n49 \n9/16/2007 \nVillafafia \nLefkowitz \nEmail with attached 5 page Agreement \n49 \n9/16/2007 \nEmail chain between Lefkowitz and Villabfia regarding changing the \ndocuments to 1512 and language in the plea agreement \n46 \n9/16/2007 \n12:00 pm draft Information \n9/16/2007 \n12:09 pm draft Plea Agreement \n9/16/2007 \n12:21_pm Lefkowitz proposed Agreement \n9/16/2007 \n4:42 pm draft Plea Agreement \n9/17/2007 \nA. Acosta \nA. Marie \nVillafafia \nEmail re negotiation \n46 \n9/17/2007 \nA. Marie \nVi&fails \nAl \nAcosta \nPlease make sure Lefkowitz understands that the Non-Prosecution agreement \nex \nprovided is only a draft and will still need final approval. \n46 \nPrivileged Confidential \nPage 16 of 51 \nContains 6(e) Material \nEFTA00225443\n", "char_count": 1635}, {"efta_number": "EFTA00225378", "page_number": 66, "text_content": "EPSTEIN INVESTIGATION TIMELINE \nDate \nTo \nFrom \nRe: \nExhibit # \n9/17/2007 \nA. Marie \nVillafana \n. \nJay Lefkowttz Email requesting obstruction proffer that is already drafted and inquiring \nwhether deferred prosecution agreement would be made public \n49 \n9/17/2007 \nA. Marie \nVillafalia and \nRoy Black; cc: \nGerald Lefcourt, \nJohn McMillan, \nKaren Atkinson, \nand Andrew \nLourie \n. \nJay Lefkowitz \nResponse to email that Jenny from Judge Marra's office spoke with the Judge \nand he agreed to take the matter off the calendar. If a plea agreement is \nreached, USAO will withdraw the subpoena and Mr. Black will withdraw his \nMotion to Quash. \n49 \n9/17/2007 \nA. Marie \nVillafaiist, R. \nGarcia, A. \nLourie, K. \nAtkinson, J. \nMcMillan \nA. Acosta \nEmail re draft Agreement with attached correspondence \n46 \n9/17/2007 \nJay Lefkowitz \nA. Marie \nVillafaiia \nOptions for plea: 1. Original agremeent where Epstein pleads only to state \ncharges and serves his time in state, except that we can agree to only 18 \nmonths imprisonment. 2. Epstein pleads guilty to the state charges and also \npleads to either two obstruction counts or to one count of violating 47 U.S.C. \n223(a)(1)(B), with a joint non-binding recommendation of 18 months, so that \nhe can serve his time federally. 3. I go back to the U.S. Attorney and ask him \nto agree to an ABA-plea to a 371 count (conspiracy to violate 2422(b)) with a \nbinding 20-month recommendation so that he can serve all of his time in a \nfederal facility. 4. Epstein pleads guilty to one obstruction count and serves \npart of his time federally and part state. \n49 \n9/17/2007 \nLeflcowitz \nVillafaha\n-\nEmail informing of removal of hearing on Motion to Quash from Judge \nMarra's calendar \n49 \nPrivileged Confidential \nPage 17 of 51 \nContains 6(e) Material \nEFTA00225444\n", "char_count": 1798}, {"efta_number": "EFTA00225378", "page_number": 67, "text_content": "EPSTEIN INVESTIGATION TIMELINE \nDate \nTo \nFrom \nRe: \nExhibit # \n9/17/2007 \nR. Garcia, A. \nLourie \nA. Marie \nVillafaiia \nEmail re negotiation strategy \n46 \n9/17/2007 \n11:39 am draft Non-Prosecution Agreement \n9/17/2007 \n11:42 am draft Non-Prosecution Agreement \n9/17/2007 \nRolando Garcia \nand Andrew \nLouric \nA. Marie \nVillafana- \nEmailre Epstein providing update re plea negotiations \n46 \n9/17/2007 \n9/17/2007-9/19/2007 Entails between Marie Villafaiia, Rolando Garcia, \nAndrew Lowrie, Alex Acosta, Karen Atkinson, and John McMillan regarding \nnegotiations of a federal plea and a non-prosecution agreement \n16 \n9/18/2007 \nA. Acosta, A. \nLouric, R. \nGarcia, K. \nAtkinson, J. \nMcMillan \nA. Marie \nVillafafia \nEmail re negotiating strategy \n16 \n9/18/2007 \nA. Marie \nVillafatia \nAcosta, Lourie, \nGarcia \nEpstein negotiations - you spent 12 hours working on drafts and you are \nadvising that the end of negotiation is nearing \n46 \n9/18/2007 \nA. Marie \nVillafatia \n. \nI av Lefkowitz \n' \nEmail chain regarding draft agreements. Lefkowitz suggests plead to one count \nof 1512, serve 12 months plus 1 year home confinement/supervised release, \nfollowed by 2 years of probation with 6 months being community control. \nVillafalia advises that USAO will not go below 18 months of prison/jail time. \n49 \n9/18/2007 \nRescheduled date for hearing on motion to quash subpoena for computer \nequipment (initially set for 9/13/2007) \n9/18/2007 \nAndrew Louie, \nRolando Garcia' \nKaren Atkinson \nA. Marie \nVillafana \nI:mail re Draft Agreements with email from Jay Lefkowitz (9/18/07) attached \n49 \n9/18/2007 \n10:45 am draft Plea Agreement \n9/18/2007 \n12:07 pm draft Plea Agreement \nPrivileged Confidential \nPage 18 of 51 \nContains 6(e) Material \nEFTA00225445\n", "char_count": 1737}, {"efta_number": "EFTA00225378", "page_number": 68, "text_content": "EPSTEIN INVESTIGATION TIMELINE \nDate \nTo \nFrom \nRe: \nExhibit # \n9/18/2007 \n12:22 pm draft Plea Agreement \n9/18/2007 \n1:37pm draft Information \n9/18/2007 \nGarcia, Villafaiia \nLourie \nEmail stating new terms that Louric negotiated with Lefkowitz \n9/19/2007 \nA. Laurie, R. \nGarcia, K. \nA. Marie \nVillafana \nEmail re negotiating strategy with attached correspondence \nl6 \n9/19/2007 \nA. \nA. Marie \nVillafaiia \nA. Laurie \nEmail re Epstein with internal U.S. Attorney's Office emails attached \n46 \n9/19/2007 \nA. Marie \nVillafaria \nJay Lefkowitz Forwarded to Laurie and R. Garcia - draft plea agreement issues \nl6 \n9/19/2007 \nAndrew Lourie, \nRolando Garcia, \nKaren Atkinson \nA. Marie \nVillafana \nEmail re Draft Plea Agreement with email from Lefkowitz to Villafana \n(9/19/07) and Lefkowitz to Villafana (9/19/07) attached \n46 \n9/ 19/2007 \nResearch re Federal Bureau of Prisons Designations \n9/19/2007 \n11:46 am draft Information \n9/20/2007 \nBelohlavek, \nKrischer \nVillafana \nEmail chain discussing proposed joint meeting with Epstein's counsel to \nfinalize all agreements \n9/20/2007 \nLourie \nVillafana \nEmail forwarding federal plea agreement incorporating Acosta and Laurie \ncomments \n9/20/2017 \nLaurie \nVillafalia \nEmail chain discussing factual proffer in support of federal plea \n9/20/2017 \nAcosta, Laurie \nVillafafia \nEmail summarizing call with Lefkowitz in response to Lefkowitz call to Acosta \n9/20/2007 \n1:17pm draft Plea Agreement \n9/20/2007 \n3:52 pm draft Plea Agreement \n9/20/2007 \nVillafafia \nLourie \nEmail stating that Lefkowitz wants to remove registration requirement \n9/20/2007 \nVillafana \nLaurie \nEmail asking Villafana to call Lefkowitz and inform him that Epstein must \nplead to registrable offense \nPrivileged Confidential \nPage 19 of 51 \nContains 6(e) Material \nEFTA00225446\n", "char_count": 1789}, {"efta_number": "EFTA00225378", "page_number": 69, "text_content": "EPSTEIN INVESTIGATION TIMELINE \nDate \nTo \nFrom \nRe: \nExhibit # \n9/21/20(17 \nLowrie, Garcia \nVillafaiia \nEmail informing Laurie of conversation with Lefkowitz about sex offender \nregistration issue \n9/21/2007 \nVillafafia, \nBelohlavek \nKrischer \nEmail summarizing SAO negotiations with Goldberger, including \nGoldberger's request that Epstein not have to register as a sex offender \n9/21/2007 \nLourie, Garcia \nVillafana \nEmail containing revised agreement incorporating some of Lefkowitz's \nlanguage and highlighting 7755 negotiations \n9/21/2007 \nResearch re Florida Statutory Authorities and Bibliography \n50 \n9/21/2007 \n2:05 pm draft Non-Prosecution Agreement \n9/21/2007 \nVillafaiia, Garcia \nLaurie \nResponse to email about Leficowitz's proposed language regarding \n immigration proceedings \n9/21/2007 \n4:47 pm Epstein state plea jpl edits (Lefkowitz) \n9/23/2007 \nAcosta, Laurie, \nSloman, \nVillafatia \nLefkowitz \nEmail admitting that defense based their agreement to plead to 796.03 on a \n\"mistaken assumption\" and requesting that Epstein not have to register as a \nsex offender \n51 \n9/23/2007 \nLefkowitz, \nLaurie, Villafaiia \nAcosta \nEmail response to Lefkowitz instructing Lefkowitz to deal directly with Laurie \nand Villafatia in negotiating agreement \n51 \n9/23/2007 \n3:56 pm draft Non-Prosecution Agreement \n9/23/2007 \n6:50 pm draft Non-Prosecution Agreement \n9/23/2007 \n8:49 pm draft Non-Prosecution Agreement \n9/24/2007\nAcosta \nSloman, Lowrie, \nGarcia, Villafaiia \nEmail containing Acosta edits to Agreement \n9/24/2007 \nVillafaiia \nLefkowitz \nEmail - 1 page with nine page NPA (3 signature pages) attached \n9/24/2007 \nWeinberg, \nLaurie, Garcia \nVillafafia \nEmail containing Acosta's final edits and asking to discuss potential victim \nrepresentative \n9/24/2007 \nAcosta, Sloman, \nLaurie, Garcia, \nAtkinson \nVillafafia \nEmail containing final agreement as approved by both parties \nPrivileged Confidential \nPage 20 of 5 I \nContains 6(c) Nlaterial \nEFTA00225447\n", "char_count": 1965}, {"efta_number": "EFTA00225378", "page_number": 70, "text_content": "EPSTEIN INVESTIGATION TIMELINE \nDate \nTo \nFrom \nRe: \nExhibit # \n9/24/2007 \n9:04 am draft Non-Prosecution Agreement \n9/ 24/2007 \n10:12 am draft Non-Prosecution Agreement \n9/24/2007 \n2:14 pm draft Non-Prosecution Agreement \n9/24/2007 \n4:20 pm draft Non-Prosecution Agreement \n9/24/2007 \nNPA signed \n32 \n9/24/2007 \nAcosta, Garcia, \nLourie \nVillafaiia \nEmail containing signed agreement \n9/25/2007 \nScheduled date for Federal Indictment \n9/30/2007 \n9/30/2007-10/1/2007 Email chain between Villafafia and Lefkowitz re \ntelephone call with attached emails from 9/23/07, 9/16/07, and 9/15/07 \n10/1/2007 \nFolder entitled \"(Victims) Additional 302's\" containing reports of interviews \nconducted in June 2007, October 2007, and March 2008 \n10/1/2007 \n10/1/2007-10/31/2007 Additional negotiations regarding selection of Special \nMaster \n10/1/2007 \n10/1 /2007-10/31 /2007 JD#1 Notified regarding signing of NPA \n10/1/2007 \n10/1/2007-10/31/2007 Investigation continues to try to identify addl victims \n10/2/2007 \nAdd'l client of Brad Edwards interviewed. She refuses to provide information. \n(She provides information on a later date). \n10/3/2007 \nLefkowitz \nVillafafia \nEmail - 2 pages with one page attachment, Proposal for Selection of Attorney \nto Represent Victims \nC-6 \n10/5/2007 \nVillafafia \nLefkowitz \nEmail - 3 pages with four page unsigned letter from Lefkowitz to Villafafta \nC-6 \n10/5/2007 \nSloman \nVillafafia \nEmail forwarding letter from Lefkowitz re special master process \nC-6 \n10/7/2007 \nVilLsfaiia \nSloman \nEmail chain including correspondence between Sloman and Sanchez \n10/8/2007 \nSloman \nLilly Ann \nSanchez \nLetter - 3 pages \n10/9/2007 \nVillafaiia \nSloman \nEmail attaching correspondence from Sanchez regarding Special Master \nProcess \n10/9/2007 \nilly Ann \nLS\nanchez \nVillafafia \nEmail - 1 page with two page letter from Villafaha to Sanchez attached \nPrivileged Confidential \nPage 21 of 51 \nContains 6(e) Material \nEFTA00225448\n", "char_count": 1937}, {"efta_number": "EFTA00225378", "page_number": 71, "text_content": "EPSTEIN INVESTIGATION TIMELINE \nDate \nTo \nFrom \nRe: \nExhibit # \n10/9/2007- \n3/25/2008 \nFBI Interview Reports of ----- (10/05/2007, 3/20/2008, and 3/25/2008), #2 \n(10/10/2007), #14 (10/26/2007), #33 (10/02/2007), #20 (10/25/2007), \n#21 (10/03/2007), \n(10/03/2007), \n(10/02/2007), #40 \n(6/12/2007), and #35 (10/02/2007) \nB-31 \n1(1/10/2007 \nA(. ).t., \nLefkowitz \nLetter - 6 pages \n10/16/2007- \n10/23/2007 \nEmails between Marie Villafafia, Jeff Sloman, Alex Acosta, and Jay Lefkowitz \nregarding Special Master \nC-7\n10/22/2007 \nLefkowitz \nSloman \nEmail - 3 pages with four page draft letter to Judge \nand two page \nAddendum to the NPA, attached \n10/23/2007 \nAcosta \nLefkowitz \nLetter - 3 pages \n10/23/2007 \nSloman, \nVillafafia \nAcosta \nResponse to Leflcowitz's letter noting specific misrepresentation \n10/24/2007 \nLefkowitz, \nAcosta, Villafana \nSloman \nEmail - 1 page with two page Addendum to the NPA, and four page draft \nletter to Judge \n, attached \n10/25/2007 \nLefkowitz \nCyndee \nCampos \nEmail - 1 page with letter to Judge \nattached \n10/25/2007 \nThe Hon. \nEdward B. \nJeffrey Sloman Background information to Special Master to appoint attorney for victims \n10/29/2007 \nDeadline date for Epstein's plea and sentencing according to Non-Prosecution \nAgreement \n10/30/2007 \nVillafafia \nSloman \nEmail attaching final addendum \n10/30/2007 \nFinal executed Addendum to the Non-Prosecution Agreement \n10/31/2007 \nLefkowitz \nSloman \nEmail - 2 pages \n11/1/2007 \nUSAO extends deadline for Epstein's plea and sentencing per request of \nEpstein's counsel \n11/1/2007 \nResearch re State Work Release \nPrivileged Confidential \nPage 22 of 5I \nContains 6(e) Material \nEFTA00225449\n", "char_count": 1662}, {"efta_number": "EFTA00225378", "page_number": 72, "text_content": "EPSTEIN INVESTIGATION TIMELINE \nDate \nTo \nFrom \nRe: \nExhibit # \n11/2/2007 \nResearch re Florida Administrative Code Chapter 33-601. Classification of \nCentral Records: 33-601.602 Community Release Programs and 33-601.606 \nPlacement of Inmates into Community Release Programs \n11/5/2007 \nLefkowitz \nSloman \nLetter - 2 pages \n11/8/2007 \nJeffrey Sloman \nJay Lefkowitz response to 11/5/07 letter stating that Epstein is complying fully with the \nNon Prosecution Agreement (with Villafana handwritten notes) \n11/13/2007 \nJay Lefkowitz \nJeffrey Slomantwo \nResponse to 11/8/07 letter stating that a guilty plea and sentencing more than \nmonths beyond the original deadline is unacceptable. The agreement as to \nthe terms of the plea and sentencing and the new date for the change of plea \nand sentencing is to be provided by 11/16/07. \n11/14/2007 \nJeffrey Sloman \nVillafana\nEmail regarding meeting with State Attorney's Office about work release and \nsex offender registration \n- , \n11/15/2007 \nVillafaiia, \nSloman, Garcia, \nAcosta, \nAtkinson \nJason Richards 11/15/2007-11/16/2007 Emails regarding research on work release \n-6 \n11/16/2007 \nSloman \nLefkowitz \nEmail - 1 Page \n11/19/2007 \nResearch re Florida Statute 921.143 Appearance of victim, next of kin, or law \nenforcement, correctional, or correctional probation officer to make statement \nat sentencing hearing; submission of written statement and Victim Notification \nRequest Form \nB-7 \n11/19/2007 \nPlea Notification Letter \nB-2 \n11/23/2007 \nUnscheduled meeting between Jay Lefkowitz, Alan Dershowitz and Jeff \nSloman. (Drop in by Lefkowitz and Dershowitz) \n11/26/2007 \nJason Richards \nPBSO D/S \nHarold Elliott Research re work release: PBSO Post Orders for the Work Release Program \nPrivileged Confidential \nPage 23 of 5I \nContains 6(e) Material \nEFTA00225450\n", "char_count": 1811}, {"efta_number": "EFTA00225378", "page_number": 73, "text_content": "EPSTEIN INVESTIGATION TIMELINE \nDate \nTo \nFrom \nRe: \nExhibit # \n11/27/2007 \nLefkowitz, \nAcosta, Villafatia \nSloman \nEmail responding to Lefkowitz's statement in his letter that he needs to \nconduct \"due dilligence\" on selection of Podhurst firm \n11/27/2007 \nPlea Notification Letter at 7:11 pm \n)3-3 \n11/28/2007 \nA. Marie \nVillafaiia, A. \nOosterbaan, R. \nGarcia \nA. Lourie \nEmail re non-prosecution agreement with attached correpondence \n11/28/2007 \nAlice S. Fisher, \nAssistant \nAttorney \nGeneral \nStarr \nLetter - 3 pages re 18 U.S.C. 2255 \n11/28/2007 \nLefkowitz, \nAcosta, Sloman' \nLourie, \nOosterbaan \nVillafana \nEmail regarding Epstein's plan to appeal to DC and proposed victim \nnotification letter \nB-8 \n11/28/2007 \nVictim notification letter prepared 11/28/2007 at 9:42 pm \nB-4 \n11/29/2007 \nA. Marie \nVillafalia \nJeffrey Sloman \nRequest to draft letter that sets forth brief history and nature of the case, \nfollowed by a chronology of the plea negotiations and vetting with CEOS that \nresults from those meetings, and how the civil resolution evolved. \n11/29/2007 \nA. Marie \nVillafaiia \nJeffrey Sloman \nForward of email chain between Jeff Sloman and Andrew Lourie advising that \ndefense backtracked on two issues: They originally agreed to plead to the state \nfelony that they thought was unregisterable (but did not tell us knowing we \nthought it was), but then discovered they were wrong and tried to get out of it. \nThey tried several times to knock down the jail time after agreeing to the time. \n11/29/2007 \nAcosta \nLefkowitz \nLetter - 4 pages, 4 page CVRA proposed notice letter attached \nB 9 \nPrivileged Confidential \nPage 24 of 51 \nContains 6(e) Material \nEFTA00225451\n", "char_count": 1683}, {"efta_number": "EFTA00225378", "page_number": 74, "text_content": "EPSTEIN INVESTIGATION TIMELINE \nDate \nTo \nFrom \nRe: \nExhibit # \n11/30/2007 \nJay Lefkowitz \nR. Alexander \nAcosta \nNeed to confer with A. Marie Villafafia and Jeffrey Sloman regarding \n11/29/07 letter. Counsel has objected to several steps taken by the USAO to \neffectuate the terms of the agreement and if Epstein is dissatisfied with the \nAgreement, we stand ready to unwind the Agreement. \nB I() \n11/30/2007 \nKenneth Starr \nAlex Acosta \nLetter in response to 11/28/2007 letter to Assistant Attorney General Fisher. \nOutlines the history of negotiations with various counsel for Epstein \nillustrating how the Non-Prosecution Agreement was reached. Request to \nprovide definitive statement signed by Epstein of his intention to abide by \neach and very term of the Agreement by dose of business on 12/14/2007, or \nwill proceed with prosecution. \n11/30/2007 \nResearch re CVRA \n12/1/2007 \nVictim notification letter prepared 12/1/2007 at 7:50 pm \nB-6 \n12/3/2007 \nAcosta \nVillafaiia \nEmails regarding research on proposed trust fund \n55 \n12/4/2007 \nKenneth Starr \nR. Alexander \nAcosta \nResponse to 11/28/07 letter regarding concerns of Non-Prosecution \nAgreement. The intent is to place the victims in the same position as they \nwould have been had Epstein been convicted at trial. \n12/5/2007 \nR. Alexander \nAcosta \nKenneth Starr \nand Jay \nLefkowitz \nEpstein reaffirms Non-Prosecution Agreement. Have no knowledge of \ndeadlines. Request for updated draft victim letters \nB-11 \n12/6/2007 \nJay Lefkowitz \nJeffrey Sloman \nConcern about Epstein's failure to set a timely plea and sentencing date. Still \nhave no received the terms of the Plea Agreement with the State Attorney's \nOffice. There has been no contact with the press from our office or the FBI. \nLetters to victims will be sent through the mail. Attached revised crime \nvictim's rights letter \nIt 12 \n12/6/2007 \nLefkowitz \nAcosta \nLetter and facsimile transmission cover sheet re victim notification latter,\nB-12 \n12/6/2007 \nLefkowitz \nSloman \nLet\n... [truncated, 2181 chars — for the full page use /api/corpus/document/EFTA00225378/74 or ?id=EFTA00225378&page=74]", "char_count": 2181}, {"efta_number": "EFTA00225378", "page_number": 75, "text_content": "EPSTEIN INVESTIGATION TIMELINE \nDate \nTo \nFrom \nRe: \nExhibit # \n12/6/2007 \nEmails between Marie Villafana, Andrew Lourie, Cyndee Campos, Jeff \nSloman, Alex Acosta, Karen Atkinson, and Nesbitt Kuyrkendall regarding \ncorrespondence from Ken Starr, request for a meeting with Epstein counsel, \nand need to notify victims of upcoming plea \n12/6/2007 \n12/6/2007-12/7/2007 Emails between Marie Villafatia, Nesbitt Kuyrkendall, \nJason Richards, Jeff Sloman, Cyndee Campos, Annette Castillo, Karen \nAtkinson, and Shawn Ball regarding request from State Attorney's Office for \ndraft plea proffer \nB-13 \n12/6/2007 \nVillafana \nBelchlank \n12/6/2007-12/7/2007 Emails between Villafana, Sloman, and Belohlavek \nregarding a factual proffer for state plea \n73 \n12/7/2007 \nAcosta, Fisher, \nSloman \nStarr//. \nLefkowitz \nLetter stating the defense will respond to Acosta letter by 12/10/07, and \nattaching \" the independent ethics opinions of Judge Herbert J. Stern and Joe \nD. Whitley\" \n12/7/2007 \nAlan Dershwitz Herbert J. Stem Letter - 27 pages \n12/7/2007 \nKenneth Starr \nR. Alexander \nAcosta \nIndependent ethics opinions of Judge Herbert J. Stem and Joe D. Whitley \nregarding the federal investigation of this matter and the Section 2255 \ncomponent of the Agreement. \n12/7/2007 \nLilly Ann \nSanchez \nJeffrey Sloman \nSigned Affirmation of the Non-Prosection Agreement and Addendum. Plea \nand sentencing hearing scheduled for 1/4/08 at 8:30 am before Judge Sandra \nMcSorley. \nR I s \n12/7/2007 \nSloman\nLilly Ann \nSanchez \nLetter -1 pages with Affirmation signed by Epstein and Notice of Heating, \nState of Florida I. Jeffrey Epstein, attached \n12/7/2007 \nVictim notification letter prepared 12/7/2007 at 9:10 pm \nB-6 \n12/7/2007 \nUnmailed victim notification letters \nB-14 \n12/10/2007 \nContacted counsel for JD#2/Individual #25 (paid for by Epstein) to \ndetermine if he still represented JD#2/Individual #25 and whether he should \nreceive upcoming victim notification \nB-19 \n12/11/2007 \nSloman and \nAcosta \nVillafatia \nE\n... [truncated, 2123 chars — for the full page use /api/corpus/document/EFTA00225378/75 or ?id=EFTA00225378&page=75]", "char_count": 2123}, {"efta_number": "EFTA00225378", "page_number": 76, "text_content": "EPSTEIN INVESTIGATION TIMELINE \nDate \nTo \nFrom \nRe: \nExhibit # \n12/11/2007 \nR. Alexander \nMona \nKenneth Starr \nand Jay \nLefkowitz \n2 separate letters to address problems with case. Letter 1 - Federal \nInvestigators relied upon tainted evidence. Improper involvement and \nconduct of Federal authorities (specifically names Villafana). Letter 2 - Section \n2255 and background of negotiations \n12/11/2007 \nEpstein counsel object to including JD#2/Indivival #25 as \"victim\" and begin \ntheir appeals to Washington, DC \n12/12/2007 \nComplete indictment package marked \"Originals 12/12/07\" \n12/12/2007 \nEmails between Marie Villafatia, Frederica Devlin, and Bob Senior regarding \nplanning indictment review \nB-1(il \n12/12/2007 \nRevised indictment package finalized \n12/13/2007 \nLefkowitz \nVillafaiia \nLetter - 5 pages \n12/14/2007 \nAlex Acosta, Jeff \nSloman, Rolando\nGarcia, and \nKaren Atkinson \nMane Villafana Email with draft letters to State Attorney's Office and victims \nB I - \n12/14/2007 \nDraft Crime Victims' Rights - Notification of Resolution of Epstein \nInvestigation letter \nB I 6 \n12/14/2007 \nResearch re Florida Procurement and Sentencing Guidelines (745 So.2d 979, \n761 So.2d 474397 So.2d 741, 715 So.2d 274, 919 So.2d 695, 701 So.2d 1181, \n711 So.2d 1290) \n12/14/2007 \nDraft letter to Krischer from Acosta regarding Epstein filing as sex offender \n69 \n12/14/2007 \nAcosta; Sloman \nVillafan-a \nEmail regarding Fl. Stat. 796.03 (procuring minors for prostitution) and 18 \nU.S.C. 2255 \n74 \n12/17/2007 \nAcosta \nLefkowitz \nEmail responding to inquiry from 12/14/07 meeting about why defense had \nwaited so long to go to DC \nPrivileged Confidential \nPage 27 of 51 \nContains 6(e) Material \nEFTA00225454\n", "char_count": 1701}, {"efta_number": "EFTA00225378", "page_number": 77, "text_content": "EPSTEIN INVESTIGATION TIMELINE \nDate \nTo \nFrom \nRe: \nExhibit # \n12/17/2007 \nAcosta \nStarr, Lefkowitz \n110-page letter addressing inapplicability of procurement statute to Epstein's \nconduct, State Attorney's Office's belief that Epstein should not have to \nregister inapplicability of 18 USC 2422 to Epstein's conduct; and reiteration of \n2255 concerns. Attachment: 7/6/07 Lefcourt letter Sloman, Menchel, Lourie, \nand Villafafia with attachments \n12/17/2007 \nJeff Sloman \nMarie Villafafia Email inquiring about case status and informing Sloman regarding agent \nconcern about victim notification \nB-18 \n12/19/2007 \nAlex Acosta, Jeff \nSloman, and \nJanice \nLaClainche \nMarie Villafasia Email regarding challenge to state charge raised by Epstein counsel during \n12/14/2007 meeting \nB-19 \n12/19/2007 \nLilly Ann \nSanchez \nAcosta \nFollow up letter from 12/14/07 meeting \n12/20/2007 \nEmails between Marie Villafafia and Jeff Sloman regarding inquiries from State \nAttorney's Office regarding Epstein plea to state charge and facts supporting \nstate plea \n12/21/2007 \n11. Al \nAcostaer \nexand \nJay Lefkowitz \nKnowledge of \"list\" of alleged victims is limited. Proposal deprives Epstein of \nhis opportunity to test the validity of these women's claims that would have \nbeen extensively tested at trial. \nB-21 \n12/26/2007 \nR. Alexander \nAcosta \nJay Lefkowitz \nWe do not object that some form of notice be given to the alleged victims. We \nrequest the opportunity to review the notification. Believe they should be sent \nby State Attorney's Office instead of USAO. More arguments about 2255 \nlanguage. \nB-22 \n1/2/2008 \nAlex Acosta and \nJeff Sloman \nMarie Villafafia Email regarding renewed plea negotiations for federal plea agreement \n1/2/2008 \nAlex Acosta and \nMarie Villafaria Jeffrey Sloman Email regarding telephone conversation with State Attorney's Office about \ndelay in Epstein state plea \nPrivileged Confidential \nPage 28 of 51 \nContains 6(e) Material \nEFTA00225455\n", "char_count": 1965}, {"efta_number": "EFTA00225378", "page_number": 78, "text_content": "EPSTEIN INVESTIGATION TIMELINE \nDate \nTo \nFrom \nRe: \nExhibit # \n1/2/2008 \nEmails between Alex Acosta, Marie Villafatia, and Jeff Sloman regarding \nrequests from Alex Acosta to Marie Villafafia for information related to the \nhandling of the investigation by the State Attorney's Office \n1/3/2008 \nI :.mails between Marie Villafatia, Alex Acosta, and Jeff Sloman regarding Alex \nAcosta telephone conference with Jay Lefkowitz where Lefkowitz admitted \nthat he never intended to have Epstein plead guilty to an offense that required \nsex offender registration \n1/4/2008 \nScheduled date for Epstein's self surrender according to the Non-Prosecution \nAgreement \n1/7/2008 \nAlex Acosta, Jeff \nSloman, Robert \nSenior, Karen \nAtkinson, and \nRolando Garcia \nMarie Villafatia Email regarding proposed additional investigative steps in Epstein case \nB-102 \n1/8/2008 \nTrial date set for State of Florida vs. Epstein \ni 9 , fiw, \n1/9/2008-1/14/2008 Emails between Marie Villafaila, Drew Oosterbaan, \nMyesha Braden, Nesbitt Kuyrkendall, and Jason Richards regarding assigning a \nCEOS attorney to the investigation, meeting with the CEOS attorney and \nvictims in Florida, the results of the meetings and planned additional meetings, \nand revisions to the indictment in light of the meetings. \nB-103 \n1/10/20”,\nEmail chain between Myesha Braden and Marie Villafaila regarding meeting \non 1/11/2008 \nB-104 \n1/14/2008 \nMarie Villafatia, \nE. Nesbitt \nKuyrkendall, \nJason Richards \nMyesha Braden Email chain regarding meeting and additional 302s \nB-105 \n1/17/2008 \nAgents compile evidence for Bob Senior indictment review \nB-106 \nPrivileged Confidential \nPage 29 of 5I \nContains 6(e) Material \nEFTA00225456\n", "char_count": 1687}, {"efta_number": "EFTA00225378", "page_number": 79, "text_content": "EPSTEIN INVESTIGATION TIMELINE \nDate \nTo \nFrom \nRe: \nExhibit # \n1/25/2008 \nEmail chain between Myesha Braden and Marie Villafana regarding victim's \nnames in indictment \nB-107 \n1/31/2008 \nAdd'l grand jury subpoenas prepared and served \nB-108 \n1/31/2008 \n1/28/2008-2/1/2008 Emails between Marie Villafafia, Jeff Sloman, Alex \nAcosta, Nesbitt Kuyrkendall, Jason Richards, and Alan Santiago regarding\n \nresults of additional victim-witness interviews and requesting intervention with \nCEOS to move review process along \nB 109\n1/31/2008 \nSloman, Acosta \nVillafafia \nEmail regarding victims \nC-1 \n2/12/2008 \n2/12/2008-2/22/2008 Emails between Marie Villafatia, E. Nesbitt \nKuyrkendall, Jason Richards, and Myesha Braden re information for \nindictment/ongoing investigation \nB-110 \n2/19/2008 \nComplete indictment package, including 3rd Supplement to Pros memo \n2/20/2008 \n2/20/2008-2/21/2008 Emails between Drew Oosterbaan, Marie Villafafia, \nRobert Senior, Jeff Sloman, Sigal Mandelker, Karen Atkinson, Alex Acosta, \nRolando Garcia and Myesha Braden regarding status of CEOS plans to meet \nwith counsel for Epstein and status of indictment review \nB-111 \n2/25/2008 \nLefkowitz \nSloman \nEmail providing deadline for Epstein to perform \n2/25/2008 \nEmail chain between Marie Villafafia and Caroline Heck \nregarding use \nB 11, \nof Grand Jury \n2/25/2008 \nJeff Sloman, Bob \nSenior, Rolando \nGarcia, Karen \nAtkinson, and \nMyesha Braden \nMarie Villafafia Email re result of conferring with Caroline Heck \nabout whether or not \nto continue presentation to same grand jury or p \nto a different grand jury \nB 1 11 \n2/26/2008 \nMyesha Braden Marie Villafafia Email re CEOS independent review and concern about victim's names being \nreleased \nB\n \n-I 14 \nPrivileged Confidential \nPage 30 of 51 \nContains 6(e) Material \nEFTA00225457\n", "char_count": 1811}, {"efta_number": "EFTA00225378", "page_number": 80, "text_content": "EPSTEIN INVESTIGATION TIMELINE \nDate \nTo \nFrom \nRe: \nExhibit # \n2/26/2008 \nSloman, Senior \nVillafatia \nEmail response with concerns regarding allowing Epstein to keep the same \ndeal as before \nR I I; \n2/27/2008 \nLefkowitz \nSloman \nEmail - 2 pages \n2/27/2008 \nEmail chain between Marie Villafatia, David Weinstein, and Bob Senior re \nemail to the Civil Rights Chief \nB I ll, \n2/28/2008 \nEntails between Marie Villafafia and Susan Roe regarding related investigation, \npotential investigatory leads, and CEOS review \n2/28/2008 \nEmail chain between Marie Villafain, Jason Richards, and E. Nesbitt \nKuyrkendall regarding further investigation \nR 1 i - \n2/29/2008 \nAcoqa \nLefkowitz \nEmail - 1 page \n2/29/2008 \nEmails between Jeff Sloman, Marie Villafafia, Robert Senior, and David \nWeinstein regarding continuing investigation and status of CEOS review \nli I I',\n3/1/2008 \n' \nFBI Reports of March 2008 interviews of additional wimess/victitn located in \nNew York \n3/1/2008 \nFolder entitled \"(Victims) Additional 302's\" containing reports of interviews \nconducted in June 2007, October 2007, and March 2008 \n3/5/2008 \nEmails between Marie Villafain and E. Nesbitt Kuyrkendall with attached \nemail to Alex Acosta, Jeff Sloman, Drew Oosterbaan, Robert Senior, Myesha \nBraden, Rolando Garcia, and Karen Atkinson regarding meeting in DC, \nadditional information to prepare for meeting, and new information from \nongoing investigation \nB 121 \n3/7/2008 \nLefkowitz \nOosterbaan \nEmail - 2 pages \n3/10/2008 \nLefkowin \nOosterbaan \nEmail - 2 pages \n3/10/2008 \nOosterbaan \nLefkowitz \n Email - 1 page \n3/10/2008 \n3/10/2008-3/12/2008 Emails between Marie Villafatia, Robert Senior, \nMyesha Braden, Krishna Patel, Nesbitt Kuyrkendall, E.J.Yen, and Karen \nAtkinson about Epstein attempts to contact victims and finding counsel for \nvictims \nB-23 \n3/12/2008 \nSub oena to ---- return date 4/15/08 \n3/12/2008 \nSubpoena to \n(return date 4/15/08) \n3/12/2008 \nVillafalia \nKuyrkendall \nEmail re affidavit for the memory cards \nB-\n... [truncated, 2082 chars — for the full page use /api/corpus/document/EFTA00225378/80 or ?id=EFTA00225378&page=80]", "char_count": 2082}, {"efta_number": "EFTA00225378", "page_number": 81, "text_content": "EPSTEIN INVESTIGATION TIMELINE \nDate \nTo \nFrom \nRe: \nExhibit # \n.3/12/2008 \n3/12/2008-3/17/2008 Emails between Marie Villafatia, Nesbitt Kuyrkendall \nand E.J. Yera regarding search warrant application and execution of search \nwarrant \n3/13/2008 \nSigal Mandelker \nLefkowitz \nEmail - 2 pages (CEOS) \n3/14/2008 \nEmails between Marie Villafaila, Rolando Garcia, Karen Atkinson, Frederica \nDevlin, and Shawn Ball regarding complete indictment package for Robert \nSenior final review \nB-27/B-\n122 \n3/14/2008 \nRevised indictment package \nB-25 \n3/17/2008 \nSearch warrants for digital camera memory cards \nB-120 \n3/18/2008 \nGrand Jury presentation materials and testimony of Special Agent E. Nesbitt \nKuyrkendall \nB-26 \n3/19/2008 \nEmail chain between Marie Villafaiia, David Weinstein, Jeff Simian, Bob \nSenior, Karen Atkinson, and Rolando Garcia with Epstein update from grand \njury presentation and grant from the Justice Department to provide legal \nrepresentation to victims \nC-2 \n3/19/2008 \n3/19/2008-3/22/2008 Emails regarding victims being harassed by Epstein's \ninvestigators \n( ; \n3/20/2008 \nVilialana \nRichard H. \nWillits \nLetter that he is representing Individual #3 \n3/21/2008 \nResponses to addil_grand jury subpoenas received \n3/25/2008 \nPlanned grand jury presentation (moved to 4/15/2008 then to 4/29/2008) \n3/28/2008 \nSigal Mandelker \nStarr \nLetter - 5 pages (CEOS) \nB-28 \n3/28/2008 \nVillafalia \nDanchuk \nLetter advising of representation of Individual #3 and that a lawsuit has been \nfiled in Palm Beach County Circuit Court \nB-41 \n4/1/2008 \nJay Lefkowitz \nJeffrey Sloman Draft letter regarding termination of agreement \nPrivileged Confidential \nPage 32 of 51 \nContains 6(c) Material \nEFTA00225459\n", "char_count": 1706}, {"efta_number": "EFTA00225378", "page_number": 82, "text_content": "EPSTEIN INVESTIGATION TIMELINE \nDate \nTo \nFrom \nRe: \nExhibit # \n4/2/2008 \nEmails between Marie Villafatia, Alex Acosta, Jeff Sloman, Karen Atkinson, \nRobert Senior, Rolando Garcia, and Nesbitt Kuyrkendall regarding efforts by \nJay Lefkowitz and Ken Starr to speak with Alex Acosta and instructions to \ndirect question to Marie Villafaila and Karen Atkinson \n4/8/2008 \nSigal Mandelker \nStarr \nLetter - 4 pages (CEOS) \n4/9/2008 \nWillits \nVillafalla \nLetter in response to 3/28/08 letter from Willits \nB-42 \n4/21/2008 \n4/21/2008-5/9/2008 Emails between Marie Villafaiia, Jeff Sloman, Karen \nAtkinson, Bob Senior, E. Nesbitt Kuyrkendall, Jason Richards, and Drew \nOosterbaan re status of grand jury presentation, and ongoing investigation, \nand delay \nB-124 \n4/22/2008 \nOffice of \nProfessional \nResponsibility \nA. Marie \nVillafafia \nLetter re Self-Report of Allegation of Conflict of Interest \n4/28/2008 \nSigal Mandelker \nStarr \nLetter - 4 pages (CEOS) \n4/29/2008 \nOperation Leap Year Revised Indictment Summary chart (by Victim) and \nGrand Jury presentation Operation Leap Year \nB-29 \n4/29/ 2008 \nDraft Indictment \n8-30 \n5/6/2008 \nSubpoena to Leigh Ann Murray (return date 5/6/08) \n5/14/2008 \nAsst Atty \nGeneral Fisher \nStarr \nLetter - 4 pages (CEOS) \n5/15/2008 \nJay Leflcowitz \nAndrew G. \nOosterbaan\nFederal prosecution would not be improper or inappropriate. \nIt -24 \n5/15/2008 \nCEOS and DAAG Fisher complete review of Epstein's appeal \n5/15/2008 \n5/15/2008-5/27/2008 Emails between Marie Villafatia, Karen Atkinson, Bob \nSenior, Jeff Sloman, and agents regarding indictment review and status of \ninvestigation \nB-125 \n5/19/2008 \nAcosta \nLefkowitz \nEmail - 3 pages \nB-35 \n5/19/2008 \nAttv\nDeputy \n' \nGeneral Filip \nStarr/Whidey Letter - 8 pages \n8-33 \nPrivileged Confidential \nPage 33 of 51 \nContains 6(e) Material \nEFTA00225460\n", "char_count": 1828}, {"efta_number": "EFTA00225378", "page_number": 83, "text_content": "EPSTEIN INVESTIGATION TIMELINE \nDate \nTo \nFrom \nRe: \nExhibit # \n5/19/2008 \nLefkowitz\nCyndee \nCampos \nEmail - 1 page with 5/19/08 letter attached \nB-35 \n5/19/2008 \nLefkowitz \nSloman \nLetter - 6 pages \nB-35 \n5/19/2008 \nLefkowitz, cc: \nSloman and \nVillafatia \nAcosta \nResponse email to Lefkowitz's 5/19/08 email re Drew Oosterbaan letter, \nwhich is attached \nB-36 \n5/19/2008 \nKirldand & Ellis LLP, Response to Letter by FAUSA Sloman dated \n5/19/2008 - 10 pages \nB-37 \n5/19/2008 \nLefkowitz \nSloman \nLetter setting June 2, 2008 deadline to comply with terms and conditions of \nthe NPA \nB-32 \n5/27/2008 \nHonorable Mark \nFilip, DAG \nKenneth Starr Request for independent review of Epstein matter \nB-33 \n5/27/2008 \nEmails between A. Marie Villafana and Karen Atkinson regarding report of\n \nnew state plea deal for J. Epstein \n11-39\n5/27/2008 \nEmails between A. Marie Villafaiia, Robert Senior, Jeff Sloman, and Karen \nAtkinson regarding potential renewed plea negotiations for J. Epstein and \nplans to review and review updated indictment package \nR ',K \n5/27/2008- \n6/13/2008 \nInternal emails after CEOS letter rejecting appeal where Marie Villafaiia asks \nto indict and Jeff/Alex advise Epstein will be given chance to perform \nB m\n5/28/2008 \nAtkinson, \nVillafana, Garcia \nVillafana, \nSloman \nEmail chain regarding information from Barry Krischer, the State Attorney \n5/28/2008 \nLefkowitz \nSloman \nEmail - 1 page \n5/28/2008 \nSoman, \nVillafana \nAtkinson \nEmail chain regarding Epstein's request to do less time than 18 months \n5/29/2008 \nVillafalia, Senior; \ncc: Atkinson, \nKuyrkendall, \nRichards \nSloman \nEmail regarding DAG decision to consider Epstein's \"appeal\" and that GJ for \nTuesday is off \nB-40\nPrivileged Confidential \nPage 34 of 51 \nContains 6(e) Material \nEFTA00225461\n", "char_count": 1774}, {"efta_number": "EFTA00225378", "page_number": 84, "text_content": "EPSTEIN INVESTIGATION TIMELINE \nDate \nTo \nFrom \nRe: \nExhibit # \n5/30/2008 \nFBI-302 of 5/28/08 Interview of Individual #35 \n13-126 \n6/2/2008 \nVillafatia \nSloman \nDraft letter to DAG \nB-127 \n6/3/2008 \nHonorable Mark \nFilip, DAG \nKenneth Starr Submission with documents for independent review \n6/3/2008 \nStarr/Whitley \nJohn Roth \nLetter - 1 page \n6/3/2008 \nHonorable Mark \nFilip , DAG \nSloman \n2nd draft letter to DAG \nB 12'1 \n6/3/2008 \nDraft letter to Deputy Attorney General Mark Filip regarding reasons to \napprove continued prosecution of J. Epstein \nB-128 \n6/6/2008 \nEmails between Marie Villafafia and E. Nesbitt Kuyrkendall and subpoena \nissued to victim/witness and need for additional subpoenas \nB-129 \n6/17/2008 \nApplication for 6001 immunity for grand jury witness \nB-130 \n6/17/2008 \nAcosta, Sloman, \nSenior, \nAtkinson, Garcia \nVillafalia \nEmail summarizing meeting with Krischer regarding Epstein's attempt to \nnegotiate a new plea deal \n78 \n6/18/2008 \nVillafafia \nSenior \nEmail regarding call with Roy Black and response that Washington has not \nmade a final decision \n6 18/2008 \nEmails between A. Marie Villafafia, Robert Senior, Alex Acosta, Jeff Sloman, \nRolando Garcia, and Karen Atkinson regarding telephone conference with \nRoy Black about allowing.). Epstein to accept state plea to 60 days' \nimprisonment \n68 \n6/18/2008 \nNotes from call to Brad Edwards, counsel for #43, and notes from message to \nRoy Black and message from Roy Black \nB-43\n6/19/2008 \nBarry Krischer; \nKaren Atkinson \n\\ ill.it.ina \nEmail re wrapping up the case \n68 \nPrivileged Confidential \nPage 35 of 51 \nContains 6(e) Material \nEFTA00225462\n", "char_count": 1629}, {"efta_number": "EFTA00225378", "page_number": 85, "text_content": "EPSTEIN INVESTIGATION TIMELINE \nDate \nTo \nFrom \nRe: \nExhibit # \n6/19/2008 \nHonorable Mark \nFilip, DAG \nKenneth Starr Additional documents for independent review \n6/19/2008 \nJohn Roth \nStephanie D. \nThacker \nLetter - 14 pages \n6/20/2008 \nRequest to travel to New York for witness interviews in June 2008 and \nsubpoena \nB-132 \n6/23/2008 \nLefkowitz/ Starr \nJohn Roth \nLetter - 1 page \n8-44 \n6/23/2008 \nEmails between Jeff Sloman, Bob Senior, and Marie Villafatia instructing \nMarie Villafaiia to inform Epstein's attorneys that he had until June 30 to enter \na guilty plea and Villafafia email to Lefkowirz re same \nB-49 \n6/23/2008 \nVillafaiia, \nKuyrkendall, \nRichards, cc: \nAtkinson \nSenior \nEmail regarding New York Jane Doe and awaiting a response from DAG's \noffice \n6/23/2008 \nEmails between A. Marie Villafafia, E. Nesbitt Kuyrkendall, J. Richards, K. \nAtkinson, and R. Senior regarding grand jury subpoena to victim/witness, \nrevisions to indictment, planned grand jury presentation, and plans to \nsupersede indictment \nIS Ill \n6/23/2008 \nDAG Filip completes review of Epstein's appeal \n6/23/2008 \n6/23/2008-6/26/2008 Emails between Marie Villafaiia and grand jury witne,\nregarding immunity and travel for grand jury appearance \nB 13d \n6/24/2008 \nLetter from Matthew W. Friedrich, Acting Assistant Attorney General \nauthorizing application for a court order granting 6001 immunity \nP, 1 'd \n6/24/2008 \nVillafaiia \nSloman \nEmail re discussion about going to the change of plea regarding Jeffrey \nEpstein \n6/24/2008 \nVillafaiia; cc: \nJack Goldberger \nRoy Black \nEmail chain regarding wrap up call \nB-45 \nPrivileged Confidential \nPage 36 of 5 I \nContains 6(e) Material \nEFTA00225463\n", "char_count": 1684}, {"efta_number": "EFTA00225378", "page_number": 86, "text_content": "EPSTEIN INVESTIGATION TIMELINE \nDate \nTo \nFrom \nRe: \nExhibit # \n6/25/2008 \nVillafafia \nSloman \nEmail regarding having telephone discusion about 2255 issue and to discuss \nplea \n8 \n6/25/2008 \nVillafafia \nSloman \nEmail with revised victim notification letter \nIS-47 \n6/25/2008 \nEmails between A. M. Villafaria, J. Sloman, R. Senior, K Atkinson, and A. \nAcosta regarding draft of notification of victim list for J. Epstein counsel with \nattached drafts \n8-48 \n6/26/2008 \nBlack and \nGoldberger \nVillafafia \nEmail re proposed plea agreement and date and time of change of plea \n6/26/2008 \nVillafaria \nSloman \nEmail regarding factual proffer \n6/26/2008 \nFax from FBI with victim list \nB-SO \n6/27/2008 \nBlack and \nGoldberger \nVillafaria \nLetter regarding plea agreement between Epstein and SA and that the \nproposed sentencing provision does not comply with the terms of the NPA \n6/27/2008 \nBlack and \nGoldberger \nVillafaria \nEmails between Villafana and Black/Goldberger about problems with state \nplea agreement \n77 \n6/27/2008 \nCounsel for Epstein advise USAO of Epstein state court change of plea on \n6/30/08 \nBSI \n6/27/2008 \nAUSA Villafafia notifies Attorney Edwards of upcoming change of plea and \nurges his clients to attend \n6/27/2008 \nUSAO notifies Palm Beach Police Chief Reiter of upcoming change of plea. \nHe states intention to notify as many victims as possible of hearing. \n8-53 \n6/27/2008 \nResearch re State Work Release \n6/27/2008 \nSloman, \nAtkinson \nVillafalia \nEmail inquiring about conversation with Chief Reiter \nB-52 \n6/27/2008 \nSloman \nVillafafia \nEmail summarizing conversation with Goldberger that Epstein would serve \nsentence in confinement \"24-hours-a-day\" \n79 \n6/28/2008 \nEmails between A. M. Villafalia, J. Sloman, A. Acosta, and IL Senior regarding \ncorrespondence with J. Goldberger and proposed change to state plea \nagreement \n77 \n6/29/2008 \n\\ 'illafafia \nKuyrkendall \nEmail regarding work release \n80 \nPrivileged Confidential \nPage 37 of Si \nContains 6(e) Material \nEFTA002\n... [truncated, 2006 chars — for the full page use /api/corpus/document/EFTA00225378/86 or ?id=EFTA00225378&page=86]", "char_count": 2006}, {"efta_number": "EFTA00225378", "page_number": 87, "text_content": "EPSTEIN INVESTIGATION TIMELINE \nDate \nTo \nFrom \nRe: \nExhibit # \n6/30/2008 \nVillafatia \nMycsha Braden Email chain regarding Epstein sentencing \n6/30/2008 \nVillafatia \nSusan Roc \nEmail chain regarding news article \n6/30/2008 \nVillataria \nTed Leopold Email chain with response to 6/30/08 email from Villafana with contact \ninfo \ndon \n6/30/2008 \nEmails between Marie Villafana and attorney for grand jury wimess \nwithdrawing subpoena \nB-I35 \n6/30/2008 \nEpstein enters guilty plea in state court in accordance with NPA. \nJD#1/Individual #43, JD#2/Individual #25, and counsel do not appear. ASA \nand counsel for Epstein disclose to state court judge existence of NPA, which \nis later incorporated into state court record. \n6/30/2008 \nNotcs from calls to Michael Danchuk and Richard Willets, Jeff Herman, Brad \nEdwards, Ted Leopold, and Mike Dutko \nB-55 \n6/30/2008 \nResearch re State Work Release \n6/30/2008 \nDraft notification of identified victims letters to Guy Lewis, Jack Goldberger, \nand Roy Black \nB 5(\n6/30/2008 \nVillafafia \nOosterbaan \nEmail regarding Epstein guilty plea and sentencing \n71 \n6/30/2008 \n2008-2009 Epstein serves prison term \n7/1/2008 \nSmachetti \nVillafana \nEmail response stating that Villafana handled Epstein case but did not come \nup with the 18-month deal \n7/1/2008 \nVillatatia \nAnne Schultz Email regarding Epstein plea \n7/1/2008 \nVillatatia \nSmachetti \nEmail chain regarding Epstein case \n7/3/2008 \nCol. M. Gauger, \nPalm Beach \nSheriffs Office \nA. Marie \nVillafana \nEmail re Epstein work release with attachment \n7/3/2008 \nSloman \nVillafaila \nEmail re victim's lawyer \n7/3/2008 \nVillafatia \nBrad Edwards \nand Jay Howell Letter advising of representation of Epstein victims \n7/3/2008 \nVillatafia \nTed Leopold Email advising client names \nPrivileged Confidential \nPage 38 of 51 \nContains 6(e) Material \nEFTA00225465\n", "char_count": 1838}, {"efta_number": "EFTA00225378", "page_number": 88, "text_content": "EPSTEIN INVESTIGATION TIMELINE \nDate \nTo \nFrom \nRe: \nExhibit # \n7/3/2008 \nVillafafia; cc: \nAcosta \nc.1/01),In \nEmail response to 7/3/08 email from Villafafia regarding victims' lawyer \n7/3/2008 \nEmails between A. M. Villafafia, J. Sloman, and A. Acosta regarding telephone \nconference with B. Edwards and regarding meeting with Sheriffs Office about \nwork release program \ns I \n7/7/2008 \nJD#1/Individual #43 files \"Emergency Petition\" \n7/7/2008 \nNotes from calls to Mike Dutko, Brian Poulton, ASA, and Ted Leopold \n7/7/2008 \nNotes of phone call with Roy Black held some time between 7/7/08 and \n9/19/08 \n7/8/2(07; \nD. Lee, A. \nAcosta, J. \nSloman \nA. Marie \nVillafafia \nEmail regarding victim notification letter provided to counsel for J. Epstein on \n11/28/2007 with attachment \n7/8/2008 \nGoldberger \nVillafafia \nLetter re victim notification letters \nB-57 \n7/8/2008 \nLee, Sloman, cc: \nVillafafia, \nJacobus \nAcosta \nEmail with attached second draft of response in Jane Doe case \n7/8/200s \nVillafafia \nGoldberger \nLetter that he will respond on 7/9/08 \nB-58 \n7/9/2008 \n1 costa, Sloman, \nAtkinson; cc: \nKuyrkendall and \nRichards \nVillafaila \nEmail regarding response to Goldberger letter \nB-59 \n7/9/2008 \nGoldberger \nVillafafia \nResponse to Goldberger's 7/9/08 letter re notification of identified victims \nB-60 \n7/9/2008 \nLee, Villafalia, \nAcosta; cc: \nAtkinson, \nJacobus \nSloman \nEmail chain regarding confidentiality provision and filing under seal for victim \nresponse \n7/9/2008 \nVillafafia \nGoldberger \nLetter re Notification of Identified Victims \nB-61 \n7/9/2008 \nVictim Notification letters to Individuals #35 and #43 via Brad Edwards \nB-66 \nPrivileged Confidential \nPage 39 of SI \nContains 6(e) Material \nEFTA00225466\n", "char_count": 1724}, {"efta_number": "EFTA00225378", "page_number": 89, "text_content": "EPSTEIN INVESTIGATION TIMELINE \nDate \nTo \nFrom \nRe: \nExhibit # \n7/9/2008 \nGovt responds to \"Emergency Petition\" \n7/10/2008 \nGoldberger \nVillafafia \nLetter stating that government will provide victim notifications on a rolling \nbasis \nB-62 \n7/10/2008 \nVillafalia \nGoldberger \nLetter requesting list of all victims \nB-64 \n7/10/2008 \nGoldberger \nVillafatia \nLetter with final notification of identified victims \nB-63 \n7/10/2008 \nVillafafia, \nAcosta, \nAtkinson, cc: \nKuyrkendall, \nRichards \nSloman \nEmail regarding proposed response to Goldberger \nB 65 \n7/10/2008 \nVictim Notification letters to Individuals #3 (via Richard H. Willits), #8 (via \nJeffrey Herman), ##17 (via Theodore J. Leopold), #25 (via Jeffrey Herman), \n#26 (via Jeffrey Herman), #37 (via Michael E. Dutko), and #44 (via Jeffrey \nHerman) \nB-67 \n7/11/2008 \nHearing before Judge Marra \n7/14/2008 \n7/14/2008-7/15/2008 Emails between A. M. Villafaria, E. Nesbitt \nKuyrkendall, J. Richards, and T. Smith regarding FBI victim notifications and \nguidance regarding language to use and information to provide \nB 6',\n7/17/2008 \nVillafafia, \nAcosta, \nAtkinson, Lee \nSloman \nEmail chain with revised draft of Tein letter \n7/17/2008 \nLetter to Tein with attached fax cover sheet and transmission report \n7/17/2008 \nTein and \nGoldberger \nVillafaila \nLetter re Notice of Continued Pendency of Federal Criminal Action \n7/18/2008 \n7/18/2008-7/21/2008 Emails between A. M. Villafacia, J. Sloman, E. Nesbitt \nKuyrkendall, J. Richards, D. Lee, and IC Atkinson regarding preparation of \nvictim notification letters, victim contact list, filing of victim notification letter \nin a civil proceeding, and contact by B. Edwards with one victim opining that \nsentence imposed was insufficient \nB-69 \nPrivileged Confidential \nPage 40 of 51 \nContains 6(e) Material \nEFTA00225467\n", "char_count": 1816}, {"efta_number": "EFTA00225378", "page_number": 90, "text_content": "EPSTEIN INVESTIGATION TIMELINE \nDate \nTo \nFrom \nRe: \nExhibit # \n7/19/2008 \nEmails with other AUSAs in other districts and documents regarding \ndisclosing identifying information about victims \n7/21/2008 \nGoldberger \nVillafafia \nLetter with 11 additional victim notification letters \n7/21/2008 \nVillafaila \nGoldberger \nLetter with attached Motion for Return of Property \n7/21/2008 \nVillafaiia \nKuyrkendall \nEmail with list of victims that Twiler still needs to make contact with \nIt 6') \n7/21/2008 \nVillafaiia \nTein \nLetter in response to 7/17/08 letter from Villafaiia \n7/21/2008 \nVictim Notification letters to Individuals #1, #2, #4, #13, #9, #14, #21, #23, \n#30, #32, and #38 \n7/21/2008 \nVillafaiia; cc: \nSenior \nSloman \nEmail response to Vilkfaiia's 7/21/08 email regarding Motion for Return of \nProperty in State Court \n7/22/2008 \nVillafaiia \nK tz% rkcndall \nEmail chain regarding victim addresses \n7/22/2008 \nEmails between A. M. Vitiate's, A. Acosta, J. Sloman, R. Senior, K. Atkinson, \nE. Nesbitt Kuyrkendall, and J. Richards regarding 7/21/2008 letter from M. \nTein announcing plan to stay the civil suits against J. Epstein and notification \nthat B. Reinhart is counts! of record for S. Kellen in civil suits \n7/23/2008 \nEmails between A. M. Villafaria and D. Lee regarding correspondence with \ncounsel for]. Epstein and notice of breach \n7/25/2008 \nEmails between A. M. Villafaria and K. Atkinson regarding extension of grand \njury to allow for continued representation of J. Epstein case \n7/30/2008 \nVillafaiia \nAtkinson \nEmail regarding contact with Roy Black \n7/30/2008 \nVillafaria \nRoy Black \nEmail chain regarding call relating to the performance of the criminal Non-\nProsecution Agreement \n8/1/2008 \nLee, Acosta; cc: \nVillafaiia, \nJacobus, Senior \nSloman \nEmail chain regarding Jane Doe litigation \n8/2/2008 \nLee, Villafaiia \nAcosta \nEmail re: Letter from Brad Edwards \n8/5/2008 \nA. Acosta, J. \nSloman R. \n, \nSenior, and K. \nAtkinson \nA. Marie \nVillafalia \nEmail regarding analysis o\n... [truncated, 2230 chars — for the full page use /api/corpus/document/EFTA00225378/90 or ?id=EFTA00225378&page=90]", "char_count": 2230}, {"efta_number": "EFTA00225378", "page_number": 91, "text_content": "EPSTEIN INVESTIGATION TIMELINE \nDate \nTo \nFrom \nRe: \nExhibit # \n8/5/2008 \nVillafaiia, Senior, \nSloman, Lee, cc: \nAtkinson \nAcosta \nEmail with attached suggestions to Superseding Non-Prosecution Agreement \nB-72 \n8/6/2008 \nVillafatia, \nAcosta, Sloman, \nAtkinson \nSenior \nEmail regarding filing in state court case \n8/7/2008 \nVillafana \nRoy Black \nEmail responding to 8/7/08 email providing notification of possible \ncompelled disclosure of the Non-Prosecution Agreement \nB-73 \n8/6/2008 \nVillafatia \nSenior \nResponse regarding Roy Black's response to email \nB-74 \n8/12/2008 \nVillafafia \nSenior \nResponse to request for conference call prior to call with Roy Black \nB-75 \n8/13/2008 \nAtkinson, \nAcosta, Sloman, \nLee, cc: Villafaiia \nSenior \nEmail re Epstein and call with Jay \nB-76 \n8/13/2008 \nAtkinson, \nSenior, Sloman, \nLee, cc: Villafafia \nAcosta \nEmail response regarding final version of agreement \nB-77 \n8/13/2008 \nLefkowitz \nVillafafia \nLetter regarding performance of the N PA \n8-78 \n8/13/2008 \nResearch re PBSO rules and regulations \n8/13/2008 \n8/13/2008-8/15/2008 Emails between A. Acosta, K. Atkinson, R.. Senior, J. \nSloman, D. Lee, and A. M. Villafafia regarding scope of Epstein agreement \nand correspondence and telephone conference with J. Lefkowitz \nB-79 \n8/14/2008 \nVillafana \n-;enior \nEmail response to 8/14/08 email from Villafaiia advising Dexter disagrees \nwith strategy \n8/14/2008 \nVillafana, cc: \nAtkinson \nLefkowitz \nEmail re Follow up point regarding victims \nB-80 \n8/14/2008 \nStatus Conf before Judge Marra \nPrivileged Confidential \nPage 42 of 51 \nContains 6(e) Material \nEFTA00225469\n", "char_count": 1607}, {"efta_number": "EFTA00225378", "page_number": 92, "text_content": "EPSTEIN INVESTIGATION TIMELINE \nDate \nTo \nFrom \nRe: \nExhibit # \n8/15/2008 \nAcosta, \nVillafafia, \nSloman, Lee, \nAtkinson \nSenior \nEmail questioning whether offer should be withdrawn as opposed to \nconsidering it a nullity \n13-81 \n8/15/2008 \nEmail chain between Villafaiia, Acosta, Sloman, Senior, Atkinson, and Lee re \ndraft response to 8/15/2008 email from Jay Leflcowitz regarding \nimplementation of the NPA \n13-82 \n8/15/2008 \nLefkowitz and \nBlack \nVillafaiia \nLetter re terms of NPA \n13-83 \n8/15/2008 \nVillafatia, cc: \nAtkinson \nLe&owitz \nEmail re Follow up point with attached entails from 8/14/08 \n8/18/2008 \nVillafaiia \nLeflcowitz \nLetter re restitution \n13-84 \n8/21/2008 \nLeflcowitz and \nBlack \nVillafafia \nLetter re Special Master and draft Notification of Identified Victim \nB-85 \n8/22/2008 \nVillafatia \nLefkowitz \nLetter re misstatements in 8/21/08 Villafafta letter \nB-86 \n8/22/2008 \nDraft Victim Notification letter to Michael E. Dutko re Individual #37 \n8/25/2008 \nEmails between A. M. Villafafia, A. Acosta, J. Sloman, R. Senior, K. Atkinson, \nand D. Lee regarding letter received from J. Leflcowitz \n8/26/2008 \nLefkowitz and \nBlack \nVillafatia \nLetter re victim's list \nB-87 \n8/26/2008 \nVillafaiia, cc: \nAcosta, Senior \nSloman \nEmail regarding changes to letter to Jay \n9/2/2008 \nVillafatia \nLefkowitz\nLetter agreeing that Goldberger should be listed as the contact person and re \nJosfsberg's fees \nB-88 \n9/2/2008 \nEmails between A. M. Villafaiia, D. Lee, R. Senior, and J. Sloman regarding \nrevised victim notification \nPrivileged Confidential \nPage 43 of 51 \nContains 6(e) Material \nEFTA00225470\n", "char_count": 1612}, {"efta_number": "EFTA00225378", "page_number": 93, "text_content": "EPSTEIN INVESTIGATION TIMELINE \nDate \nTo \nFrom \nRe: \nExhibit # \nMailed Amended Victim Notification letters to Individuals #1, #2, #3 (via \n9/2/2008 \nRichard H. Willits), #4, #13, #8 (via Jeffrey Herman), #9, #10, #11, #14, \n#16, #17 (via Theodore Leopold), #20, #21, #23, #24, #25 (via Jeffrey \nB-89 \nHerman), #26 (via Jeffrey Herman), #30, #31, #32, #33, #37 (via Michael E. \nDutko), #38, #44 (via Jeffrey Herman)\n9/3/2008 \nVictim notification letters to Individuals #36, #35 (via Brad Edwards), #42, \n#43 (via Brad Edwards) \nB ()c \nEmail chain regarding Epstein and recommendation on working with same \n9/8/2008 \nVillafana \nSusan Roe \nteam \nMichael \n9/12/2008 \nVillafatia \nDanchuk \nLetter requesting copy of the settlement agreement \n9/12/2008 \nNotification of Identified Victim letter. Individual #39 \nB-91 \n9/15/2008 \nMichael \nDanchuk \nVillafafia \nLetter in response to 9/12/08 letter from Danchuk \n9/15/2008 \nMailed victim notification letters for Individuals #18 and #32 \nB-92 \n9/17/2008- \nEmails and coorespondence with The Florida Bar re victim notifications \nB-93 \n11/4/2008 \n9/16/2008- \nEmails between Villafafia, Krischer, Belohlavek, Garcia, Sloman, and Atkinson \n70 \n9/17/2008 \nregarding Palm Beach Daily News requesting copy of the NPA and discussion \n9/17/2008 \nLefkowitz, \nBlack, and \nVillafatia \nLetter re Palm Beach Daily News requesting information about the NPA \nGoldberger \n9/17/2008 \nVillafaila, \nAcosta, Senior, \nLee, Atkinson \n•1( )man \nEmail chain regarding obligation to sealing NPA \n9/19/2008 \nNotes of calls to Bob Josefsberg \nEmail agreeing with Villafalia's 10/8/08 email that a copy of the Response to \n10/8/2008 \nVillafatia \nSenior \nJane Does' Motion to Unseal the NPA should be mailed to Epstein's attorneys \nPrivileged Confidential \nPage 44 of 51 \nContains 6(e) Material \nEFTA00225471\n", "char_count": 1819}, {"efta_number": "EFTA00225378", "page_number": 94, "text_content": "EPSTEIN INVESTIGATION TIMELINE \nDate \nTo \nFrom \nRe: \nExhibit # \n19/8/2008 \nVillafaiia \nSlornan \nEmail response to Villafafia's 10/8/08 email advising to send a copy of \npleading to Roy and Jay \n10/8/2008 \nVillafaiia, Roy \nBlack, cc: \nAtkinson, Lee \nLefkowitz \nEmail thanking Villafaiia for fowarding United States' Response to Petitioners' \nMotion to Unseal the Non-Prosecution Agreement with attached email from \n10/8/08 \n10/16/2008 \nVillafaiia, Roy \nBlack, cc: \nAtkinson, Lee \nLefkowitz\nEmail thanking Villafaila for forwarding the reply brief filed by Brad Edwards \nwith attached 10/16/08 email \n10/23/2008 \n10/23/2008-5/27/2008 ? Emails between A. Marie illafafia, Nesbitt \nKuyrkendall, and J. Richards regarding plans to meet to prepare for indictment \npresentation, service of grand jury subpoenas, interviews of additional \nwitnesses, and plea negotiation issue \n10/27/2008 \nVillafafia \nMyesha Braden Email chain titled Things to do in West Palm \n11/4/2008 \nVillafafia \nSenior \nEmail thanking Villafatia for her 11/3/08 email advising she spoke with the \nFlorida Bar \n11/4/2008 \nCorrespondence from Florida Bar Ethics Counsel regarding Florida Ethics \nRules involved in distributing victim notification letters \n11/14/2008 \nNotification of Identified Victim letters to Individuals #20, #40 \nB 9 I \n11/17/2008 \nVillafaiia \nLefkowitz \nEmail chain regarding meeting \n11/19/2008 \nVillafaiia; cc: \nKatherine W. \nEzell and Amy \nEden \nRobert C. \nJosefsberg \nEmail with list of Epstein victims and representation \n11/20/2008 \nVillafaiia \nSenior \nEmail response to Villafaiia's 11/20/08 email advising that Epstein is on work \nrelease and request to indict him \n82 \n11/21/2008 \nVillafaiia, \nAcosta, Sloman, \nAtkinson; cc: \nGarcia \nSenior \nEmail advising Jeff Sloman is in agreement with approach and next steps \n82 \n11/24/2008 \nRoy Black \nVillafafia \nLetter re work release program and research \nPrivileged Confidential \nPage 45 of 51 \nContains 6(e) Material \nEFTA00225472\n", "char_count": 1971}, {"efta_number": "EFTA00225378", "page_number": 95, "text_content": "EPSTEIN INVESTIGATION TIMELINE \nDate \nTo \nFrom \nRe: \nExhibit # \n11/26/2008 \nVillafafia and cc: \nAtkinson \nRoy Black \nEmail stating that Jeffrey Epstein has not breached his Non-Prosecution \nAgreement by performing work release \n11/26/2008 \nEmails between A. M. Villafafia, J. Sloman, and R. Senior regarding email from \nIt. Black about work release \n12/3/2008 \nVillafalia \nLefkowitz \nEmail that he will not be attending meeting with Roy Black \n12/4/2008 \nVillafatia \nAtkinson \nEmail with attached draft letter to notify victims of Epstein's work release \nB-95 \n12/4/2008 \nVillafaiia; cc: \nSloman\nRoy Black \nEmail with attached Motion to Correct Sentence \n12/5/2008 \nBrad Edwards, \nEsq. \nVillafaiia \nEmail with attached Work Release Notice \nB-96 \n—12/5/2008 \nHerman \nVillafafia \nEmail with attached Work Release Notice \nB-96 \n12/5/2008 \nLefkowski, \nVillafaiia; cc: \nAtkinson \nRoy Black \nEmail response to 12/5/08 email from Villafafia advising that Brad Edwards \nfiled the Non-Prosecution Agreement in the Jane Doe case and has asked the \nCourt to unseal it \n12/5/2008 \nRobert C. \nJosefsberg \nVillafana \nEmail with attached Work Release Notice \nB-96 \n12/5/2008 \nTed Leopold \nVillafatia \nEmail with attached Work Release Notice \nB-96 \n12/5/2008 \nVillafalia \nSloman \nEmail advising no objections to the draft letter for work release notice \nattached to Villafafia's 12/4/08 email \n12/5/2008 \nWillits \nVillafaiia \nEmail with attached Work Release Notice \nB 96 \n12/8/2008 \nSpencer Kuvin, \nJack Scarola, \nMichael Dutko, \n#11, #39 \nVillafalia \nEmail with attached Work Release Notice \np, ir \n12/8/2008 \nNotification of Work Release Letter to Individual #40 \nIt ')-\n12/8/2008 \nFlorida Statute 796.03 Procuring person under age of 18 for prostitution \n12/8/2008 \nFlorida Statute 775.0837 Habitual misdemeanor offenders \nPrivileged Confidential \nPage 46 of 51 \nContains 6(c) Material \nEFTA00225473\n", "char_count": 1888}, {"efta_number": "EFTA00225378", "page_number": 96, "text_content": "EPSTEIN INVESTIGATION TIMELINE \nDate \nTo \nFrom \nRe: \nExhibit # \n12/8/2008 \nFlorida Statute 796.07 Prohibiting prostitution, etc.: evidence; penalties; \ndefinitions \n12/9/2008 \nNotification of Work Release letters to Individuals #4, #10, #16, #18, #23, \n#24, #33, #38, #30 (personal note), #42 \nB-98 \n12/9/2008 \nResearch re false statements on Epstein's application for work release \n83 \n12/10/2008 \nVillafaria \nSenior \nEmail requesting to speak with Villafafia regarding article about Epstein's work \nrelease \n12/10/2008 \nVillafafia \nSloman \nEmail re Epstein work release letter \n12/11/2008 \nCaptain David \nSleeth, Palm \nBeach Sheriffs \nOffice \nA. Marie \nVillafaiia \nLetter regarding Work Release Application of Jeffrey Epstein stating that there \nare some inaccuracies and omissions in Mr. Epstein's file. \n‘.\\ 4\n12/11/2008 \nVillafafia, cc: \nSenior \nSloman \nEmail advising a copy of the letter should be sent to Mr. Black \n12/11/2008 \nVillafaiia , \nSloman \nSenior \nEmail chain regarding sending copy of letter to Mr. Black \n12/12/2008 \nVillataria; cc: \n. \nMitch Kitroser \nSpencer Kuvin Email response advising he will consult with client in response to Villatalia's \n12/11/08 email re: Epstein work release \n12/12/2008 \nNotification of Work Release letter to #42 \n8-100 \n12/12/2008- \n12/29/2008 \nEmails with attorneys for victims regarding Epstein work release \nIt 'F) \n12/15/2008 \nVillafaiia, \nSloman, \nAtkinson, cc: \nKuyrkendall, \nRichards \nSenior \nEmail chain regarding articles about Epstein \n2/3/2009 \nRoy Black \nJosefsberg \nEmail re payment \nPrivileged Confidential \nPage 47 of SI \nContain): 6(c) Material \nEFTA00225474\n", "char_count": 1627}, {"efta_number": "EFTA00225378", "page_number": 97, "text_content": "EPSTEIN INVESTIGATION TIMELINE \nDate \nTo \nFrom \nRe: \nExhibit # \n2/11/2009 \nAmy Ederl, \nEvelyn Sheehan, \nKatherine W. \nEzell, Bert \nPatton \nJosefsberg \nEmail chain regarding payment and client's position \n2/13/2009 \nJosefsberg \nLefkowitz \nLetter re invoices are for services exceeding scope of services for which \nEpstein agreed to pay for \n2/20/2009 \nLefkowitz \nJosefsberg \nResponse to 2/13/09 Lefkowitz letter \n3/3/2009 \nJosefsberg \nLefkowitz \nResponse to 2/20/09 Josefsberg letter \n6/8/2009 \nRobert Critton \nKatherine W. \nEzell \nLetter re payment \n6/9/2009\nSloman, Senior, \nGarcia, Atkinson \nVillafana \nMemorandum re Operation Leap Year: Request to Provide Notification of \nBreach \n85 \n6/9/2009 \nFile folder entitled \"6/9/09 Signed Indictment\" containing signed indictment \npackage dated 6/9/2009 with corrections \n86 \n6/9/2009 \nIndictment package signed again for presentation on 6/16/2009 \n6/11/2009 \nVillafatia \nKatherine W. \nI lizell \nEmail re letter from Critton Denying any fees and hearing on 6/12/09 \n6/12/2009 \nGoldberger \n\\ illafafia \nLetter re violation of NPA \n87 \n6/12/2009 \nVillafaila \n1.efkowitz \nLetter re response to Villafaila 6/12/09 letter giving notice of breach with \nattached Defendant Jeffrey Epstein's Notice of Withdrawal of Arguments I \nthrough VII of the Defendant's Motion to Dismiss Plaintiffs First Amended \nComplaint \n6/12/2009 \nFile folder entitled \"6/12/09 Victim Notif. Log: containing chart with victim \ncontact information and attorney notes regarding dates and type of contacts \n6/12/2009 \nTranscript of Motion Hearing before judge Marra \n6/15/2009 \nLefkowitz, \nBlack, and \nGoldberger \nN'illafatia \nLetter regarding history of Epstein's performance under the NPA \n88 \nPrivileged Confidential \nPage 48 of 51 \nContains 6(e) Material \nEFTA00225475\n", "char_count": 1785}, {"efta_number": "EFTA00225378", "page_number": 98, "text_content": "EPSTEIN INVESTIGATION TIMELINE \nDate \nTo \nFrom \nRe: \nExhibit # \n6/15/2009 \nVillafalia \nLefkowitz \nLetter re Josefsberg's fees \n6/16/2009 \nVillafafia \nKa\nKatherine \nEll W. Email with attachment \n6/17/2009 \nLefkowitz \nVillafafia \nLetter in response to Lefkowitis 6/15/09 letter \n,..,) \n6/19/2009 \nVillafafia \nLefkowitz \nLetter re discussion regarding ongoing obligations per NPA \n7/6/2009 \nVillalatia \nSpencer Kuvin Letter requesting copy of NPA \n7/7/2009 \nLefkowitz \nVillafarla\n-\nLetter in response to 6/19/09 letter \n7/8/2009 \nVillafafia \nCritton \nLetter rc NPA with attached Defendant Epstein's Motion to Dismiss \nPlaintiffs Complaint (Jane Doe #8) \n7/31/2009 \nVillafatia \nSpencer Kuvin Letter with follow up request for NPA \n8/4/2009 \nSpencer Kuvin \nVillafana \nLetter in response to request for NPA \n8/5/2009 \nRespondent BB's Motion to Supplement the Record (4D09-2554) \n8/20/2009 \nJeffrey Epstein's Response to Motion to Supplement the Record (4D09-2554) \n9/1/2009 \nRoy Black \nA. Marie \nVillafaria \nDraft of letter regarding breach of Non Prosecution Agreement with \nhandwritten attorney (Villafana) notes \n9/1/2009 \nSloman \nRoy Black \nLetter re Epstein wanting to transfer his supervision from State of Florida to \nthe Virgin Islands \n90 \n9/17/2008 \nDraft of letter regarding transfer of supervision to the Virgin Islands with \nattorney \n9/18/2009 \nBlack \nVillafana \nLetter in response to transfer of supervision to the Virgin Islands (Villafafia) \nLetter\nnotes \n9/29/2009 \nHon. Jeffrey \nColbath \nAdam Horowitz Letter that Epstein violated his No-Contact Order on 9/16/09 by coming \nwithin 10 feet of Horowitz's client, Individual #44, Jane Doe No. 4. \n10/21/2009 \nVillafafia \nRoy Black \nResponse to 9/18/09 letter \n10/29/2009 \nOpen file and request USAO# (2009R02690, Operation Stolen Globe) \nPrivileged Confidential \nPage 49 of 51 \nContains 6(e) Material \nEFTA00225476\n", "char_count": 1875}, {"efta_number": "EFTA00225378", "page_number": 99, "text_content": "EPSTEIN INVESTIGATION TIMELINE \nDate \nTo \nFrom \nRe: \nExhibit # \n12/9/2009 \nVillafafia \nRoy Black \nLetter in response to 11/02/09 letter re Epstein's place of employment with \nattached Complaint against Scott Rothstein and Bradley J. Edwards \n1/4/2010 \nVillafafia \nSpencer Kuvin Letter re computer seized by FBI \n1/20/2010 \nVillafalia \nRoy Black \nLetter re attorney's fees \n1/21/2010 \nVillafatia \nRoy Black \nEmail re 1/20/10 letter \n2/11/2010 \nRoy Black \nVillafafia \nLetter in follow up to meeting held week prior \n2/18/2010 \nVillafatia \nRoy Black \nLetter in response to 2/11/10 letter from Villafatia \n3/4/2010 \nRoy Black and \nMartin Weinberg \nCritton \nLetter on thoughts and issues concerning NPA \n3/5/2010 \nSloman, . \nVillafana, Senior Roy Black \nLetter renewing request for clarity as to what legal issues civil counsel can \n. \nitigated without causing breach of NPA \n3/29/2010 \nSloman, \nVillafana, Senior \nRoy Black \nLetter re Motion to Dismiss \n4/2/2010 \nRoy Black \nVillafafia \nLetter re obligation to victims \n7/1/2010 \n7/1/2010-7/31/2010 Epstein completed term of house arrest \n9/8/2010 \nAdministrative Order closing case \n3/20/2011 \nLetter from Acosta re Epstein case \n7/29/2011 \nVillafalia \nLefkowitz \nLetter in response to 7/27/11 letter from Villafafia \n8/1/2011 \nEmails between Richard Sudder, Assistant General Counsel, Executive Office \nfor United States Attorneys, and Benjamin Greenberg, First Assistant U.S. \nAttorney, Southern District of Florida, regarding Formal Notice of Office-\nwide Recusal of Southern District of Florida dated July 28, August 3, August \n24 and August 29, 2011 \nPrivileged Confidential \nPage 50 of 51 \nContains 6(e) Material \nEFTA00225477\n", "char_count": 1681}, {"efta_number": "EFTA00225378", "page_number": 100, "text_content": "EPSTEIN INVESTIGATION TIMELINE \nDate \nTo \nFrom \nRe: \nExhibit # \n8/24/2011 \nWilfredo Ferrer \n(U.S. Attorney, \nSDFL), Robert \nO'Neill (U.S. \nAttorney, \nMDFL), \nBenjamin \nGreenberg \n(FAUSA, \nSDFL), and Lee \nBentley \n(FAUSA, \nMDFL) \nRichard Sudder \nEmail regarding Formal Notice of Office-wide Recusal of Southern District of \nFlorida. Cc's David MSODAG), Jay Macklin (USAEO), Thomas \nAnderson (USAEO), \nTapken (USAEO), and James Read (USAEO) \nPrivileged Confidential \nPage 51 of 51 \nContains 6(e) Material \nEFTA00225478\n", "char_count": 517}, {"efta_number": "EFTA00225378", "page_number": 101, "text_content": "UNITED STATES DISTRICT COURT \nSOUTHERN DISTRICT OF FLORIDA \nFGJ 07-103(WPB) \nU.S. District Judge Donald M. Middlebrooks \nIN RE: \nGRAND JURY PROCEEDINGS \nSEALED ORDER GRANTING APPLICATION FOR PERMISSION TO DISCLOSE \nGRAND JURY MATERIAL \nTHIS MATTER has come before the Court on the United States' Sealed Application for \nPermission to Disclose Grand Jury Material and for Entry of a Protective Order. The Court has \nconsidered the Motion and finds that: \n(I) \nthe United States has shown a \"particularized need\" for the limited disclosure of \nmaterials related to matters occurring before the Grand Jury; \n(2) \nthe United States has shown that the disclosure is \"in connection with a judicial \nproceeding,\" that is, in connection with an administrative proceeding conducted by the Justice \nDepartment's Office of Professional Responsibility (OPR) arising out of a decision by United \nStates District Judge Kenneth A. Marra in the matter of Jane Doe 1 and Jane Doe 2I United \nStates, S.D. Fla. Case No. 08-80736-Civ-Marra; \n(3) \nthe materials are needed to avoid an injustice in another proceeding, that is, the \nOPR administrative proceeding and any referrals to state bar authorities, other government \nagencies for law enforcement purposes, courts, and grand juries in accordance with OPR's Policies \nand Procedures; \n(4) \nthe need for disclosure is greater than the need for continued secrecy; and \n(5) \nthe request is structured to cover only the needed materials. \nEFTA00225479\n", "char_count": 1482}, {"efta_number": "EFTA00225378", "page_number": 102, "text_content": "Accordingly, the United States Attorney's Office for the Southern District of Florida, \nincluding Assistant United States Attorney A. Marie Villafafia, and the Justice Department's \nOffice of Professional Responsibility may disclose to attorney Jonathan Biran matters occurring \nbefore the grand jury necessary to: (a) allow AUSA Villafafia to respond to OPR's written \nquestions; (b) prepare for OPR's interview of AUSA Villafarla; and (c) participate fully in OPR's \ninterview of AUSA Villafaiia. \nDisclosure shall be limited as set forth in the attached Protective Order. \nTo the extent that AUSA Villafafla's May 10, 2019 Response to OPR's written questions \nand any drafts thereof disclosed any material that arguably referred to matters occurring before the \ngrand jury, this Order is entered nuns pro tune to authorize those disclosures to Mr. Biran. \nThis Order and the attached Protective Order shall be SEALED, except that copies may be \nprovided to the U.S. Attorney's Office for the Southern District of Florida, which may provide \ncopies to OPR and attorney Jonathan Biran. \nIT IS SO ORDERED. \nDone and Ordered in West Palm Beach, Fl \nay of May, 2 19. \nCertified Copies Furnished to: \nAUSA A. Marie Villafaila \nALD M. MIDDLEBROOKS \nUNITED STATES DISTRICT TT 1111W \nCertified to be a true and \ncorrect copy of the document on file \nAngola E. Noble, Clerk, \nDistri \nC \n2 \nEFTA00225480\n", "char_count": 1396}, {"efta_number": "EFTA00225378", "page_number": 103, "text_content": "UNITED STATES DISTRICT COURT \nSOUTHERN DISTRICT OF FLORIDA \nFGJ 07-103(WPB) \nU.S. District Judge Donald M. Middlebrooks \nIN RE: \nGRAND JURY PROCEEDINGS \nSEALED PROTECTIVE ORDER \nThis matter came before the Court on the United States' Sealed Application for Permission \nto Disclose Grand Jury Material and for Entry of a Protective Order. Having granted the \nApplication to Disclose Grand Jury Material in a separate Order, the Court hereby enters the \nfollowing Protective Order, which governs the conditions for disclosure, maintenance, and \ndestruction of any material containing \"matters occurring before the grand jury\" (hereinafter \nreferred to as \"grand jury material\"). \nAccordingly, it is HEREBY ORDERED THAT: \n1. \nThe government is authorized nunc pro tune to produce to attorney Jonathan Biran \nof Baker Donelson grand jury material relevant to his representation of Assistant U.S. Attorney A. \nMarie Villafafia that is necessary to: (a) allow AUSA Villafafia to respond to OPR's written \nquestions; (b) prepare for OPR's interview of AUSA Villafaila; and (c) participate fully in OPR's \ninterview of AUSA Villafafia. \n2. \nThe government and Mr. Biran shall make efforts to minimize the amount of grand \njury material produced to or maintained by Mr. Biran. Mr. Biran shall not be given copies of \nsubpoenas, documents produced in response to subpoenas, transcripts, proposed or completed \nindictments, prosecution memoranda, or items prepared for use in front of the grand jury, but these \nPage 1 of 2 \nEFTA00225481\n", "char_count": 1527}, {"efta_number": "EFTA00225378", "page_number": 104, "text_content": "items may be shown to Mr. Biran and discussed in preparation sessions and during interviews. \n3. \nAny hard copies of grand jury material provided to Mr. Biran shall not be \nphotocopied and shall be securely maintained. \n4. \nAny digital copies of grand jury material provided to Mr. Biran shall be encrypted. \n5. \nAny grand jury material provided to Mr. Biran can only be reviewed by him and \nnot by anyone else in his firm. \n6. \nAt the conclusion of the OPR proceedings and any related proceedings wherein Mr. \nBiran represents AUSA Villafaha, all grand jury material in Mr. Biran's possession shall be \ndestroyed. Hard copy documents must be shredded and electronic documents must be deleted \nand purged. \nDONE AND ORDERED this ,i li day of May, \nCertified to be a true and \ncorrect copy of the document on file \nAngela E. Noble, Clerk, \nU S. Distr ct C \nALD M. MIDDLEBROOKS \nUNITED STATES DISTRICT JUDGE \nI certify that I have read and agree to be bound by the terms of this Protective Order: \nDate: \nJonathan Biran, Esq. \nBaker Donelson \nPage 2 of 2 \nEFTA00225482\n", "char_count": 1068}, {"efta_number": "EFTA00225378", "page_number": 105, "text_content": "STATEMENT OF A. MARIE VILLAFARA IN RESPONSE TO \nAPRIL 2, 2019 LETTER FROM JEFFREY It RAGSDALE \nTo the extent possible, I have provided all information relevant to your inquiry, including \napplicable documents. Due to the passage of time, updates to various software and hardware, and \nthe crash of my work laptop several years ago, I no longer have every piece of relevant material \nand my memory may be imperfect.' I have organized the response to conform with the April 2, \n2019 letter from Jeffrey R. Ragsdale to Jonathan Biran. Please note that there were numerous oral \nand written communications between others at the U.S. Attorney's Office and the Justice \nDepartment with counsel for Mr. Epstein. While in some cases I was told of the communications \nor cc'ed on emails or letters summarizing the communications, for many conversations, meetings, \nand emails, I do not have knowledge of what occurred. \nIntroduction \nThe investigation of Jeffrey Epstein and a series of co-conspirators, named \"Operation \nLeap Year,\" officially began in May 2006. In theory, it was supposed to conclude on September \n24, 2007 with the signing of a \"Non-Prosecution Agreement\" (\"NPA\").2 As will be discussed \nbelow, the investigation presented several issues of first impression and challenges related to \nobtaining evidence and securing the cooperation of witnesses. Nonetheless, I felt certain that the \nagents, my co-counsel, \n'it a very strong case ag \nthree \nrsonal assistants — \nAdriana Ross, a/k/a \" \nand \nThe case was presented for federal investigation by the Palm Beach Police Department \nafter they felt that Jeffrey Epstein's legal team had put inappropriate pressure on the Palm Beach \nCounty State Attorney's Office to file only misdemeanor charges. Allegations of misconduct had \nbeen leveled against the local detective and the Police Chief and they reported being followed and \nharassed. As described below, the defense attorneys employed the same tactics at the federal level \nagainst myself \n... [truncated, 3221 chars — for the full page use /api/corpus/document/EFTA00225378/105 or ?id=EFTA00225378&page=105]", "char_count": 3221}, {"efta_number": "EFTA00225378", "page_number": 106, "text_content": "Once the USAO opened the file, Epstein took the same approach that had been used with \nthe State — at each level of review, he hired an attorney with a personal connection to the \nAUSA/USAJDOJ Attorney who was conducting the review. The attorneys raised a series of \nchallenges to the veracity of the victims and the veracity of the state investigators, as well as quasi-\nPetite-policy arguments. When those failed, more formal legal analysis and federalism policy \narguments were presented. \nThroughout this process, I wanted to keep my investigation as confidential as possible. For \nexample, I did not see the benefit of telling Epstein's counsel that we had uncovered additional \nvictims, that we had been able to corroborate victims' accounts, or the legal theories that we were \npursuing. My objections to making these disclosures were all overruled. Also, unbeknownst to \nme, at least one supervisory AUSA was engaging in plea discussions with counsel for Epstein \nwithout consulting with me, the agents, or the victims. These discussions led to the creation of the \nNPA — an agreement that allowed Epstein to plead guilty to state charges in exchange for immunity \nfor federal prosecution by the USAO for the Southern District of Florida. \nAfter the NPA was signed on September 24, 2007, when I attempted to notify the victims \nand enforce the agreement, the attacks became more personal. Epstein's attorneys raised the same \npolicy arguments — which could have been raised prior to signing the NPA — as high as the DAG's \nOffice, and coupled them with claims of prosecutorial misconduct. As these attacks occurred, the \nUSAO — U.S. Attorney Alex Acosta and later First Assistant U.S. Attorney Jeff Sloman offered \nEpstein the option of simply \"unwinding\"3 the NPA — after all, he had never performed any part \nof it. In my mind it was unfathomable that Epstein would be allowed to spend months attacking \nnot just the validity of our investigation and the validity of the NPA, but also makin\n... [truncated, 4027 chars — for the full page use /api/corpus/document/EFTA00225378/106 or ?id=EFTA00225378&page=106]", "char_count": 4027}, {"efta_number": "EFTA00225378", "page_number": 107, "text_content": "that the state offered, including work release. Because of this, I had to withdraw the Notice of \nBreach and could only write a letter to the Sheriff's Office pointing out all of the false statements \ncontained in Epstein's application for work release and letters to the victims informing them that \nEpstein was in work release status. The Sheriff's Office never responded to or acknowledged my \nletter. \nOn June 9, 2009, I prepared what I believe was the last Memorandum requesting \nauthorization to issue a Notice of Breach and to indict Epstein. The Office authorized issuance of \nthe Notice of Breach, and the Indictment Packs es was re-reviewed a roved, and signed, with \narrest warrants for Jeffrey Epstein, \nand \nThe Notice of Breach \nwas served on June 12, 2009 at a hearing on pstein's Motion to Dismiss one of the civil suits \nfiled by one of the victims identified during the federal investigation. Once again, Epstein was \nallowed to \"cure\" his breach, and we were not allowed to file the indictment. \nThere were strong internal disagreements on a number of subjects, including: the handling \nof the meetings with Epstein's counsel; plea negotiations; the NPA generally; the failure to consult \nwith the victims; continuing plea negotiations in the face of Epstein's clear bad faith; the refusal \nto defend me against personal attacks from Epstein's attorneys; the agreement to put off seeking \nEpstein's computer equipment; the consultations with Epstein's attorneys regarding victim \nnotifications; the handling of the \"appeals\" to Washington; allowing delays during those \"appeals,\" \nwhile Epstein's attorneys were harassing the victims and their family members; attempts by \nEpstein to renegotiate the term of imprisonment; attempts by Epstein to renegotiate the payment \nof damages to the victims and attorneys' fees to their attorney representative; allowing Epstein to \nparticipate in the work release program after specifically discussing it during plea negotiations; \nand repeat\n... [truncated, 3891 chars — for the full page use /api/corpus/document/EFTA00225378/107 or ?id=EFTA00225378&page=107]", "char_count": 3891}, {"efta_number": "EFTA00225378", "page_number": 108, "text_content": "set aside the NPA and see Mr. Epstein federally charged due to violations of the Crime Victims' \nRights Act. \nIn response to your questions, I have attempted to distill the past 13 years of emails, letters, \nresearch, pleadings, and conversations into a coherent document and attach the most relevant \nitems. Given the sheer volume of materials involved here and the passage of time, while I have \nworked diligently to answer your questions as fully as possible, I certainly could have missed \nsomething amongst the thousands of pages of emails, drafts, and hard copy and electronic \ndocuments. \nIf there are additional items or topics that need further explanation or more \ndocumentation, I can delve further. \nA. The Non-Prosecution Agreement \n1. Describe the circumstances under which the investigation of Jeffrey Epstein \nwas referred to the USAO, including when, why, how, and by whom the \nreferral was made. Explain why the USAO decided to initiate a federal grand \njury investigation into this matter, including what federal interests were \nperceived to be involved, and identify the individuals participating in the \ndecision. \nSome time in early 2006, FBI Special Agent E. Nesbitt Kuyrkendall approached me about \nan investigation being conducted by the Town of Palm Beach Police Department (\"PBPD\"). I do \nnot know how or when S/A Kuyrkendall was first contacted about the matter. \nThe first mentions of the investigation were just passing comments during meetings on \nother matters. S/A Kuyrkendall and I were working on a number of different child exploitation \nmatters at the time, along with ICE Special Agent David Malone. I remember generally that S/A \nKuyrkendall mentioned an investigation of a wealthy man who lived on Palm Beach and recruited \nminors for sexual activity. During these casual conversations, I do not believe that Mr. Epstein's \nname was mentioned. If it was mentioned, it held no significance for me. I recall that S/A \nKuyrkendall mentioned that PBPD had reached \n... [truncated, 3391 chars — for the full page use /api/corpus/document/EFTA00225378/108 or ?id=EFTA00225378&page=108]", "char_count": 3391}, {"efta_number": "EFTA00225378", "page_number": 109, "text_content": "girls and young women were coached to massage Mr. Epstein in various states of undress. The \nsexual activity varied and included: Mr. Epstein masturbating himself at the end of the massage; \nhaving the females masturbate him; Mr. Epstein fondling the females' breasts and genitalia; using \nsex toys on the females; digital penetration of the females; sexual intercourse with Mr. Epstein; \nand Mr. Epstein observing while one of the girls had sex with one of his assistants. At the end of \neach \"massage\" session, Mr. Epstein or one of his assistants would pay the female involved. If \nthe female involved in the massage was brought to Mr. Epstein's residence by a \"recruiter,\" then \nthe \"recruiter\" also would be paid. \nDetective Recarey did not have any information regarding any of the females traveling \ninterstate or internationally to engage in sexual activity, but Det. Recarey reported that Mr. Epstein \nand his assistants traveled in and out of the Palm Beach International Airport on Epstein's private \nairplane. Det. Recarey stated that flight logs he had seen sometimes referred to passengers as \n\"females,\" without names or ages, so it was possible that girls could have been on board, but Det. \nRecarey had not been able to confirm that. Det. Recarey stated that a search warrant had been \nexecuted on Mr. Epstein's residence and evidence had been seized, including message pads \nshowing calls from females confirming that they would be coming to \"work,\" which was the \neuphemism used for giving a \"massage\" — another euphemism for engaging in sexual activity for \nmoney. Det. Recarey also reported that it had appeared that Mr. Epstein had been \"tipped oft\" \nabout the coming search warrant because all of the computer CPUs had been removed from the \nresidence — the keyboards and screens were still in place, just the CPUs had been taken. Det. \nRecarey also reported that some surveillance cameras were in place but they had only recovered a \nlimited amount of surveillance video. Det.\n... [truncated, 3711 chars — for the full page use /api/corpus/document/EFTA00225378/109 or ?id=EFTA00225378&page=109]", "char_count": 3711}, {"efta_number": "EFTA00225378", "page_number": 110, "text_content": "I recommended that we begin the process of investigating whether there was a \njurisdictional basis for federal charges, and S/A Kuyrkendall and Det. Recarey concurred. Det. \nRecarey asked that Chief Reiter be given an additional opportunity to convince the State Attorney \nto charge Epstein.' I explained that opening a case file and beginning a federal investigation would \nnot preclude the State Attorney from charging Epstein. \nI then prepared the paperwork to open a file. The investigation was dubbed \"Operation \nLeap Year\" because there were approximately 29 young women and girls who had been identified \nthrough the State investigation. \nThere were several aspects of the case that involved federal interests. First, as to the \nsubstantive crimes that Epstein was accused of committing, they involved the victimization of \nminor females through the use of facilities of interstate commerce (telephones and airports); and \nEpstein was traveling interstate and internationally to come to the Southern District of Florida to \ncommit those offenses. During the course of the investigation, I often said that, if there were a \ntrial, I would tell the jury that Jeffrey Epstein traveled to Florida to use Royal Palm Beach High \nSchool as his personal brothel. Second, the removal of the computer equipment from Epstein's \nhome prior to the execution of the search warrant suggested possible public corruption at the Palm \nBeach County courthouse (where the search warrant application was signed) and also raised the \npossibility that Epstein may have been involved in the manufacture and/or possession of child \npornography. Eradication of child pornography was a particular focus of Project Safe Childhood; \nits production and storage on computer equipment involved the use of items produced in interstate \nand foreign commerce; and child pornography was often distributed through facilities of interstate \nand foreign commerce. Third, Det. Recarey was suggesting that political or other pressure \n... [truncated, 3974 chars — for the full page use /api/corpus/document/EFTA00225378/110 or ?id=EFTA00225378&page=110]", "char_count": 3974}, {"efta_number": "EFTA00225378", "page_number": 111, "text_content": "Assistant, Alex Acosta and Jeff Sloman, where I traveled to Miami and told them about the case. \nI recall that I explained the case and how the PBPD believed that Epstein had used political or \nother pressure to avoid serious punishment in Palm Beach County state court. That possibility \ntroubled me greatly; hence, my request to meet with executive management. Messrs. Acosta and \nSloman had the same reaction that I had the first time that Det. Recarey told me about Mr. Epstein \n— if I have never heard of him, how much influence could this person have? I remember \nspecifically saying to them that I expected the case would be time and resource-intensive and I did \nnot want to invest the time and the FBI's resources if the Office would just back down to pressure \nat the end. Messrs. Acosta and Sloman assured me that, if there was sufficient evidence to support \nthe case, Mr. Epstein would be charged appropriately.8\n2. Describe in detail your role, and the role of each other person in the USAO, \nthe Federal Bureau of Investigation (FBI), and elsewhere within the \nDepartment of Justice — collectively herein \"the government\" — who was \ninvolved in the assessment of the viability and strength of the federal case \nagainst Mr. Epstein and in the decision to negotiate a pre-indictment \nresolution of the case. \nMy Role \nI was the line AUSA assigned to the case. In conjunction with the case agents, I handled \nall aspects of the grand jury investigation — deciding what subpoenas to issue; whom to interview; \nwhom to call to testify before the grand jury; what lines of inquiry to pursue to support various \nlegal theories; I conducted legal research to support charges; I reached out to others throughout the \nDepartment and the federal government for information on previous investigations of Mr. Epstein, \nand for legal guidance on various aspects of the case (e.g., OEO, CEOS, SEC, SDNY, and \nAFMLS); along with the FBI agents and the FBI Victim-Witness Coordinator, I had direct cont\n... [truncated, 3711 chars — for the full page use /api/corpus/document/EFTA00225378/111 or ?id=EFTA00225378&page=111]", "char_count": 3711}, {"efta_number": "EFTA00225378", "page_number": 112, "text_content": "charges in federal court and a plea to state charges in state court). I was reprimanded for doing so. \nThus, as will be discussed in more detail below, I played no role in the decision to enter into a \nNon-Prosecution Agreement in exchange for Jeffrey Epstein's entry of a guilty plea to a state \ncharge requiring a sentence of 18 months' imprisonment or Epstein's plea to federal charges \nresulting in a maximum sentence of 18 months' imprisonment (as will be explained below, \nEpstein's counsel repeatedly changed their minds about whether to take the federal route or the \nstate route). Although I was tasked with drafting the agreements and Information, all of the \ndocuments were repeatedly and substantively revised by various supervisors, and I was responsible \nfor incorporating those edits. I also was asked to sign the Non-Prosecution Agreement. \nWhen Epstein sought to have the Non-Prosecution Agreement set aside by \"appealing\" the \nmatter to CEOS, the AAG, and the DAG, I handled the continued investigation of Epstein, \nincluding working with the FBI to identify additional victims, issue additional grand jury \nsubpoenas, and prepare an updated indictment package. At the request of the U.S. Attorney, I also \nresponded to inquiries from CEOS, the AAG, and the DAG's Office and drafted submissions on \nbehalf of the USAO in response to arguments raised by Epstein's attorneys. \nI believe that I prepared a first draft of the Addendum to the Non-Prosecution Agreement, \nbut others took the laboring oar on that document. I drafted numerous victim notification letters \nand responded to defense objections to those letters. I drafted the letter to the Special Master with \nthe USAO's recommendations for the qualities to look for in the attorney representative for the \nvictims. I monitored Epstein's compliance with the Non-Prosecution Agreement and served \nseveral breach notices. \nU.S. Attorney's Office Personnel \nAUSA Karen Atkinson (now retired): AUSA Atkinson was my direct superv\n... [truncated, 3375 chars — for the full page use /api/corpus/document/EFTA00225378/112 or ?id=EFTA00225378&page=112]", "char_count": 3375}, {"efta_number": "EFTA00225378", "page_number": 113, "text_content": "to legal arguments raised by Epstein's counsel. MAUSA Lourie also participated in \nconversations with the State Attorney, and directly participated in negotiations of the \nlanguage to be used in the Non-Prosecution Agreement, federal Plea Agreement, and \nInformation. He had numerous conversations with counsel for Epstein outside of my \npresence when they objected to my refusal to agree with their changes. MAUSA Lourie \nalso communicated with the U.S. Attorney about the negotiations. He would then \ncommunicate changes from the defense and the U.S. Attorney to me to incorporate. Later, \nwhen Epstein's attorneys appealed to AAG Alice Fisher, Mr. Lourie was on detail as AAG \nFisher's Chief of Staff and facilitated the meeting between Epstein's counsel and the AAG. \nAAG Fisher's written response was issued while MAUSA Lourie was still her Chief of \nStaff. I do not know who drafted the written response. \nActing MAUSA Rolando Garcia (still with the USAO): When MAUSA Lourie was on \ndetail with AAG Fisher's Office, Rolando Garcia was named the Acting MAUSA. He \nparticipated in at least one meeting with Epstein's attorneys and the State Attorney. Mr. \nGarcia also was involved in some of the negotiations regarding the language of the Non-\nProsecution Agreement. He later reviewed at least one of the iterations of the indictment \npackage and signed the indictment that was supposed to be presented to the grand jury in \nJune 2009. \nCriminal Chief Matthew Menchel (now in private practice): Criminal Chief Menchel \nwas the third line supervisor of the matter. Generally, West Palm Beach indictments are \nreviewed and approved by the MAUSA and are not reviewed by Miami. However, unusual \nor especially significant indictments are reviewed by the Criminal Chief. Criminal Chief \nMenchel reviewed and commented on the first proposed indictment package. His \ncomments were incorporated into a revised indictment, and he possibly reviewed those \nchanges. Criminal Chief Menchel participated in nu\n... [truncated, 3280 chars — for the full page use /api/corpus/document/EFTA00225378/113 or ?id=EFTA00225378&page=113]", "char_count": 3280}, {"efta_number": "EFTA00225378", "page_number": 114, "text_content": "of a crime. One of Epstein's attorneys also falsely accused FAUSA Sloman (and me) of \npromising money to a victim in exchange for her willingness to accuse Epstein. \nU.S. Aftorney R. Alexander Acosta (now Secretary of the U.S. Department of Labor): \nUSA Acosta served as the head of the U.S. Attorney's Office throughout the investigation \nof Jeffrey Epstein, including the decision to enter into a Non-Prosecution Agreement, \nnegotiation of its terms, and attempts to enforce its terms. When Epstein's attorneys were \ndissatisfied with answers they received from me, MAUSA Lourie, and FAUSA Sloman, \nthey would frequently contact USA Acosta directly. USA Acosta was directly involved in \nreviewing and revising the documents, including sending exact wording that he wanted \nincorporated into the agreement. There were some communications between USA Acosta \nand counsel for Epstein that I was not aware of at the time. For example, I did not know, \nuntil after I had sent a breach notice, that USA Acosta agreed that Epstein could be \nconsidered for work release. At some point after the NPA was signed, USA Acosta was \nrecused from the Epstein matter. \nAUSA John McMillan (still at USA0): Early in the investigation, I asked AUSA \nMcMillan if he would serve as co-counsel on the case. Before I joined the West Palm \nBeach Office, AUSA McMillan had handled the bulk of the child exploitation cases in \nWest Palm Beach. He and I discussed how to structure the investigation and he joined me \nin opposing meeting with Epstein's attorneys prior to the completion of the investigation. \nHe attended some of the meetings with Epstein's attorneys. When the Office overruled \nour positions and when it appeared that the case was not going to be charged, AUSA \nMcMillan decided that he should focus on other cases. \nAUSA Bruce Reinhart (now U.S. Magistrate Judge): AUSA Reinhart was my office \nneighbor and colleague. At one point early in the investigation (I believe before I asked \nAUSA McMillan to serve\n... [truncated, 3114 chars — for the full page use /api/corpus/document/EFTA00225378/114 or ?id=EFTA00225378&page=114]", "char_count": 3114}, {"efta_number": "EFTA00225378", "page_number": 115, "text_content": "SLC Dexter Lee (still at USAO): SLC Lee was not directly involved in the Epstein \ninvestigation or negotiation of the NPA, but he has been lead counsel in the Jane Doe'. \nUnited States litigation. SLC Lee had contact with USA Acosta regarding his recusal, and \nwith FAUSA Sloman and myself regarding self-reports to OPR about accusations of \nmisconduct raised by Epstein's counsel. I also had contact with SLC Lee regarding a \nFlorida Bar Complaint filed by a civil attorney for some of the victims who complained \nthat my victim notification letters amounted to inappropriate business referrals to the \nattorney selected by the Special Master.1°\nAppellate SLC Anne Ruth Schultz (still at USAO): SLC Schultz was not directly \ninvolved in the Epstein investigation or negotiation of the NPA. It is my understanding \nthat USA Acosta asked SLC Schultz to check my legal analysis. I also understand that \nCriminal Chief Matt Menchel contacted SLC Schultz about moving me to Appeals after I \npointed out actions that I considered to be in violation of the Ashcroft memo and victims' \nrights legislation. I also understand that SLC Schultz may have knowledge of USA Acosta \nproviding my prosecution memorandum to Criminal Appellate Chief Patty Stemler at Main \nJustice. \nShawn Ball (still at USAO): My legal assistant during most of the Epstein investigation \nand its aftermath. She assisted with preparing indictment packages, victim notification \nletters, grand jury subpoenas, travel, expert witness contracts, and other items. \nCyndee Campos/Annette Castillo (both still at USAO): Executive assistants to AUSA \nAcosta and FAUSA Sloman. They compiled correspondence between the USAO and \ncounsel for Epstein; scheduled meetings; and dealt with inquiries from the press and DOJ. \nThey may have information related to correspondence or communications between the \nExecutive Division and Epstein's counsel that I am unaware of. \nFBI Personnel \nS/A Nesbitt Kuyrkendall (retired from FBI): Lead case agent on\n... [truncated, 2821 chars — for the full page use /api/corpus/document/EFTA00225378/115 or ?id=EFTA00225378&page=115]", "char_count": 2821}, {"efta_number": "EFTA00225378", "page_number": 116, "text_content": "S/A Jason Richards (still at FBI): Co-case agent with S/A Kuyrkendall. Became lead \ncase agent during the post-guilty plea period (i.e., the interview of \nresponding to FOIA requests, etc.). He conducted interviews, prepared reports, analyzed \nrecords, and communicated directly with victims. S/A Richards also participated in \nmeetings with some of the senior members of the USAO and counsel for Epstein. \nS/A Tim Slater (still at FBI): Co-case agent with S/A Kuyrkendall until he was \ntrans \nI e conducted interviews, including the original telephone interview \nwith \nwhere she asked that the FBI have no further contact with her. He \nalso prepared reports and analyzed records. \nGroup Supervisor Eliasib (\"Junior\") Ortiz (still at FBI): GS Ortiz supervised S/As \nKuyrkendall, Richards, and Slater. He also participated in meetings with some of the senior \nmembers of the USAO and counsel for Epstein. \nASAC Valerie Parlave (still at FBI): ASAC Parlave supervised GS Ortiz. She attended \nthe July 26, 2007 meeting where Criminal Chief Menchel announced the two-year plea \noffer. \nS/A \nPryor: S/A Pryor participated in the interview of \nin \nAustralia. \nS/A Gavin Gumbiner (still at FBI): S/A Gumbiner was the case agent on Operation \nStolen Globe, which involved the investigation of Alfredo Rodriguez (Jeffrey Epstein's \nbutler), who tried to sell evidence to Brad Edwards. \nGroup Supervisor Michael Donohoe (retired from FBI): GS Donohoe replaced GS \nOrtiz as head of the violent crime group during the post-guilty plea period. He supervised \nS/As Richards, Pryor, and Gumbiner. \nVictim-Witness Coordinator Twiler Smith: Ms. Smith sent letters to victims, met with \nthem in person. and assisted in finding counseling and other services for them. \nJustice Denar ment Personnel \nCEOS Deputy Chief \nGelber (still at DOJ): Ms. Gelber was part of the team \nthat reviewed the case and the NPA when Epstein \"appealed\" to DOJ. Ms. Gelber also is \nfamiliar with my work from a prior case that she and I wor\n... [truncated, 2355 chars — for the full page use /api/corpus/document/EFTA00225378/116 or ?id=EFTA00225378&page=116]", "char_count": 2355}, {"efta_number": "EFTA00225378", "page_number": 117, "text_content": "counsel for Epstein. I conferred with Mr. Oosterbaan about charging, staffing, and victim-\nrelated issues. \nCEOS Trial Attorney Myesha Braden (now at a non-profit): I first had contact with \nMs. Braden when conducting research regarding some of the legal issues raised by the case \n(she was the CEOS Duty Attorney on the day that I called). After AUSA McMillan left \nthe case, I contacted Mr. Oosterbaan about having a CEOS Trial Attorney co-chair the case \nand asked if Ms. Braden was available. She participated in interviews, discussed case \nstrategy, and reviewed pros memos and indictments. \nCriminal Appellate Chief Patty Stemler (still at DOJ): At various times, I have heard \nthat USA Acosta provided my pros memo to Chief Stemler and asked her to review my \nlegal analysis. I have never asked Chief Stemler whether this actually occurred. SLC Anne \nSchultz may know whether this occurred. \nAAG Alice Fisher (now in private practice): After CEOS rejected the \"appeal\" from \nMr. Epstein's attorneys, they asked for further review by AAG Fisher. She met with the \nattorneys and prepared a written opinion rejecting Epstein's arguments. \nSenior Associate Deputy Attorney General John Roth (now private in-house counsel): \nFollowing AAG Fisher's rejection, Epstein's attorneys asked for review by the DAG. I do \nnot know whether Epstein's counsel met with the DAG, but they did present arguments to \nMr. Roth, who was Chief of StafPSr. Associate Deputy Attorney General. Mr. Roth wrote \na letter rejecting Epstein's arguments. \nDeputy Attorney General Mark Filip (now in private practice): Mark Filip was the \nDeputy Attorney General to whom Mr. Epstein's arguments were addressed. As noted \nabove, I do not know if Mr. Filip met with Epstein's counsel, or if the meetings were only \nheld with Mr. Roth. \nOthers Whose Counsel I Sought During the Case: \nAssistant U.S. Attorney Susan Roe (still an AUSA in Seattle): AUSA Roe was not \ninvolved in the Epstein investigation. During the pendency of t\n... [truncated, 2631 chars — for the full page use /api/corpus/document/EFTA00225378/117 or ?id=EFTA00225378&page=117]", "char_count": 2631}, {"efta_number": "EFTA00225378", "page_number": 118, "text_content": "Assistant U.S. Attorney E.J. Yera (still at DO.)): Mr. Yera and I were dating at the time \nof the Epstein investigation. (We are now married.) He was a more senior AUSA who \nwas familiar with some of Epstein's counsel. I sought his advice on some of the issues —\nlegal and non-legal — that arose during the case. \nAssistant U.S. Attorney Lynn Kirkpatrick (still at the USAO): Ms. Kirkpatrick and I \nare friends from my time in Miami. She was a supervisor in Miami although not in my \nchain of command. I would often speak or email with her just for advice. \n3. Explain fully the process and circumstances leading to the decision to resolve \nthe case through a non-prosecution agreement (sometimes referred to by \ndefense counsel and the government as a deferred prosecution agreement, but \ndescribed herein as the non-prosecution agreement). \nExplain why the \ngovernment initially prepared to resolve the case through a federal plea \nagreement, but ultimately did not require Mr. Epstein to enter a plea in federal \ncourt. The explanation should identify the parties involved in the decision, the \nindividual(s) responsible for all final decisions regarding the non-prosecution \nagreement and its terms, and the basis for the decision to resolve the case \nthrough a non-prosecution agreement. \nLet me preface with some background on how I normally handle investigations and \nprosecutions. When undertaking investigations, my normal practice is to meet with agents, confer \nwith them about an investigative plan, and work together until the case is ready for indictment. I \nupdate my supervisors along the way, seek advice or guidance from supervisors and colleagues if \nan issue is especially complex or novel, and get approval for actions as required by the USAM, \nbut I have always focused on learning as much as possible about the subject area, the defendant, \nand the facts related to the alleged crime — I want to be the subject matter expert in the courtroom. \nThen, once all of those items are\n... [truncated, 3334 chars — for the full page use /api/corpus/document/EFTA00225378/118 or ?id=EFTA00225378&page=118]", "char_count": 3334}, {"efta_number": "EFTA00225378", "page_number": 119, "text_content": "My confidentiality rule extends to pm-indictment communications with defendants and \ntheir attorneys. In cases where defendants are considered a flight risk, I generally have no contact \npre-indictment. If proven, the crimes under investigation created a statutory presumption that the \ndefendant was a risk of flight and a danger to the community, and Epstein had virtually unlimited \nresources to flee.'2\nOur effort to maintain the confidentiality of the investigation was thwarted almost \nimmediately by PBPD Chief Reiter. On July 24, 2006, Chief Reiter sent letters to some of the \nvictims identified in the state investigation informing them that the State Attorney's Office had \ndecided to proceed on a single charge of solicitation of prostitution. (Exhibit 6.) Chief Reiter \nencouraged the victims to contact the State Attorney's Office with any complaints about the \nhandling of the matter. Chief Reiter then felt the need to disclose that he did \"not feel that justice \nhas been sufficiently served by the indictment that has been issued. Therefore, please know that \nhis [sic] matter has been referred to the Federal Bureau of Investigation to determine if violations \nof federal law have occurred.\" (Id.). While Chief Reiter did not mention the USAO, Epstein's \ncounsel certainly understood that engaging the FBI meant engaging the USAO. Chief Reiter's \nactions were published in the local newspaper. (Exhibit 7.) \nBecause the federal investigation had been exposed by Chief Reiter, there was no ability \nto operate covertly, so we began serving subpoenas on persons and entities affiliated with Epstein. \nBeginning on August 2, 2006, a number of grand jury subpoenas were issued for bank information, \ninformation related to travel on Epstein's airplanes, school attendance records, rental car \ninformation, and other information that would corroborate statements made by victims (see Exhibit \nA-1). A subpoena also was issued for all of the evidence collected by the PBPD (see id.). Vic\n... [truncated, 3923 chars — for the full page use /api/corpus/document/EFTA00225378/119 or ?id=EFTA00225378&page=119]", "char_count": 3923}, {"efta_number": "EFTA00225378", "page_number": 120, "text_content": "and in a way contradicted by other witnesses and evidence. The hiring of Eisenberg, the insistence \non 6001 immunity — something that I had never faced before or since for a child victim — and the \nfalse exculpatory statements — all showed me how the defense would be approaching this case. \nThe subpoenas and interviews apparently concerned Epstein because soon after I began \ntrying to set up Individual #28's testimony, Epstein hired former U.S. Attorney Guy Lewis, who \nbegan contacting me by phone and email, asking to meet with me. I declined to meet because it is \nmy policy not to meet during the pendency of a child exploitation investigation. Mr. Lewis \nexpressed his client's willingness to cooperate with the investigation. (Exhibit 10.) \nWhen Mr. Lewis was unable to set a meeting, Epstein hired Lilly Ann Sanchez, another \nformer AUSA from the Miami USAO. Ms. Sanchez began calling and emailing me in early \nNovember 2006. (Exhibit 11). Ms. Sanchez also expressed Epstein's interest in \"cooperating\" \nwith the investigation. I knew that feigned cooperation would be used to ask for pre-trial release, \nso I tested the veracity of the offer of cooperation by asking for documents that would disprove \nmany of Epstein's defenses.13 Sure enough, Ms. Sanchez objected to the requests as \"overbroad.\" \nI politely declined the request for a meeting and then delayed setting up the requested meeting so \nthat I would have time to complete the investigation. My co-counsel, John McMillan, and I agreed \nthat a meeting at this early stage offered no benefit for us and only benefitted the defense. \nWhen Ms. Sanchez could not set a meeting with me, she skipped my immediate supervisor \nand contacted MAUSA Andy Lourie whom she knew from their time together in Miami. MAUSA \nLourie told AUSA McMillan and me that he had agreed to meet with Ms. Sanchez and Gerald \nLefcourt. AUSA McMillan and I told MAUSA Lourie that we had made a conscious decision not \nto meet with Epstein's attorneys and that\n... [truncated, 4014 chars — for the full page use /api/corpus/document/EFTA00225378/120 or ?id=EFTA00225378&page=120]", "char_count": 4014}, {"efta_number": "EFTA00225378", "page_number": 121, "text_content": "the auditorium to a more private area because I did not think it was a conversation meant for public \nconsumption but they would not move. As the PSC Coordinator, I had overseen the invitations \nfor the law enforcement representatives from the S.D. Fla., and Mr. Krischer had not been on the \nlist. So I now wonder whether this \"random\" meeting was staged by Epstein. \nAs you will see from the timeline (Exhibit A-1), in late January 2007, I created a file folder \nentitled \"Research re NPAs and 6001 immunity.\" (Exhibit 15.) This was not research related to \nNon-Prosecution Agreements in connection with resolving the case against Epstein. In November \npoenas were served on two other Epstein employees — Janusz Banasiak \nBoth initially asked for immunity. After speaking with Banasiak's \nattorney, \nr. anasi \nwas satisfied with a standard Kastigar letter, but Ms. Mucinska's attorney \nwas insistent on formal immunity, and as noted above, so was Individual #28. I don't believe that, \nprior to this investigation, I had ever prepared a request for 6001 immunity, so I was researching \nthe process. \nThe meeting with Ms. Sanchez and Mr. Lefcourt was set for February 1, 2007. As noted \nabove, despite Ms. Sanchez' statements of Epstein's willingness to cooperate, she complained that \nmy document requests were \"overbroad,\" so MAUSA Lourie and I drafted a more specific list \n(Exhibit 14).14 Ms. Sanchez also asserted that Epstein had hired attorneys for all of his current \nand prior employees, but refused to provide me with a list of those employees and attorneys, \nwanting me to give her essentially a roadmap of my investigation. I refused (Exhibits 14 and A-\n1). Instead, the agents and I continued to press forward with our investigation and I continued my \nextensive legal research in preparation for the meeting with Sanchez and Lefcourt. \nAlthough materials were supposed to be provided in advance, the \"talking points\" for the \nmeeting with Sanchez and Lefcourt did not arrive until the \n... [truncated, 3390 chars — for the full page use /api/corpus/document/EFTA00225378/121 or ?id=EFTA00225378&page=121]", "char_count": 3390}, {"efta_number": "EFTA00225378", "page_number": 122, "text_content": "to corroborate our victim statements and to undermine Epstein's potential defenses through \nsubpoenas for a wide variety of documents (see Exhibit A-1). Subpoenas also were issued to some \nvictims for photographs, gifts, and other records of direct or indirect contact with Epstein (see id). \nPresentation of background information to the grand jury began in February 2007 (Exhibits 17, \n18, and 20). \nI continued to research potential charges against Epstein. Again, knowing how Epstein's \nattorneys would likely approach any trial in this matter, I wanted to prepare both a strong offense \n— by including all relevant charges for jury consideration and possible plea negotiations — and a \nstrong defense — by including charges that would allow the admission of the widest range of \nrelevant evidence. With that mindset, I researched money laundering and racketeering offenses in \nChapter 95 because I knew that prostitution was a racketeering offense (see Exhibit 56). In \naddition to the IRS, I conferred with an attorney at the Asset Forfeiture and Money Laundering \nSection in DC who opined that Epstein's conduct could be a violation of 18 U.S.C. § 1960 and 2 \nor another currency offense because he caused the interstate transmission of funds related to \nprostitution (see Exhibit 57).16\nThe investigation continued at a brisk pace with Epstein's attorneys frequently seeking \nreviews from Messrs. Lourie and Menchel (see, e.g., Exhibit 58). [NB: They completely excluded \nmy immediate supervisor, Karen Atkinson, throughout the process.] Because of this, and because \nthe grand jury was very interested in the case, I tried to keep the Miami office up to date on what \nwas happening. There also had been little feedback from Miami to the proposed indictment that \nhad been provided in late April/early May. So, for example, on May 14, 2007,1 emailed Menchel \nand Lourie about Epstein's travel and asked whether I would be permitted to present the indictment \nthe following day or proceed by w\n... [truncated, 3467 chars — for the full page use /api/corpus/document/EFTA00225378/122 or ?id=EFTA00225378&page=122]", "char_count": 3467}, {"efta_number": "EFTA00225378", "page_number": 123, "text_content": "having heard nothing in response to my 5/18/2007 email, I issued the subpoena to the private \ninvestigator (Exhibit 59). \nThe following day, May 22, 2007, Mr. Lefcourt sent a letter to MAUSA Lourie stating: \nI understand from you that in the next month or two a decision will be made by \nyour office whether to seek an indictment of Mr. Epstein. This will confirm that, \nprior to any such decision being made, I and other attorneys on behalf of Mr. \nEpstein will be given an opportunity to meet with you. \nAdditionally, . . . if our meeting does not resolve the matter, we would like an \nopportunity to make a presentation first to Matthew Menchel, Chief of the Criminal \nDivision, and Jeffrey Sloman, First Assistant United States Attorney, and then, \nagain, if no resolution is reached, the opportunity to meet with United States \nAttorney Alexander Acosta. \n(Exhibit 28.) \nAUSA McMillan and I were not part of the conversation where MAUSA Lourie disclosed \nthe timeline to Mr. Lefcourt, so I was surprised by the letter, which sought multiple opportunities \nto meet with members of the Executive Division. Mr. Lourie responded, again, without meeting \nwith AUSA McMillan or me, stating: \"I think we are on the same page . . . I did say that if you \nwant 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. \nEpstein. If that was your understanding, then please allow me to clarify. Our investigation is \nongoing and if we decide to seek an indictment, we don't intend to call Mr. Epstein's \nrepresentatives to let him know that. Of course, in the interim, if you would like to make a \npresentation to us, we are willing to listen. ...\" (Id.). \nI strenuously objected and drafted an email setting forth the reasons why (id.). I shared it \nwith my supervisor and she advised me not to send it. I orally advised MAUSA Lourie that I \nobjected to meetings, delays, and \n... [truncated, 3398 chars — for the full page use /api/corpus/document/EFTA00225378/123 or ?id=EFTA00225378&page=123]", "char_count": 3398}, {"efta_number": "EFTA00225378", "page_number": 124, "text_content": "meeting, Chief Menchel told the defense attorneys that they needn't address the money laundering \nstatutes. I think he referred to them as \"silly,\" without even having the benefit of my conversations \nwith IRS and AFMLS and my legal research.18 \nSo Epstein's counsel focused on the child \nexploitation statutes. They falsely insisted that the use of the interne was needed for a 2422(b) \ncharge and that some sort of force, fraud, or coercion was required for a 1591 charge because 16-\nand 17-year-old girls were \"adults.\" They stated that there was no federal law prohibiting sex with \nchildren and one would be unconstitutional. \nAfter the meeting, MAUSA Lourie and I analyzed the materials (Exhibit 32). We both \nconcluded that the defense had overstated the strength of their position (id.). MAUSA Lourie felt \nthat the 2422(b) charges were stronger than the 2423(b) charges because we would need proof that \nhaving a sexual massage was a motivation for Epstein's travel (id.). My research showed that \ndifferent circuits had different standards of proof on the \"purpose of travel\" element (id). I never \nreceived any feedback from Chief Menchel or FAUSA Sloman regarding Lefcourt's written \npresentation, but after the June 26, 2007 meeting, I was left with the impression that we were \ncontinuing towards indictment. \nOn July 3, 2007, at 6:26 a.m., I sent an email to Jeff Sloman, Matt Menchel, and Andy \nLourie advising them about calls I had received from Lilly Ann Sanchez seeking to delay subpoena \nresponses and their plans to present our Office with additional analysis as well as their planned \nresolution with the State Attorney's Office (Exhibit 3). I informed everyone of my proposed \nresponse regarding the subpoenas and that I intended to invite Lilly Ann Sanchez to call me to \ndiscuss a resolution of the federal investigation that could include concurrent time, i.e., a plea to a \nfederal charge with a recommendation that the federal sentence would run concurrently with the \nst\n... [truncated, 3965 chars — for the full page use /api/corpus/document/EFTA00225378/124 or ?id=EFTA00225378&page=124]", "char_count": 3965}, {"efta_number": "EFTA00225378", "page_number": 125, "text_content": "number of legal issues. Despite being told these things, you prepared a pros memo and indictment \nthat included a definitive date for indictment.\" (Id.) Mr. Menchel also told me that my arguments \nthat he had violated the Ashcroft memo, the USAM and other policies were not well taken because, \nas \"Chief of the Criminal Division, I am the person designated by the US Attorney to exercise \nappropriate discretion in deciding whether certain pleas are appropriate and consistent with the \nAshcroft memo and the USAM — not you.\" (Id.) Mr. Menchel also told me that I could not dictate \na meeting. (Id.) \nOn July 6, 2007, Gerald Lefcourt sent another letter further explaining why Epstein should \nnot be charged with violations of § 2422(b) (Exhibit 33). Most of the letter raised policy arguments \nand the letter ended by expounding on Mr. Epstein's good works (id.). \nOn July 13, 2007, after I finished my trial, I responded to Mr. Menchel's reprimand, noting \nmy frustration over the Office's failure to provide me with any guidance on its position on the \nmatter.19 I pointed out that I had handled this case the same as I had handled all of my other cases, \nby working with the agents to gather evidence and preparing an indictment package that \nestablished not just probable cause but proof beyond a reasonable doubt. I re-iterated that I was \n\"asking to have the same courtesy that was extended to the defense attorneys extended to the FBI \nand an Assistant in the Office. ... [And,] my first and only concern in this case . . . is the victims. \nIf our personality differences threaten their access to justice, then please put someone on the case \nwhom you trust more, and who will also protect their rights.\" (Id.) Mr. Menchel never responded; \nnor did he allow me to make my requested presentation to USA Acosta. I do not know whether \nhe shared my request with FAUSA Sloman or USA Acosta. \nAlso on July 13, 2007, I received a letter from Roy Black complaining about the grand jury \nsubpoena se\n... [truncated, 3671 chars — for the full page use /api/corpus/document/EFTA00225378/125 or ?id=EFTA00225378&page=125]", "char_count": 3671}, {"efta_number": "EFTA00225378", "page_number": 126, "text_content": "After these exchanges and being reprimanded by Criminal Chief Menchel for raising those \nobjections, I was not consulted again about a pre-indictment plea. On July 26, 2007, agents and \nsupervisory personnel from the FBI and I traveled to a scheduled meeting with Chief Menchel in \nMiami. That morning, before departing for Miami, I sent an email to Mr. Menchel and MAUSA \nLotuie that read, \"in advance of our meeting this afternoon, I wanted to let you know my thoughts \nabout some of the recommended changes [to the indictment] that we had discussed the last time I \nwas in Miami . . .\" (Exhibit 64). The FBI agents, their supervisor, their ASAIC, and I met with \nMr. Menchel. Criminal Chief Menchel entered the meeting and announced to us that \"Alex \n[Acosta] has decided to offer a two-year state plea.\" We were not asked our opinions and the \nmeeting ended soon thereafter (see Exhibit 5). I remember feeling stunned. I don't remember \nsaying anything at the meeting. \nIn an attempt to provide some benefits to the victims and protections to the public, I asked \nthat two terms be added to this two-year deal: (1) that the victims be provided compensation via \n18 U.S.C. § 2255 as a substitute for restitution because Epstein was pleading to state charges; and \n(2) that Epstein be required to plead guilty to an offense requiring sex offender registration. The \nOffice agreed to add these two terms. On July 31, 2007, I finalized a term sheet, entitled \n\"CONFIDENTIAL PLEA NEGOTIATIONS: TERMS OF EPSTEIN NON-PROSECUTION \nAGREEMENT.\" (Exhibit 4.) On the same date, it was provided to counsel for Epstein. Present \nat the meeting for the government were FAUSA Jeff Sloman, Criminal Chief Matt Menchel, \nMAUSA Andy Lourie, S/A Nesbitt Kuyrkendall, S/A Jason Richards, and myself, and for Epstein \nwere Roy Black, Gerald Lefcourt, and Lilly Ann Sanchez. (See Exhibit 5.) At the meeting, counsel \nfor Epstein stated that their client would not consider a plea that required state jail time. During \n\n... [truncated, 3949 chars — for the full page use /api/corpus/document/EFTA00225378/126 or ?id=EFTA00225378&page=126]", "char_count": 3949}, {"efta_number": "EFTA00225378", "page_number": 127, "text_content": "to West Palm Beach, I advised Mr. Oosterbaan that I had worked with CEOS Trial Attorney \nMyesha Braden on some of the legal issues and that, if there were a trial, I was hoping she might \nbe able to assist (Exhibit 43). \nIn preparation for the planned meeting on September 7, 2007, FAUSA Sloman emailed me \nto ask what the status of the plea negotiations were. I wrote: \nHere is the term sheet and guidelines calculation that we provided at the last \nmeeting. You and Matt and I had also discussed a possible federal plea to an \nInformation charging a 371 conspiracy, with a Rule 11 plea with a two-year cap, \nbut I think Matt must have asked Alex about it and it was nixed. Just to be prepared \nfor tomorrow, I was just starting to draft a Rule 11 Plea agreement in case Alex \nchanges his mind and a formal non-prosecution agreement containing the state plea \nterms. . . . There are three concerns that I hope we can address tomorrow. . . . \n[including] that 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. \n(Exhibit 44). \nOn September 7, 2007, USA Acosta, FAUSA Sloman, CEOS Chief Oosterbaan, AUSA \nMcMillan, and I met with Kenneth Starr, Jay Lefkowitz, and Lilly Ann Sanchez (Exhibit 5). At \nthe meeting, Mr. Starr focused primarily on federalism/policy arguments, and Mr. Epstein's \nbackground. I remember Mr. Starr thanking me for bringing § 2255 to their attention and that it \nwould allow a state resolution that still provided the equivalent of federal restitution. \nFollowing the meeting, there were communications between Gerald Lefcourt, USA \nAcosta, and MAUSA Lourie that I was not privy to. The fact of the conversations was mentioned \nin later emails. Based upon those communications, on September 10, 2007, I was asked to send \nMr. Lefcourt an office response to Lefcourt's counterproposal (see Exhibit 47 (\"Gerry: As per \nyour discussion with U.S. Attorney Acosta, I have attached the Office'\n... [truncated, 3192 chars — for the full page use /api/corpus/document/EFTA00225378/127 or ?id=EFTA00225378&page=127]", "char_count": 3192}, {"efta_number": "EFTA00225378", "page_number": 128, "text_content": "Krischer, ASA Belohlavek, Jay Lefkowitz, Gerry Lefcourt, and Jack Goldberger (Exhibit 5). The \npurpose of the meeting was to finalize and coordinate the terms of the state and federal agreements. \nMr. Lefkowitz still expressed some interest in having Epstein serve his time in a federal facility, \nrather than a state one, and I remember Mr. Goldberger saying that because Mr. Epstein's home \nwas on Palm Beach Island and touching the Intracoastal Waterway, it was somehow in \n\"international waters\" and federal jurisdiction. Other items that were discussed were: (1) that the \nstate crime that Epstein agreed to plead guilty to was one requiring sex offender registration; and \n(2) that Epstein would be incarcerated 24-7 during the 20-month period of imprisonment. We left \nthe meeting with an understanding that Epstein's counsel would contact us about whether Epstein \nwanted to plead to federal charges pursuant to a plea agreement or proceed with the Non-\nProsecution Agreement. With that in mind, on September 13, 2007, I sent an email to USA Acosta, \nFAUSA Sloman, MAUSA Lourie, Rolando Garcia, and Karen Atkinson advising them that I had \nresearched three potential federal charges that could be used for Epstein, but they would all result \nin a 24-month maximum. If Epstein's counsel rejected those charges because of the 24-month \nexposure, I recommended reconsidering a binding Rule 11 plea \"rather than try to create violations \nout of whole cloth\" (Exhibit 46 at 19). I provided a proposed plea agreement and information \ncontaining two counts of violations of 18 U.S.C. § 403. \nMr. Lourie wrote to me later on September 13, 2007, \"He is going to give us an assault on \nthe plane or we can do conspiracy\"20 (Exhibit 46 at 21). I responded, \"It would still have to be a \nconspiracy to commit an assault on a plane. I just want to make sure that we have something that \nis factually accurate. Just trying to plan ahead\" (id). At Jay Lefkowitz's request, MAUSA Lourie \nand I scheduled a co\n... [truncated, 4024 chars — for the full page use /api/corpus/document/EFTA00225378/128 or ?id=EFTA00225378&page=128]", "char_count": 4024}, {"efta_number": "EFTA00225378", "page_number": 129, "text_content": "The agreement was finally completed and signed on September 24, 2007. \n4. Explain fully the process and circumstances leading to the development of the \nfollowing terms of the non-prosecution agreement: \na. an 18-month period of incarceration in a state facility, including the \nbasis for the determination that it sufficiently satisfied the federal \ninterest in the case; \nAs noted above, the only information that I received was from Mr. Menchel's \nannouncement that USA Acosta had decided to offer a two-year state deal. I do not know how \nMessrs. Menchel and Acosta determined that two years' incarceration sufficiently satisfied the \nfederal interest in the case. During one meeting, Epstein's attorneys raised the possibility of a \nstate-court plea with home confinement. USA Acosta specifically rejected the suggestion, noting \nthat confinement in Mr. Epstein's home was not equivalent to incarceration. As discussed above, \nthe 24-month term was reduced to 20 months and then, finally, to 18 months. \nb. victim restitution, including why and how to address victims' rights \nthrough 18 U.S.C. § 2255; \nThe federal crimes that were under investigation all called for mandatory or discretionary \nrestitution under 18 U.S.C. §§ 3663 and 3663A.2' \nGelber and Drew Oosterbaan from \nCEOS are experts in this area, but as PSC Coordinator, \new that restitution in child exploitation \ncases was a hot-button issue at the time. \nThe District of Alaska USAO had a multi-victim child exploitation case with a wealthy \ndefendant (Boehm) where they had set up a trust fund with a bank and a trustee. With Drew \nOosterbaan's help, I explored setting up a similar situation in the Epstein case (Exhibit 48), in \nconnection with using a guardian ad litem (\"GAL\") for the victims,22 if there had been a plea to \nfederal charges. In cases like the Epstein cases, using a GAL seemed the most prudent course \nbecause, to the extent that the victims' interests ever diverged from the government's, the GAL \ncould ad\n... [truncated, 3499 chars — for the full page use /api/corpus/document/EFTA00225378/129 or ?id=EFTA00225378&page=129]", "char_count": 3499}, {"efta_number": "EFTA00225378", "page_number": 130, "text_content": "Alaska. The trust fund agreement was very complex and required a bank to agree to serve as the \nholder of the corpus and a trustee to oversee the administration of the trust, as well as the Court to \nenter an order setting up the trust and a mechanism for resolving disputes amongst beneficiaries \nor between a beneficiary and the trustee. \nIn light of the amount of details and the number of victims involved, and the simple fact \nthat, if there was only a state plea, there would be no federal judge to undertake the process, I knew \nthat there was no way to accomplish a trust fund like Boehm within the confines of the NPA. In \nthe Boehm case, there was a much smaller number of victims and, if I remember correctly, the \nvictims were younger. The Alaska AUSA was able to confer with Boehm's victims and obtain \ntheir consent to the trust agreement procedure in advance of entering into the plea agreement. The \nAlaska AUSA also obtained the defendant's agreement to proceed ex pane. Our situation was \nquite different. There were more victims with disparate interests. In my emails, I made it clear \nthat I could not bind the victims to such a procedure because I did not represent them. For example, \nhow would the USAO decide on the size of the corpus of the trust? Would the USAO hire expert \npsychologists to evaluate the victims and economists to quantify their losses? If the USAO picked \na number, would that preclude a victim from bringing a state tort claim? Would every victim \nreceive the same amount? This is not how criminal restitution works — normally after a guilty \nplea, the Court's Probation Office works with victims to calculate losses, and issues are litigated \nat sentencing or within 90 days after sentencing. Lefkowitz was asking the USAO to pick a number \nvirtually out of thin air to use as the corpus of the trust for a group of victims who were not clients \nof the USAO. We also would have to locate an independent bank to serve as the hold of the corpus. \nGiven how\n... [truncated, 3999 chars — for the full page use /api/corpus/document/EFTA00225378/130 or ?id=EFTA00225378&page=130]", "char_count": 3999}, {"efta_number": "EFTA00225378", "page_number": 131, "text_content": "to the attention of others, they thought I was mis-citing 28 U.S.C. § 2255 and I had to explain that \nthere actually was an 18 U.S.C. § 2255, which was a civil provision within the criminal code. \nI do not know when I first discussed the possibility of using § 2255 as a replacement for \nthe victims' lost restitution benefits, but I know that I conducted research on § 2255 cases on July \n27, 2007 (Exhibit 37). That was the day after the meeting where Criminal Chief Menchel had \nannounced that USA Acosta had decided to offer Epstein a two-year state plea (Exhibit 5). \nLanguage regarding § 2255 was included in the plea agreement term sheet provided to \nEpstein's counsel on July 31, 2007 (Exhibit 38). The issue must have been raised in advance of \nthe meeting, because that was the first meeting attended by Ken Starr, and he specifically thanked \nme for bringing § 2255 to their attention. On August 2, 2007, Lilly Ann Sanchez sent a letter to \nCriminal Chief Menchel making a series of counterproposals including: \"Application of 18 U.S.C. \n§ 2255\" (Exhibit 40 at 2). Ms. Sanchez went on to explain: \n18 U.S.C. 2255 provides that any minor who suffers injury as a result of the \ncommission of certain offenses shall recover actual damages and the cost of any \nsuit. It is important to note that Mr. Epstein is prepared to fully fund the identified \ngroup of victims which are the focus of the Office — that is, the 12 individuals noted \nat the meeting on July 31, 2007. This would allow the victims to be able to \npromptly put this behind them and go forward with their lives. If given the \nopportunity to opine as to the appropriateness of Mr. Epstein's proposal, in my \nextensive experience in these types of cases, the victims prefer a quick resolution \nwith compensation for damages and will always support any disposition that \neliminates the need for trial (id. at n.1). \nThus, the use of § 2255 as a replacement for restitution was not controversial — it was \npromoted by Epstein's own\n... [truncated, 3633 chars — for the full page use /api/corpus/document/EFTA00225378/131 or ?id=EFTA00225378&page=131]", "char_count": 3633}, {"efta_number": "EFTA00225378", "page_number": 132, "text_content": "ges against an \nco \n, \nem, including but not limited to \nAdriana Ross, \nor \n\" (Exhibit 52 at 5). To the extent \nthat there was a \"criminal organization,\" the Office and the investigators considered Epstein to be \nthe head of that organization. He was certainly the most culpable individual, and we did not \nforesee any scenario where we would defer prosecution against Epstein but proceed to prosecute \nhis subordinates. Also, while the agreement included the language \"including but not limited to,\" \nat the time that the NPA was signed, with the possible exception of Ghislaine Maxwell, the \ninvestigation had not disclosed any co-conspirators other than those listed. \nI recall that there was extensive discussion of Lefkowitz's proposed immigration language, \nbut I do not recall much discussion of this language for the reasons stated above. \nd. the October 2007 addendum, including its purpose. \nDuring the negotiation of the NPA, I had been admitted to the hospital for surgery. After \nthe surgery, I returned to the office almost immediately to try to complete the negotiations. When \nthe NPA was signed, I sought permission to take a leave of absence to address my health concerns. \nWhile I was away, the Addendum was negotiated. While I conducted some of the drafting, I \nbelieve that FAUSA Sloman handled the bulk of the negotiations and drafting. \nMy understanding was that the USAO wanted to formally assign its right to select the \nattorney representative for the victims to a Special Master. The NPA stated that the USAO would \nselect the attorney representative in consultation with and subject to the good faith approval of \nEpstein's counsel. I had provided Epstein's counsel with a list of attorneys, none of whom I had \never met, that I had culled from consulting with one of the district judges24 and some AUSAs, \nincluding Mr. Yen, who I was dating at the time. After getting that list of names, I did my own \nresearch to determine who would be good fits for the type of litigat\n... [truncated, 3650 chars — for the full page use /api/corpus/document/EFTA00225378/132 or ?id=EFTA00225378&page=132]", "char_count": 3650}, {"efta_number": "EFTA00225378", "page_number": 133, "text_content": "Rather than simply elect to use a Special Master to exercise its right to make the attorney \nrepresentative selection, the USA() believed that it should formalize the assignment in writing. \n5. To the extent not evidenced in e-mails or other correspondence, identify and \ndescribe all interactions with defense counsel — such as phone conversations, \nmeetings, or communications by private e-mail — that you or any other \nmember of the government had regarding the investigation, potential \nprosecution, or negotiation of a resolution of this case. If at any point you \nbecame concerned about the nature of any member of the government's \ninteraction with defense counsel, describe the interaction and explain when \nand why you became concerned. \nMy communications with opposing counsel occurred primarily via email. Most of those \ncommunications were via office email, and some were from my home email. All of my home \nemails were collected and produced as part of the Jane Doe litigation. Negotiations were occurring \nat nights, on weekend, and while I was recuperating from surgery, and this occurred during a time \nwhen out of office access to email was very limited. I believe that only supervisors had Blackberry \ndevices at that time. \nThe meetings that I attended are catalogued on the meeting timeline (Exhibit 5). I believe \nthere was one other meeting soon after Epstein entered his guilty plea, when I went to Jack \nGoldberger's office and met with him and Mike Tein (Guy Lewis' law partner) about the victim \nlist. Other than that, I do not recall any in-person meetings. \nI had a couple of telephone conversations with Lilly Ann Sanchez and Guy Lewis at the \nstart of the investigation that were very brief. Jeff Sloman and/or Andy Lourie was on some of \nthese. I had telephone conversations later during the investigation with Lilly Ann Sanchez, Gerry \nLefcourt, Roy Black, and Nate Dershowitz about subpoena responses. Karen Atkinson and Andy \nLourie were on some of those calls. I ha\n... [truncated, 3422 chars — for the full page use /api/corpus/document/EFTA00225378/133 or ?id=EFTA00225378&page=133]", "char_count": 3422}, {"efta_number": "EFTA00225378", "page_number": 134, "text_content": "6. Provide a detailed description of all settlement negotiations conducted in this \nmatter in which you took part or of which you were otherwise aware, including \nall terms of settlement that were discussed, considered, and rejected during \nthe negotiations. \nIdentify all individuals who participated in those \nnegotiations, including government personnel and defense counsel. In each \ncase, identify all participants and describe the discussions that occurred. \nPlease see my response to Question A.3. \n7. Describe the interactions by you, or anyone else within the USAO, with any \nemployees of the Palm Beach County State Attorney's Office concerning the \nfederal or state investigation of Mr. Epstein, the terms of a proposed resolution \nof the case, and the terms of the federal non-prosecution agreement, including \nthe terms of Mr. Epstein's incarceration. \nAs noted above, my first interaction with anyone from the Palm Beach County State \nAttorney's Office about the Epstein case was at the Project Safe Childhood Conference in \nWashington, DC, when State Attorney Barry Krischer introduced himself to USA Acosta and me \nand started railing against the victims and the case. \nMy next interaction was with ASA Lanna Belohlavek at some later date. I was in her \noffice, I believe on another matter, and I mentioned the case. She said that she \"hated\" the case \nand that she \"hated\" prostitution cases. She stated that some of the girls were not really victims \nbecause they had been paid \"thousands of dollars.\" I was a bit taken aback because Ms. Belohlavek \nwas the supervisor of the division charged with prosecuting child sex offenses, including child \nprostitution cases and, by definition, child prostitutes receive money. \nAlthough not personal interactions, I also had collected and reviewed the state grand jury \ntranscript, indictment, and the state investigative materials. I had conferred with former ASAs \nabout the use of the grand jury in the case, which was very unusual. In Fl\n... [truncated, 3660 chars — for the full page use /api/corpus/document/EFTA00225378/134 or ?id=EFTA00225378&page=134]", "char_count": 3660}, {"efta_number": "EFTA00225378", "page_number": 135, "text_content": "offense that required sex offender registration — namely, procuring a minor for prostitution in \nviolation of Fl. Stat. 796.03; and a sentence totaling 18 or 20 months' imprisonment.26 I recall \nthat either Mr. Lourie or I asked Ms. Behlolavek to confirm that § 796.03 required sex offender \nregistration, and she said that it did. Epstein's attorneys also said that it did. We also specifically \ndiscussed that Epstein would be confined for the term of imprisonment. State Attorney Krischer \nsaid that a term of imprisonment of longer than one year usually required placement in a state \npenitentiary, but there was a way to structure the sentence as a split sentence so that Epstein would \nbe housed at the Palm Beach County Jail. And we again confirmed that Epstein would remain in \ncustody at the jail, not home confinement or any other type of release and we were told that he \nwould be in jail. We also discussed wrapping the matter up quickly because of the extensive \ndelays. \nOn September 23, 2007, Jay Lefkowitz sent an email to Alex Acosta essentially admitting \nthat, during the meeting on September 12, 2007, Epstein's attorneys and Ms. Behlolavek all \nbelieved that a conviction for Fl. Stat. 796.03, procurement of minors for prostitution, did not \nrequire sex offender registration — despite our specific inquiries (see Exhibit 51 (\"I write to follow \nup on our conversation on Friday and to ask you to reconsider your decision to require that Mr. \nEpstein plead guilty to a registerable state charge. It appears that there was a misunderstanding at \nthe meeting I had with Messrs. Laurie, Krischer, Goldberger, Lefcourt, Ms. Villafana and Ms. \nBelohlavek. . . . Before the meeting, Mr. Krischer, and Ms. Belohlavek, a sex prosecutor for 13 \nyears, told us that solicitation of a minor, under 796.03, is not a registerable offense. However, as \nit turned out, 796.03 is a registerable offense and our discussion at the meeting was based on a \nmistaken assumption.\" (emphasis added)). \n... [truncated, 3603 chars — for the full page use /api/corpus/document/EFTA00225378/135 or ?id=EFTA00225378&page=135]", "char_count": 3603}, {"efta_number": "EFTA00225378", "page_number": 136, "text_content": "On June 19, 2008, I sent an email to State Attorney Krischer advising him that we had \nspoken with Roy Black about wrapping up both the state and federal /times (Exhibit 68). I reminded \nState Attorney Krischer that the signed NPA required a plea to the current state indictment and to \nan information charging an offense that requires sex offender registration, namely procuring \nminors to engage in prostitution, with a sentence of at least 18 months' imprisonment (id.). \nI attended the change of plea on June 30, 2008 but did not have any contact with any \nmember of the SAO that day. Later, when the issue arose regarding whether or not Epstein was \ntaking the position that the NPA included USA Acosta's December 2007 letter, I contacted Ms. \nBehlolavek and SA Krischer to obtain a copy of what Epstein's counsel had filed in state court. \nIn September 2008, I had communications with Mr. Krischer about a suit filed in state court \nto unseal the NPA (Exhibit 70). \nAt some point, Mr. Krischer sent me an email about wanting to buy me a cup of coffee. I \nwas not able to find the email while preparing this response, but with additional time, I can \nprobably locate it. I don't believe I ever answered Mr. Krischer. I know I never met him for \ncoffee. \nI recall that in many of Epstein's letters to the Justice Department, there were complaints \nof a lack of coordination between the USAO and the SAO. That lack of coordination was not \ncaused by the government agencies, but, rather, by the tactics of Epstein's counsel. For example, \nEpstein's counsel insisted that I should conduct a completely independent review of the evidence \nso that I would not be tainted by bias from the PBPD or the SAO. When I did so and reached a \nconclusion that they did not like, Epstein's attorneys insisted that Criminal Chief Senior and that \nCEOS conduct similarly sterile reviews free from the \"taint\" of me and the federal agents. If Ms. \nAtkinson and I or the agents and I reached out to the SAO to discu\n... [truncated, 3111 chars — for the full page use /api/corpus/document/EFTA00225378/136 or ?id=EFTA00225378&page=136]", "char_count": 3111}, {"efta_number": "EFTA00225378", "page_number": 137, "text_content": "b. The propriety of including in a non-prosecution agreement with Mr. \nEpstein a provision that the federal government would forgo \nprosecution of any potential co-conspirators of Mr. Epstein, including \nunidentified co-conspirators. \nI do not recall doing any research on this particular point, other than discussing with \nMAUSA Lourie that we would not pursue an investigation into Epstein's subordinates after closing \nthe investigation of Epstein. \nc. The propriety of including in the non-prosecution agreement a \nprovision incorporating 18 U.S.C. § 2255. \nAs noted above, I became familiar with § 2255 through my work as the PSC Coordinator. \nI also was aware, as set forth in the victim notification letters that I prepared, that, under the CVRA, \nI was obligated to use my \"best efforts\" to protect the victims' rights to \"full and timely restitution \nas provided in law.\" 18 U.S.C. § 3771(a)(6). As I discussed above, restitution in child exploitation \ncases was an issue of growing concern, so I was mindful that this plea mechanism that Criminal \nChief Menchel had devised with Lilly Ann Sanchez would extinguish, the victims' right to \nrestitution. That was one of the reasons why, on July 4, 2007, I wrote to Mr. Menchel that I \nbelieved the plea proposal violated the victims' rights legislation. \nWhen Mr. Menchel announced in late July that USA Acosta was going forward with the \ntwo-year state plea offer despite those concerns, I undertook my best efforts to still afford those \nrestitution rights to the victims identified through the federal investigation. Immediately after the \nmeeting where Mr. Menchel announced to me and the investigative team that USA Acosta \nintended to offer a state plea, I delved further into the requirements for claims under § 2255 \n(Exhibit 37). While § 2255 is a civil damages statute, not a criminal restitution provision, the \ncriminal restitution statutory scheme recognizes that there is some overlap. See 18 U.S.C. § \n3664(j)(2)(A), (1). Sectio\n... [truncated, 3250 chars — for the full page use /api/corpus/document/EFTA00225378/137 or ?id=EFTA00225378&page=137]", "char_count": 3250}, {"efta_number": "EFTA00225378", "page_number": 138, "text_content": "d. How the Florida state judicial system would address issues pertaining \nto the terms of Mr. Epstein's incarceration, including designation of an \nappropriate facility, the availability of work release (or any similar \nrelease condition), and the availability of other privileges. Identify \nwhether such research was conducted before or after the non-\nprosecution agreement was signed, and whether it was conducted \nbefore or after Mr. Epstein entered his state court plea. Describe any \ncommunications you or other USAO personnel had with \nrepresentatives of the Palm Beach County State Attorney's Office, \nother law enforcement, or local corrections officials regarding these \nmatters. \nOne of my concerns about using a state forum to resolve this case was that it left our Office \nwith no control over the process. We also did not have any members of our team who had \nexperience with the Palm Beach County state courts — Criminal Chief Menchel had been a state \nprosecutor in New York before joining the USAO; I had been in private practice. Similarly, no \none else involved in the process had been an ASA or even a criminal defense attorney in Palm \nBeach County. The defense team, on the other hand, included Roy Black and Jack Goldberger, \nwho had extensive state court criminal experience in Palm Beach County. Any litigator will tell \nyou that knowing the Court is a key component of success, so we were placed at a distinct \ndisadvantage. It was exacerbated by defense counsel's tactics of prohibiting coordination between \nthe USAO and the SAO — which somehow was successful.28 It also required the USAO to place \nan inordinate amount of trust in the SAO, when one of the reasons for opening the federal \ninvestigation was the concerns that undue influence had been brought to bear on the State \nAttorney.29\nThe loss of control did not just end with the Court proceedings, it included how the sentence \nwould be executed. Federal sentences are executed by the U.S. Marshals and the Bureau\n... [truncated, 3525 chars — for the full page use /api/corpus/document/EFTA00225378/138 or ?id=EFTA00225378&page=138]", "char_count": 3525}, {"efta_number": "EFTA00225378", "page_number": 139, "text_content": "he would have to plead guilty, not nolo contendere. Third, I researched different terms that Florida \ncourts would use that appeared to impose a term of incarceration, but really imposed something \nelse, and prohibited those sentences (\"Epstein shall be sentenced to consecutive terms of twelve \n(12) months and six (6) months in county jail for all charges, without any opportunity for \nwithholding adjudication or sentencing, and without probation or community control is lieu of \nimprisonment\" (Exhibit 52 at 3 (emphasis added)). Fourth, I included a waiver of the right to \nchallenge the Information and an appeal waiver. Fifth, I included a requirement that Epstein would \nhave to provide the USA° with a copy of his plea agreement with the SAO before he signed it. \nSixth, I required Epstein to use his best efforts to enter his guilty plea within approximately 30 \ndays and an agreement that that term (like all others) was material. Seventh, I included an \nagreement that Epstein would not be afforded any gain time benefits different from any other \ninmate, and that he would provide an accounting of gain time if asked. Finally, \"breach of any \none of these conditions allows the United States to elect to terminate the agreement and to \ninvestigate and prosecute Epstein and any other individual or entity for any and all federal \noffenses\" (id. at 6). \nIn addition to the terms of the NPA, the agents and I also did our best to make sure that \nEpstein would be serving jail time like anyone else. Prior to the September 12, 2007 meeting at \nthe State Attorney's Office, I spoke with Andy Lourie and emailed Jeff Sloman about research I \nhad conducted on Florida sentencing practices to avoid \"trucks up the sleeves of the defense\" \n(Exhibit 46 at I.) Normally a defendant who is sentenced to a term of prison in excess of 12 \nmonths must go to a state prison. The Office did not object to \"splitting\" Epstein's sentence into \ntwo pieces — 12 months followed by 6 months — so that he would\n... [truncated, 4090 chars — for the full page use /api/corpus/document/EFTA00225378/139 or ?id=EFTA00225378&page=139]", "char_count": 4090}, {"efta_number": "EFTA00225378", "page_number": 140, "text_content": "In June 2008, when Epstein had exhausted his appeals to the DAG, in accordance with the \nNPA, I asked to see the plea agreement that his attorneys had negotiated with the State Attorney's \nOffice to insure that it was consistent with the NPA (Exhibit 77). After a number of requests to \nRoy Black and Jack Goldberger, I finally received the document (id.). After conferring with an \nAUSA who had previously worked at the Palm Beach County SAO, and with FAUSA Sloman, I \ninformed Messrs. Goldberger and Black that the agreement was insufficient because it did not \nspecify that the defendant was supposed to serve his sentence in a custodial setting (id.). After \nproviding the written notice, Mr. Goldberger agreed to make the change (id) Goldberger also \ncalled me and \"'swore' [his word] that Epstein would be in custody 24-hours-a-day during the \ncommunity confinement portion of the sentence\" (Exhibit 79). \nThe agents also confirmed with local officers that the language in the state plea agreement \nsuggested that Epstein would be at the Palm Beach County Detention Center, a/k/a the Palm Beach \nCounty Jail, and that, during their meeting with PBSO Col. Gauger several months before, he had \nassured them that Epstein would be ineligible for work release (Exhibit 80). Nonetheless, we \ndecided that we would go meet with the Colonel together. Karen Atkinson joined us, and we \nlearned that, despite the language in the agreement, Epstein was housed at the stockade rather than \nthe jail (a lower security \"camp-style\" facility) (Exhibit 81). Gauger also told us that Epstein \nwould be eligible for work release and will be placed on work release — directly contradicting what \nhe had told the agents a few months before (id. ).30 We asked Col. Gauger to let us know if Epstein \ndid, in fact, apply for work release. \nWe never received any notice of Epstein's application. Instead, on November 20, 2008, \nwhen Gauger stopped by to see Karen Atkinson on another matter, he told her that Epstein \n... [truncated, 3768 chars — for the full page use /api/corpus/document/EFTA00225378/140 or ?id=EFTA00225378&page=140]", "char_count": 3768}, {"efta_number": "EFTA00225378", "page_number": 141, "text_content": "9. Describe all efforts made by you, or by anyone else within the USAO, to ensure \nthat Mr. Epstein complied with the terms of the non-prosecution agreement \n(including its addendum) that he signed. Include in your response a discussion \nof all breaches of the agreement by Mr. Epstein of which the USAO was aware, \nand explain why the USAO decided not to rescind the agreement as a \nconsequence of such non-compliance, who was involved in that decision, and \nhow the decision was made. \nMany instances of notices of breach have been catalogued throughout this letter, as well as \nmy efforts to force Epstein to abide by the terms of the NPA prior to declaring a breach (e.g., \nresisting efforts to change the state plea to one that did not require sex offender registration; \nrequiring Epstein's counsel to provide us with copies of the state plea agreement before the plea; \nrequiring the appointment of the attorney-representative who representative the victims; etc.). The \nattempt to declare a breach in connection with Epstein's application for work release is discussed \nabove. \nIn June 2009, Epstein and his lawyers tried to dismiss a lawsuit filed in the Southern \nDistrict of Florida by the attorney-representative on behalf of one of the identified victims that \nraised a single claim under 18 U.S.C. § 2255. I prepared a lengthy memorandum analyzing why \nEpstein's actions were a breach and seeking permission to serve a breach letter (Exhibit 85). The \nOffice approved the request to serve the breach letter. At the same time, the indictment package \nwas re-reviewed and approved (Exhibit 86). The notice of breach letter was served on June 12, \n2009 (Exhibit 87). Epstein promptly \"cured\" the breach, but I took the opportunity to catalogue \nhis past breaches and advised that continuing on that course of conduct would no longer be \ntolerated (Exhibit 88). Perhaps sensing that the Office's patience had waned, perhaps having \ngained a greater understanding (through the civil litigati\n... [truncated, 4059 chars — for the full page use /api/corpus/document/EFTA00225378/141 or ?id=EFTA00225378&page=141]", "char_count": 4059}, {"efta_number": "EFTA00225378", "page_number": 142, "text_content": "10. Identify any cases in which you have been involved as an AUSA, or of which \nyou were otherwise aware, that were resolved through a non-prosecution \nagreement. \nI have not been involved in, nor am I aware of, any other cases that have been resolved via \na non-prosecution agreement. On one occasion, in my eighteen years with the Justice Department, \nI recommended a Pre-Trial Diversion agreement for a doctor who wrote and filled a small number \nof fraudulent opioid prescriptions that she took herself for her post-cancer pain. \nThe \nrecommendation was vetted and approved through the chain of command in accordance with \nDepartment policy (the USAM) and the USAO's Criminal Circular. \nB. CVRA Compliance \n1. Describe your understanding of any USAO, Department, or FBI policy or \npractice regarding victim notification rights, obligations, or procedures that \nwere in effect from the time the federal investigation of Mr. Epstein began to \nthe time that he entered his state plea, including the applicability of the CVRA \nto cases resolved through non-prosecution agreements, and identify the \nsource(s) of such understanding. Explain when and how you became aware of \nsuch policy or practice. Describe your prior experience notifying victims \nunder the CVRA. Explain whether and how victim notifications in the Epstein \ncase departed from the USAO's general practice. \nMy understanding of USAO/DOJ victim notifications policies that were in effect in 2006-\n2007 had come from my own work on PSC cases. I do not recall receiving any training from the \nUSAO on the CVRA or the AG's Guidelines on Victims' Rights prior to the Epstein case. I was \nfamiliar with the CVRA, the Victims' Rights and Restitution Act, and other pieces r victims' \nrights legislation, primarily from two prior cases that I had handled. In United States \nO'Neil, I \nhad litigated the Office's first case where a defendant objected to a victim impact statement. It \nwas a case where a 41-year-old man gave a lethal overdose\n... [truncated, 3578 chars — for the full page use /api/corpus/document/EFTA00225378/142 or ?id=EFTA00225378&page=142]", "char_count": 3578}, {"efta_number": "EFTA00225378", "page_number": 143, "text_content": "their parents to know. Several girls needed counseling and at least one attempted suicide. S/As \nKuyrkendall and Richards, Victim-Witness Specialist Smith, and I all worked to find counseling \nfor those who wanted it through Palm Beach County Victim Services, and I reported the issues to \nKaren Atkinson, Andy Lourie (when he was still in West Palm Beach), and Jeff Sloman. I also \nrecall sending and receiving emails regarding the emotional toll on the victims when agents and I \nenquired into the status of the indictment review. \nWith regard to specific office procedures at the time of the Epstein investigation, there was \nno victim-witness coordinator in West Palm Beach and no standardized way to do any victim \nnotifications prior to indictment. Our Office's procedure — which was still being developed at the \ntime of the Epstein investigation — required a victim list to be submitted along with the indictment \npackage. That victim list would be used to notify victims of upcoming court proceedings — to the \nextent that those upcoming court dates appeared in the case tracking system used at the time. \nConferring with victims regarding plea negotiations could not happen through that victim \nnotification system, so my practice, when possible, was to ask agents to work with me to contact \nvictims about a potential plea. I also asked agents to work with me to notify victims of court dates \nbecause I knew there was a delay with the victim notification system. For example, often a \ndefendant will decide the day before or the day of calendar call or trial to plead guilty. If it is a \ncase with victims, like a bank robbery case, the agents and I will do our best to contact the victims \nto advise and confer, and to invite the victims to appear at the change of plea if they wish. The \nvictims also are informed that they will have the opportunity to give a victim impact statement for \npurposes of sentencing. \nIn child exploitations cases where there has been a lot of contact with \n... [truncated, 3955 chars — for the full page use /api/corpus/document/EFTA00225378/143 or ?id=EFTA00225378&page=143]", "char_count": 3955}, {"efta_number": "EFTA00225378", "page_number": 144, "text_content": "of the defendant, it made sense to put the victim, who was, I believe, 9 years' old at the time, \nthrough the stress of a trial. After conferring with my supervisor, we decided to go forward with \nthe change of plea. The victim's father and the GAL made victim-impact statements and, in the \nend, the judge imposed a sentence of 140 years' imprisonment followed by lifetime supervised \nrelease. \nWith regard to the Epstein investigation in particular, the handling of victim notifications \nvaried from my understanding and my practice in two significant ways. First, it never occurred to \nme that this was not a situation where conferring with the victims was required. I specifically \ninformed the Office in writing on two occasions and orally on other occasions, that I thought the \nvictims should be consulted before entering into the Non-Prosecution Agreement.34 The first of \nthese written reminders was in July 2007 when I learned that Criminal Chief Menchel had engaged \nin plea discussions with Lilly Ann Sanchez. (Exhibit 3.) The second was in early September 2007 \nafter my discussion with CEOS Chief Drew Oosterbaan regarding this subject. (Exhibit 44.) Later, \nI believe after the NPA was already signed, Jeff Sloman told me that the Office had taken the \nposition in other cases that there is no obligation to confer in the absence of the filing of a federal \ncase, but I don't recall discussing that at the time. 35 I had never before used a non-prosecution \n34 As I noted in my filings in the Jane Doe' United States litigation, I had concerns about \ninforming the victims that part of the negotiations involved securing for them the right to obtain \ndamages from Epstein until we knew that Epstein would, in fact, enter into and perform his \nobligations under the NPA. As stated above, during the State investigation, Epstein's counsel had \nfrequently accused the victims of faking or exaggerating their statements for purposes of civil \ndamages claims. In a deposition for one of the\n... [truncated, 4212 chars — for the full page use /api/corpus/document/EFTA00225378/144 or ?id=EFTA00225378&page=144]", "char_count": 4212}, {"efta_number": "EFTA00225378", "page_number": 145, "text_content": "agreement or deferred prosecution in favor of state prosecution in the way that the Epstein case \nwas handled. I believed that the fairest course was to consult with the victims before the execution \nof any agreement. \nThe second significant departure from my regular practice was the victim notification \nprocedure. Never before or since have I shared \"drafts\" of victim notifications with counsel for \nthe defendants. The CVRA places the entire burden of complying with the Act on the government \nand the court and provides that a \"person accused of the crime may not obtain any form of relief \nunder this Chapter.\" 18 U.S.C. § 3771(d)(1) (2004). But, in this case, I was required to provide \ndraft victim notification letters, rewrite them due to objections from defense counsel, and refrain \nfrom sending them altogether. My protestations appear in my emails, and were shared with the \nagents, my legal assistant, and my supervisors. \nWith regard to FBI policies and practices, I understood that the FBI had its own victim \nnotification procedures. I had previously worked with Twiler Smith on other cases (and worked \nwith her on other cases after the Epstein investigation). I did not know the details of what FBI \nincluded in its letters or when they were sent. I did not instruct FBI on what to send or when to \nsend it. My general rule is to tell agencies to follow their regular procedures. I don't remember \nsaying anything different in this case. I did not see any FBI letters in this case prior to collecting \nthe FBI letters to Brad Edwards' clients in connection with the Jane Doe I United States litigation. \nI did not instruct the FBI to include the language about the case being under investigation and that \nthey should be patient. \n2. Identify all victims in this case to whom written or oral notifications were \nmade, when and how each notification was made, and the contents of the \nnotifications. Explain why notifications were made to some victims, and not \nto others, and who\n... [truncated, 3724 chars — for the full page use /api/corpus/document/EFTA00225378/145 or ?id=EFTA00225378&page=145]", "char_count": 3724}, {"efta_number": "EFTA00225378", "page_number": 146, "text_content": "letters did not receive August 11, 2006 letters. If an August 11, 2006 letter was prepared, I believe \nthat meant that the agents had not yet made contact with the person and the agents discarded the \nAugust 4, 2006 letter. We included letters for witnesses who we knew were over the age of 18 to \nadvise them to contact us if they felt they were being harassed because the agents had learned of \npotential harassment during the early set of interviews. I decided to prepare these letters after \ndiscussing the issue with Special Agent Kuyrkendall and I decided on the content of those letters. \nAlthough I do not have a clear recollection of this, I believe that a new letter was issued \nfor Individual #4 because the agents had difficulty interviewing her and did not want to provide \nher with a letter that was several months old. On June 7, 2007, I simply printed the same letter \nwith a new date and signed it. (Exhibit 30.) I do not believe that the August 11, 2006 letter was \never provided to her. The same explanation applies for the June 7, 2007 letters for Individuals 9, \n31, 38, and 43. (Exhibit 30.) Individuals 3 and 40 were not identified until several months into \nthe federal investigation. Victim notification letters were prepared for them on June 7, 2007. \n(Exhibit 30.) I decided to prepare these letters after discussing the issue with Special Agent \nKuyrkendall and I decided on the content of the letters. \nAs discussed above, in July 2007 and September 2007, I raised in writing the need to confer \nwith the victims regarding the proposed agreement with Epstein. I also raised the issue in internal \nconversations with supervisors, agents, and others. I was told that I could not discuss the matter \nwith the victims. (See Exhibits 3 and 44.) \nAfter the Non-Prosecution Agreement was signed, I drafted a notification letter to inform \nthe victims of the terms of the agreement and the date of the state court proceedings. After several \ndelays, the state plea and sentencing\n... [truncated, 3636 chars — for the full page use /api/corpus/document/EFTA00225378/146 or ?id=EFTA00225378&page=146]", "char_count": 3636}, {"efta_number": "EFTA00225378", "page_number": 147, "text_content": "2007, (Exhibit B-63'), later that day, my legal assistant and I prepared 32 victim notification letters \nand envelopes to send. (Exhibit B-14). At 5:08 pm, I received an email from Jeff Sloman that \nsaid, \"Hold the letter\" (Exhibit B-54). \nOn December 10 007, I contacted Jim Eisenberg, counsel for Individual # 28, who is Jane \nDoe #2 in the Jane Doe I United States suit. As noted on the attached chart, Mr. Eisenberg was \npaid for by Mr. Epstein. I told Mr. Eisenberg that I was preparing victim notification letters and \nneeded to know if he was still representing Individual #28. He said that he was and instructed me \nto send the letter to him. My continued designation of Individual #28 as a victim, based upon the \nstatements of other witnesses and the documentary evidence collected by federal and state agents, \nwas one of the main bases that Epstein's counsel used to support their allegations of prosecutorial \nmisconduct with officials at the Department of Justice. (See Exhibit B-20.) Based upon those \nattacks, which relied upon the videotaped statement given by Individual #28, I was instructed by \neither Jeff Sloman or Alex Acosta, not to consider Individual #28 as a victim for purposes of the \nNPA because she was not someone whom the Office was prepare to include in an indictment. \nOn December 7, 2007, Lilly Ann Sanchez sent a letter to Jeff Sloman fmally providing the \nUSAO with the date and time of the change of plea for Mr. Epstein. (Exhibit B-15). Based upon \nthat information, on December 14, 2007, I prepared another version of the victim notification \nletter. (Exhibit B-I 638). I provided a copy via email to Alex Acosta, Jeff Sloman, Rolando Garcia, \nand Karen Atkinson. (Exhibit B-17). On December 17, 2007, I sent an email to Jeff Sloman \ninquiring about the status of the case and informing him that the agents also were expressing their \nconcerns about the delays in victim notifications. (Exhibit B-18). Over my objection, my request \nto send the victim notifi\n... [truncated, 3835 chars — for the full page use /api/corpus/document/EFTA00225378/147 or ?id=EFTA00225378&page=147]", "char_count": 3835}, {"efta_number": "EFTA00225378", "page_number": 148, "text_content": "from the State Attorney's Office. Lefkowitz insisted on the right to review the letters. (Exhibit \nB-22).39\nThe matter was tabled while Epstein was allowed time to raise his federal jurisdiction, \nsufficiency, and prosecutorial misconduct challenges with CEOS, the DAAG, and the AAG. \nWhile everything was supposed to be \"on hold\" pending those reviews, I learned that Epstein was \ntrying to contact some of the victims — victims who would have been represented if Epstein had \nperformed his obligations under the terms of the NPA. I then worked to find pro bono counsel for \nthose victims (Exhibit B-23). \nOn May 15, 2008, CEOS, DAAG Mandelker, and AAG Fisher completed their review, \nfinding that our case against Epstein was neither improper nor inappropriate (Exhibit B-24). By \nthat time, a revised indictment package had already been reviewed and approved (Exhibits B-25 \nthrough B-28). Additional victims also had been identified through the continued investigation \n(Exhibits B-29 through B-31). \nOn May 19, 2008, FAUSA Sloman wrote to counsel for Epstein giving Epstein two weeks \nto enter his guilty plea in state court in accordance with the terms of the NPA (Exhibit B-32). \nRather than performing, Epstein sought continued review, again alleging prosecutorial \nmisconduct and challenging both the sufficiency of the evidence and the federal interest in the \ncase. At this point, Epstein sought review from Deputy Attorney General Mark Filip (Exhibit B-\n33), and he hired Joe Whitley to join his defense team. I was informed that Epstein's deadline to \nenter his guilty plea would be extended again, and we continued preparing for indictment (Exhibits \nB-34 through B-37). So, on May 27, 2008, Bob Senior, who took Matt Menchel's place as \nCriminal Chief, Jeff Sloman, who had taken over for USA Acosta due to his recusal from the \nEpstein matter, Karen Atkinson, and 1 all had an email exchange agreeing that there would be no \nfurther negotiations and that the case would be indicted (E\n... [truncated, 3601 chars — for the full page use /api/corpus/document/EFTA00225378/148 or ?id=EFTA00225378&page=148]", "char_count": 3601}, {"efta_number": "EFTA00225378", "page_number": 149, "text_content": "forward to indictment. I invited him to send whatever information he could and expressed that \ntime was of the essence (Exhibit B-43). Given the uncertainty of the situation — Epstein was still \nchallenging our ability to prosecute him federally, pressing allegations of prosecutorial \nmisconduct, and trying to negotiate better plea terms, while the agents, my supervisors, and I were \nall moving towards indictment — I did not feel comfortable sharing any information about the case. \nIt also is my practice not to talk about status before the grand jury. For those reasons, and because \nI had never met Mr. Edwards, I listened more than I spoke. \nEarly on June 23, 2008, FAUSA Sloman emailed Criminal Chief Senior saying that, if the \nUSAO received the go-ahead from the DAG's Office, I should immediately notify Epstein's \nattorneys that Epstein would only have until June 3011' to comply with the September 246\nagreement or be held in breach. Later that day, Mr. Senior responded, cc'ing me, instructing me \nto send out that notification (Exhibit B-49). On June 23, 2008, DAG Filip completed his review, \nand John Roth sent a letter to Attorneys Starr and Lefkowitz stating their finding that there was no \nabuse of discretion and no misconduct (Exhibit B-44). I immediately sent an email to Jay \nLefkowitz in accordance with Mr. Senior's instructions (Ex. B-49). The following day, Roy Black \nand Jack Goldberger, as local counsel for Epstein, contacted me to wrap up the details of \nperforming pursuant to the terms of the NPA (Exhibit B-45). On June 25 and 26, 2008, there were \na series of internal communications regarding victim notification letters and providing Epstein \nwith a final list of victims (Exhibits B-46, B-47, B-48). I provided my draft victim notification \nletter to FAUSA Sloman and USA Acosta (Exhibits B-47, B-48).4° Since Mr. Acosta had agreed \nin December 2007 that we would not provide written notice of the state change of plea, the written \nvictim notifications were\n... [truncated, 3941 chars — for the full page use /api/corpus/document/EFTA00225378/149 or ?id=EFTA00225378&page=149]", "char_count": 3941}, {"efta_number": "EFTA00225378", "page_number": 150, "text_content": "provided a draft of the proposed victim notification letter to counsel for Epstein (Exhibit B-56). I \nwas concerned that Epstein and his counsel were again creating a potential problem. USA Acosta \nhad taken the position that the final NPA consisted of three documents — the 9/24/2007 NPA, the \n10/29/2007 Addendum, and the 12/19/07 letter from USA Acosta to Lilly Ann Sanchez. I prepared \nvictim notifications (and, later, a Declaration in the Jane Doe litigation) based upon this \nunderstanding. When Epstein entered his guilty plea, Judge McSorley required him to file his \nfederal Non-Prosecution Agreement with the Court since that formed part of the consideration for \nthe state plea. I wanted to confirm that Epstein was taking a consistent position with the State \nAttorney's Office, Judge McSorley, and the USAO, so I asked for a copy of what was filed in the \nState Court. This led to multiple letters with counsel for Epstein before I could finalize the victim \nnotification letters (Exhibits B-57 through B-65). On July 9, 2008, I finally sent the first two \nvictim notification letters to two of Brad Edwards' clients, Individuals 35 and 43 (Exhibit B-66). \nWhenever I sent a victim notification letter, a redacted version of the letter also was sent to Jack \nGoldberger, counsel for Jeffrey Epstein. I was not authorized to send a victim notification letter \nto Individual # 28 or to include her on the list of persons provided to Epstein because she was not \na person that the Office was prepared to name in an indictment.42\nOn July 10, 2008, I sent victim notification letters to a number of other represented victims, \nIndividuals 3, 8, 17, 25, 26, 37, and 44 (Exhibit B-67). The FBI also asked for some assistance of \nlanguage to use in its own victim notifications (Exhibit B-68), and I was waiting for contact \ninformation for the unrepresented victims (Exhibit B-69). On July 21, 2008, I sent victim \nnotification letters to a group of unrepresented victims, Individuals 1, 2, 4,\n... [truncated, 4096 chars — for the full page use /api/corpus/document/EFTA00225378/150 or ?id=EFTA00225378&page=150]", "char_count": 4096}, {"efta_number": "EFTA00225378", "page_number": 151, "text_content": "On that date, Notification Letters were sent directly to Individuals 1, 2, 4, 9, 10, 11,43 13, 14, 16, \n20,44 21, 23, 24, 30, 31, 32,45 33, and 38, and via counsel to Individuals 3, 8, 17, 25, 26, 37, and \n44 (Exhibit B-89). On September 3, 2008, Notification Letters were sent via counsel to Individuals \n35 and 43, and via FBI Legal Attaches to Individuals 36 and 42 (Exhibit B-90). On September \n12, 2008, I sent a Notification Letter to Individual 39 (Exhibit B-91). On September 15, 2008, I \nsent Notification Letters to Individuals 18 and 32 (Exhibit B-92). \nSoon thereafter, I received a letter from Jeffrey Herman, one of the civil attorneys who \nrepresented a number of victims, notifying me that he had complained to the Florida Bar that the \nVictim Notification Letters violated the Florida Bar rules against solicitation. He had filed \ncomplaints against myself and against Robert Josefsberg — the attorney-representative selected by \nthe Special Master. On September 18, 2008, I wrote to the Florida Bar asking for an Ethics opinion \n(Exhibit B-93). I did not feel that I could send out any additional notifications until I received a \nresponse to that inquiry. The Florida Bar eventually issued a letter reviewing the relevant rules \nthat (a) contacts with represented and unrepresented persons required by law are permitted and (b) \nbusiness solicitation prohibitions are limited to those motivated by pecuniary gain. Thereafter, I \nissued notification letters to Individuals 20 and 40 on November 14, 2008 (Exhibit B-94). \nI only issued one other set of victim notifications: when I learned that Epstein had been \nallowed out on work release. While it technically was not required, I knew that the State \nAttorney's Office had not provided the notice, so I wanted to provide the victims with at least the \noption to take advantage of \"exclusionary zones.i46 On December 4, 2008, I drafted a work release \nnotice, which was approved by my office (Exhibit B-95). The following day, I se\n... [truncated, 3656 chars — for the full page use /api/corpus/document/EFTA00225378/151 or ?id=EFTA00225378&page=151]", "char_count": 3656}, {"efta_number": "EFTA00225378", "page_number": 152, "text_content": "3. Identify all individuals within the USAO and FBI who had a role in \ndetermining whether, when, how, and to which victims to provide victim \nnotifications in the Epstein case and explain what decisions were made and the \nbasis for them. \nGreater detail is provided in the answer to Item B-2, above, and the exhibits referenced \ntherein. Normally the line AUSA is the person who handles deciding who should receive victim \nnotifications. Prior to indictment, the line AUSA has responsibility for those notifications, in \nconjunction with the case agents. Post-indictment, a victim list is provided to the victim-witness \ncoordinator who is supposed to issue letters (again, I do not know how automated that was in 2006-\n2008). In this matter, I made the decision to make contact with victims early and I decided on the \ncontent of the introductory letters as well as the recipients of those letters. At the time of plea \nnegotiations, Criminal Chief Menchel made the decision that he had the authority to vary from the \ngeneral policy of conferring with victims before entering into a plea. I do not know the basis for \nthat decision (see Exhibit 3). His email to me said that the decision was made with USA Acosta's \nconcurrence. I do not know the veracity of that statement. I know that, even after Chief Menchel \nleft the USAO, as the plea negotiations continued, when I re-raised the issue of conferring with \nthe victims after discussing it with CEOS Chief Drew Oosterbaan (see Exhibit 44), the Office still \ndid not confer. I do not know the basis for this decision. \nRegarding providing notifications of the date of the change of plea, I drafted several \niterations of a notification letter and also asked to provide oral notifications. USA Acosta decided \nthat the USAO should not provide any notifications of a state court proceeding. From the \ncorrespondence that he drafted, the basis for doing so was that it was a state proceeding, not a \nfederal one, so the notice should come from the\n... [truncated, 3786 chars — for the full page use /api/corpus/document/EFTA00225378/152 or ?id=EFTA00225378&page=152]", "char_count": 3786}, {"efta_number": "EFTA00225378", "page_number": 153, "text_content": "2007, but they became concerned that it appeared that Epstein was going to renege on the NPA. \nThe agents suspected that, at trial, Epstein would allege that the agents had told the victims that \nthey could get money from Epstein. So they decided to suspend the notifications until Epstein was \nindicted or his \"challenges\" to the NPA and the investigation were settled. \n5. Explain why victims who received victim notification letters after the non-\nprosecution agreement was first signed in September 2007 were notified in the \nletters that the federal investigation of Jeffrey Epstein \"is currently under \ninvestigation.\" \nExplain whether you, or other government personnel, \nconsidered whether the statement was accurate in light of the non-prosecution \nagreement; describe the process leading to the decision to so advise the victims; \nand describe any discussions among government personnel concerning the \nstatement and its accuracy, occurring before or after it was made. \nThe letters containing the quoted language were prepared by FBI victim-witness specialist \nTwit Smith and I was unaware of them until they were collected in connection with the Jane \nDoe \nUnited States litigation. I do not recall ever discussing the wording of the FBI's letters \nprior to their distribution. The decision to issue the letters and the wording of those letters were \nexclusively FBI decisions. \nEven though I was unaware of the language at the time, there is no doubt that from the \nperspective of the agents and myself the matter was, in fact, \"currently under investigation.\" The \nNPA was signed on September 24, 2007. The letters that Judge Marra referred to in his order were \ndated January 10, 2008 and May 30, 2008. During the period that the letters were sent, Epstein \nwas asserting that: (a) there was insufficient evidence to charge him with any offense; (b) there \nwas no basis for federal prosecution and that federal prosecution violated the Petite policy; (c) I \nhad engaged in prosecutoria\n... [truncated, 3976 chars — for the full page use /api/corpus/document/EFTA00225378/153 or ?id=EFTA00225378&page=153]", "char_count": 3976}, {"efta_number": "EFTA00225378", "page_number": 154, "text_content": "Chief Senior's ongoing indictment review (Exhibit B-106). Ms. Braden, the agents, and I \ncontinued working on the best way to charge the case, and collecting evidence to corroborate \nwitness statements (see Exhibit B-107). On January 31, 2008, another group of grand jury \nsubpoenas was prepared and served (Exhibit B-108). On January 31 and February 1, 2008, Ms. \nBraden, the agents and I re-interviewed a series of victims (Exhibit B-109). As you can see from \nExhibit B-109, it wasn't simply the agents and I who thought that the investigation was ongoing, \nthe supervisory chain (up to and including the U.S. Attorney and the Chief of CEOS) was aware \nthat: (1) victim and witness interviews were occurring; (2) grand jury subpoenas were being issued; \nand (3) an indictment package was being revised and reviewed. \nIn February 2008, I was focused on working with the agents and Ms. Braden to finalize a \nrevised indictment package and having it reviewed and signed by my supervisors (Exhibit B-110). \nOn February 20, 2008, I sent an email to USA Acosta, FAUSA Sloman, CEOS Chief Oosterbaan, \nCriminal Chief Senior, and others in the supervisory chain letting them know that I had provided \nthe final indictment package to my immediate supervisor the previous day (Exhibit B-I 11). I also \ninformed Ms. Braden that I reserved time with the grand jury on March 11, 2008 and asked her to \nattend on that date (id). On February 25, 2008, I conferred with my immediate supervisor and \nwith one of our Senior Litigation Counsel, who also was one of our Professional Responsibility \nOfficers, about whether there was any reason to re-present the case to a different grand jury \n(Exhibit B-112). I provided the result of my inquiry to FAUSA Sloman, Criminal Chief Senior, \nthe West Palm Beach supervisors, and Ms. Braden (Exhibit B-113). My supervisor completed her \nreview the following day (see Exhibit B-114). \nAlso on February 26, 2008, FAUSA Sloman informed me that he had told attorney Jay \nLefkow\n... [truncated, 3875 chars — for the full page use /api/corpus/document/EFTA00225378/154 or ?id=EFTA00225378&page=154]", "char_count": 3875}, {"efta_number": "EFTA00225378", "page_number": 155, "text_content": "On March 5, 2008, I updated the Office supervisory chain and CEOS Chief Oosterbaan on \na number of case developments (Exhibit B-121). In that email, I noted that, if we were not going \nto proceed, we needed to be mindful of the state statute of limitations, to allow the PBPD to present \ncharges to the Palm Beach State Attorney's Office (id). I also reported on the status of indictment \nreview and my plan to start presenting to the grand jury on March 18, 2008, so that the grand jury \nwould have sufficient time to hear all of the evidence and reflect on it before voting on an \nindictment (id.). On March 14, 2008, the head of the West Palm Beach office completed his review \nof the indictment package and it was forwarded to Criminal Chief Senior for final review and \napproval (Exhibits B-25, B-122). On March 18, 2008, I began my grand jury presentation (Exhibit \nB-26). The planned continued presentation to the grand jury was postponed while we awaited \nCEOS' review. I expressed my concerns about the impact on the ongoing investigation (Exhibit \nB-124). \nIn mid-May, 2008, CEOS completed its review, finding that a federal prosecution of \nEpstein's conduct was factually and legally sound (Exhibit B-24). The agents and I immediately \nprepared to go back to the grand jury (Exhibit B-125). My supervisors also immediately prepared \nto review and finalize an indictment incorporating the results of the continued investigation \n(Exhibit B-38). The agents continued locating and interviewing more victims (see, e.g., Exhibit \nB-126). When DAG Filip agreed to consider Epstein's challenges, the planned grand jury \npresentation was canceled (Exhibit 8-40). \nEven after that delay, the agents and I pressed on. In June 2008, even as I was assisting \nwith the USAO's submissions to DAG Filip (Exhibits B-123, B-127, and B-128), the agents and I \nwere working on additional grand jury subpoenas and obtaining 6001 immunity for a witness \n(Exhibit B-129). On June 17, 2008, I applied for, and re\n... [truncated, 3784 chars — for the full page use /api/corpus/document/EFTA00225378/155 or ?id=EFTA00225378&page=155]", "char_count": 3784}, {"efta_number": "EFTA00225378", "page_number": 156, "text_content": "C. General \n1. As to all of the foregoing matters, identify any disagreements or concerns \nexpressed by government personnel as to these matters, the parties involved, \nhow the disagreements were resolved, and any concerns you had about any \nsuch resolution and the individuals, if any, with whom you discussed your \nconcerns. \nI raised a multitude of concerns during the investigation, negotiations, and enforcement \nperiods. They ranged from the explicit — my July 2007 email exchange with Matt Menchel about \nhis violations of the USAM, CVRA, and Ashcroft Memo (Exhibit 3) — to the subtle — repeated \nrequests to just meet with the victims. Here is one especially poignant request from January 31, \n2008: \nHi Jeff and Alex - We just finished interviewing three of the girls. I wish you could \nhave been there to see how much this has affected them. \nOne girl broke down sobbing so that we had to stop the interview twice within a 20 \nminute span. She regained her composure enough to continue a short time, but she \nsaid that she was having nightmares about Epstein coming after her and she started \nto break down again, so we stopped the interview. \nThe second girl, who has a baby girl of her own, told us that she was very upset \nabout the 18 month deal she had read about in the paper. She said that 18 months \nwas nothing and that she had heard that the girls could get restitution, but she would \nrather not get any money and have Epstein spend a significant time in jail. \nThe FBI's victim-witness coordinator attended and she has arranged for counseling \nfor several of the girls. \nPlease reach out to Alice to make her decision. These girls deserve so much better \nthan they have received so far, and I hate feeling that there is nothing I can do to \nhelp them. \nWe have four more girls coming in tomorrow. Can I persuade you to attend? \n(Exhibit C-1.) \nMany of the disagreements have been catalogued above, but I will try to collect them into \ngeneral categories in chronological order. \n... [truncated, 2787 chars — for the full page use /api/corpus/document/EFTA00225378/156 or ?id=EFTA00225378&page=156]", "char_count": 2787}, {"efta_number": "EFTA00225378", "page_number": 157, "text_content": "protected child victims' identities. I told my supervisor, Karen Atkinson, my concerns and \nthat I thought I should ask to have the case reassigned, and she counseled against it (Exhibit \nC-4). \nc. Ms. Atkinson, the agents, and I all tried to impress upon the others that, due to the nature \nof the crimes under investigation, time was of the essence — Epstein was accused of \ncommitting sexual offenses against dozens of minor girls. Our expert witness, as well as \nour own experience, led us to believe that Epstein would not cease his criminal behavior \nvoluntarily. We also knew that Epstein was continuing to travel extensively using his \nprivate airplanes, and that he would have the ability to flee to a jurisdiction that did not \nextradite if he knew that charges were coming. At one point in May 2007, after the \nindictment had been reviewed on several levels, we knew where Epstein would be and I \nasked to arrest him on a criminal complaint. Criminal Chief Menchel responded that he \nwas \"having trouble understanding — given how long this case has been pending — what the \nrush is.\" (Exhibit C-5). There was another instance a month or two later where we knew \nthat Epstein was traveling to serve as a judge for a beauty contest and I again asked for \npermission to prepare a criminal complaint. Criminal Chief Menchel's denial of the \nrequest was even more emphatic. \nd. In July 2007, Mr. Menchel and I exchanged strong words when he reported that he had \nengaged in plea negotiations without the input or knowledge of the agents, victims, or \nmyself (Exhibit 3). My objections included: \ni. The failure to meet and consult with the victims, agents, and me before \ndeciding what plea offer to extend. \nii. Offering a plea to a state offense. There was never any explanation of why \na federal investigation would be resolved with a state plea, and I understood \nthat a state plea would remove all control over the plea and sentencing \nprocedure. \niii. Starting the negotiations at only 24\n... [truncated, 3125 chars — for the full page use /api/corpus/document/EFTA00225378/157 or ?id=EFTA00225378&page=157]", "char_count": 3125}, {"efta_number": "EFTA00225378", "page_number": 158, "text_content": "g. \nto \"continue\" the hearing pending our \"plea negotiations.\" I repeatedly recommended \nmoving forward on the computer equipment because it was obvious that they did not want \nto turn it over and the equipment likely contained hard evidence of travel, contact with \nvictims, obstruction of justice, and possibly child pornography offenses. Instead, the \nOffice continuously agreed to put off the hearing and even when Epstein's attorneys tried \nto use the existence of the pending motion to quash as a basis to stay some of the victims' \ncivil suits. \nf. Once I was informed that I had to devise a plea agreement with a sentencing cap of 24 \nmonths' imprisonment, I drafted a plea to a conspiracy to violate 18 U.S.C. § 2422, in \nviolation of 18 U.S.C. § 371 — one of the crimes that had been the subject of the \ninvestigation and that was included in the indictment. That crime was a felony with a five-\nyear statutory maximum, and the guidelines would have exceeded the five-year max, so \nthe plea agreement would have had to be a binding plea pursuant to Fed. R. Crim. P. \n11(c)(1)(C), which is what I drafted. I was informed by Mr. Lourie that USA Acosta did \nnot want to do a (c)(1)(C) plea, so I had to find charges that would result in a two-year \nstatutory maximum. This resulted in me having to research misdemeanors and find facts \nthat would fit those misdemeanors. I thought it was totally inappropriate. Luckily, Andy \nLourie finally stepped in and told Lefkowitz that we would not agree to a misdemeanor \ncharge unrelated to the crimes that we had investigated. \nThroughout the drafting of the NPA, every time Jay Lefkowitz and I reached an impasse, \nhe and/or Ken Starr would appeal to Andy Lourie, Jeff Sloman, or Alex Acosta, making it \nimpossible to hold a firm line or keep a singular negotiating strategy. I tried to work from \nthe Office's standard plea agreement language, but even after language was agreed to, it \nwould be rewritten by Mr. Acosta. \ni. I strenuously objected \n... [truncated, 3445 chars — for the full page use /api/corpus/document/EFTA00225378/158 or ?id=EFTA00225378&page=158]", "char_count": 3445}, {"efta_number": "EFTA00225378", "page_number": 159, "text_content": "J. \niv. I told FAUSA Sloman and USA Acosta that I did not want to sign the NPA \nbecause I did not think that it was \"my\" agreement. USA Acosta asked me \nto sign it. \nh. After the NPA was signed, USA Acosta continued to concede points that had already been \ndecided. For example, he agreed to the preparation of the Addendum. He then made a \nnumber of concessions regarding the letter to the Special Master, including a statement that \nwe would not vouch for the veracity of the victims, despite the fact that these were victims \nthat we intended to include in an indictment. These were all areas that were the subject of \na signed, binding agreement. On October 5, 2007, and October 23, 2007, I against asked \nfor permission to proceed to indictment (Exhibits C-6, C-7). \ni. After the Addendum was signed, USA Acosta wrote in the 12/19/2007 letter to Lilly Ann \nSanchez that he had \"considered defense counsel arguments regarding the Section 2255 \nportions of the Agreement. ... During the course of negotiations [our] intent was reduced \nto writing in Paragraphs 7 and 8, which as I wrote previously, appear far from simple to \nunderstand.\" (Exhibit B-19). I raised concerns about undermining an Agreement entered \ninto by our Office and giving away one of the protections that had been negotiated for the \nvictims — representation by an attorney selected by the Special Master. \nI raised concerns about delays in entering Epstein's guilty plea and sentencing. These were \nportrayed as \"professional courtesies\" but it quickly became obvious that the NPA was \nsigned with no intention of actual performance — it was simply a way for Epstein to buy \ntime to avoid indictment and intimidate victims. \nk. I raised objections to the multiple \"appeals\" to DC and the delays that those entailed. USA \nAcosta explained that \"every defendant\" has the right to appeal to DC and raise federalism \nconcerns. I explained that the objections should have been raised prior to signing the NPA, \nnot after, and, if \n... [truncated, 3515 chars — for the full page use /api/corpus/document/EFTA00225378/159 or ?id=EFTA00225378&page=159]", "char_count": 3515}, {"efta_number": "EFTA00225378", "page_number": 160, "text_content": "best to get counseling for all of our needy victims, but I just can't stress enough how \nimportant it is for these girls to have a resolution in this case. The `please be patient' \nanswer is really wearing thin, especially when Epstein's group is still on the attack while \nwe are forced to wait on the sidelines. Your guidance is needed.\" (Exhibit C-2) I followed \nup on March 19 and 22, 2008 to let everyone know that Epstein was subpoenaing victims \nand was using particularly aggressive means of service — having the Sheriff's Office serve \nthe subpoenas at the places of work, calling them into the Dean's Office at their colleges, \netc. I explained that Epstein was issuing these subpoenas in the context of the state criminal \ncase — even though these victims were not named victims in the state criminal case, and I \nasked FAUSA Sloman to try to have Epstein's attorneys stop this contact as it was \ninconsistent with Epstein's alleged interest in resolving the matter (Exhibit C-3). I do not \nbelieve that anyone contacted Epstein's attorneys about this. I worked to secure pro bono \ncounsel for as many victims as possible so that Epstein would only be able to contact them \nthrough counsel (id.). My concerns about the victims' mental health were brought to the \nattention of management in emails and telephone calls throughout the entire period from \n2006 through 2008 and probably into 2009. \no. Even after Epstein enter his guilty plea and was sentenced, there were a number of material \nbreaches. Every time I tried to enforce the agreement and enforce the Office's authority to \nproceed to indictment, the Office would accept Epstein's excuse that he received \"bad \nadvice\" from his attorneys and then he would \"cure\" the breach. With regard to the work \nrelease, either Roy Black or Jay Lefkowitz informed me that USA Acosta had agreed, after \nthe NPA was signed, that Epstein would be allowed to participate in work release like any \nother state prisoner — in direct contravention o\n... [truncated, 4021 chars — for the full page use /api/corpus/document/EFTA00225378/160 or ?id=EFTA00225378&page=160]", "char_count": 4021}, {"efta_number": "EFTA00225378", "page_number": 161, "text_content": "and were delaying for strategic reasons; (13) repeatedly ceding our discretion to the defense, for \nexample, agreeing that they could review and comment on victim notification letters and decide \nwhether or not we could provide notice; (14) even after the NPA was signed, continuing to water \nit down, with the Addendum, the 12/19/07 Acosta letter, and then later offering Epstein the option \nof not having to provide the attorney-representative for the victims; (15) refusing to allow the \nagents and Ito notify the victims about the terms of the NPA and about the change of plea; (16) \nallowing Epstein to continue to enjoy the benefits of the NPA even after he failed to promptly \nperform its terms and filed specious delays in order to try to negotiate better terms or win a battle \nof attrition; (17) refusing to defend me from the false allegations of prosecutorial misconduct; (18) \nrefusing to step in and protect the victims from harassment from Epstein's attorneys when Epstein \nwas \"appealing\" to DC; and (19) allowing Epstein to repeatedly breach the NPA and then claim \nthat he just got bad advice from his lawyers and \"cure\" the breaches. \nAt various times during the investigation, negotiations, etc., I spoke with a number of \npeople about my disagreements with the Office, including my supervisor, Karen Atkinson, my co-\ncounsel, John McMillan, Special Agents Kuyrkendall and Richards, AUSAs Lynn Kirkpatrick, \nSusan Roe, E.J. Yera, and DOJ Trial Attorneys Tammie Gregg and Myesha Braden. On several \noccasions, I drafted emails about re-assigning the case because the Office's handling of the matter \nwas so contrary to my methods. I shared at least one of these with Ms. Atkinson (Exhibit C-4). \nShe counseled against sending it. The agents asked me not to leave the case because they believed \nthat, if I left, the case would simply disappear. I couldn't disagree with them. \nCriminal Chief Menchel's response to my email in July 2007 was, in my mind, \ninappropriate and meant to \n... [truncated, 3935 chars — for the full page use /api/corpus/document/EFTA00225378/161 or ?id=EFTA00225378&page=161]", "char_count": 3935}, {"efta_number": "EFTA00225378", "page_number": 162, "text_content": "sometimes followed no debate. I was sometimes heard on the issue; other times I knew nothing \nabout it until I received the directive. There were times that I learned of communications between \ndefense counsel and the Executive Division where concessions were made only after the decision \nwas made. Many of these decisions were incorrect, in my opinion, but I did not believe that they \nwere illegal. As a line AUSA, I was duty bound to follow the directives of the U.S. Attorney, \nwhich I did. I do not know that following a direct order from the Executive Division would qualify \nas coercion — even if it follows very strong objections. \nI felt strongly that we should have conferred with the victims before entering into the NPA \nand that we should have informed them of the change of plea and sentencing. I felt strongly that \nEpstein's attorneys were given unprecedented access to members of the Executive Division, and \nthat the victims were given no access -- I could not even talk with them about plea negotiations or \nnotify them about the plea hearing. At one point, my assistant and I had letters and envelopes \nready to be stuffed and put through the franking machine and we received notice from Miami that \nthey could not go out. While I felt that conferring was the right thing to do, as noted above, the \nAG Guidelines vest discretion in the U.S. Attorney, so I could not say that USA Acosta's decision \nwas illegal. I also believed that, because the resolution of the federal case rested on Epstein's state \nguilty plea, the federal victims were entitled to notice of the state hearing. But I could not say that \nUSA Acosta's decision that the CVRA was limited to notice of federal proceedings was illegal. \nI think that pressure was brought in more subtle ways. For example, I believe that one of \nthe reasons why USA Acosta did not take an aggressive stance against the prosecutorial \nmisconduct claims against me was because he disliked my insistence on pushing the case forward. \n... [truncated, 2401 chars — for the full page use /api/corpus/document/EFTA00225378/162 or ?id=EFTA00225378&page=162]", "char_count": 2401}, {"efta_number": "EFTA00225378", "page_number": 163, "text_content": "BAKER,DONELSON \n100 116111 STREET • BALTIMORE, MARYLAND 21202 • 410.685.1120. bakerdonelson.com \nJONATHAN BRAN \nDirect Dial: 410.862.1073 \nE-Mail AddresallkitAN@bakerdonelson.com \nMay 10, 2019 \nVIA EMAIL °N4\" \nLaura Ingersoll \nCounsel, Office of Professional Responsibility \nU.S. Department of Justice \n950 Pennsylvania Avenue, N.W. — Room 3266 \nWashington, D.C. 20530 \nRe: OPR Investigation Relating to Jeffrey Epstein Federal Criminal Investigation \nDear Ms. Ingersoll: \nAttached please find the written response of Assistant United States Attorney A. Marie \nVillafafia to the letter of Jeffrey R. Ragsdale, dated April 2, 2019, regarding the criminal \ninvestigation of Jeffrey Epstein. AUSA Villafafia separately has sent you encrypted disks \ncontaining the exhibits referenced in her written response, and has emailed other exhibits that \nwere not included on the disks. \nMr. Ragsdale's letter also requested background information concerning AUSA \nVillafafia's professional background and experience. The remainder of this letter provides that \ninformation. \nA native of Minnesota, A. Marie Villafafia graduated from Cornell University and the \nUniversity of California, Berkeley, School of Law. She was admitted to the California Bar in \n1995, to the Minnesota Bar in 1997, and to the Florida Bar in 2005. She is currently an active \nmember of the Florida Bar, and maintains inactive status in California and Minnesota. \nMs. Villafafia began her legal career as a judicial law clerk to the Honorable David F. \nLevi, United States District Judge for the Eastern District of California, from 1993 to 1994. Ms. \nVillafafia then worked in private practice for seven years, including as a litigation associate at \nMorrison & Foerster in San Francisco and a trial associate with Dorsey & Whitney, LLP, in \nMinneapolis, Minnesota, and London, England. Ms. Villafafia remained in civil practice, \nspecializing in intellectual property litigation until 2001, when she was hired by the United \nStates Att\n... [truncated, 2482 chars — for the full page use /api/corpus/document/EFTA00225378/163 or ?id=EFTA00225378&page=163]", "char_count": 2482}, {"efta_number": "EFTA00225378", "page_number": 164, "text_content": "Laura Ingersoll \nMay 10, 2019 \nPage 2 of 7 \nAUSAs, described the job as the best of their careers. Ms. Villafafia also wanted to serve her \ncommunity. She was in the first generation of her family to graduate from college. She is the \nonly member of her family to get an advanced degree. Personal experiences left her deeply \ncommitted to wanting to create safer communities for victims of crime. After several years of \nwaiting for an opening at the USAO in Minneapolis, when Ms. Villafafia's brother moved to the \nWest Palm Beach area, she applied for a position at the U.S. Attorney's Office for the Southern \nDistrict of Florida. \nOn September 10, 2001, Ms. Villafafia began serving as an Assistant United States \nAttorney in the Southern District of Florida. She did a rotation through the Appellate Section \nand then joined the Major Crimes Section from late September 2001 until January 2004. While \nin that unit, she handled reactive cases and short-term investigations and cases, including \nnarcotics, firearms, child exploitation offenses, immigration matters, credit card fraud, bank \nrobbery, violent offenses, and supervised release violations. While serving in that unit, she was \nalso selected as one of the Southern District of Florida's first Project Safe Neighborhood \nprosecutors. \nIn January 2004, AUSA Villafafia transferred to the West Palm Beach Office. In 2006, \nthe U.S. Department of Justice initiated Project Safe Childhood, and, in recognition of her \nexpertise in child exploitation matters, AUSA Villafalia became the Southern District of \nFlorida's first Project Safe Childhood coordinator. From 2004 through early 2009, AUSA \nVillafaha handled the bulk of the child exploitation cases in West Palm Beach, as well as other \ncases involving violent crime, gangs, narcotics, firearms, immigration, and white collar matters. \nIn March 2009, AUSA Villafafia was selected as the first Chief of the Special \nProsecutions North Section, which was a new section in the Fort Lau\n... [truncated, 3262 chars — for the full page use /api/corpus/document/EFTA00225378/164 or ?id=EFTA00225378&page=164]", "char_count": 3262}, {"efta_number": "EFTA00225378", "page_number": 165, "text_content": "Laura Ingersoll \nMay 10, 2019 \nPage 3 of 7 \nAs the Southern District of Florida's first Project Safe Childhood Coordinator, she \npersonally handled dozens of child exploitation cases. \nIt appears from a review of Westlaw and Courtlink research, that AUSA Villafafia was \nthe first prosecutor in the Southern District of Florida to convince the court to recognize the \nrights of a victim's family to appear and speak to the Court about the proper sentence: \n• \nU.S.'. William Charles O'Neil, 04-Cr-80040 \nThe victim's mother remains in touch with AUSA Villafafia to this day. \nFrom Westlaw and Courtlink research, it appears that AUSA Villafafia was the first \nprosecutor in the Southern District of Florida to advocate for the appointment of a guardian ad \nlitem for minor victims in connection with a criminal prosecution. \n• \nU.S.'. Jimmy Oliver, 06-Cr-80023 \n• \nU.S.'. Marion Yarbrough, 07-Cr-80099 \nFrom Westlaw and Courtlink research, it appears that AUSA Villafafia was the first \nprosecutor in the Southern District of Florida to charge enticement of a minor based upon use of \na cellular phone. \nU.S.'. McDaniel, 06-Cr-80058 \nFrom Westlaw and Courtlink research, it appears that AUSA Villafafia was the first \nprosecutor in the Southern District of Florida to charge a violation of the child pornography \nadvertising statute. \nU.S.'. Frank Grasso, 05-Cr-80111 \nFrom Westlaw and Courtlink research, it appears that AUSA Villafafia was the first \nprosecutor in the Southern District of Florida to charge failure to register as a sex offender. \nAUSA Villafafia trained other prosecutors and agents on how to investigate and prosecute those \ncases. \nU.S.'. Alfonso Diaz Cardenas, 07-Cr-80108 \nAUSA Villafafia assisted in the drafting of Eleventh Circuit Pattern [Criminal] Jury \nInstructions related to child exploitation offenses, including clarifying that, in cases of actual \ncontact with a child, there is no requirement of proving the defendant's knowledge of age. \n4822-54644166v1 \n2865555-\n... [truncated, 2032 chars — for the full page use /api/corpus/document/EFTA00225378/165 or ?id=EFTA00225378&page=165]", "char_count": 2032}, {"efta_number": "EFTA00225378", "page_number": 166, "text_content": "Laura Ingersoll \nMay 10, 2019 \nPage 4 of 7 \nAccording to inquiries with DOJ's Health Care Fraud Section, Ms. Villafaila was the first \nprosecutor in the nation to charge sex trafficking in connection with a health care fraud case. \nU.S.'.\n0 \n Kenneth Chatman, 17-Cr-80013 (subject of an American Greed episode, \nCNBC, Season 12, Episode 10 \"Florida Rehab Gone \n\" July 2, 2018) \nChatman was the first of several cases to target fraud in connection with substance abuse \ntreatment. To date, AUSA Villafafia has convicted 30 individuals, including six licensed \nmedical or mental health professionals, for related offenses: \nII \nU.S. . Kenneth Chatman, et al., 17-Cr-80013 \nO \nU.S. . Barry Gregory, 17-Cr-80033 \nI\nfl \nU.S. . Richard Botero, et al., 17-Cr-80070 \nO \nU.S. . Tovah Lynn Jasperson, et al., 17-Cr-80194 \nU \nU.S.'. Jeffrey Williams, 17-Cr-80195 \nU \nU.S. . Albert Jones Saye, l7-Cr-80229 \nO \nU.S. . John Skeffington, et al., 18-Cr-80018 \nO \nU.S. . Anthony Jackson, 18-Cr-80040 \nU \nU.S. . Lanny Fried, 18-Cr-80100 \nO \nU.S.'. 13osco Vega, 18-Cr-80101 \nfl \nU.S.'. Mark Hollander, 18-Cr-80102 \nO \nU.S.'. Larry Weisberg, 18-Cr-80108 \nU \nU.S. I. Kenneth MI\n-Kolb, 18-Cr-80121 \nI \nO \nU.S. . Arman Abovyan, et al., 18-Cr-80122 \nfl \nU.S.'. Hamilton Wayne, et al., 18-Cr-80165 \nO \nU.S.'. Ethan Wayne, 18-Cr-80168 \nThe Chatman case resulted in AUSA Villafafia being awarded the 2018 Council of the \nInspectors General on Integrity and Efficiency Award and the 2017 National Healthcare Anti-\nFraud Association Investigation of the Year Award. This series of investigations has been \nnominated for this year's FBI Director's Award and the Florida Insurance Fraud Education \nCommittee's Award. \nAt the request of DOJ's Office of Legislative Affairs, AUSA Villafafia has provided \nadvice on Congress' recent legislation on fraud involving sober homes and treatment facilities. \n4822-5464-6166%1 \n2865555-000127 05/10/2019 \nEFTA00225544\n", "char_count": 1927}, {"efta_number": "EFTA00225378", "page_number": 167, "text_content": "Laura Ingersoll \nMay 10, 2019 \nPage 5 of 7 \nAUSA Villafafia's prosecution of a member of Guatemala's Kaibil military branch led to \nwar crimes investigations and prosecutions of numerous high-ranking military and political \nfigures in Guatemalan and international courts, and resulted in her receipt of the Justice \nDepartment's 2011 National Crime Victims' Rights Service Award. The case was the subject of \nan award-wining documentary entitled \"Finding Oscar\" and numerous television shows and \npodcasts. \nU.S.'. Gilberto Jordan, 10-Cr-80069 \nAUSA Villafafia prosecuted the leader and numerous members of the Krazy Locos street \ngang in Palm Beach County (an MS-13 affiliate) for two murders in connection with \nracketeering activity and numerous firearms, drug, and sex trafficking offenses. \nU.S.'. Jonathan a, \net al., 09-Cr-80091 \nU.S.'. Ivan Santiago, 09-Cr-80135 \nU.S.'. Itzel Candela-Campos, 10-Cr-80042 \nAUSA Villafafia prosecuted 57 individuals, including 21 medical professionals, for \ncharges related to staged accidents and chiropractic clinic fraud. According to information \nreceived from victim insurance companies, the prosecutions resulted in a 50% decrease in \nfraudulent auto insurance claims in Palm Beach County as well as changes to state legislation. \nAUSA Villafafia received the Attorney General's Award for Fraud Prevention and the [EOUSA] \nDirector's Award for this series of cases. She also received Prosecutor of the Year awards from \nthe Coalition Against Insurance Fraud and the Florida Insurance Fraud Education Committee for \nher work in these cases. \n• \nU.S.'. Vladimir Lopez, et al., 11-Cr-80106 \n• \nU.S.'. Ketty a, \net al., 11-Cr-80211 \n• \nU.S.'. Obelio Rodriguez, et al., 12-Cr-80107 \n• \nU.S.'. Yuliet Tapanes, et al., 12-Cr-80108 \n• \nU.S.'. M \nAdams, 12-Cr-80112 \n• \nU.S.'. Iris Roca, 13-Cr-80109 \n• \nU.S.'. Olinda Rodriguez, 13-Cr-80110 \nAUSA Villafafia successfully handled the appeal in the matter of U.S.'. Damian Baston \n(14-14444 (11th Circuit)), arguing\n... [truncated, 2259 chars — for the full page use /api/corpus/document/EFTA00225378/167 or ?id=EFTA00225378&page=167]", "char_count": 2259}, {"efta_number": "EFTA00225378", "page_number": 168, "text_content": "Laura Ingersoll \nMay 10, 2019 \nPage 6 of 7 \nFrom Westlaw and Courtlink research, it appears that AUSA Villafaha was the first \nprosecutor in the Southern District of Florida to charge violations of the federal money \ntransmitting statute. \n• \nU.S. 1 Nolaco-Argueta, 02-Cr-20465 \nSignificant Sentences: \n130 years' imprisonment for Jimmy Oliver, who had molested numerous female \nfamily members over several decades. (06-Cr-80023) \n• \nLife plus 135 years for Jonathan \n, head of the Krazy Locos gang, for \nordering two murders and an attempted murder in aid of racketeering and other \noffenses (09-Cr-80091) \nLife imprisonment plus 35 years for Manuel Medina for murder in aid of \nracketeering and other offenses (09-Cr-80091) \n40 years' imprisonment for Marion Yarbrough, who had enticed a Florida girl to \nboard a bus to Kentucky where he repeatedly abused her sexually (07-Cr-80099) \n40 years' imprisonment for Mark Joseph Harvey, who was found in possession of \nover 1 million images of child pornography, organized in files by age and subject \nmatter, and who had previously sexually abused family members (09-Cr-80023) \n• \n30 years' imprisonment for Ivan Isidro Santiago, co-head of the Krazy Locos \ngang, for his role in two murders and an attempted murder in aid of racketeering \nand other offenses (09-Cr-80091 and 09-Cr-80135) \n27.5 years for Kenneth Chatman, who had forced female patients of his substance \nabuse treatment program into prostitution (17-Cr-80013) \n• \n25 years for Frank Grasso, who used social media to advertise for child \npornography (05-Cr-80111) \n• \n20 years for Jonathan Earl Clark on charges of enticement of a minor and child \npornography (08-Cr-80067) \n• \n20 years for Eric Runyan on charges of distribution of obscenity to a minor and \nenticement (12-Cr-80115) \n• \n19 years for Alejandro Tomas for aiding and abetting murder in aid of \nracketeering (09-Cr-80091) \n• \n15 years for Christopher \n-Chamberlain on a charge of aggravated assault \nin connection with the \n... [truncated, 2302 chars — for the full page use /api/corpus/document/EFTA00225378/168 or ?id=EFTA00225378&page=168]", "char_count": 2302}, {"efta_number": "EFTA00225378", "page_number": 169, "text_content": "Laura Ingersoll \nMay 10, 2019 \nPage 7 of 7 \n• \n12 years for John Walsh on charges of distribution of child pornography (05-Cr-\n80185) \n• \n11 years for Silverio Macedonio-Gregorio for aiding and abetting murder in aid of \nracketeering and other offenses (09-Cr-80091) \n• \n10 years for Thomas Bohannon on charges of enticement of a minor (05-Cr-\n80023) \n• \n10 years for Gilberto Jordan on charges of false statements on immigration \napplication for failing to disclose his involvement in war crimes in Guatemala \n(10-Cr-80069) \n• \n8 years for Christopher Prindle for possession of child pornography (04-Cr-\n80156) \nIf you have any questions about any of the above information and the information \nincluded AUSA Villafafia's attached letter, please contact me at your convenience. \nVery truly yours, \nBAKER, DONELSON, BEARMAN, \nCALDWELL & BERKOWITZ, PC \n/s/ \nJonathan Biran \nJB/smr \nEnclosures/Attachment \ncc: AUSA A. Marie Villafafia \n4822.5464-0166x1 \n2865555-000127 05/10/2019 \nEFTA00225547\n", "char_count": 991}, {"efta_number": "EFTA00225378", "page_number": 170, "text_content": "U.S. Department of Justice \nUnited States Attorney \nSouthern District of Florida \n500 South Australian Ave., Suite 400 \nWest Palm Beach, FL 33401 \n(561) 820-8711 \nFacsimile: (56!) 820-8777 \nJuly 10, 2008 \nNOTIFICATION OF IDENTIFIED VICTIM \nNOTICE: IN ACCORDANCE WITH TITLE 18, UNITED \nSTATES CODE, SECTION 3509(d) AND FLORIDA LAW, \nTHE ATTACHED DOCUMENT IS TO BE TREATED AS \nCONFIDENTIAL AND SHALL NOT BE DISCLOSED \nEXCEPT IN CONNECTION WITH A LEGAL \nPROCEEDING. \nEFTA00225548\n", "char_count": 477}, {"efta_number": "EFTA00225378", "page_number": 171, "text_content": "THEODORE J. LEOPOLD, ESQ. \nNOTIFICATION OF IDENTIFIED VICTIM \nJutx 10, 2008 \nPAGE 2 OF 2 \nhad been tried federally and convicted of an enumerated offense. For purposes \nof implementing this paragraph, the United States shall provide Mr. Epstein's \nattorneys with a list of individuals whom it was prepared to name in an \nIndictment as victims of an enumerated offense by Mr. Epstein. Any judicial \nauthority interpreting this provision, including any authority determining \nwhich evidentiary burdens if any a plaintiff must meet, shall consider thatit is \nthe intent of the parties to place these identified victims in the same position \nas they would have been had Mr. Epstein been convicted at trial. No more; no \nless.\" \nSt\nough this letter, this Office hereby provides Notice that your client, \nis an individual whom the United States was prepared to name as a victim o. an \nenumerated offense. \nShould your client decide to file a claim against Jeffrey Epstein, his attorney, Jack \nGoldberger, asks that you contact him at Atterbury Goldberger and Weiss, 250 Australian \nAvenue South, Suite 1400, West Palm Beach, FL 33401. \nPlease understand that neither the U.S. Attorney's Office nor the Federal Bureau of \nInvestigation can take part in or otherwise assist in civil litigation; however, if you do file a \nclaim under 18 U.S.C. § 2255 and Mr. Epstein denies that your client is a victim of an \nenumerated offense, please provide written documentation of that denial to the undersigned. \nPlease thank your client for all of her assistance during the course of this investigation \nand express the heartfelt regards of m self and Special Agents Kuyrkendall and Richards for \nthe health and well-being of Ms. \nR. ALEXANDER ACOSTA \nUNITED STATES ATTORNEY \nBy: \ncc: \nJack Goldberger, Esq. \n...•••••••• \n. MARIE VELLAFARA \nASSISTANT U.S. ATTORNEY \nEFTA00225549\n", "char_count": 1862}, {"efta_number": "EFTA00225378", "page_number": 172, "text_content": "U.S. Department of Justice \nUnited States Attorney \nSouthern District of Florida \n500 South Australian Ave., Suite 400 \nWest Palm Beach, FL 33401 \n(561)8204711 \nFacsimile: (56!) 8204777 \nJuly 10, 2008 \nVIA FACSIMILE AND U.S. MAIL \nTheodore J. Leopold, Esq. \nRicci—Leopold, P.A. \n2925 PGA Boulevard, Suite 200 \nPalm Beach Gardens, FL 33410 \nRe: \nJeffrey Epstein/: NOTIFICATION OF \nIDENTIFIED VICTIM.\nDear Mr. Leopold: \n• By virtue of this letter, the United States Attorney's Office for the Southern District \nof Florida asks that you provide the following notice to your client, \nOn June 30, 2008, Jeffrey Epstein (hereinafter referred to as \"Epstein) entered a plea \nof guilty to violations of Florida Statutes Sections 796.07 (felony solicitation of prostitution) \nand 796.03 (procurement of minors to engage in prostitution), in the 15th Judicial Circuit in \nand for Palm Beach CoUnty (Case Nos. 2006-d-009454/OOOOAB and 2008-cf-\n009381AXXXMB) and was sentenced to a term of twelve months' imprisonment to be \nfollowed by an additional six months' imprisonment, followed by twelve months of \nCommunity Control 1, with conditions of community confinement imposed by the Court. \nIn light of the entry of the guilty plea and sentence, the United States has agreed to \ndefer federal prosecution in favor of this state plea and sentence, subject to certain \nconditions. \nOne such condition to which Epstein has agreed is the following: \n\"Any person, who while a minor, was a victim of a violation of an offense \nenumerated in Title 18, United States Code, Section 2255, will have the same \nrights to proceed under Section 2255 as she would have had, if Mr. Epstein \nEFTA00225550\n", "char_count": 1677}, {"efta_number": "EFTA00225378", "page_number": 173, "text_content": "U.S. Department of Justice \nFILE COPY i \nUnited States Attorney \nSouthern District of Florida \n.14.•411 Mr. \n500 South Australian Ave., Suite 400 \nWest Palm Beach, FL 33401 \n(561) 820-8711 \nFacsimile: (561) 820-8777\nJuly 10, 2008 \nNOTIFICATION OF IDENTIFIED VICTIM \nNOTICE: IN ACCORDANCE WITH TITLE 18, UNITED \nSTATES CODE, SECTION 3509(d) AND FLORIDA LAW, \nTHE ATTACHED DOCUMENT IS TO BE TREATED AS \nCONFIDENTIAL AND SHALL NOT BE DISCLOSED \nEXCEPT IN CONNECTION WITH A LEGAL \nPROCEEDING. \nEFTA00225551\n", "char_count": 503}, {"efta_number": "EFTA00225378", "page_number": 174, "text_content": "JEFFREY HERMAN, ESQ. \nNOTIFICATION OF IDENTIFIED VICTIM ANGELIQUE GARCIA (NEE CAVALLARO) \nJULY 10, 2008 \nPAGE 2 OF 2 \nrights to proceed under Section 2255 as she would have had, if Mr. Epstein \nhad been tried federally and convicted of an enumerated offense. For purposes \nof implementing this paragraph, the United States shall provide Mr. Epstein's \nattorneys with a list of individuals whom it was prepared to name in an \nIndictment as victims of an enumerated offense by Mr. Epstein. Any judicial \nauthority interpreting this provision, including any authority determining \nwhich evidentiary burdens if any a plaintiff must meet, shall consider that it is \nthe intent of the parties to place these identified victims in the same position \nas they would have been had Mr. Epstein been convicted at trial. No more; no \nless.\" \nThrough this letter, this Office hereby provides Notice that your client, \n), is an individual whom the United States was prepared to name as a \nvictim of an enumerated offense. \nShould your client decide to file a claim against Jeffrey Epstein, his attorney, Jack \nGoldberger, asks that you contact him at Atterbury Goldberger and Weiss, 250 Australian \nAvenue South, Suite 1400, West Palm Beach, FL 33401. \nPlease understand that neither the U.S. Attorney's Office nor the Federal Bureau of \nInvestigation can take part in or otherwise assist in civil litigation; however, if you do file a \nclaim under 18 U.S.C. § 2255 and Mr. Epstein denies that your client is a victim of an \nenumerated offense, please provide written documentation of that denial to the undersigned. \nPlease thank your client for all of her assistance during the course of this investigation \nand express the heartfelt regards of myself and Special Agents Kuyrkendall and Richards for \nthe health and well-being of Ms. Garcia. \nR. ALEXANDER ACOSTA \nUNITED STATES ATTORNEY \nBy: \nC/ \"Z. \nA. MARIE VILLAFANA \nASSISTANT U.S. ATTORNEY \ncc: \nJack Goldberger, Esq. \nEFTA00225552\n", "char_count": 1974}, {"efta_number": "EFTA00225378", "page_number": 175, "text_content": "U.S. Department of Justice \nUnited States Attorney \nSouthern District of Florida\n500 South Australian Ave.. Suite 400 \nWest Palm Beach, FL 33401 \n(561)820-8711 \nFacsimile: (561) 820-8777 \nJuly 10, 2008 \nVIA FACSIMILE AND U.S. MAIL \nJeffrey Herman, Esq. \nHerman & Mermelstein, P.A. \n18205 Biscayne Boulevard \nSuite 2218 \nMiami, Florida 33160 \nRe: \nJeffrey Epstein/Angelique Garcia (née Cavatiara): \nNOTIFICATION OF IDENTIFIED VICTIM \nDear Mr. Herman: \nBy virtue of this letter, the United States Attorney's Office for the Southern District \nof Florida asks that you provide the following notice to your client, \nGarcia. \nOn June 30, 2008, Jeffrey Epstein (hereinafter referred to as \"Epstein) entered a plea \nof guilty to violations of Florida Statutes Sections 796.07 (felony solicitation of prostitution) \nand 796.03 (procurement of minors to engage in prostitution), in the 15th Judicial Circuit in \nand for Palm Beach County (Case Nos. 2006-cf-009454AXXXMB and 2008-cf-\n009381AXX3CMB) and was sentenced to a term of twelve months' imprisonment to be \nfollowed by an additional six months' imprisonment, followed by twelve months of \nCommunity Control 1, with conditions of community confinement imposed by the Court. \nIn light of the entry of the guilty plea and sentence, the United States has agreed to \ndefer federal prosecution in favor of this state plea and sentence, subject to certain \nconditions. \nOne such condition to which Epstein has agreed is the following: \n\"Any person, who while a minor, was a victim of a violation of an offense \nenumerated in Title 18, United States Code, Section 2255, will have the same \nEFTA00225553\n", "char_count": 1642}, {"efta_number": "EFTA00225378", "page_number": 176, "text_content": "U.S. Department of Justice \nUnited States Attorney \nSouthern District of Florida \n500 South Australian Ave., Suite 400 \nWest Bohn Beach, FL 33401 \n(561)820-8711 \nFacsimile: (561) 820-8777 \nJuly 10, 2008 \nNOTIFICATION OF IDENTIFIED VICTIM \nNOTICE: IN ACCORDANCE WITH TITLE 18, UNITED \nSTATES CODE, SECTION 3509(d) AND FLORIDA LAW, \nTHE ATTACHED DOCUMENT IS TO BE TREATED AS \nCONFIDENTIAL AND SHALL NOT BE DISCLOSED \nEXCEPT IN CONNECTION WITH A LEGAL \nPROCEEDING. \nEFTA00225554\n", "char_count": 476}, {"efta_number": "EFTA00225378", "page_number": 177, "text_content": "RICHARD WILLITS, ESQ. \nNCYFIFICATION OF IDENTIFIED VICTIM \nANDRIANO \nJULY 10, 2008 \nPAGE 2 OF 2 \nof implementing this paragraph, the United States shall provide Mr. Epstein's \nattorneys with a list of individuals whom it was prepared to name in an \nIndictment as victims of an enumerated offense by Mr. Epstein. Any judicial \nauthority interpreting this provision, including any authority determining \nwhich evidentiary burdens if any a plaintiff must meet, shall consider that it is \nthe intent of the parties to place these identified victims in the same position \nas they would have been had Mr. Epstein been convicted at trial. No more; no \nless.\" \nThrough this letter, this Office hereby provides Notice that your client, \nis an individual whom the United States was prepared to name as a victim of an \nenumerated offense. \nShould your client decide to file a claim against Jeffrey Epstein, his attorney, Jack \nGoldberger, asks that you contact him at Atterbury Goldberger and Weiss, 250 Australian \nAvenue South, Suite 1400, West Palm Beach, FL 33401. \nPlease understand that neither the U.S. Attorney's Office nor the Federal Bureau of \nInvestigation can take part in or otherwise assist in civil litigation; however, if you do file a \nclaim under 18 U.S.C. § 2255 and Mr. Epstein denies that your client is a victim of an \nenumerated offense, please provide written documentation of that denial to the undersigned. \nPlease thank your client for all of her assistance during the course of this investigation \nand express the heartfelt regards of m self and Special Agents Kuyrkendall and Richards for \nthe health and well-being of Ms. \nR. ALEXANDER ACOSTA \nUNITED STATES ATTORNEY \nBy: \nA. MARIE V1LLAFAN- A \nASSISTANT U.S. ATTORNEY \ncc: \nJack Goldberger, Esq. \nEFTA00225555\n", "char_count": 1781}, {"efta_number": "EFTA00225378", "page_number": 178, "text_content": "U.S. Department of Justice \nUnited States Attorney' \nSouthern District of Florida \n.500 South Australian Ave., Suite 400 \nWest Palm Beach, FL 33401 \n(561)820-8711 \nFacsimile: (561) 820-8777 \nJuly 10, 2008 \nVIA FACSIMILE AND U.S. MAIL \nRichard H. Willits, P.A. \n2290 10th Avenue North, Suite 404 \nLake Worth, FL 33461 \nRe: \nJeffrey Epstein/Carolyn \nNOTIFICATION OF \nIDENTIFIED VICTIM \nDear Mr. Willits: \nBy virtue of this letter, the United States Attorney's Office for the Southern District \nof Florida asks that you provide the following notice to your client, \nOn June 30, 2008, Jeffrey Epstein (hereinafter referred to as \"Epstein) entered a plea \nof guilty to violations of Florida Statutes Sections 796.07 (felony solicitation of prostitution) \nand 796.03 (procurement of minors to engage in prostitution), in the 15th Judicial Circuit in \nand for Palm Beach County (Case Nos. 2006-cf-009454/OOaMB and 2008-cf-\n009381AXXXMB) and was sentenced to a term of twelve months' imprisonment to be \nfollowed by an additional six months' imprisonment, followed by twelve months of \nCommunity Control 1, with conditions of community confinement imposed by the Court. \nIn light of the entry of the guilty plea and sentence, the United States has agreed to \ndefer federal prosecution in favor of this state plea and sentence, subject to certain \nconditions. \nOne such condition to which Epstein has agreed is the following: \n\"Any person, who while a minor, was a victim of a violation of an offense \nenumerated in Title 18, United States Code, Section 2255, will have the same \nrights to proceed under Section 2255 as she would have had, if Mr. Epstein \nhad been tried federally and convicted of an enumerated offense. For purposes \nEFTA00225556\n", "char_count": 1739}, {"efta_number": "EFTA00225378", "page_number": 179, "text_content": "U.S. Department of Justice \nUnited States Attorney \nSouthern District of Florida \n•\n \n500 South Australian Ave., Suite 400 \nWest Palm Beach, FL 33401 \n(561) 820-8711 \nFacsimile: (561) 820-8777 \nJply.10, 2008 \nNOTIFICATION OF IDENTIFIED VICTIM \nNOTICE: IN ACCORDANCE WITH TITLE 18, UNITED \nSTATES CODE, SECTION 3509(d) AND FLORIDA LAW, \nTHE ATTACHED DOCUMENT IS TO BE TREATED AS \nCONFIDENTIAL AND SHALL NOT BE DISCLOSED \nEXCEPT IN CONNECTION WITH A LEGAL \nPROCEEDING. \nEXHIBIT B-67 \nEFTA00225557\n", "char_count": 495}, {"efta_number": "EFTA00225378", "page_number": 180, "text_content": "BRAD EDWARD$, ESQ. \nNOTIFICATION OF IDENTIFIED VICTIM \nJULY 9, 2008 \nPAGE 2 OF 2 \nhad been tried federally and convicted of an enumerated offense. For purposes \nof implementing this paragraph, the United States shall provide Mr. Epstein's \nattorneys with a list of individuals whom it was prepared to name in an \nIndictment as victims of an enumerated offense by Mr. Epstein. Any judicial \nauthority interpreting this provision, including any authority determining \nwhich evidentiary burdens if any a plaintiff must meet, shall consider that it is \nthe intent of the parties to place these identified victims in the same position \nas they would have been had Mr. Epstein been convicted at trial. No more; no \nless.\" \n• \nThrough this letter, this Office hereby provides Notice that your client, \nis an individual whom the United States was prepared to name as a victim of an enumerated \noffense. \nShould your client decide to file a claim against Jeffrey Epstein, his attorney, Jack \nGoldberger, asks that you contact him at Atterbury Goldberger and Weiss, 250 Australian \nAvenue South, Suite 1400, West Palm Beach, FL 33401, (561) 659-8300. \nPlease understand that neither the U.S. Attorney's Office nor the Federal Bureau of \nInvestigation can take part in or otherwise assist in civil litigation; however, if you do file a \nclaim under 18 U.S.C. § 2255 and Mr. Epstein denies that your client is a victim of an \nenumerated offense, please provide notice of that denial to the undersigned. \nPlease thank your client for all of her assistance during the course of this examination \nand express the heartfelt regards ofAlself and Special Agents Kuyrkendall and Richards for \nthe health and well-being of Ms. M. \nR. ALEXANDER ACOSTA \nUNITED STATES ATTORNEY \nBy: \nA. MARIE VILLAFARA \nASSISTANT U.S. ATTORNEY \ncc: \nJack Goldberger, Esq. \nEFTA00225558\n", "char_count": 1847}, {"efta_number": "EFTA00225378", "page_number": 181, "text_content": "U.S. Department of Justice \nUnited States Attorney \nSouthern District of Florida \n500 South Australian Ave., Suite 400 \nWest Palm Beach, FL 33401 \n(561) 820-8711 \nFacsimile: (561) 820-8777 \nJuly 9, 2008 \n. \nVIA FACSIMILE \nBrad Edwards, Esq. \nThe Law Offices of Brad Edwards & Associates, LLC \n2028 Harrison Street, Suite 202 \nHollywood, Florida 33020. \nRe: \nJeffrey Epstein/Courtney \nNOTIFICATION OF \nIDENTIFIED VICTIM \nDear Mr. Edwards: \nBy virtue of this letter, the United States Attorney's Office for the Southern District \nof Florida asks that you provide the following notice to your client, \nOn June 30, 2008, Jeffrey Epstein (hereinafter referred to as \"Epstein) entered a plea \nof guilty to violations of Florida Statutes Sections 796.07 (felony solicitation of prostitution) \nand 796.03 (procurement of minors to engage in prostitution), in the 15th Judicial Circuit in \nand for Palm Beach County (Case Nos. 2006-cf-009454A=MB and 2008-cf-\n009381AXXXMB) and was sentenced to a term of twelve months' imprisonment to be \nfollowed by an additional six months' imprisonment, followed by twelve months of \nCommunity Control 1, with conditions of community confinement imposed by the Court. \nIn light of the entry of the guilty plea and sentence, the United States has agreed to \ndefer federal prosecution in favor of this state plea and sentence, subject to certain \nconditions. \nOne such condition to which Epstein has agreed is the following: \n\"Any person, who while a minor, was a victim of a violation of an offense \nenumerated in Title 18, United States Code, Section 2255, will have the same \nrights to proceed under Section 2255 as she would have had, if Mr. Epstein \nEFTA00225559\n", "char_count": 1694}, {"efta_number": "EFTA00225378", "page_number": 182, "text_content": "U.S. Department of Justice \nFILE COPY \nUnited States Attorney \nSouthern District of Florida \n500 South Australian Ave., Suite 400 \nWest Palm Beach, FL 33401 \n(561) 820-8711 \nFacsimile: (561) 820-8777 \nJuly 9, 2008 \nNOTIFICATION OF IDENTIFIED VICTIM \nNOTICE: IN ACCORDANCE WITH TITLE 18, UNITED \nSTATES CODE, SECTION 3509(d) AND FLORIDA LAW, \nTHE ATTACHED DOCUMENT IS TO BE TREATED AS \nCONFIDENTIAL AND SHALL NOT BE DISCLOSED \nEXCEPT IN CONNECTION WITH A LEGAL \nPROCEEDING. \nEFTA00225560\n", "char_count": 487}, {"efta_number": "EFTA00225378", "page_number": 183, "text_content": "BRAD EDWARDS, ESQ. \nNOTIFICATION OF IDENTIFIED VICTIM a \nRIVERA \nJULY 9, 2008 \nPAGE 2 OF 2 \nhad been tried federally and convicted of an enumerated offense. For purposes \nof implementing this paragraph, the United States shall provide Mr. Epstein's \nattorneys with a list of individuals whom it was prepared to name in an \nIndictment as victims of an enumerated offense by Mr. Epstein. Any judicial \nauthority interpreting this provision, including any authority determining \nwhich evidentiary burdens if any a plaintiff must meet, shall consider that it is \nthe intent of the parties to place these identified victims in the same position \nas they would have been had Mr. Epstein been convicted at trial. No more; no \nless.\" \nThrough this letter, this Office hereby provides Notice that your client, \nM\n, is an individual whom the United States was prepared to name as a victim of an \nenumerated offense. \nShould your client decide to file a claim against Jeffrey Epstein, his attorney, Jack \nGoldberger, asks that you contact him at Atterbury Goldberger and Weiss, 250 Australian \nAvenue South, Suite 1400, West Palm Beach, FL 33401, (561) 659-8300. \nPlease understand that neither the U.S. Attorney's Office nor the Federal Bureau of \nInvestigation can take part in or otherwise assist in civil litigation; however, if you do file a \nclaim under 18 U.S.C. § 2255 and Mr. Epstein denies that your client is a victim of an \nenumerated offense, please provide notice of that denial to the undersigned. \nPlease thank your client for all of her assistance during the course of this examination \nand express the heartfelt regards of m self and Special Agents Kuyrkendall and Richards for \nthe health and well-being of Ms. \nR. ALEXANDER ACOSTA \nUNITED STATES ATTORNEY \nBy: \ncc: \nJack Goldberger, Esq. \nA. MARIE VILLAFARA \nASSISTANT U.S. ATTORNEY \nEFTA00225561\n", "char_count": 1856}, {"efta_number": "EFTA00225378", "page_number": 184, "text_content": "U.S. Department of Justice \nUnited States Attorney \nSouthern District of Florida \n500 South Australian Ave., Suite 400 \nWest Palm Beach, FL 33401 \n(561)820-8711 \nFacsimile: (561)820-8777 \nJuly 9, 2008 \nVIA FACSIMILE \nBrad Edwards, Esq. \nThe Law Offices of Brad Edwards & Associates, LLC \n2028 Harrison Street, Suite 202 \nHollywood, Florida 33020. \nRe: \nJeffrey EpsteinMIM \nNOTIFICATION OF \nIDENTIFIED VICTIM \nDear Mr. Edwards: \nBy virtue of this letter, the United States Attorney's Office for the Southern District \nof Florida asks that you provide the following notice to your client, \nOn June 30, 2008, Jeffrey Epstein (hereinafter referred to as \"Epstein) entered a plea \nof guilty to violations of Florida Statutes Sections 796.07 (felony solicitation ofprostitution) \nand 796.03 (procurement of minors to engage in prostitution), in the 15th Judicial Circuit in \nand for Palm Beach County (Case Nos. 2006-ef-009454AXXXMB and 2008-cf-\n00938 1 AXXXMB) and was sentenced to a term of twelve months' imprisonment to be \nfollowed by an additional six months' imprisonment, followed by twelve months of \nCommunity Control 1, with conditions of community confinement imposed by the Court. \nIn light of the entry of the guilty plea and sentence, the United States has agreed to \ndefer federal prosecution in favor of this state plea and sentence, subject to certain \nconditions. \nOne such condition to whichEpstein has agreed is the following: \n\"Any person, who while a minor, was a victim of a violation of an offense \nenumerated in Title 18, United States Code, Section 2255, will have the same \nrights to proceed under Section 2255 as she would have had, if Mr. Epstein \nEFTA00225562\n", "char_count": 1685}, {"efta_number": "EFTA00225378", "page_number": 185, "text_content": "U.S. Department of Justice \nUnited States Attorney \nSouthern District of Florida \n500 South Australian Ave., Suite 400 \nWest Palm Beach, FL 33401 \n(561) 820-8711 \nFacsimile: (561) 820-8777 \nJuly 9, 2008 \nNOTIFICATION OF IDENTIFIED VICTIM \nNOTICE: IN ACCORDANCE WITH TITLE 18, UNITED \nSTATES CODE, SECTION 3509(d) AND FLORIDA LAW, \nTHE ATTACHED DOCUMENT IS TO BE TREATED AS \nCONFIDENTIAL AND SHALL NOT BE DISCLOSED \nEXCEPT IN CONNECTION WITH A LEGAL \nPROCEEDING. \nEXHIBIT B-66 \nEFTA00225563\n", "char_count": 490}, {"efta_number": "EFTA00225378", "page_number": 186, "text_content": "Villafana, Ann Marie C. (USAFLS) \nFrom: \nSloman, Jeff (USAFLS) \nSent: \nThursday, July 10, 2008 5;15 PM \nTo: \nVillafana, Ann Mane C. (USAFLS); Acosta. Alex (USAFLS): Atkinson, Karen (USAFLS) \nCc: \nKuyrkendall, E N. (FBI); Richards, Jason R. (FBI) \nSubject: \nRe: Proposed response to Goldberger's letter \nFine \n \n Original Message \nFrom: Villafana, Ann Marie C. (USAFLS) \nTo: Acosta, Alex (USAFLS); Sloman, Jeff (USAFLS); Atkinson, Karen (USAFLS) \nCc: Kuyrkendall, E N. (FBI); Richards, Jason R. (FBI) \nSent: Thu Jul 10 17:12:26 2008 \nSubject: Proposed response to Goldberger's letter \nPlease let me know if this is alright to fax out today. I can see no reason for \nus to disclose any of the additional information that they have requested. \nThe message is ready to be sent with the following file or link attachments: \n080710 Response to Goldberger ltr re notification.wpd \nNote: To protect against computer viruses, e-mail programs may prevent sending or \nreceiving certain types of file attachments. Check your e-mail security settings \nto determine how attachments are handled. \nEXHIBIT 8-65 \n543 \nEFTA00225564\n", "char_count": 1115}, {"efta_number": "EFTA00225378", "page_number": 187, "text_content": "indicated in your letter of December 13, 2007)? \nFifth, please recall that Mr. Sloman wrote to Judge \non October 25, 2007 that \"The \nUnited States takes no position as to the validity of any such claim under this statute.\" To \navoid any appearance that the United States is endorsing or encouraging litigation by the \nidentified individuals, we believe that such a statement should be included in any \nnotification letter. \nI look fonyard to receiving your input on these issues. Until then, I remain, \nJack A. Goldberger \nJAG/na \ncc: \nJeffrey E. Epstein \nEFTA00225565\n", "char_count": 569}, {"efta_number": "EFTA00225378", "page_number": 188, "text_content": "• JOSEPH R.ATFERBURY \nt JACK A. GOLDBERGER \nJASON S.WEISS \n' Board Certified Criminal TrialAttomey \nMember of New Jersey & Florida Bars \nJuly 10, 2008 \nA. Marie C. Villafana, Esq. \nAssistant United States Attorney \n500 S. Australian Avenue \n4th Floor, Suite 400 \nWest Palm Beach, Florida 33401 \nSENT VIA E-MAIL 8 FACSIMILE \n(561) 820-8777 \nRe: \nJeffrey E. Epstein \nDear Ms. Villafana: \nThank you for your letter of yesterday. Kindly allow me a few follow-up points. \nFirst, we respectfully request a reasonable opportunity to review and comment on a draft \nof the modified notification letter you intend to mail before you send it. \nSecond, we respectfully ask that you provide us with the identity of the victims' rights \norganization described in your letter; the name and contact information of the person at \nthat organization with whom the Government has been communicating; copies of any \ncommunications with that organization and the pro-bono lawyers/groups who were \nrecommended by that organization; and a description of any non-written communications \nthat the Government has had with that organization and the pro-bono lawyers/groups. \nThird, while we appreciate your offer to disclose the names of the lawyers currently \nrepresenting the individuals when you have finished compiling all of that information, we \nwould be very grateful if you would provide any contact information you do have, on a \nrolling basis. \nFourth, would it be possible for you to advise us of the full name of the minor to whom you \nhave referred by initials, as well as the identities of the three individuals whom the \nGovernment notified about the deferred-prosecution agreement shortly after its signing (as \nEXHIBIT B-64 \nOne Cleartake Centre, Suite 1400 \n250 Australian Avenue South West Palm Beach. FL 33401 \np 561.659.8300 f 561.835.8691 www.agwpa.com \nEFTA00225566\n", "char_count": 1861}, {"efta_number": "EFTA00225378", "page_number": 189, "text_content": "JACK GOLDBERGER, ESQ. \nJULY 10, 2008 \nPAGE 2 OF 2 \nof implementing this paragraph, the United States shall provide Mr. Epstein's \nattorneys with a list of individuals whom it was prepared to name in an \nIndictment as victims of an enumerated offense by Mr. Epstein. Any judicial \nauthority interpreting this provision, including any authority determining \nwhich evidentiary burdens if any a plaintiff must meet, shall consider that it is \nthe intent of the parties to place these identified victims in the same position \nas they would have been had Mr. Epstein been convicted at trial. No more; no \nless.\" \nThrough this letter, this Office hereby provides Notice that the individuals identified \nbelow are individuals whom the United States was prepared to name as victims of an \nenumerated offense. \nIdentified Individuals \n \nBy: \ncc: \nKaren Atkinson, AUSA \nSincerely, ( \n• \nR. Alexander Acosta \nUnited States Attorney \nA. Marie Villafafia \nAssistant United States Attorney \nEFTA00225567\n", "char_count": 989}, {"efta_number": "EFTA00225378", "page_number": 190, "text_content": "U.S. Department of Justice \nUnited States Attorney \nSouthern District of Florida \n500 South Australian Ave., Suite 400 \nWest Palm Beach, FL 3340! \n(561) 820-8711 \nFacsimile: (561) 820-8777 \nJuly 10, 2008 \nVIA CERTIFIED MAIL \n. Jack A. Goldberger, Esq. \nAtterbury, Goldberger & Weiss, P.A. \nOne Clearlake Centre, Suite 1400 \n250 Australian Ave S. \nWest Palm Beach, FL 33401-5015 \nRe: \nJeffrey Epstein \nDear Mr. Goldberger: \nFINAL NOTIFICATION OF IDENTIFIED VICTIMS \nOn June 30, 2008, Jeffrey Epstein (hereinafter referred to as \"Epstein) entered a plea \nof guilty to violations of Florida Statutes Sections 796.07 (felony solicitation of prostitution) \nand 796.03 (procurement of minors to engage in prostitution), in the 15th Judicial Circuit in \nand for Palm Beach County (Case Nos. 2006-cf-009454AXXXMB and 2008-cf-\n00938 I AXXXMB) and was sentenced to a term of twelve months' imprisonment to be \nfollowed by an additional six months' imprisonment, followed by twelve months of \nCommunity Control I, with conditions of community confineinent imposed by the Court. \nIn light of the entry of the guilty plea and sentence, the United States has agreed to \ndefer federal prosecution in favor of this state plea and sentence, subject to certain \nconditions. \nOne such condition to which Epstein has agreed is the following: \n\"Any person, who while a minor, was a victim of a violation of an offense \nenumerated in Title 18, United States Code, Section 2255, will have the same \nrights to proceed under Section 2255 as she would have had, if Mr. Epstein \nhad been tried federally and convicted of an enumerated offense. For purposes \nEFTA00225568\n", "char_count": 1644}, {"efta_number": "EFTA00225378", "page_number": 191, "text_content": "U.S. Department of Justice \nUnited States Attorney \nSouthern District of Florida FILE COPY \nSOO South Australian Ave., Suite 400 \nWest Palm Beach. FL 3340! \n(561) 820-8711 \nFacsimile: (561) 820-8777 \nJuly 10, 2008 \nNOTIFICATION OF IDENTIFIED VICTIMS \nNOTICE: IN ACCORDANCE WITH TITLE 18, UNITED \nSTATES CODE, SECTION 3509(d) AND FLORIDA LAW, \nTHE ATTACHED DOCUMENT IS TO BE TREATED AS \nCONFIDENTIAL AND SHALL NOT BE DISCLOSED \nEXCEPT IN CONNECTION WITH \nA LEGAL \nPROCEEDING. \nEXHIBIT B-63 \nEFTA00225569\n", "char_count": 503}, {"efta_number": "EFTA00225378", "page_number": 192, "text_content": "U.S. Department of Justice \nUnited States Attorney \nSouthern District of Florida \nA. Marie VIHafalia \n500 S. Australian Ave, 4th Floor \nWest Palm Beach, Florida 33401 \n(561) 8204711 \nFacsimile (561) 8204777 \nFACSIMILE COVER SHEET \nTO: \nJack Alan Goldberger \nDATE: \nJuly 10. 2008 \nFAX NO. \n561-835-8691 \n# OF PAGES: \n2\nPHONE NO. 561 659-8300 \n \nRE: \nJeffrey Epstein \nFROM: \nA. MARIE VILLAFARA, Assistant U.S. Attorney \nPHONE NO. 561 209-1047 \nCOMMENTS: \nEFTA00225570\n", "char_count": 469}, {"efta_number": "EFTA00225378", "page_number": 193, "text_content": "r. \n* * * TRANSMISSION RESULT REPORT ( JUL.10:200B 5:26PM ) * * * \n• . \nTTI USAO WPB FL \nDATE \nTIKE \nADDRESS \nMODE \nTIME \nPAGE RESULT \nPERS. NAME \nFILE \n__________----___ \nJUL.10. 5:26PM \n5618358691 TES \n0'24\" P. 2 OK \n434 \n: BATCH \nL : SEND LATER \nS : STANDARD \nA-: ASYNC MODE \nC \nCONFIDENTIAL \ne : FORWARDING \nD : DETAIL \n1 -: MIL_STD MODE \nP : POLLING \nM : MEMORY \nE \nECM \n> : REDUCTION \nF \nFINE \nG \nRICOH -MG3/COMPATIBLE MODE \nEFTA00225571\n", "char_count": 444}, {"efta_number": "EFTA00225378", "page_number": 194, "text_content": "U.S. Department of Justice \nUnited States Attorney \nSouthern District of Florida \n500 South Australian Ave., Suite 400 \nWest Palm Beach, FL 33401 \n(561)820-8711 \nFacsimile: (561) 820-8777 \nJuly 10, 2008 \nVIA FACSIMILE \nJack A. Goldberger, Esq. \nAtterbury, Goldberger & Weiss, P.A. \nOne Clearlake Centre, Suite 1400 \n250 Australian Ave S. \nWest Palm Beach, FL 33401-5015 \nRe: \nJeffrey Epstein \nDear Mr. Goldberger: \nIn response to your letter of today's date, copies of the victim notifications are being \nmailed to you on a rolling basis. For those victims who have counsel, the attorneys' contact \ninformation will be included. As you will see, the letter makes clear that neither the U.S. \nAttorney's Office nor the Federal Bureau of Investigation can take part in or otherwise assist \nin civil litigation. The Office feels that is a sufficient statement of its position and we will \nnot include the language that you have requested. \nAlso, a final list of victims has been sent to you today via Certified Mail. That list is \nidentical to the draft provided to you on June 30th, except that it also includes the full name \nof the minor victim. \nBy: \ncc: \nKaren Atkinson, AUSA \nSincerely, \nR. Alexander Acosta \nUnited States Attorney,\nA. Marie Villafafia \nAssistant United States Attorney \nEXHIBIT B-62 \nEFTA00225572\n", "char_count": 1318}, {"efta_number": "EFTA00225378", "page_number": 195, "text_content": "(c) You eliminate from any notification any language that is currently contained in \nthe \"acknowledgment\" section of the June 30, 2008 memorandum; and \n(d) You supplement the notification with the Government's previously made \nrepresentation that it is not vouching for the =un ity of any claim by any identified \nindividual. See Letter from J. Sloman to E. \n(10/25/07). \nSecond, please note also that we do not understand your request that Mr. Epstein and his attorneys \nexecute the rider / acknowledgment contained within your June 30 hand-delivered draft. \nSpecifically, we do not believe that the Non-Prosecution Agreement requires Mr. Epstein's execution \nof any such additional stipulation. Because we want to ensure that Mr. Epstein continues to strictly \ncomply with the letter of the parties' agreement, we respectfully ask that you explain why you \nbelieve that the Non-Prosecution Agreement requires execution of your stipulation. \nOur understanding of the Non-Prosecution Agreement is that it does not require Mr. Epstein to \n\"acknowledge\" anything not already contained within the four corners of the written agreement. The \nagreement certainly contains no written term obligating that he \"waive any evidentiary challenge to \nthe introduction of a copy\" of any \"Notification of Identified Victims\" in \"any judicial proceeding \nbetween any identified individual\" and Mr. Epstein, as your memorandum currently requests. \nFurther, please note that your June 30 stipulation, as drafted, is not limited to Section 2255 \nproceedings. Rather, your June 30 draft requires Mr. Epstein to waive evidentiary challenges in \"any \njudicial proceeding\" - - which clearly exceeds the bounds of the parties' written agreement. \nThird, I would respectfully request that you provide me with the names of the \"pro bono lawyers\" \nwho, you indicated to me at our June 30 meeting at my office, were intending to represent certain \npersons identified on your June 30 draft notification, as well as any knowledge\n... [truncated, 2560 chars — for the full page use /api/corpus/document/EFTA00225378/195 or ?id=EFTA00225378&page=195]", "char_count": 2560}, {"efta_number": "EFTA00225378", "page_number": 196, "text_content": "ty.st\nJuly 9, 2008 \nA. Marie C. Villafana, Esq. \nAssistant United States Attorney \nUnited States Attorney's Office \n500 South Australian Avenue \n41\" Floor, Suite 400 \nWest Palm Beach, Florida 33401 \nSENT PIA E-MAIL & FACSIMILE \n(561) 820-8777 \nRe: \nJeffrey E. Epstein \nDear Ms. Villafana: \nWritgrc*: \n4 14\ns \nitA.,V4 \ntA:41:e. \n• JOSEPH R.ATTERBURY \n•t JACK A.GOLDBERGER \nJASON S.WE1SS \n•Board Certified CriminalTrial Attorney \nt Member of New Jersey & Horlda Ben \nThank you for your letter to me dated July 8, 2008 and the draft document dated, e-mailed and faxed \nto me at my office on June 30, 2008, styled \"Notification of Identified Victims.\" I would like to \naddress a few related issues. \nFirst, please note that we have several requests concerning any such notification. Specifically, we \nrequest that: \n(a) Any notification be sent to any individual by mail (or served upon their attorney, \nto the extent known), and we respectfully object to any service by hand, a method of \nservice which carries the concomitant risk of conversations regarding the notification \nthat potentially would place the federal authorities in a position of being advocates \nfor civil litigation; \n(b) Any notification be effectuated by a separate mailing to each individual without \nthe inclusion of any language that appeared on the second page of your June 30, 2008 \nmemorandum; i.e. rather than including in each notification a large section listing \n\"identified individuals\" with redactions other than the name of the recipient (which \nwe contend would be a clear and impermissible signal to any individual that the \nnotification is a broad notification to numerous other alleged victims). Rather, a \nsimple one page notification directed only to the recipient, and limited to the \ninformation currently on the first page of your draft memorandum would suffice. \nOne Clearlake Centre, Suite 1400 \n250 Australian Avenue South West Palm Beach, FL 33401 \np 561.659.8300 f 561.835.8691 www.agwpa.com \nEXHIBIT B-6I\n... [truncated, 2015 chars — for the full page use /api/corpus/document/EFTA00225378/196 or ?id=EFTA00225378&page=196]", "char_count": 2015}, {"efta_number": "EFTA00225378", "page_number": 197, "text_content": "P. 1 \n* * * TRANSMISSION RESULT REPORT ( JUL. 9.2008 4:05PM ) * * * \nTTI USA° WPB FL \nDATE \nTIME \nADDRESS \nMODE \nTIME \nPAGE RESULT \nPERS. NAME \nFILE \nJUL. 9. 4:04PM \n• : BATCH \nL : SEND LATER \nS : STANDARD \nA-: ASYNC MODE \n5618358691 TES \n0'36\" P. 3 \nOK \n412 \nC : CONFIDENTIAL \n@ : FORWARDING \nD \nDETAIL \n1-: MIL_STD MODE \nP : POLLING \nE : ECM \nF : FINE \nG-: RICOH-MG3/COMPATIBLE MODE \nM : MEMORY \n> : REDUCTION \nEFTA00225575\n", "char_count": 426}, {"efta_number": "EFTA00225378", "page_number": 198, "text_content": "U.S. Department of Justice \nUnited States Attorney \nSouthern District of Florida \nA. Marie Villafalia \n500 S. Australian Ave, 4th Floor \nWest Palm Beach, Florida 33401 \n(561) 820-8711 \nTO: \nFacsimile (561) 820-8777 \nFACSIMILE COVER SHEET \nJack Alan Goldberger \nDATE: \nJuly 9, 2008 \n3 \nFAX NO. \n561-835-8691 \n# OF PAGES: \nPHONE NO. \n561 659-8300 \nRE: \nJeffrey Epstein \nFROM: \nA. MARIE VILLAFARA, Assistant U.S. Attorney \nPHONE NO. \n561 209-1047 \nCOMMENTS: \nEFTA00225576\n", "char_count": 469}, {"efta_number": "EFTA00225378", "page_number": 199, "text_content": "JACK GOLDBERGER, ESQ. \nJULY 9, 2008 \nPAGE 2 \nwas prepared to include in an indictment. This means that, pursuant to Justice Department \npolicy, these are individuals for whom the United States believes it has proof beyond a \nreasonable doubt that each of them was a victim of an enumerated offense. There will be no \nstatement one way or the other regarding the validity of any claim. \nYou have asked for an explanation of why I believe the Acknowledgment portion is \nrequired by the terms of the Agreement. Under a strict reading of the Agreement, it is not \nrequired, other than to Acknowledge that the United States has performed its obligation of \nproviding Mr. Epstein with a list of identified victims following his guilty plea and \nsentencing. The purpose of the Acknowledgment was to create one single document \nincorporating the parties' agreement on'the single topic of the right to proceed under 18 \nU.S.C. § 2255. This would avoid litigation regarding the victims' rights to have access to \nthe original Non-Prosecution Agreement. Without such an express Acknowledgment by Mr. \nEpstein that the Notice contains the substance of that Agreement, I believe that the victims \nwill have a justification to petition for the entire agreement, which is contrary to the \nconfidentiality clause that the parties have signed. If you believe that particular words are \nobjectionable, I am happy to consider a modification. \nAs I mentioned to you last week, I will provide you with the names of the attorneys \ncurrently representing the victims when we have compiled all of that information. Some of \nthe victims are represented by attorneys from the South Carolina Victim Assistance Network \nand the Maryland Crime Victims Resource Center, both of which were recommended by a \nvictims' rights organization that receives grants from the Justice Department. \nIf you have any suggestions for a modification of the Acknowledgment, please let me \nknow. \nSincerely, \nR. Alexander Acosta \nUnited States Atto\n... [truncated, 2106 chars — for the full page use /api/corpus/document/EFTA00225378/199 or ?id=EFTA00225378&page=199]", "char_count": 2106}, {"efta_number": "EFTA00225378", "page_number": 200, "text_content": "O.S. Department of Justice \nUnited States Attorney \nSouthern District of Florida \n500 South Australian Ave, Suite 400 \nWest Palm Beach, FL 33401 \n(561)8204711 \nFacsimile: (561)8204777 \nJuly 9, 2008 \nVIA FACSIMILE \nJack A. Goldberger, Esq. \nAtterbury, Goldberger & Weiss, P.A. \nOne Clearlake Centre, Suite 1400 \n250 Australian Ave S. \nWest Palm Beach, FL 33401-5015 \nRe: \nJeffrey Epstein \nDear Mr. Goldberger: \nThank you for your letter of today's date regarding theproposed Victim Notification. \nLet me address some of the items in your letter. \nWe have no objection to doing individual mailings. The Notification was drafted in \nthat way in order to minimize the number of documents that Mr. Epstein would sign. Now \nthat you have raised an objection to signing the Acknowledgment, each notification will list • \nonly the victim who is being notified. \nIn light of Mr. Epstein's refusal to sign the Acknowledgment, the Acknowledgment \nportion has been deleted and the notification has been slightly modified in order to provide \nmore complete information and it has been formatted as a letter rather than a more formal \n\"Notification\" document. \nWe will not be including any statement that the U.S. Attorney's Office is not vouching \nfor the veracity of any claim. As you know, the U.S. Attorney's modification of the 2255 \nportion of the Agreement now limits our victim list to those persons whom the United States \nEXHIBIT B-60 \nEFTA00225578\n", "char_count": 1445}, {"efta_number": "EFTA00225378", "page_number": 201, "text_content": "Recipient \nRoad \nAcosta. Alex (USAFLS) \nRead: 7/9/2008 1:26 PM \nSloman, Jeff (USAFLS) \nRead: 7/9/20081:05 PM \nAtkinson, Karen (USAFLS) \nKuyrkendall, E N. (FBI) \nRichards, Jason R. (FBI) \n2 \nEFTA00225579\n", "char_count": 203}, {"efta_number": "EFTA00225378", "page_number": 202, "text_content": "Villafana, Ann Marie C. (USAFLS) \nFrom: \nVillafana, Ann Marie C. (USAFLS) \nSent: \nWednesday, July 09, 2008 1:04 PM \nTo: \nAcosta, Alex (USAFLS); Sloman, Jeff (USAFLS); Atkinson, Karen (USAFLS) \nCc: \nKuyrkendall, E N. (FBI); Richards, Jason R. (FBI) \nSubject: \nResponse to Goldberger Letter \nHere are my thoughts: \n1. \nNotification only by mail: For those girls who are currently not represented (or for whom we do not know of \nany representation), we intend to contact the victims by telephone to tell them of the resolution and to get mailing \naddresses to send the written notification or to determine if they have secured counsel to send it to them. For the \ngirls who are represented, contact will be made by telephone followed by the mailing of the notification. I think a \n\"live\" thank you is the least that is required at this point and a \"check in\" to make sure that girls who need \ncounseling are getting it. (FBI has already arranged counseling for several girls.) In any written response to Mr. \nGoldberger, I would simply ignore this request. \n2. Separate mailings: I have no objection to this change. The notice was drafted the way it was so that Epstein \nwould only have to sign one document rather than 33. Since he isn't going to sign any, that change is fine with \nme. \n3. Notification limited to the information on the first page of the draft notification: In light of Epstein's refusal \nto sign the acknowledgement, I think some additional explanation is required. I will prepare that revision and \nsend to you shortly. \n4. Eliminate the Acknowledgement portion: I have no objection to this. \n5. Supplement the notification with our previous statement that we are not vouching for the veracity of any \nclaim: I would reject this request and, in our response to Goldberger, state that we have limited our list to those \nwhom we were prepared to name in an indictment and, accordingly, we believe that there is proof beyond a \nreasonable doubt that each was a victim of Epstein's. \n6.\n... [truncated, 3407 chars — for the full page use /api/corpus/document/EFTA00225378/202 or ?id=EFTA00225378&page=202]", "char_count": 3407}, {"efta_number": "EFTA00225378", "page_number": 203, "text_content": "v v4. vv L.VV4.4 4 VI.4 vl • N., I II \nJuly 8, 2008 \nA. Marie Villafana, AUSA \nU.S. Department of Justice \nUnited States Attorney \nSouthern District of Florida \n500 South Australian Avenue, Suite 400 \nWest Palm Beach, Florida 33401 \nI slit \nIIV, \nN.4,44 1 U04-JULOU I \n' JOSEPH R.ATTERBURY \n• I JACK A. GOLDBERGER \nJASON S.WEISS \nI &NA Conified CrinainaI Trul Aourney \nMentes.' of New Nati & Florida Roe \nRe: \nJeffrey Epstein \nDear Marie, \nI am out of the office today. I will response to your fax of July 8, 2008 by return of fax tomorrow. \nVery truly yours, \n‘ 41\nJack A. Goldberger \nDictated hut not mid \nJAG/na \nOne Clearlake Centre, Suite 1400 \n250 Australian Avenue Solid) West Palm Beach, FL. 33401 \np 561,659.8300 f 561.835.8691 www.agwpa.com \nEFTA00225581\n", "char_count": 765}, {"efta_number": "EFTA00225378", "page_number": 204, "text_content": "„III ,IV, QV I I. \nI %).1I-I UO I \nr. ul \nATTERBURY, GOLDBERGER & WEISS, P.A. \n250 Australian Avenue South \nSuite 1400 \nWest Palm Beach, Florida 33401 \n(561) 659-8300 \nFax: (561) 835-8691 \nFAX TRANSMITTAL COVER SHEET \nDATE: \nJuly 8, 2008 \nTO: \nA. Marie Villafana, Assistant U.S. Attorney \nFAX NO.: \n561-820-8777 \nFROM: \nNayanira, Assistant to Jack A. Goldberger, Esquire \nREMARKS: \nJeffrey Epstein \nTOTAL PAGES: \n2 \n , Including cover sheet \n*** PLEASE NOTE - CONFIDENTIALITY WARNING *** \nTHIS MESSAGE IS INTENDED FOR THE USE OF THE INDiDUAL OR ENTITY TO WHICH IT IS \nADDRESSED AND MAY CONTAIN INFORMATION THAT IS PR \nEGED. CONFIDENTIAL AND EXEMPT \nFROM DISCLOSURE UNDER APPLICABLE LAW. If the reader of this message is not the Intended recipient or \nthe employee or agent responsible for delivering the message to the Intended recipient, you are hereby notified \nthat any dissemination, distribution or copying of this communication Is strictly prohibited. If you have received this \ncommunication in error, please notify us immediately by telephone, and return the original message to us at the \nabove address via the U.S. Postal Mail Service. Thank you for your cooperation. \nEXHIBIT B-58 \nEFTA00225582\n", "char_count": 1206}, {"efta_number": "EFTA00225378", "page_number": 205, "text_content": "U.S. Department of Justice \nUnited States Attorney \nSouthern District of Florida \nA Marie Villafalta \n500 S. Australian Ave, 4th Floor \nWest Palm Beach, Florida 33401 \n(561) 820-8711 \nFacsimile (561) 820-8777 \nFACSIMILE COVER SHEET \nTO: \nJack Alan Goldberger \nDATE: \nJuly 8. 2008 \nFAX NO. \n561-835-8691 \n \n# OF PAGES: \n3\nPHONE NO. 561 659-8300 \n \nRE: \nJeffrey Epstein \nFROM: \nA. MARIE VILLAFARA. Assistant U.S. Attorney \nPHONE NO. \n561 209-1047 \nCOMMENTS: \nEFTA00225583\n", "char_count": 472}, {"efta_number": "EFTA00225378", "page_number": 206, "text_content": "P. 1 \n* * * TRANSMISSION RESULT REPORT ( JUL. 8.2008 2:11PM ) * * * \nTTI USA() WPB FL \nDATE \nTIME \nADDRESS \nMODE \nTIME \nPAGE RESULT \nPERS. NAPE \nFILE \nJUL. 8. 2:10PM \n5618358691 TES \n0'34\" P. 3 \nOK \n398 \n* : BATCH \nC : CONFIDENTIAL \nP : POLLING \nM : MEMORY \nL : SEND LATER \ny01 : FORWARDING \nE : ECM \n> : REDUCTION \nR \nF : FINE \n\\DE \nG-: RICOH-MG3ICOMPATIBLE MODE \nEFTA00225584\n", "char_count": 378}, {"efta_number": "EFTA00225378", "page_number": 207, "text_content": "JACK 9OLDBERGER, ESQ. \nJULY 8, 2008 \nPAGE 2 \nto pursue damages. If the United States learns that a civil suit has been filed against Mr. \nEpstein and he has denied that one of these victims is entitled to proceed under 18 U.S.C. \n§ 2255, that will be considered a breach of the Non-Prosecution Agreement and the United \nStates will proceed accordingly. \nSincerely, \nIt. Alexander Acosta \nUnited States Attorney \nI ly : \nA. Marie Villafafia \nAssistant United States Attorney \ncc: \nKaren Atkinson, AUSA \nEFTA00225585\n", "char_count": 515}, {"efta_number": "EFTA00225378", "page_number": 208, "text_content": "U.S. Department of Justice \nUnited States Attorney \nSouthern District of Florida \n500 South Australian Ave., Suite 400 \nWest Palm Beach, FL 33401 \n(561) 820-8711 \nFacsimile: (561) 820-8777 \nJuly 8, 2008 \nVIA FACSIMILE AND ELECTRONIC MAIL \nJack A. Goldberger, Esq. \nAtterbury, Goldberger & Weiss, P.A. \nOne Clearlake Centre, Suite 1400 \n25i.) Australian Ave S. \nWest Palm Beach, FL 33401-5015 \nRe: \nJeffrey Epstein \nDear Mr. Goldberger: \nIn accordance with the terms of the Non-Prosecution Agreement, on June 30, 2008, \nthe United States Attorney's Office provided you with a list of thirty-one individuals \"whom \nit was prepared to name in an Indictment as victims of an enumerated offense by Mr. \nEpstein.\" Yesterday, I provided you with the identification of another victim whom I had \nerroneously left off of that list. At the time the list was provided, Special Agent Kuyrkendall \nand I impressed upon you the need to finalize this last piece of the agreement as quickly as \npossible so that we could fulfill our victim notification obligations. In deference to your \nvacation, we allowed you a week to provide us with any objections or requested \nmodifications to the list and/or the Notification language. Yesterday, I contacted you via \ntelephone and e-mail, but received no response. \nAccordingly, the United States hereby notifies you that it will distribute the victim \nnotifications tomorrow, July 9, 2008, to each of the thirty-two identified victims, either \ndirectly or via their counsel. A carbon copy of each notification will be provided to you, and \nthe notification will list you as the contact person for any civil litigation, if the victim decides \nEXHIBIT B-57 \nEFTA00225586\n", "char_count": 1697}, {"efta_number": "EFTA00225378", "page_number": 209, "text_content": "NOTIFICATION OF IDENTIFIED VICTIMS \nJUNE 30, 2008 \nPAGE 3 OF 3 \nthat an exact copy of this Notification will be provided to each identified individual, except \nthat the names of all other identified individuals will be redacted, and I hereby waive any \nevidentiary challenges to the introduction of a copy of this document—even in redacted \nform—in any judicial proceeding between any identified individual and myself. \nDated: \nJeffrey Epstein \nWitnessed by: \nRoy Black, Esquire \nEFTA00225587\n", "char_count": 493}, {"efta_number": "EFTA00225378", "page_number": 210, "text_content": "NOTIFICATION OF IDENTIFIED VICTIMS \nJUNE 30, 2008 \nPAGE 2 OF 3 \nThrough this letter, this Office hereby provides Notice that the individuals identified \nbelow are individuals whom the United States was prepared to name as a victim of an \nenumerated offense. \nIdentified Individuals \nDated: \nR. ALEXANDER ACOSTA \nUNITED STATES ATTORNEY \nBy: \nA. MARIE VILLAFARA \nASSISTANT U.S. ATTORNEY \nACKNOWLEDGMENT \nI have received this Notification from my attorney, Roy Black, Esquire, have read it \nand discussed it with my attorney, and I hereby acknowledge that it accurately sets forth my \nunderstanding and agreement with the Office of the United States Attorney for the Southern \nDistrict of Florida regarding the notification and rights of identified victims. I understand \nInitials of Jeffrey Epstein \n Initials of Roy Black \nEFTA00225588\n", "char_count": 835}, {"efta_number": "EFTA00225378", "page_number": 211, "text_content": "U.S. Department of Justice \nUnited States Attorney \nSouthern District of Florida \n500 South Australian Ave.. Suite 400 \nWest Palm Beach, FL 3340! \n(561) 820-8711 \nFacsimile: (561) 820-8777 \nJune 30, 2008 \nNOTIFICATION OF IDENTIFIED VICTIMS \nOn June 30, 2008, Jeffrey Epstein (hereinafter referred to as \"Epstein) entered a plea \nof guilty to violations of Florida Statutes Sections 796.07 (felony solicitation of prostitution) \nand 796.03 (procurement of minors to engage in prostitution), in the 15th Judicial Circuit in \nand for Palm Beach County (Case Nos. 2006-cf-009454AXXXMB and 2008-cf-\n009381A,DOUvD3) and was sentenced to a term of twelve months' imprisonment to be \nfollowed by eighteen months' of Community Control 1, the first six months of which must \nbe served iniprisoned at the Palm Beach County Detention Facility. \nIn light of the entry of the guilty plea and sentence, the United States has agreed to \ndefer federal prosecution in favor of this state plea and sentence, subject to certain \nconditions. \nOne such condition to which Epstein has agreed is the following: \n\"Any person, who while a minor, was a victim of a violation of an offense \nenumerated in Title 18, United States Code, Section 2255, will have the same \nrights to proceed under Section 2255 as she would have had, if Mr. Epstein \nhad been tried federally and convicted of an enumerated offense. For purposes \nof implementing this paragraph, the United States shall provide Mr. Epstein's \nattorneys with a list of individuals whom it was prepared to name in an \nIndictment as victims of an enumerated offense by Mr. Epstein. Any judicial \nauthority interpreting this provision, including any authority determining \nwhich evidentiary burdens if any a plaintiff must meet, shall consider that it is \nthe intent of the parties to place these identified victims in the same position \nas they would have been had Mr. Epstein been convicted at trial. No more; no \nless.\" \n• \nInitials of Jeffrey Epstein \n Initials of Roy\n... [truncated, 2021 chars — for the full page use /api/corpus/document/EFTA00225378/211 or ?id=EFTA00225378&page=211]", "char_count": 2021}, {"efta_number": "EFTA00225378", "page_number": 212, "text_content": "U.S. Department of Justice \nUnited States Attorney \nSouthern District of Florida \n500 South Australian Ave., Suite 400 \nWest Palm Beach, FL 33401 \n(561) 820-8711 \nFacsimile: (561) 820-8777 \nJune 30, 2008 \nNOTIFICATION OF IDENTIFIED VICTIMS \nNOTICE: IN ACCORDANCE WITH TITLE 18, UNITED \nSTATES CODE, SECTION 3509(d) AND FLORIDA LAW, \nTHE ATTACHED DOCUMENT IS TO BE TREATED AS \nCONFIDENTIAL AND SHALL NOT BE DISCLOSED \nEXCEPT IN CONNECTION \nWITH A LEGAL \nPROCEEDING. \nEFTA00225590\n", "char_count": 479}, {"efta_number": "EFTA00225378", "page_number": 213, "text_content": "NOTIFICATION OF IDENTIFIED VICTIMS \nJUNE 30, 2008 \nPAGE 3 OF 3 \nthat an exact copy of this Notification will be provided to each identified individual, except \nthat the names of all other identified individuals will be redacted, and I hereby waive any \nevidentiary challenges to the introduction of a copy of this document—even in redacted \nform—in any judicial proceeding between any identified individual and myself. \nDated: \nJeffrey Epstein \nWitnessed by: \nRoy Black, Esquire \nEFTA00225591\n", "char_count": 493}, {"efta_number": "EFTA00225378", "page_number": 214, "text_content": "NOTIFICATION OF IDENTIFIED VICTIMS \nJUNE 30, 2008 \nPAGE 2 GP 3 \nThrough this letter, this Office hereby provides Notice that the individuals identified \nbelow are individuals whom the United States was prepared to name as a victim of an \nenumerated offense. \nIdentified Individuals \nDated: \nR. ALEXANDER ACOSTA \nUNITED STATES ATTORNEY \nBy: \nA. MARIE VILLAFARA \nASSISTANT U.S. ATTORNEY \nACKNOWLEDGMENT\nI have received this Notification from my attorney, Roy Black, Esquire, have read it \nand discussed it with my attorney, and I hereby acknowledge that it accurately sets forth my \nunderstanding and agreement with the Office of the United States Attorney for the Southern \nDistrict of Florida regarding the notification and rights of identified victims. I understand \nInitials of Jeffrey Epstein \nInitials of Roy Black \nEFTA00225592\n", "char_count": 833}, {"efta_number": "EFTA00225378", "page_number": 215, "text_content": "U.S. Department of Justice \nUnited States Attorney \nSouthern District of Florida \n500 South Australian Ave, Suite 400 \nWest Palm Beach, FL 33401 \n(561) 820-8711 \nFacsimile: (561) 8204777 \nJune 30, 2008 \nNOTIFICATION OF IDENTIFIED VICTIMS \nOn June 30, 2008, Jeffrey Epstein (hereinafter referred to as \"Epstein) entered a plea \nof guilty to violations of Florida Statutes Sections 796.07 (felony solicitation of prostitution) \nand 796.03 (procurement of minors to engage in prostitution), in the 15th Judicial Circuit in \nand for Palm Beach County (Case Nos. 2006-cf-009454MOOUVIB and 2008-cf-\n00938 1 AXXKM:B) and was sentenced to a term of twelve months' imprisonment to be \nfollowed by eighteen months' of Community Control 1, the first six months of which must \nbe served imprisoned at the Palm Beach County Detention Facility. \nIn light of the entry of the guilty plea and sentence, the United States has agreed to \ndefer federal prosecution in favor of this state plea and sentence, subject to certain \nconditions. \nOne such condition to which Epstein has agreed is the following: \n\"Any person, who while a minor, was a victim of a violation of an offense \nenumerated in Title 18, United States Code, Section 2255, will have the same \nrights to proceed under Section 2255 as she would have had, if Mr. Epstein \nhad been tried federally and convicted of an enumerated offense. For purposes \nof implementing this paragraph, the United States shall provide Mr. Epstein's \nattorneys with a list of individuals whom it was prepared to name in an \nIndictment as victims of an enumerated offense by Mr. Epstein. Any judicial \nauthority interpreting this provision, including any authority determining \nwhich evidentiary burdens if any a plaintiff must meet, shall consider that it is \nthe intent of the parties to place these identified victims in the same position \nas they would have been had Mr. Epstein been convicted at trial. No more; no \nless.\" \nInitials of Jeffrey Epstein \n Initials of Roy Bla\n... [truncated, 2017 chars — for the full page use /api/corpus/document/EFTA00225378/215 or ?id=EFTA00225378&page=215]", "char_count": 2017}, {"efta_number": "EFTA00225378", "page_number": 216, "text_content": "U.S. Department of Justice \nUnited States Attorney \nSouthern District of Florida \n500 South Australian Ave., Suite 400 \nWest Palm Beach, FL 33401 \n(561) 820-8711 \nFacsimile: (561) 820-8777 \nJune 30, 2008 \nNOTIFICATION OF IDENTIFIED VICTIMS \nNOTICE: IN ACCORDANCE WITH TITLE 18, UNITED \nSTATES CODE, SECTION 3509(d) AND FLORIDA LAW, \nTHE ATTACHED DOCUMENT IS TO BE TREATED AS \nCONFIDENTIAL AND SHALL NOT BE DISCLOSED \nEXCEPT IN CONNECTION WITH A LEGAL \nPROCEEDING. \nEFTA00225594\n", "char_count": 478}, {"efta_number": "EFTA00225378", "page_number": 217, "text_content": "NOTIFICATION OF IDENTIFIED VICTIMS \nJuNE 30, 2008 \nPAGE 3 OF 3 \nthat an exact copy of this Notification will be provided to each identified individual, except \nthat the names of all other identified individuals will be redacted, and I hereby waive any \nevidentiary challenges to the introduction of a copy of this document—even in redacted \nform—in any judicial proceeding between any identified individual and myself. \nDated: \nJeffrey Epstein \nWitnessed by: \nRoy Black, Esquire \nEFTA00225595\n", "char_count": 493}, {"efta_number": "EFTA00225378", "page_number": 218, "text_content": "NOTIFICATION OF IDENTIFIED VICTIMS \nJuNE 30, 2008 \nPAGE 2 OF 3 \nThrough this letter, this Office hereby provides Notice that the individuals identified \nbelow are individuals whom the United States was prepared to name as a victim of an \nenumerated offense. \nIdentified Individuals \nDated: \nR. ALEXANDER ACOSTA \nUNITED STATES ATTORNEY \nBy: \nA. MARIE VILLAFARA \nASSISTANT U.S. ATTORNEY \nACKNOWLEDGMENT \nI have received this Notification from my attorney, Roy Black, Esquire, have read it \nand discussed it with my attorney, and I hereby acknowledge that it accurately sets forth my \nunderstanding and agreement with the Office of the United States Attorney for the Southern \nDistrict of Florida regarding the notification and rights of identified victims. I understand \nInitials of Jeffrey Epstein \nInitials of Roy Black \nEFTA00225596\n", "char_count": 834}, {"efta_number": "EFTA00225378", "page_number": 219, "text_content": "U.S. Department of Justice \nUnited States Attorney \nSouthern District of Florida \n500 South Australian Ave., Suite 400 \nWest Palm Beach, FL 33401 \n(561) 820-8711 \nFacsimile: (561) 8204777 \nJune 30, 2008 \nNOTIFICATION OF IDENTIFIED VICTIMS \nOn June 30, 2008, Jeffrey Epstein (hereinafter referred to as \"Epstein) entered a plea \nof guilty to violations of Florida Statutes Sections 796.07 (felony solicitation of prostitution) \nand 796.03 (procurement of minors to engage in prostitution), in the 15th Judicial Circuit in \nand for Palm Beach County (Case Nos. 2006-cf-009454AXXXMB and 2008-cf-\n00938 lAXXYMB) and was sentenced to a term of twelve months' imprisonment to be \nfollowed by eighteen months' of Community Control 1, the first six months of which must \nbe served imprisoned at the Palm Beach County Detention Facility. \nIn light of the entry of the guilty plea and sentence, the United States has agreed to \ndefer federal prosecution in favor of this state plea and sentence, subject to certain \nconditions. \nOne such condition to which Epstein has agreed is the following: \n\"Any person, who while a minor, was a victim of a violation of an offense \nenumerated in Title 18, United States Code, Section 2255, will have the same \nrights to proceed under Section 2255 as she would have had, if Mr. Epstein \nhad been tried federally and convicted of an enumerated offense. For purposes \nof implementing this paragraph, the United States shall provide Mr. Epstein's \nattorneys with a list of individuals whom it was prepared to name in an \nIndictment as victims of an enumerated offense by Mr. Epstein. Any judicial \nauthority interpreting this provision, including any authority determining \nwhich evidentiary burdens if any a plaintiff must meet, shall consider that it is \nthe intent of the parties to place these identified victims in the same position \nas they would have been had Mr. Epstein been convicted at trial. No more; no \nless.\" \nInitials of Jeffrey Epstein \n Initials of Roy Black\n... [truncated, 2015 chars — for the full page use /api/corpus/document/EFTA00225378/219 or ?id=EFTA00225378&page=219]", "char_count": 2015}, {"efta_number": "EFTA00225378", "page_number": 220, "text_content": "U.S. Department of Justice \nUnited States Attorney \nSouthern District of Florida \n500 South Australian Ave., Suite 400 \nWest Pahn Beach. FL 33401 \n(561) 820-8711 \nFacsimile: (561) 820-8777 \nJune 30, 2008 \nNOTIFICATION OF IDENTIFIED VICTIMS \nNOTICE: IN ACCORDANCE WITH TITLE 18, UNITED \nSTATES CODE, SECTION 3509(d) AND FLORIDA LAW, \nTHE ATTACHED DOCUMENT IS TO BE TREATED AS \nCONFIDENTIAL AND SHALL NOT BE DISCLOSED \nEXCEPT IN CONNECTION WITH A LEGAL \nPROCEEDING. \nEFTA00225598\n", "char_count": 478}, {"efta_number": "EFTA00225378", "page_number": 221, "text_content": "NOTIFICATION OF IDENTIFIED VICTIMS \nJUNE 30, 2008 \nPAGE 3 OF 3 \nunderstand that an exact copy of this Notification will be provided to each identified \nindividual, except that the names of all other identified individuals will be redacted, and I \nhereby waive any evidentiary challenges to the introduction of a copy of this document—even \nin redacted form—in any judicial proceeding between any identified individual and myself. \nDated: \nJeffrey Epstein \nWitnessed by: \nJack Goldberger, Esquire \nEFTA00225599\n", "char_count": 510}, {"efta_number": "EFTA00225378", "page_number": 222, "text_content": "NOTIFICATION OF IDENTIFIED VICTIMS \nJUNE 30, 2008 \nPAGE 2 OF 3 \nThrough this letter, this Office hereby provides Notice that the individuals identified \nbelow are individuals whom the United States was prepared to name as a victim of an \nenumerated offense. \nIdentified Individuals \nDated: \nR. ALEXANDER ACOSTA \nUNITED STATES ATTORNEY \nBy: \nA. MARIE VILLAFARA \nASSISTANT U.S. ATTORNEY \nel \nACKNOWLEDGMENT \nI have received this Notification from my attorney, Jack Goldberger, Esquire, have \nread it and discussed it with my attorney, and I hereby acknowledge that it accurately sets \nforth my understanding and agreement with the Office of the United States Attorney for the \nSouthern District of Florida regarding the notification and rights of identified victims. I \nInitials of Jeffrey Epstein \n Initials of Jack Goldberger \nEFTA00225600\n", "char_count": 840}, {"efta_number": "EFTA00225378", "page_number": 223, "text_content": "U.S. Department of Justice \nUnited States Attorney \nSouthern District of Florida \nS00 South Australian Ave., Suite 400 \nWest Palm Beach, FL 33401 \n(561) 820-8711 \nFacsimile: (561)820-8777 \nJune 30, 2008 \nNOTIFICATION OF IDENTIFIED VICTIMS \nOn June 30, 2008, Jeffrey Epstein (hereinafter referred to as \"Epstein) entered a plea \nof guilty to violations of Florida Statutes Sections 796.07 (felony solicitation of prostitution) \nand 796.03 (procurement of minors to engage in prostitution), in the 15th Judicial Circuit in \nand for Palm Beach County (Case Nos. 2006-cf-009454AXXX1v1B and 2008-cf-\n00938 lAXIOCKB) and was sentenced to a term of twelve months' imprisonment to be \nfollowed by eighteen months' of Community Control 1, the first six months of which must \nbe served imprisoned at the Palm Beach County Detention Facility. \nIn light of the entry of the guilty plea and sentence, the United States has agreed to \ndefer federal prosecution in favor of this state plea and sentence, subject to certain \nconditions. \nOne such condition to which Epstein has agreed is the following: \n\"My person, who while a minor, was a victim of a violation of an offense \nenumerated in Title 18, United States Code, Section 2255, will have the same \nrights to proceed under Section 2255 as she would have had, if Mr. Epstein \nhad been tried federally and convicted of an enumerated offense. For purposes \nof implementing this paragraph, the United States shall provide Mr. Epstein's \nattorneys with a list, of individuals whom it was prepared to name in an \nIndictment as victims of an enumerated offense by Mr. Epstein. Any judicial \nauthority interpreting this provision, including any authority determining \nwhich evidentiary burdens if any a plaintiff must meet, shall consider that it is \nthe intent of the parties to place these identified victims in the same position \nas they would have been had Mr. Epstein been convicted at trial. No more; no \nless.\" \nInitials of Jeffrey Epstein \n Initials of Jack G\n... [truncated, 2024 chars — for the full page use /api/corpus/document/EFTA00225378/223 or ?id=EFTA00225378&page=223]", "char_count": 2024}, {"efta_number": "EFTA00225378", "page_number": 224, "text_content": "U.S. Department of Justice \nUnited Stales Attorney \nSouthern District of Florida \n500 South Australian Ave., Suite 400 \nWest Palm Beach, FL 33401 \n(561) 820-8711 \nFacsimile: (561) 820-8777 \nJune 30, 2008 \nNOTIFICATION OF IDENTIFIED VICTIMS \nNOTICE: IN ACCORDANCE WITH TITLE 18, UNITED \nSTATES CODE, SECTION 3509(d) AND FLORIDA LAW, \nTHE ATTACHED DOCUMENT IS TO BE TREATED AS \nCONFIDENTIAL AND SHALL NOT BE DISCLOSED \nEXCEPT IN CONNECTION WITH A LEGAL \nPROCEEDING. \nEFTA00225602\n", "char_count": 478}, {"efta_number": "EFTA00225378", "page_number": 225, "text_content": "NOTIFICATION OF IDENTIFIED VICTIMS \nJUNE 30, 2008 \nPAGE 3 oF• 3 \nthat an exact copy of this Notification will be provided to each identified individual, except \nthat the names of all other identified individuals will be redacted, and I hereby waive any \nevidentiary challenges to the introduction of a copy of this document—even in redacted \nform—in any judicial proceeding between any identified individual and myself. \nDated: \nJeffrey Epstein \nWitnessed by: \nGuy Lewis, Esquire \nEFTA00225603\n", "char_count": 494}, {"efta_number": "EFTA00225378", "page_number": 226, "text_content": "NOTIFICATION OF IDENTIFIED VICTIMS \nJUNE 30, 2008 \nPAGE 2 OF 3 \nThrough this letter, this Office hereby provides Notice that the individuals identified \nbelow are individuals whom the United States was prepared to name as a victim of an \nenumerated offense. \nIdentified Individuals \nR. ALEXANDER ACOSTA \nUNITED STATES ATTORNEY \nDated: \nBy: \nA. MARIE VILLAFARA \nASSISTANT U.S. ATTORNEY \nACKNOWLEDGMENT \nI have received this Notification from my attorney, Guy Lewis, Esquire, have read it \nand discussed it with my attorney, and I hereby acknowledge that it accurately sets forth my \nunderstanding and agreement with the Office of the United States Attorney for the Southern \nDistrict of Florida regarding the notification and rights of identified victims. I understand \nInitials of Jeffrey Epstein \n Initials of Guy Lewis \nEFTA00225604\n", "char_count": 835}, {"efta_number": "EFTA00225378", "page_number": 227, "text_content": "U.S. Department of Justice \nUnited States Attorney \nSouthern District of Florida \n500 South Australian Ave, Suite 400 \nWest Palm Beach, FL 33401 \n(561) 820-8711 \nFacsimile: (561) 820-8777 \nJune 30, 2008 \nNOTIFICATION OF IDENTIFIED VICTIMS \nOn June 30, 2008, Jeffrey Epstein (hereinafter referred to as \"Epstein) entered a plea \nof guilty to violations of Florida Statutes Sections 796.07 (felony solicitation of prostitution) \nand 796.03 (procurement of minors to engage in prostitution), in the 15th Judicial Circuit in \nand for Palm Beach County (Case Nos.. 2006-cf-009454/OO(Xle and 2008-cf-\n009381AXXXMB) and was sentenced to a term of twelve months' imprisonment to be \nfollowed by eighteen months' of Community Control I, the first six months of which must \nbe served imprisoned at the Palm Beach County Detention Facility. \nIn light of the entry of the guilty plea and sentence, the United States has agreed to \ndefer federal prosecution in favor of this state plea and sentence, subject to certain \nconditions. \nOne such condition to which Epstein has agreed is the following: \n\"Any person, who while a minor, was a victim of a violation of an offense \nenumerated in Title 18, United States Code, Section 2255, will have the same \nrights to proceed under Section 2255 as she would have had, if Mr. Epstein \nhad been tried federally and convicted of an enumerated offense. For purposes \nof implementing this paragraph, the United States shall provide Mr. Epstein's \nattorneys with a list of individuals whom it was prepared to name in an \nIndictment as victims of an enumerated offense by Mr. Epstein. My judicial \nauthority interpreting this provision, including any authority determining \nwhich evidentiary burdens if any a plaintiff must meet, shall consider that it is \nthe intent of the parties to place these identified victims in the same position \nas they would have been had Mr. Epstein been convicted at trial. No more; no \nless.\" \nInitials of Jeffrey Epstein \n Initials of Guy Lewis\n... [truncated, 2015 chars — for the full page use /api/corpus/document/EFTA00225378/227 or ?id=EFTA00225378&page=227]", "char_count": 2015}, {"efta_number": "EFTA00225378", "page_number": 228, "text_content": "U.S. Department of Justice \nUnited States Attorney \nSouthern District of Florida \n500 South Australian Ave., Suite 400 \nWest Palm Beach, FL 3340/ \n(561) 820-8711 \nFacsimile: (561)820-8777 \nJune 30, 2008 \nNOTIFICATION OF IDENTIFIED VICTIMS \nNOTICE: IN ACCORDANCE WITH TITLE 18, UNITED \nSTATES CODE, SECTION 3509(d) AND FLORIDA LAW, \nTHE ATTACHED DOCUMENT IS TO BE TREATED AS \nCONFIDENTIAL AND SHALL NOT BE DISCLOSED \nEXCEPT IN CONNECTION WITH A LEGAL \nPROCEEDING. \nEFTA00225606\n", "char_count": 477}, {"efta_number": "EFTA00225378", "page_number": 229, "text_content": "N0TIFICATI0N OF IDENTIFIED VICTIMS \nJUNE. 30, 2008 \nI'AGE 3 OF 3 \nthat an exact copy of this Notification will be provided to each identified individual, except \nthat the names of all other identified individuals will be redacted, and I hereby waive any \nevidentiary challenges to the introduction of a copy of this document—even in redacted \nform—in any judicial proceeding between any identified individual and myself. \nDated: \nJeffrey Epstein \nWitnessed by: \nGuy Lewis, Esquire \nEFTA00225607\n", "char_count": 495}, {"efta_number": "EFTA00225378", "page_number": 230, "text_content": "NOTIFICATION OF IDENTIFIED VICTIMS \nJun 30, 2008 \nPAGE 2 OF 3 \nThrough this letter, this Office hereby provides Notice that the individuals identified \nbelow are individuals whom the United States was prepared to name as a victim of an \nenumerated offense. \nIdentified Individuals \nDated: \nIt. ALEXANDER ACOSTA \nUNITED STATES ATTORNEY \nBy: \nA. MARIE VILLAFARA \nASSISTANT U.S. ATTORNEY \nACKNOWLEDGMENT \n• \nI have received this Notification from my attorney, Guy Lewis, Esquire, have read it \nand discussed it with my attorney, and I hereby acknowledge that it accurately sets forth my \nunderstanding and agreement with the Office of the United States Attorney for the Southern \nDistrict of Florida regarding the notification and rights of identified victims. I understand \nInitials of Jeffrey Epstein \n Initials of Guy Lewis \nEFTA00225608\n", "char_count": 838}, {"efta_number": "EFTA00225378", "page_number": 231, "text_content": "U.S. Department of Justice \nUnited States Attorney \nSouthern District of Florida \n500 South Australian Ave., Suite 400 \nWest Palm Beach, FL 33401 \n(561) 820-8711 \nFacsimile: (561) 820-8777 \nJune 30, 2008 \nNOTIFICATION OF IDENTIFIED VICTIMS \nOn June 30, 2008, Jeffrey Epstein (hereinafter referred to as \"Epstein) entered a plea \nof guilty to violations of Florida Statutes Sections 796.07 (felony solicitation of prostitution) \nand 796.03 (procurement of minors to engage in prostitution), in the 15th Judicial Circuit in \nand for Palm Beach County (Case Nos. 2006-cf-009454MOCKMB and 2008-cf-\n00938 1 AXXXMB) and was sentenced to a term of twelve months' imprisonment to be \nfollowed by eighteen months' of Community Control I, the first six months of which must \nbe served imprisoned at the Palm Beach County Detention Facility. \nIn light of the entry of the guilty plea and sentence, the United States has agreed to \ndefer federal prosecution in favor of this state plea and sentence, subject to certain \nconditions. \nOne such condition to which Epstein has agreed is the following: \n\"Any person, who while a minor, was a victim of a violation of an offense \nenumerated in Title 18, United States Code, Section 2255, will have the same \nrights to proceed under Section 2255 as she would have had, if Mr. Epstein \nhad been tried federally and convicted of an enumerated offense. For purposes \nof implementing this paragraph, the United States shall provide Mr. Epstein's \nattorneys with a list of individuals whom it was prepared to name in an \nIndictment as victims of an enumerated offense by Mr. Epstein. Any judicial \nauthority interpreting this provision, including any authority determining \nwhich evidentiary burdens if any a plaintiff must meet, shall consider that it is \nthe intent of the parties to place these identified victims in the same position \nas they would have been had Mr. Epstein been convicted at trial. No more; no \nless.\" \nInitials of Jeffrey Epstein \n Initials of Guy Lew\n... [truncated, 2017 chars — for the full page use /api/corpus/document/EFTA00225378/231 or ?id=EFTA00225378&page=231]", "char_count": 2017}, {"efta_number": "EFTA00225378", "page_number": 232, "text_content": "U.S. Department of Justice \nUnited States Attorney \nSouthern District of Florida \n500 South Australian Ave., Suite 400 \nWest Palm Beach, FL 33401 \n(561) 820-8711 \nFacsimile: (561)820-8777 \nJune 30, 2008 \nNOTIFICATION OF IDENTIFIED VICTIMS \nNOTICE: IN ACCORDANCE WITH TITLE 18, UNITED \nSTATES CODE, SECTION 3509(d) AND FLORIDA LAW, \nTHE ATTACHED DOCUMENT IS TO BE TREATED AS \nCONFIDENTIAL AND SHALL NOT BE DISCLOSED \nEXCEPT IN CONNECTION WITH A LEGAL \nPROCEEDING. \nEXHIBIT B-56 \nEFTA00225610\n", "char_count": 491}, {"efta_number": "EFTA00225378", "page_number": 233, "text_content": "r \n30 — \nmice-aer \n(Auk- r- RVicuvt. GaRel-S \n5„ i \n5Fz. - 24.00 \nCC\nU t A \na \n3)5 13/ - 2-2-0() \nr\n4n, fk \n_idtricazit \n7/ — \ni ---I.,17-\n--q‘22- 773 \nfa---1:54grcarc-UpfctL—\nSiztol CAthgt4dA \nqc V 2 944 - 754' 4/ \nTM -\"S- \nNNITeak Lg./420a \n---(5:55MPO* C.,,gt-i- C:51515-\ngot 31 ( - Bvt-tkcolloblilrick-flow—C44e) \nge 4,71: 2-3V3 \n—\n1'1 \nrrl \n1 \n. \ngt-2-- \n• \nSil l \nEXHIBIT B-55 \nEFTA00225611\n", "char_count": 397}, {"efta_number": "EFTA00225378", "page_number": 234, "text_content": "U.S. Department of Justice \nWashington, D.C. 20530 \nJune 23, 2008 \nJay Lefkowitz, Esq. \nKenneth Starr, Esq. \nKirkland and Ellis LLP \n777 South Figueroa Street \nLos Angeles, CA 90017 \nGentlemen: \nThis Office has completed a thorough review of the U.S. Attorney's handling of the matter \ninvolving your client, Jeffrey Epstein. We have received and reviewed your letters of May 19, \nJune 3 and June 19, 2008, the attachments to the June 19 letter, as well as your submissions to \nthe Criminal Division and the U.S. Attorney's Office. Additionally, we have reviewed an \nextensive set of materials provided by the U.S. Attorney's Office and conferred with a number of \nhighly experienced Department attorneys about this matter. The Deputy Attorney General has \nalso been briefed. \nAs you know, the Department of Justice vests considerable discretion in its U.S. Attorneys, and \nthe Deputy Attorney General will intervene in only the most unusual of circumstances. We do \nnot believe such intervention is warranted here. Even if we were to substitute our judgment for \nthat of the U.S. Attorney, we believe that federal prosecution of this case is appropriate. \nMoreover, having reviewed your allegations of prosecutorial misconduct, and the facts \nunderlying them, we see nothing in the conduct of the U.S. Attorney's Office that gives us any \nreason to alter our opinion. \ncc: \nAlex Acosta \nSincerely, \nJohn Roth \nSenior Associate Deputy Attorney General \nEXHIBIT B-44 \nEFTA00225612\n", "char_count": 1480}, {"efta_number": "EFTA00225378", "page_number": 235, "text_content": "EXHIBIT B-45 \nEFTA00225613\n", "char_count": 27}, {"efta_number": "EFTA00225378", "page_number": 236, "text_content": "Villafana, Ann Marie C. (USAFLS) \nFrom: \nVillafana, Ann Marie C. (USAFLS) \nSent: \nTuesday, June 24, 2008 3:08 PM \nTo: \nRoy BLACK \nSubject: \nRE: FW: Jeffrey Epstein \nHi Roy -- Is this the best number to call? (305) 371-6421 \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: Roy BLACK [mailto:RBLACK@royblack.com] \nSent: Tuesday, June 24, 2008 3:02 PM \nTo: Villafana, Ann Marie C. (USAFLS) \nCc: jack goldberger \nSubject: Re: FW: Jeffrey Epstein \nMarie that is a good time. I also want to conference Jack Goldberger into the \ncall. This will be a wrap up call. Roy \n>>> \"Villafana, Ann Marie C. (USAFLS)\" \n 6/24/2008 12:23 PM >> > Dear Roy: \nJeff Sloman contacted me and asked me to return your call regarding the Epstein \nmatter. I am forwarding to you an e-mail that I sent to Jay Lefkowitz last \nnight. \nKaren and I can call you at 3:30 to speak about your list of issues. \nIf that time does not work, please let me know what times you are available. \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 \nFrom: Villafana, Ann Marie C. (USAFLS) \nSent: Monday, June 23, 2008 5:55 PM \nTo: lefkowitz@kirkland.com; Jay Lefkowitz \nA \nEFTA00225614\n", "char_count": 1399}, {"efta_number": "EFTA00225378", "page_number": 237, "text_content": "Cc: Atkinson, Karen (USAFLS) \nSubject: Jeffrey Epstein \nDear Mr. Lefk6witz: \nI understand that the Deputy Attorney General has completed his review \nof the Epstein matter and has determined that federal prosecution of \nMr. Epstein's case is appropriate. \nAccordingly, Mr. Epstein has until the close of business on Monday, \nJune 30, 2008, to comply with the terms and conditions of the agreement \nbetween the United States and Mr. Epstein (as modified by the U.S. \nAttorney's December 19th letter to Ms. Sanchez), including entry of a \nguilty plea, sentencing, and surrendering to begin his sentence of \nimprisonment. \nIf you have any questions, please feel free to contact me at the number \nshown below. \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 \nEFTA00225615\n", "char_count": 863}, {"efta_number": "EFTA00225378", "page_number": 238, "text_content": "Villafana, Ann Marie C. (USAFLS) \nFrom: \nVillafana, Ann Marie C. (USAFLS) \nSent: \nTuesday, June 24, 2008 4:05 PM \nTo: \nRoy BLACK; Jack Goldberger \nCc: \nAtkinson, Karen (USAFLS) \nSubject: \nJeffrey Epstein Agreement \nDear Roy and Jack: \nI am just writing to re-state that it is the Government's position that we have a signed, binding agreement and \nthat there is no need for further modification. \nPlease keep us informed of the date and time of the change of plea and sentencing. \n\"Thank 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: \nEFTA00225616\n", "char_count": 662}, {"efta_number": "EFTA00225378", "page_number": 239, "text_content": "Villafana, Ann Marie C. (USAFLS) \nFrom: \nRoy BLACK \nSent: \nTuesday, June 24, 2008 3:13 PM \nTo: \nVillafana, Ann Marie C. (USAFLS) \nSubject: \nRE: FW: Jeffrey Epstein \nyes. \n>>> \"Villafana, Ann Marie C. (USAFLS)\" \n 6/24/2008 3:08 PM >» \nIii Roy -- Is this the best number to call? (305) 371-6421 \nA. Marie Villafafla \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: Roy BLACK [mailto:RBLACK®rovblack.coml\nSent: Tuesday, June 24, 2008 3:02 PM \nTo: Villafana, Ann Marie C. (USAFLS) \nCc: jack goldberger \nSubject: Re: FW: Jeffrey Epstein \nMarie that is a good time. I also want to conference Jack Goldberger \ninto the call. This will be a wrap up call. Roy \n>>> \"Villafana, Ann Marie C. (USAFLS)\" \n 6/24/2008 12:23 PM >>> \nDear Roy: \nJeff Sloman contacted me and asked me to return your call regarding \nthe \nEpstein matter. 1 am forwarding to you an e-mail that I sent to Jay \n1.efkowitz last night. \nKaren and I can call you at 3:30 to speak about your list of issues. \nIf that time does not work, please let me know what times you are \navailable. \nThank you. \nA. Marie Villafafla \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: Monday, June 23, 2008 5:55 PM \nTo: lefkowitz@kirkland.com; Jay Lefkowitz \nCc: Atkinson, Karen (USAFLS) \n3 \nEFTA00225617\n", "char_count": 1557}, {"efta_number": "EFTA00225378", "page_number": 240, "text_content": "Subject: Jeffrey Epstein \nDear Mr. Lefkowitz: \nI understand that the Deputy Attorney General has completed his review \nof the Epstein matter and has determined that federal prosecution of \nMr. Epstein's case is appropriate. \nAccordingly, Mr. Epstein has until the close of business on Monday, \nJune 30, 2008, to comply with the terms and conditions of the \nagreement \nbetween the United States and Mr. Epstein (as modified by the U.S. \nAttorney's December 19th letter to Ms. Sanchez), including entry of a \nguilty plea, sentencing, and surrendering to begin his sentence of \nimprisonment. \nIf you have any questions, please feel free to contact me at the \nnumber \nshown below. \nA. Marie Villafafta \nAssistant U.S. Attorney \n500 S. Australian Ave, Suite 400 \nWest Palm Beach, FL 33401 \nPhone 561 209-1047 \nFax 561 820-8777 \n4 \nEFTA00225618\n", "char_count": 839}, {"efta_number": "EFTA00225378", "page_number": 241, "text_content": "Villafana, Ann Marie C. (USAFLS) \nFrom: \nRoy BLACK \nSent: \nTuesday, June 24, 2008 3:02 PM \nTo: \nVillafana, Ann Marie C. (USAFLS) \nCc: \njack goldberger \nSubject: \nRe: FW: Jeffrey Epstein \nMarie that is a good time. I also want to conference Jack Goldberger \ninto the call. This will be a wrap up call. Roy \n>>> \"Villafana, Ann Marie C. (USAFLS)\" \n 6/24/2008 12:23 PM >>> \nDear Roy: \nJeff Sloman contacted me and asked me to return your call regarding the \nEpstein matter. I am forwarding to you an e-mail that I sent to Jay \nLefkowitz last night. \nKaren and I can call you at 3:30 to speak about your list of issues. \nIf that time does not work, please let me know what times you are \navailable. \nThank you. \nA. Marie Villafalla \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: Monday, June 23, 2008 5:55 PM \nTo: lefkowitz@kirkland.com; Jay Lefkowitz \nCc: Atkinson, Karen (USAF S) \nSubject: Jeffrey Epstein \nDear Mr. Lefkowitz: \nI understand that the Deputy Attorney General has completed his review \nof the Epstein matter and has determined that federal prosecution of \nMr. Epstein's case is appropriate. \nAccordingly, Mr. Epstein has until the close of business on Monday, \nJune 30, 2008, to comply with the terms and conditions of the agreement \nbetween the United States and Mr. Epstein (as modified by the U.S. \nAttorney's December 19th letter to Ms. Sanchez), including entry of a \nguilty pica, sentencing, and surrendering to begin his sentence of \nimprisonment. \nIf you have any questions, please feel free to contact me at the number \nshown below. \nEFTA00225619\n", "char_count": 1747}, {"efta_number": "EFTA00225378", "page_number": 242, "text_content": "A. Marie Villafafla \nAssistant U.S. Attorney \n500 S. Australian Ave, Suite 400 \nWest Palm Beach, FL 33401 \nPhone 561 209-1047 \nFax 561 820-8777 \n2 \nEFTA00225620\n", "char_count": 161}, {"efta_number": "EFTA00225378", "page_number": 243, "text_content": "Villafana, Ann Marie C. (USAFLS) \nFrom: \nSloman, Jeff (USAFLS) <1Sloman ®usa.doj.gov> \nSent: \nTuesday, June 24, 2008 9:14 PM \nTo: \nVillafana, Ann Marie C. (USAFLS) \nSubject: \nRe: Jeffrey Epstein Agreement \nLet's talk about going to the COP \n \nOriginal Message \nFrom: Villafana, Ann Marie C. (USAFLS) \nTo: Roy BLACK ; Jack Goldberger \nCc: Atkinson, Karen (USAFLS) \nSent: Tue Jun 24 16:04:55 2008 \nSubject: Jeffrey Epstein Agreement \nDear Roy and Jack: \n1 am just writing to re-state that it is the Government's position that we have a signed, binding agreement and that there is no need for \nfurther modification. \nPlease keep us informed of the date and time of the change of plea and sentencing. \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 \n6 \nEFTA00225621\n", "char_count": 916}, {"efta_number": "EFTA00225378", "page_number": 244, "text_content": "Villafana, Ann Marie C. (USAFLS) \nFrom: \nSloman, Jeff (USAFIS) <1Sloman@usa.doj.gov> \nSent: \nWednesday, June 25, 2008 8:46 AM \nTo: \nVillafana, Ann Marie C. (USAFIS) \nSubject: \nRe: Jeffrey Epstein Agreement \nI have a des apptmt @ 10:45 in ftm laud so call me on my cell. \n— Original Message --\nFrom: Villafana, Ann Marie C. (USAFLS) \nTo: Sloman, Jeff (USAFLS) \nSent: Wed Jun 25 08:39:31 2008 \nSubject: RE: Jeffrey Epstein Agreement \nHi Jeff— I think I have designed a solution to the 2255 issue and I will call you to discuss the plea. I am still finishing up these search \nwarrants. As soon as they are done, I will give you a call. \nA. Marie Villafafta \nAssistant U.S. Attorney \n500 S. Australian Ave, Suite 400 \nWest Palm Beach, FL 33401 \nPhone 561 209-1047 \nFax 561 820-8777 \n— Original Message—\nFrom: Sloman, Jeff (USAFLS) \nSent: Tuesday, June 24, 2008 9:14 PM \nTo: Villafana, Ann Marie C. (USAFLS) \nSubject: Re: Jeffrey Epstein Agreement \nLet's talk about going to the COP \n— Original Message --\nFrom: Villafana, Ann Marie C. (USAFLS) \nTo: Roy BLACK ; Jack Goldberger \nCc: Atkinson, Karen (USAFLS) \nSent: Tue Jun 24 16:04:55 2008 \nSubject: Jeffrey Epstein Agreement \nDear Roy and Jack: \nI am just writing to re-state that it is the Government's position that we have a signed, binding agreement and that there is no need for \nfurther modification. \nPlease keep us informed of the date and time of the change of plea and sentencing. \nThank you. \nA. Marie Villafafta \nAssistant U.S. Attorney \n500 S. Australian Ave, Suite 400 \nWest Palm Beach, FL 33401 \nPhone 561 209-1047 \nFax 561 820-8777 \nEXHIBIT B-46 \n94 \nEFTA00225622\n", "char_count": 1671}, {"efta_number": "EFTA00225378", "page_number": 245, "text_content": "Villafana, Ann Marie C. (USAFLS) \nFrom: \nSloman, Jeff (USAFLS) clSlomangiusa.doj.gov> \nSent: \nWednesday, June 25, 2008 6:05 PM \nCc: \nVillafana, Ann Marie C. (USAFLS) \nSubject: \nFw. Revised Victim Notification \nAttachments: \nU.wpd \nThis simplifies it. What do u think? \n---- Original Message --\nFrom: Acosta, Alex (USAFLS) \nTo: Sloman, Jeff (USAFLS) \nSent: Wed Jun 25 18:00:14 2008 \nSubject: RE: Revised Victim Notification \nWhat do you think \n<> \n«LLANO» \nFrom: Sloman, Jeff (USAFLS) \nSent: Wednesday, June 25, 2008 5:43 PM \nTo: Acosta, Alex (USAFLS) \nSubject: FW: Revised Victim Notification \nFrom: Villafana, Ann Marie C. (USAFLS) \nSent: Wednesday, June 25, 2008 5:25 PM \nTo: Sloman, Jeff (USAFLS); Senior, Robert (USAFLS); Atkinson, Karen (USAFLS) \nSubject: Revised Victim Notification \nHi Jeff -- I have tried to phrase it in a way that suggests that, since Epstein has performed certain provisions, it is now our turn to \nperform. \n<< File: Revised Victim Notification.wpd >> \nA. Marie Villafafla \nAssistant U.S. Attorney \n500 S. Australian Ave, Suite 400 \nWest Palm Beach, FL 33401 \nPhone 561 209-1047 \nFax 561 820-8777 \nEXHIBIT B-47 \n9 \nEFTA00225623\n", "char_count": 1164}, {"efta_number": "EFTA00225378", "page_number": 246, "text_content": "Villafana, Ann Marie C. (USAFLS) \nFrom: \nSloman, Jeff (USAFLS) \nSent: \nWednesday, June 25, 2008 6:05 PM \nCc: \nVillafana, Ann Marie C. (USAFLS) \nSubject: \nFvr. Revised Victim Notification \nAttachments: \nU.wpd \nThis simplifies it. What do u think? \n--- Original Message --\nFrom: Acosta, Alex (USAFLS) \nTo: Sloman, Jeff (USAFLS) \nSent: Wed Jun 25 18:00:14 2008 \nSubject: RE: Revised Victim Notification \nWhat do you think \n«U.wpd>> \n«U.wpd>> \nFrom: Sloman, Jeff (USAFLS) \nSent: Wednesday, June 25, 2008 5:43 PM \nTo: Acosta, Alex (USAFLS) \nSubject: FW: Revised Victim Notification \nFrom: Villafana, Ann Marie C. (USAFLS) \nSent: Wednesday, June 25, 2008 5:25 PM \nTo: Sloman, Jeff (USAFLS); Senior, Robert (USAFLS); Atkinson, Karen (USAFLS) \nSubject: Revised Victim Notification \nHi Jeff— I have tried to phrase it in a way that suggests that, since Epstein has performed certain provisions, it is now our turn to \nperform. \n« File: Revised Victim Notification.wpd >> \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 \n08-80736-CV-MARRA \n96 \nEXHIBIT B-48 \nP-014982 \nEFTA00225624\n", "char_count": 1189}, {"efta_number": "EFTA00225378", "page_number": 247, "text_content": "Villafana, Ann Marie C. (USAFLS) \nFrom: \nVillafana, Ann Marie C. (USAFLS) \nSent: \nThursday, June 26, 2008 8:31 AM \nTo: \nSloman, Jeff (USAFLS) \nSubject: \nRE Revised Victim Notification \nJeff — tam running off to grand jury. I will call as soon as I get back, probably around 9:45. Thanks. \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----Original Message---\nFrom: Sloman, Jeff (USAFLS) \nSent: Wednesday, June 25, 2008 6:05 PM \nCc: Villafana, Ann Marie C. (USAFLS) \nSubject: Fw: Revised Victim Notification \nThis simplifies it. What do u think? \n— Original Message ---\nFrom: Acosta, Alex (USAFLS) \nTo: Sloman, Jeff (USAFLS) \nSent: Wed Jun 25 18:00:14 2008 \nSubject: RE: Revised Victim Notification \nWhat do you think \n<> \nA. Marie Villarada \nAssistant U.S. Attorney \n500 S. Australian Ave, Suite 400 \nWest Palm Beach, FL 33401 \nPhone 561 209-1047 \nFax 561 8204777 \n08-80736-CV-MARRA \n98 \nP-014984 \nEFTA00225626\n", "char_count": 233}, {"efta_number": "EFTA00225378", "page_number": 249, "text_content": "U.S. Department of Justice \nUnited States Attorney \nSouthern District of Florida \n500 South Australian Ave., Suite 400 \nWest Palm Beach FL 33401 \n(361)820-8711 \nFacsimile: (561)820-8777 \nJuly \n2008 \nNOTIFICATION OF IDENTIFIED VICTIMS \nOn June 30, 2008, Jeffrey Epstein (hereinafter referred to as \"Epstein) entered a \nplea of guilty to violations of Florida Statutes Sections 796.07 (felony solicitation of \nprostitution) and 796.03 (procurement of minors to engage in prostitution), in the 15th \nJudicial Circuit in and for Palm Beach County (Case Nos. 2006-cf-009495AXXXMEB and \n2008- \n) and was sentenced to a term of eighteen months' imprisonment \nto be followed by \nyears of probation. \nIn light of the entry of the guilty plea and sentence, the United States has agreed to \ndefer federal prosecution in favor of this state plea and sentence, subject to certain \nconditions. \nOne such condition to which Epstein has agreed is the following: \n\"My person, who while a minor, was a victim of a violation of an offense \nenumerated in Title 18, United States Code, Section 2255, will have the \nsame rights to proceed under Section 2255 as she would have had, if Mr. \nEpstein had been tried federally and convicted of an enumerated offense. \nFor purposes of implementing this paragraph, the United States shall \nprovide Mr. Epstein's attorneys with a list of individuals whom it was \nprepared to name in an Indictment as victims of an enumerated offense by \nMr. Epstein. Any judicial authority interpreting this provision, including \nany authority determining which evidentiary burdens if any a plaintiff must \nmeet, shall consider that it is the intent of the parties to place these \nidentified victims in the same position as they would have been had Mr. \nEpstein been convicted at trial. No more; no less.\" \nThrough this letter, this Office hereby provides Notice that the individuals \nidentified below are individuals whom the United Stats was prepared to name as a victim \nof an enumerated offens\n... [truncated, 2046 chars — for the full page use /api/corpus/document/EFTA00225378/249 or ?id=EFTA00225378&page=249]", "char_count": 2046}, {"efta_number": "EFTA00225378", "page_number": 250, "text_content": "NOTIFICATION OF IDENTIFIED VICTIMS \nJULY \n2008 \nPAGE 2 OF 3 \nIdentified Individuals \nJane Doe #1 \nJane Doe #2 \nJane Doe #3 \nJane Doe #4 \nJane Doe #5 \nJane Doe #6 \nJane Doe #7 \nJane Doe #8 \nJane Doe #9 \nJane Doe #10 \nJane Doe #11 \nJane Doe #12 \nJane Doe #13 \nJane Doe #14 \nJane Doe #15 \nJane Doe #16 \nJane Doe #17 \nJane Doe #18 \nJane Doe #19 \nJane Doe #20 \nDated: \n \nBy: \nA. MARIE VILLAFARA \nASSISTANT U.S. ATTORNEY \nACKNOWLEDGEMENT \nI have received this Notification from my attorney, Roy Slack Esquire, have read it and discussed it with my \nattorney, and I hereby acknowledge that it accurately sets forth my understanding and agreement with the Office of the \nUnited States Attorney for the Southern District of Florida. \nI understand that an exact copy of this Notification will be \nprovided to each identified individual, except that the names of all other identified individuals will be redacted, and I \nhereby waive any evidentiary challenges to the introduction of a copy of this \ndocument-even in redacted form-in any judicial proceeding between any identified \nindividual and myself. \nJane Doe #21 \nJane Doe #22 \nJane Doe #23 \nJane Doe #24 \nJane Doe #25 \nJane Doe #26 \nJane Doe #27 \nJane Doe #28 \nJane Doe #29 \nJane Doe #30 \nR. ALEXANDER ACOSTA \nUNITED STATES ATTORNEY \n08-80736-CV-MARRA \nP-014986 \nEFTA00225628\n", "char_count": 1322}, {"efta_number": "EFTA00225378", "page_number": 251, "text_content": "NOTIFICATION OF IDENTIFIED VICTIMS \nJULY \n2008 \nPAGE 3 OF 3 \nDated: \nJeffrey Epstein \nWitnessed \nby: \nRoy Black, Esquire \n08-80736-CV-MARRA \nP-014987 \nEFTA00225629\n", "char_count": 164}, {"efta_number": "EFTA00225378", "page_number": 252, "text_content": "U.S. Department of Justice \nUnited States Attorney \nSouthern District of Florida \n500 South Australian Ave., Suite 400 \nWest Palm Beach, FL 33401 \n(561)8204711 \nFacsimile: (561) 820-8777 \nJuly \n2008 \nNOTIFICATION OF IDENTIFIED VICTIMS \nOn June 30, 2008, Jeffrey Epstein (hereinafter referred to as \"Epstein) entered a \nplea of guilty to violations of Florida Statutes Sections 796.07 (felony solicitation of \nprostitution) and 796.03 (procurement of minors to engage in prostitution), in the 15th \nJudicial Circuit in and for Palm Beach County (Case Nos. 2006-cf-009495AXXXtv1B and \n2008- \n) and was sentenced to a term of eighteen months' imprisonment \nto be followed by \nyears of probation. \nIn light of the entry of the guilty plea and sentence, and pursuant to the terms of \nthe deferred prosecution agreement between Epstein and the United States Attorney's \nOffice for the Southern District of Florida (hereinafter referred to as \"the Office\"), the \nOffice hereby provides notice to Epstein that the following is a list of individuals whom \nthe Office was prepared to name as victims in an Indictment charging Epstein with \nviolations of federal statutes enumerated in Title 18, United States Code, Section 2255 \n(hereinafter referred to as \"identified individuals\"). \nThe terms of the deferred prosecution agreement provide that the identified \nindividuals shall have the same right to seek damages pursuant to Title 18, United States \nCode, Section 2255, as they would have had if Mr. Epstein had been tried and convicted \nof those enumerated offenses in a federal court. Section 2255 provides, in relevant part: \nAny person who, while a minor, was a victim of a violation of section . . . \n2422, or 2423 of this title and who suffers personal injury as a result of such \nviolation, regardless of whether the injury occurred while such person was a \nminor, may sue in any appropriate United States District Court and shall \nrecover the actual damages such person sustains and the cost of the \n... [truncated, 2295 chars — for the full page use /api/corpus/document/EFTA00225378/252 or ?id=EFTA00225378&page=252]", "char_count": 2295}, {"efta_number": "EFTA00225378", "page_number": 253, "text_content": "NOTIFICATION OF IDENTIFIED terms \nJULY \n2008 \nPAGE 2 OF 3 \nEpstein, the Office hereby provides Notice to the identified individuals that each of them \nis a person who, while a minor, was a victim of a violation of an offense enumerated in \nTitle 18, United States Code, Section 2255, committed by Epstein. The Office further \nprovides Notice to the identified individuals that, pursuant to the Agreement between the \nOffice and Epstein, a copy of this document may be introduced in a judicial proceeding \nbetween any such identified individual and Epstein, and that any judicial authority \ninterpreting this Notification, including any authority determining what evidentiary \nburdens, if any, a plaintiff must meet, shall consider that it is the intent of Epstein and the \nOffice to place the identified individuals in the same position as they would have been \nhad Epstein been convicted of those federal offenses. \nIdentified Individuals \nJane Doe #1 \nJane Doe #2 \nJane Doe #3 \nJane Doe #4 \nJane Doe #5 \nJane Doe #6 \nJane Doe #7 \nJane Doe #8 \nJane Doe #9 \nJane Doe #10 \nJane Doe #11 \nJane Doe #12 \nJane Doe #13 \nJane Doe #14 \nJane Doe #15 \nJane Doe #16 \nJane Doe #17 \nJane Doe #18 \nJane Doe #19 \nJane Doe #20 \nDated: \n \nBy: \nA. MARIE VILLAFARA \nASSISTANT U.S. ATTORNEY \nACKNOWLEDGEMENT \nI have received this Notification from my attorney, Roy Black Esquire, have read it and discussed it with my \nattorney, and I hereby acknowledge that it accurately sets forth my understanding and agreement with the Office of the \nUnited States Attorney for the Southern District of Florida. \nI understand that an exact copy of this Notification will be \n08-80736-CV-MARRA \nP-014989 \nJane Doe #21 \nJane Doe #22 \nJane Doe #23 \nJane Doe #24 \nJane Doe #25 \nJane Doe #26 \nJane Doe #27 \nJane Doe #28 \nJane Doe #29 \nJane Doe #30 \nR. ALEXANDER ACOSTA \nUNITED STATES ATTORNEY \nEFTA00225631\n", "char_count": 1870}, {"efta_number": "EFTA00225378", "page_number": 254, "text_content": "NOTIFICATION OF IDENTIFIED VICTIMS \nJULY \n2008 \nPAGE 3 OF 3 \nprovided to each identified individual, except that the names of all other identified individuals will be redacted, and \nhereby waive any evidentiary challenges to the introduction of a copy of this \ndocument-even in redacted form-in any judicial proceeding between any identified \nindividual and myself. \nDated: \nJeffrey Epstein \nWitnessed \nby: \nRoy Black, Esquire \n08-80736-CV-MARRA \nP-014990 \nEFTA00225632\n", "char_count": 470}, {"efta_number": "EFTA00225378", "page_number": 255, "text_content": "Villafana, Ann Marie C. (USAFLS) \nFrom: \nSenior. Robert (USAFLS) \nSent: \nMonday, June 23, 2008 5:30 PM \nTo: \nVillafana, Ann Marie C. (USAFLS) \nCc: \nSloman, Jeff (USAFLS) \nSubject: \nFW: Epstein \nI agree. Marie can you make this communication today please. Thank you. \n \nOriginal Message \nFrom: Sloman, Jeff (USAFLS) \nSent: Monday, June 23, 2008 6:45 AM \nTo: Senior, Robert (USAFLS) \nSubject: Epstein \nBob, \nIf we get the go-ahead, I think Marie should immediately notify Lefkowitz that JE \nhas until COB Monday June 30 to comply with the 9/24 Agreement as modified by the \nUSA's 12/17 letter otherwise the Office will deem him in breach. What say you? \nJeff \nEXHIBIT B-49 \n859 \nEFTA00225633\n", "char_count": 690}, {"efta_number": "EFTA00225378", "page_number": 256, "text_content": "Villafana, Ann Marie C. (USAFLS) \nFrom: \nVillafana, Ann Marie C. (USAFLS) \nSent: \nMonday, June 23, 2008 5:55 PM \nTo: \nlefkowitz@kirkland.conY: Jay Leffcowitz \nCc: \nAtkinson, Karen (USAFLS) \nSubject: \nJeffrey Epstein \nDear Mr. 1-efkowitz: \nI understand that the Deputy Attorney General has completed his review of the Epstein matter and has \ndetermined that federal prosecution of Mr. Epstein's case is appropriate. \nAccordingly, Mr. Epstein has until the close of business on Monday. June 30, 2008, to comply with the terms \nand conditions of the agreement between the United States and Mr. Epstein (as modified by the U.S. Attorney's \nDecember I9th letter to Ms. Sanchez), including entry of a guilty plea, sentencing, and surrendering to begin his \nsentence of imprisonment. \nIf you have any questions, please feel free to contact me at the number shown below. \nA. Marie Villafaaa \nAssistant U.S. Attorney \n500 S. Australian Ave, Suite 400 \nWest Palm Beach, FL 33401 \nPhone 561 209-1047 \nFax 561 820-8777 \nTracking: \n851 \nEFTA00225634\n", "char_count": 1037}, {"efta_number": "EFTA00225378", "page_number": 257, "text_content": "Amenold, Jennifer \nAndriano, \nBritan \nwegel, \niciliano, Jennifer \nmythe, \nelasco, Shady \nWild, Courtne \nlis, \n20'd itila \n3/14 Recently identified. Law Enforcement has not interviewed. \n17 No recollection regarding ever going to Epstein's residence or providing massage to Epstein \n17 Original interview stated that she modeled lingerie for Epstein. \n117 Uncooperative. Law Enforcement has not interviewed. \n5/16 Uncooperative - confirmed age she provided massage but said Epstein did not touch her or masturbate. \n17 Left 2 messages. Original Interview to FBI stated that she was 18 and she did not admit to providing massages. \n15 Inconsistent statements to Law Enforcement Uncooperative. \ntVa No contact with Epstein nor did she know anyone associated with Epstein. \nEXHIBIT B-50 \nEFTA00225635\n", "char_count": 797}, {"efta_number": "EFTA00225378", "page_number": 258, "text_content": "Villafana, Ann Marie C. (USAFLS) \nFrom: \nVillafana. Ann Marie C. (USAFLS) \nSent: \nFriday. June 27, 2008 3:48 PM \nTo: \nSloman, Jeff (USAFLS); Atkinson, Karen (USAFLS): Senior, Robert (USAFLS) \nCc: \nNesbitt Kuyrkendall (E.Kuyrkendall@ic.fbi.goy); Jason Richards (Jason.Richards2 \n@ic.fbi.gov) \nSubject: \nEpstein Plea \nWow, am I good. Here it is already. I think our faxes crossed in cyber-space. Sorry for the poor quality, that is how it \ncame to me. \nEpstein \nPlea001.pdf \n;4. :Marie fliltafaiiii \nidIssistant US. .'A tiorney \n561 209-1047 \n781 \nEXHIBIT B-5I \nEFTA00225636\n", "char_count": 573}, {"efta_number": "EFTA00225378", "page_number": 259, "text_content": "Villafana, Ann Marie C. (USAFLS) \nFrom: \nVillafana, Ann Marie C. (USAFLS) \nSent: \nFriday. June 27, 2008 3:40 PM \nTo: \nSloman, Jeff (USAFLS); Atkinson. Karen (USAFLS) \nSubject: \n080627 Goldberger Black Itr.pdf \nHere is the letter that I just faxed over. \nPolice checked the docket and it is on at 8:30 for a \"status conference.\" It also looks like the required \nprocurement of minors charge has been filed. Will keep you posted. \n080627 \nIberger Black Itri \n782 \nEFTA00225637\n", "char_count": 475}, {"efta_number": "EFTA00225378", "page_number": 260, "text_content": "Villafana, Ann Marie C. (USAFLS) \nFrom: \nVillafana, Ann Marie C. (USAFLS) \nSent: \nFriday, June 27, 2008 10:14 AM \nTo: \nSloman, Jeff (USAFLS) \nCc: \nAtkinson, Karen (USAFLS) \nSubject: \nStill haven't heard anything \nHow did things go with Chief Reiter? \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: \nEXHIBIT B-52 \n797 \nEFTA00225638\n", "char_count": 438}, {"efta_number": "EFTA00225378", "page_number": 261, "text_content": "Villafana, Ann Marie C. (USAFLS) \nFrom: \nSloman, Jeff (USAFLS) \nSent: \nSaturday, June 28, 2008 12:56 PM \nTo: \nVilleama,AnnblarieC.(JSAFLS) \nSubject: \nRe: Chief reiter \nGood \n \n Original Message \nFrom: Villafana, Ann Marie C. (USAFLS) \nTo: Sloman, Jeff (USAFLS) \nSent: Sat Jun 28 11:21:34 2008 \nSubject: Chief reiter \nJeff. I spoke with the chief this morning. He is going to notify victims about \nthe plea. \n770 \nEXHIBIT B-53 \nEFTA00225639\n", "char_count": 441}, {"efta_number": "EFTA00225378", "page_number": 262, "text_content": "Villafana, Ann Marie C. (USAFLS) \nFrom: \nSloman, Jeff (USAFLS) \nSent: \nFriday, December 07, 2007 5:08 PM \nTo: \nVillafana, Ann Marie C. (USAFLS) \nSubject: \nRe: Epstein \nHold the letter \nSent from my BlackBerry Wireless Handheld \n \n Original Message \nFrom: Villafana, Ann Marie C. (USAFLS) \nTo: Sloman, Jeff (USAFLS); Acosta, Alex (USAFLS) \nSent: Fri Dec 07 17:05:56 2007 \nSubject: Epstein \nHello - Any word? Am I free to send out the victim notification letter? And, is \nit alright to send copies of the victim notification letter to Mr. Josefsberg? \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 \nEXHIBIT B-54 \n2327 \n08-80736-CV-MARRA \nP-014420 \nEFTA00225640\n", "char_count": 757}, {"efta_number": "EFTA00225378", "page_number": 263, "text_content": "r callziai artezza-\n-Lesii \nk lenre\nstakilsaf_ra_liut-gv 111MJ. ; Aka_ \n_ a_stgi1/2\nRS 251 4 - 9;544_ \nI1: 50 aa16.12,_LA aimd_ \na-to el \n---a, _Can----411AXIBLOCICS \nibiat0121/S_ _ crednACh6<15...!. \n'ILAtainAl2/2eA. \" _We \n2.Lthe#__16\n1\nvt _ \nA i_J-A4_nistad__ \n/1/4 _trasiai• \n11%52- Fax \nEQCL12ak \ncalt\n • \n- \nEXHIBIT B-43 \nEFTA00225641\n", "char_count": 344}, {"efta_number": "EFTA00225378", "page_number": 264, "text_content": "Villafana, Ann Marie C. (USAFLS) \nFrom: \nBrad Edwards (be@bradedwardslaw.com] \nSent: \nThursday, June 19, 2008 11:34 AM \nTo: \nVillafana. Ann Marie C. (USAFLS) \nSubject: \nJeff Epstein \nHi Marie, \nI have information and concerns that I would like to share. While I understand that you are limited in what you can \ndiscuss. I would like to meet with you and discuss my plans. This would be beneficial to you and me. Let me know if you \nare interested in meeting and talking. My schedule is free next Monday, Tuesday, and Wednesday, July 23-25. If any of \nthose days are open for you, then I will go to you and can meet you at any time convenient for you. I am scheduling to \nmeet with my client again next week in your area anyway, so it would be no problem for me to meet you on the same \nday. I look forward to hearing back from you. \nSincerely, \nBrad Edwards, Esquire \nLaw Office of Brad Edwards & Associates \n2028 Harrison Street \nSuite 202 \nHollywood, Florida 33020 \nTelephone: \n954414-8033 (Broward) \n305-935-2011 (Miami-Dade) \nFacsimile: \n954-924- 1530(Broward) \n305/935-4227 (Miami-Dade) \ne-mail: \nbe@bradedwardslaw.com \nPRIVILEGED AND CONFIDENTIAL: The information contained in this e-mail message is intended for the \nuse of the individual or entity to which it is \naddressed and may contain information that is proprietary, privileged, confidential, and exempt from disclosure \nunder applicable laws. If the reader of this \nmessage is not the intended recipient, or the employee or agent responsible for delivery to the intended \nrecipient, you are hereby notified that any use, printing, \nreproduction, disclosure or dissemination of this communication may be subject to legal restriction or sanction. \n909 \nEFTA00225642\n", "char_count": 1729}, {"efta_number": "EFTA00225378", "page_number": 265, "text_content": "j.S. Department of Justice \nUnited States Attorney \nSouthern District of Florida \n500 South Australian Ave., Suite 400 \nWest Palm Reach, FL 33401 \n(561)820-8711 \nFacsimile: (561) 820-8777 \nApril 9, 2008 \nVIA FACSIMILE \nRichard H. Willets, Esq. \nMr. Michael Danchuk \n2290 10th Avenue North, Suite 404 \nLake Worth, FL 33461 \nRe: \nCarolyn El \nDear Messrs. Willits and Danchuk: \nThank you for your letter of March 28, 2008, regarding \nPursuant to the strict rules of grand jury secrecy, I am not able to prow e you wt \ne \ninformation that you have requested. I believe that some of the information you are \nseeking is available from ublic sources on the intemet. We also do not have any \nphotographs of Ms. \nI regret that I cannot be of more assistance. I would appreciate it if you would \nkeep me updated on the course of the civil litigation. \nSincerely, \nR. Alexander Acosta \nUnited States Attorney \nA. Marie Vitfafaka \nAssistant United States \nAttorney \ncc: \nE. Nesbitt Kuyrkendall, FBI \nEXHIBIT B-42 \nEFTA00225643\n", "char_count": 1015}, {"efta_number": "EFTA00225378", "page_number": 266, "text_content": "A. Maria Di Ilafana, F-sq. \nMarch 28, 2008 \nPaga 2 \nWe look forward to hearing from you on whether you can assist us. \nThank you for your assistance. \nSincerely, \nMichael Danchuk \nLegal Administrator/Paralegal \nMD/ \ncc: \nchard H.\n Esq. \nEFTA00225644\n", "char_count": 250}, {"efta_number": "EFTA00225378", "page_number": 267, "text_content": "Richard H. Willits, P.A. \nBoard Certified Civil Trial Lawyer \n2290 10th Avenue North, Suite 404 \nLake Worth, Florida 33461 \nOffice: (561) 582-7600 \nFax: (561) 588-8819 \nMarch 28, 2008 \nA. Maria Dillafana, Esq. \nUS Dept. of Justice \n500 S. Australian Ave., Suite 400 \nWest Palm Beach, FL 33401 \nRe: \nOur Client: \nDefendant: \nJe ey Epstein \nDear Ms. Dillafana: \nPlease be advised we have been retained to represent \nEM \nas a result of a relationship \nwith Mr. Epstein. \nAs we understand you are investigating this matter, we wanted you to be aware of our involvement. \nWe have filed a lawsuit in Palm Beach County Circuit Court under Ms. \ninitials, C.M.A. \nWe are using the initials to try to keep publicity on this matter limited for Ms. Andriano's benefit. \nPossibly, you can help us with one of the problems that we are having. We have not been able to \nserve Mr. Epstein, and his attorney will not accept service on his behalf \nWe had discussed this with FBI Agent Elizabeth Kirkdale, and she suggested that we contact you to \nsee if you could provide us the information we are requesting. \nWe are trying to locate Mr. Epstein's airplane \"tail registration number\" for the 727 plane that he \nhas. If you have this information and can provide it to us, it would be greatly appreciated. \nAlso we understand that either the FBI or your office may have photographs taken of Ms. \nby \nallegedly for Mr. Epstein. \nIf you do have these photographs, we, of course, would request that they be preserved and also \ncopies made for us. \nIf there are any copy charges involved, we would be happy to reimburse your department. \nEXI-I1B1T 8-41 \nEFTA00225645\n", "char_count": 1644}, {"efta_number": "EFTA00225378", "page_number": 268, "text_content": "Villafana, Ann Marie C. (USAFLS) \nFrom: \nSloman, Jeff (USAFLS) \nSent: \nThursday, May 29, 2008 9:29 AM \nTo: \nVillafana, Ann Marie C. (USAFLS); Senior, Robert (USAFLS) \nCc: \nAtkinson, Karen (USAFLS); Kuyrkendall, E N. (MM) (FBI); Richards, Jason R. (MM) (FBI) \nSubject: \nRE: Epstein \nNo telling how long the DAG's office will take to decide. Tuesday is off. \n—Original Message—\nFrom: Villafana, Ann Marie C. (USAFLS) \nSent: Thursday, May 29, 2008 9:03 AM \nTo: Sloman, Jeff (USAFLS); Senior, Robert (USAFLS) \nCc: Atkinson, Karen (USAFLS); Kuyrkendall, E N. (FBI); Richards, Jason R. (FBI) \nSubject: Epstein \nHi Jeff and Bob. I received Jeff's e-mail stating that the DAG agreed to meet with epstein's people. Does this mean that Tuesday is \noff? I need to let the gj coordinator know. \nAlso, I am sure that you remember \nin. She was the person whom we initially classified as a victim until epstein's attorneys \ncomplained. Well. nesbitt ha\ninigted a girl who was I4 or I5 when she first went to epstein's house who reports that epstein \ntold her that he had sex with. \nprobably would have been 15 or 16 when this conversation occurred.) The girl also reports \nthat she told epstein her true age and epstein told her that he doesn't care about age. \nI know that cpstein's people will, no doubt, continue to tell the dag and others that epstein didn't know about the girls' ages so I \nthought you should know. \nPlease let me know about tuesday so I don't needlessly spoil nesbitt's sunday. And, any chance the case was discussed with the ag \nwhen he was in town? \nThanks. \nEXHIBIT B-40 \nEFTA00225646\n", "char_count": 1618}, {"efta_number": "EFTA00225378", "page_number": 269, "text_content": "Villafana, Ann Marie C. (USAFLS) \nFrom: \nVillafana, Ann Marie C. (USAFLS) \nSent: \nTuesday, May 27, 2008 1:20 PM \nTo: \nAtkinson, Karen (USAFLS) \nSubject: \nRe: Epstein \nPlease tell me you that you are joking. Maybe we should throw him a party and tell him we are sorry to have bothered him. \n \nOriginal Message \nFrom: Atkinson, Karen (USAFLS) \nTo: Villafana, Ann Marie C. (USAFLS) \nSent: Tue May 27 10:27:10 2008 \nSubject: Epstein \nDon't know what is up but Barry talked to Rolando and according to Rolando said something about 90 days in jail. Rolando is talking \nto Jeff-he said. K \n08-80736-CV-MARRA \nEXHIBIT B-39 \n40 \nEFTA00225647\n", "char_count": 658}, {"efta_number": "EFTA00225378", "page_number": 270, "text_content": "Villafana, Ann Marie C. (USAFLS) \nFrom: \nSenior, Robert (USAFLS) \nSent: \nTuesday, May 27, 2008 5:09 PM \nTo: \nVillafana, Ann Marie C. (USAFLS) \nSubject: \nRE: Epstein \nPerfect. Enjoy your trip. Wc'rc in good shape (so far). \n \nOriginal Message \nFrom: Villafana, Ann Marie C. (USAFLS) \nSent: Tuesday, May 27, 2008 3:56 PM \nTo: Senior, Robert (USAFLS) \nSubject: Re: Epstein \nHi bob. I get back on saturday. I will spend sunday with nesbitt and monday with you. I will be there by 10:00 unless you need me \nthere earlier. \n \nOriginal Message \nFrom: Senior, Robert (USAFLS) \nTo: Villafana, Ann Marie C. (USAFLS); Sloman, Jeff (USAFLS) \nCc: Atkinson, Karen (USAFLS) \nSent: Tue May 27 15:24:50 2008 \nSubject: RE: Epstein \nMarie, are you back ? We need to spend some time together on the indictment. I was planning on Monday because I thought you \nwere back that day but if you're already back let me know. By the way, Jeff and Alex have been very clear that we are not negotiating \nwith this guy any more in any way. \nThx. Bob \n----Original Message \nFrom: Villafana, Ann Marie C. (USAFI.S) \nSent: Tuesday, May 27, 2008 2:54 PM \nTo: Sloman, Jeff (USAFLS); Senior, Robert (USAFLS) \nCc: Atkinson, Karen (USAFLS) \nSubject: Epstein \nHi jeff. Karen sent me an email about epstein wanting to do less time. I hope that his request will be denied. The original deal was \nsupposed to be 2 years so he has already gotten a big break. Plus we have identified more victims since we agreed to the 18 months. \nPlease keep me posted. Thanks. \nEXHIBIT B-38 \n08-80736-CV-MARRA \nP-014927 \n44 \nEFTA00225648\n", "char_count": 1601}, {"efta_number": "EFTA00225378", "page_number": 271, "text_content": "Villafana, Ann Marie C. (USAFLS) \nFrom: \nVillafana, Ann Marie C. (USAFLS) \nSent: \nTuesday, May 27, 2008 3:56 PM \nTo: \nSenior, Robert (USAFLS) \nSubject: \nRe: Epstein \nHi bob. I get back on saturday. I will spend sunday with nesbitt and monday with you. I will be there by 10:00 unless you need me \nthere earlier. \n---- Original Message \nFrom: Senior, Robert (USAFLS) \nTo: Villafana, Ann Marie C. (USAFLS); Sloman, Jeff (USAFLS) \nCc: Atkinson, Karen (USAFLS) \nSent: Tue May 27 15:24:50 2008 \nSubject: RE: Epstein \nMarie, are you back ? We need to spend some time together on the indictment. I was planning on Monday because I thought you \nwere back that day but if you're already back let me know. By the way, Jeff and Alex have been very clear that we are not negotiating \nwith this guy any more in any way. \nThx. Bob \n \nOriginal Message-----\nFrom: Villafana, Ann Marie C. (USAFLS) \nSent: Tuesday, May 27, 2008 2:54 PM \nTo: Sloman, Jeff (USAFLS); Senior, Robert (USAFLS) \nCe: Atkinson, Karen (USAFLS) \nSubject: Epstein \nIli jeff. Karen sent me an email about cpstein wanting to do less time. I hope that his request will be denied. The original deal was \nsupposed to be 2 years so he has already gotten a big break. Plus we have identified more victims since we agreed to the 18 months. \nPlease keep me posted. Thanks. \n08-80736-CV-MARRA \n42 \nP-014926 \nEFTA00225649\n", "char_count": 1390}, {"efta_number": "EFTA00225378", "page_number": 272, "text_content": "Villafana, Ann Marie C. (USAFLS) \nFrom: \nSenior, Robert (USAFLS) \nSent: \nTuesday, May 27, 2008 3:25 PM \nTo: \nVillafana, Ann Marie C. (USAFLS); Sloman, Jeff (USAFLS) \nCc: \nAtkinson, Karen (USAFLS) \nSubject: \nRE: Epstein \nMarie, are you back ? We need to spend some time together on the indictment. I was planning on Monday because I thought you \nwere back that day but if you're already back let me know. By the way, Jeff and Alex have been very clear that we arc not negotiating \nwith this guy any more in any way. \nThx. Bob \n \nOriginal Message \nFrom: Villafana, Ann Marie C. (USAFLS) \nSent: Tuesday, May 27, 2008 2:54 PM \nTo: Sloman, Jeff (USAFLS); Senior, Robert (USAFLS) \nCc: Atkinson, Karen (USAFLS) \nSubject: Epstein \nHi jeff. Karen sent me an email about cpstein wanting to do less time. I hope that his request will be denied. The original deal was \nsupposed to be 2 years so he has already gotten a big break. Plus we have identified more victims since we agreed to the III months. \nPlease keep me posted. Thanks. \n08-80736-CV-MARRA \nP-014925 \n41 \nEFTA00225650\n", "char_count": 1091}, {"efta_number": "EFTA00225378", "page_number": 273, "text_content": "KIRKLAND & ELLIS LLP \nmake an independent decision not adversely affected by conclusions that over and over have \nproven, witness by witness, allegation by allegation, to be inaccurate and unwarranted and not an \nappropriate basis for the exercise of federal prosecutorial authority. \n10 \nRFP MIA 000440 \nEFTA00225651\n", "char_count": 318}, {"efta_number": "EFTA00225378", "page_number": 274, "text_content": "KIRKLAND & ELLIS LLP \nrole. They said they would only advise on an abuse of discretion standard. Making the \noutcome a foregone conclusion. Furthermore, in response to the February 25 e-mail, \nwhich attempted to establish a schedule to limit the entire review process (the defense has \nrepeatedly suggested that the misconduct was intertwined with the investigation and \nwould therefore seek higher review), Mr. Lefkowitz e-mailed Mr. Acosta directly. On \nFebruary 29, 2008, Mr. Sloman responded to Mr. Lefkowitz's e-mail to Mr. Acosta, \nstating that Mr. Sloman was acting out of frustration, but \"[p]lease be assured that it has \nnot, and never has been, this Office's intent to interfere or restrict the \"review process\" \nfor either Mr. Epstein or CEOS. I leave it to you and CEOS to figure out how best to \nproceed and will await the results of that process.\" As stated above, CEOS determined \nthat it would not review many of the defense's objections and as to the remainder of those \nobjections, its review would be limited (contrary to Mr. Acosta's assurances), which left \nthe need, supplemented by the defense's subsequent request, for a more thorough review \nof critical issues by others at the Department of Justice. Mr. Sloman's re-imposition of \nthe (albeit modestly extended) timetable was an obvious attempt, in violation of his \nFebruary 29 agreement, to thwart the request made by the defense to the Deputy Attorney \ngeneral, to complete the review process that Mr. Acosta bad promised. \n11. \n\"DELAY.\" \nMr. Sloman's Letter: \n• In a section entitled \"Delay.\" Mr. Sloman states that \"the SDFL again agreed to \naccommodate Epstein's request to appear in state court for plea and sentencing on \nJanuary 4, 2008.\" \nId., p. 3. \nThe Truth: \n• \nCuriously, Mr. Sloman fails to mention correspondence from the U.S. Attorney stating \nthat delay of that date would be \"inevitable\" as the defense has raised \"serious questions\" \nabout the propriety of the prosecution. Strikingly, in that same sec\n... [truncated, 2814 chars — for the full page use /api/corpus/document/EFTA00225378/274 or ?id=EFTA00225378&page=274]", "char_count": 2814}, {"efta_number": "EFTA00225378", "page_number": 275, "text_content": "KIRKLAND & ELLIS LLP \nthis same individual would nevertheless be entitled to engage an attorney paid for by Mr. \nEpstein to recover $150,000 of damages from Mr. Epstein under § 2255 without ever \nalleging any injury. In fact, the defense was told that the only question Mr. Epstein \nwould be permitted to ask before paying the girls is \" have you ever met Epstein.\". Thus, \nthe Deferred Prosecution Agreement places identified individuals in a far better position \nthan they would be in if Mr. Epstein were convicted at trial. \n9. \nASSIGNMENT OF RIGHT TO SELECT LEGAL REPRESENTATIVE. \nMr. Sloman's Letter: \n• \"Prior to any issues arising concerning the implementation of the 2255 provision, the \nSDFL unilaterally agreed to assign its responsibility to select the attorney representative \nfor the alleged victims to an independent third-party.\" \nSee Tab I, May 19, 2008 Letter from J. Sloman, p. 4, f.3. \nThe Truth: \n• \nThat such an assignment was the SDFL's \"unilateral\" decision is false. Before the \nSDFL decided to assign selection of the \"attorney representative\" to an independent third \nparty, AUSA Marie Villafana had already proposed an \"attorney representative.\" She \nhad proposed local products-liability lawyer, Humberto Ocariz, and claimed he bad been \nrecommended by a \"good friend in the Appellate Division.\" Ms. Villafana's account was \nmisleading, as it omitted that this \"good friend\" was her live-in boyfriend, and that Mr. \nOcariz was his former law-school roommate. When we discovered this independently, \nwe objected. \nOnly then did the SDFL propose assigning the selection process to an \nindependent special master and agree to amend the Deferred Prosecution Agreement. \nThus, while it may be true that the SDFL assigned its selection responsibility to avoid the \nappearance of favoritism, it did not do it \"unilaterally,\" but, rather, only after Epstein \nuncovered the Office's misleading disclosure and apparent conflict-of-interest. \n10. \nTIMETABLE FOR MOVING FORWARD. \nMr. \n... [truncated, 2512 chars — for the full page use /api/corpus/document/EFTA00225378/275 or ?id=EFTA00225378&page=275]", "char_count": 2512}, {"efta_number": "EFTA00225378", "page_number": 276, "text_content": "KIRKLAND & ELLIS LLP \n8. \nALL IDENTIFIED VICTIMS BE PUT IN SAME POSITION AS IF EPSTEIN \nHAD BEEN TRIED. \nMr. Sloman's Letter: \n• \n\"The Agreement provides for a method of compensation for the victims such that they \nwould be placed in the same position as if Epstein had been convicted of one of the \nenumerated offenses set forth in Title 18, United States Code Section, 2255.\" \nId. \nThe Truth: \n• Mr. Sloman continues to mischaracterize the highly irregular provisions of the Deferred \nProsecution Agreement. The SDFL did not merely attempt to preserve the compensation \nrights of those it identified as victims; it attempted to create compensation rights for those \nit identified, without imposing on them the burden of proving that they were in fact \nvictims under § 2255. \no In the Deferred Prosecution Agreement, the SDFL required Mr. Epstein to waive \nthe right to contest liability under 18 U.S.C. § 2255 as to a list of individuals that \nthe SDFL would not disclose to Mr. Epstein until after he was sentenced and to \npay for an attorney to secure compensation under § 2255 for those undisclosed \nindividuals, or if they decided to sue Mr. Epstein. \no § 2255 ordinarily provides individuals with a right to recover minimum guaranteed \ndamages of $150,000, without having to prove actual damages, only if: (I) they \nwere victims of an enumerated federal offense, including offenses under 18 U.S.C. \n§§ 2422 and 2423, (2) they were minors at the time of the offense, and most \nimportantly (3) they were personally injured as a result of the offense. \no The defense has confirmed examples of women who testified that they were not \nvictims of Mr. Epstein and suffered no personal injury. These women were, \nnevertheless, on the list of \"victims\" identified by the government. . In fact, when \nconfronted with the testimony of a women who denied both being a victim and \nincurring personal injury, Ms. Villafana actually acknowledged such testimony. \nTo justify inclusion of that woman on the gov\n... [truncated, 2745 chars — for the full page use /api/corpus/document/EFTA00225378/276 or ?id=EFTA00225378&page=276]", "char_count": 2745}, {"efta_number": "EFTA00225378", "page_number": 277, "text_content": "KIRKLAND & ELLIS LLP \nAgreement to Defer Prosecution to the State, an agreement without precedent and fraught \nwith substantial practical and legal hurdles to its implementation. \n6. \nTHE SDFL DID NOT DEFER TO THE STATE. \nSloman's Letter: \n• \n\"(Tihe SDFL indicated a willingness to defer to the State the length of incarceration.\" \nId., p. 2. \nThe Truth: \n• \nThe SDFL neither deferred to the State, nor even discussed with the State, the length of \nMr. Epstein's incarceration. In a letter to the defense, Criminal Division Chief, Matthew \nMenchel rejected the sentence contemplated by the State's plea agreement, writing that \n\"the federal interest will not be vindicated in the absence of a two-year term of state \nimprisonment.\" See Tab 40, August 3, 2007 Email from M. Menchel. Of course, this \nposition is contrary to Section 9-2031D of the U.S. Attorney's Manual (indicating that \nthe \"result\" of a state prosecution is \"presumefdf' to have vindicated the federal interest). \nIt is understandable, therefore, that Mr. Sloman might want to retreat from it now. \nIndeed, the final Deferred Prosecution Agreement (DPA) restricts the state-court judge \nfrom exercising any of his rightful discretion and to specifically prohibit the judge from \noffering probation, community control or any other alternative in lieu of incarceration. \nDPA, 1) 2(a). \n7. \nSUGGESTION OF ADDITIONAL STATE PLEA \nMr. Sloman's Letter: \n• The parties considered: \"as suggested by [the defense], a plea to state charges \nencompassing Epstein's conduct.\" See Tab 1, May 19, 2008 Letter from J. Sloman, p.2, \n1 2. \nThe Truth: \n• It was the government, and not the defense, that suggested a plea to state charges to \nresolve the federal investigation. Andrew Lourie proposed declining prosecution in favor \nof the state. Although Mr. Epstein and the State Attorney's Office had already reached \na plea agreement, in August 2007, Mr. Sloman and AUSA Marie Villafana warned that \nthey intended to prosecute Epstein federally unl\n... [truncated, 2347 chars — for the full page use /api/corpus/document/EFTA00225378/277 or ?id=EFTA00225378&page=277]", "char_count": 2347}, {"efta_number": "EFTA00225378", "page_number": 278, "text_content": "• \nKIRKLAND & ELLIS LLP \ndescribes the additional charge to which Mr. Epstein is required to plead guilty \nunder the Deferred Prosecution Agreement as \"procurement of minors to engage \nin prostitution\" or \"solicitation of minors to engage in prostitution.\" The former \nis an offense for which Mr. Epstein would be required to register, but one for \nwhich the state has no evidence to charge Mr. Epstein and the SDFL refuses or is \nunable to provide evidence that it claims it has. \nThe latter requires no \nregistration, but it is the offense which, over and over again, Ms. Villafana \ninsisted upon including in the Deferred Prosecution Agreement, and is one which \nthe State believes is appropriate. The inconsistency between the description of \nthe offense required by the SDFL, the elements of an offense that can be justified \non the facts of this case and the SDFL's requirement that the offense be a \nregistrable one has created substantial confusion. \no As a result of this confusion, in December 2007, both the defense and the state \nrequested that the SDFL provide the factual allegations to enable Mr. Epstein and \nthe State to create a truthful factual recitation of a registrable offense required by \nthe Deferred Prosecution Agreement, but, to date, the SDFL has failed to do so \nwithout any explanation. \n• Mr. Sloman refuses to provide the requested factual allegations, which the State cannot \nfurnish, and now demands a two week deadline to comply. Thus Mr. Sloman has \nunreasonably imposed a deadline with which he himself has made it impossible for Mr. \nEpstein to comply. \n5. \nWAIVER OF APPEAL TO ASSISTANT ATTORNEY GENERAL FISHER. \nMr. Sloman's Letter: \n• \"[T]he SDFL provided you with 30 days to appeal the decision to the Assistant Attorney \nGeneral of the United States Alice Fisher\" and \"you chose to forego an appeal to AAG \nFisher.\" \nId., p. 2. \nThe Truth: \n• Mr. Acosta tolled an August 17 deadline, acknowledging that there were \"serious issues\" \nabout the case that need\n... [truncated, 2639 chars — for the full page use /api/corpus/document/EFTA00225378/278 or ?id=EFTA00225378&page=278]", "char_count": 2639}, {"efta_number": "EFTA00225378", "page_number": 279, "text_content": "KIRKLAND & ELLIS LLP \nevidence that Mr. Epstein routinely and daily receives massages from adults. Only a \nsmall percentage of the masseuses turned out to be minors. The majority of those minors \ninterviewed by law enforcement admitted to lying directly to Epstein about their ages \n(not \"unbeknownst to Epstein\"), and inventing further false details to substantiate their \nlies. Indeed, the civil attorney for several of these women admitted at his recent press \nconference that they lied to Mr. Epstein about their ages. Numerous witnesses testified \nthat Mr. Epstein asked that all masseuses be over the age of 18. Further, the evidence is \nundisputed that Mr. Epstein's assistants scheduled the massages and Mr. Epstein did not \nknow which masseuses his assistants had scheduled on a particular day, until the massage \ntook place. We admitted that there was sexual conduct, and argued—not that it was \n\"innocuous\" as Mr. Sloman alleges—but that it was mostly Mr. Epstein's own self-\npleasuring, which did not satisfy the requisite federal element of criminal sexual conduct \n(which is, in turn, defined by state law). These are important distinctions and show that \nMr. Sloman has misrepresented the record about the most basic part of our defense. \n4. \nSLOMAN DEMANDS AN UNREALISTIC DEADLINE TO COMPLY WITH AN \nAGREEMENT HE UNILATERALLY MODIFIES. \nMr. Sloman's Letter: \n• \"Unless [Mr. Epstein] complies with all of the terms and conditions of the [Deferred \nProsecution] Agreement, as modified by the United States Attorney's December 19, \n2007 letter to Ms. Sanchez by close of business on Monday, June 2, 2008, the SDFL will \nelect to terminate the Agreement.\" Id., p.1 \nThe Truth: \n• The Deferred Prosecution Agreement was never modified by U.S. Attorney Acosta's \nDecember 19, 2007 letter. Oddly, Mr. Sloman acknowledges this on page 4 of his May \n19 letter, where he writes that Mr. Acosta \"proposed\" this modification and that \"[Mr. \nLefkowitz] rejected these proposals.\" Thus, Mr. Sloman \n... [truncated, 3007 chars — for the full page use /api/corpus/document/EFTA00225378/279 or ?id=EFTA00225378&page=279]", "char_count": 3007}, {"efta_number": "EFTA00225378", "page_number": 280, "text_content": "KIRKLAND & ELLIS LLP \nSee Tab I, May 19, 2008 Letter from J. Sloman, p. 4, 1 1. \nThe Truth: \n• \nThe defense engaged in days of negotiation and made 14 separate substantive objections \nto the unprecedented notification letter that Mr. Sloman threatened to send to an \nundisclosed list of \"victims.\" The eventual transmission of this highly misleading letter \nwas only halted by an appeal to AAG Fisher. Among those substantive objections \n(which related to far more than the \"time and place\" of the state's sentencing hearing) \nwere: \no Sending the letter would contravene the government's commitment to take no \nposition regarding potential claims of government witnesses. \nSee Tab 39, \nNovember 28, 2008 Email from J. Lefkowitz to J. Sloman. \no The letter cited to an inapplicable statute (the Justice for All Act of 2004) as its \njustification for being sent. Id. AUSA Acosta later conceded that the citation to \nthis statute as a justification was wholly incorrect. \no The letter wrongly advised all recipients that Mr. Epstein would be required to \nregister as \"a sexual predator for the remainder of this life.\" \no The letter amounted to an invitation to civil litigation against Mr. Epstein, \nadvising recipients that they had the right to seek civil damages from Mr. Epstein, \nand in an underlined instruction, stated that if they chose an attorney other than \nthe one chosen by the government they would be required to pay his fees, but if \nthey chose the government's choice, Mr. Epstein would be required to pay the \nfees. \n3. \nMISCIIARACEERIZATION OF OUR ARGUMENTS. \nMr. Sloman's Letter: \n• \nMr. Sloman's letter misleadingly characterizes our substantive defense of the \ngovernment's investigation as, \"the investigation merely produced evidence of relatively \ninnocuous sexual conduct with some minors who, unbeknownst to Mr. Epstein, \nmisrepresented their ages.\" \nSee Tab I, May 19, 2008 Letter from J. Sloman, p. 2. \nThe Truth: \n• We never made such a claim. To the contrary, we argued \n... [truncated, 2239 chars — for the full page use /api/corpus/document/EFTA00225378/280 or ?id=EFTA00225378&page=280]", "char_count": 2239}, {"efta_number": "EFTA00225378", "page_number": 281, "text_content": "KIRKLAND & ELLIS LLP \n■ \nThe defense immediately raised concerns regarding the non-independence \nof the review when told that it would be Mr. Oosterbaan tasked with \nproviding the review, but was told that when Mr. Oosterbaan rendered his \nprior opinion, \"he was not really up to speed on the facts\" \no CEOS' review was not de novo: \n• By letter dated May 15, 2008 (four days before Mr. Sloman's letter), Mr. \nOosterbaan advised Mr. Lefkowitz that CEOS reviewed the matter only \nfor abuse of discretion: \nalhe question we sought to answer was whether U.S. \nAttorney Acosta would abuse his discretion if he \nauthorized prosecution in this case. \nSee Tab 38, May 15, 2008 Letter from D. Oosterbaan, p. I (emphasis \nadded). \nSee also, id., p. 2 (\"Mr. Acosta would not be abusing his \ndiscretion if he decided to pursue such a course of action.'); and p. 5 \n(\"Mr. Acosta would not be abusing his prosecutorial discretion should he \nauthorized federal prosecution of Mr. Epstein.\"). \n• For the factual record of its \"abuse of discretion\" review, CEOS relied on \nthe very same prosecution memo that it had already reviewed in rendering \nits prior opinion, stating: \nAs you know, our review of this case is limited, both factually and \nlegally. We have not looked at the entire universe of facts in this \ncase. \nSee Id., p. 1 (emphasis added). \n• Nor did CEOS review any facts related to the irregular provisions in the \nDeferred Prosecution Agreement or the numerous complaints of \nprosecutorial misconduct, both of which are inextricably intertwined with \nthe impropriety of the investigation. Id. at 1. \n2. \nNOTIFICATION OF WITNESSES. \nMr. Sloman's Letter: \n• Mr. Sloman dismissed the totality of the defense's objections to the inappropriate \nnotification the SDFL proposed to send to its witnesses, stating merely that: \n\"[Y]ou objected to victims['] being notified of time and place of Epstein's \nstateNcourt sentencing hearing.\" \n2 \nRFP MIA 000432 \nEFTA00225659\n", "char_count": 1962}, {"efta_number": "EFTA00225378", "page_number": 282, "text_content": "KIRKLAND & ELLIS LLP \nResponse to Letter by FAUSA Sloman Dated May 19, 2008 \nIn a May 19, 2008 letter to Jay Lelkowitz (See Tab I), SDFL First Assistant U.S. \nAttorney Jeffrey Sloman provided what purported to be a summary of the events that have \noccurred during the investigation of Mr. Epstein. \nMr. Sloman's letter is fraught with \ninconsistencies, false and misleading characterizations and outright falsehoods. The comparison \nbelow between the false assertions in Mr. Sloman's letter and what actually transpired is only the \ntip of the iceberg. We respectfully submit that Mr. Sloman's letter alone demonstrates the \ndegree to which the record of facts have been distorted and these distortions have permeated this \nunprecedented investigation. \n1. \n\"INDEPENDENT\" AND \"DE NOVO\" REVIEW. \nMr. Sloman's Letter: \n• \n\"[W]e obliged your request for an independent de novo review of the investigation and \nfacilitated such review at the highest levels of the Department of Justice. \" Tab 1, May \n19, 2008 Letter from J. Sloman, p. 5, 1 3. \nThe Truth: \n• \nCEOS' review, concluded in May 2008, was neither independent nor de novo. \no CEOS' review was not \"independent:\" \n• Drew Oosterbaan, who conducted the review on behalf of CEOS, had \nalready reviewed the prosecution memo on this matter eight months \nearlier. During a meeting with defense counsel at the United States \nAttorney's Office in Miami (the \"USAO\") in September of 2007, he \nopined that he so believed in the prosecution that he \"would try the case \nmyself\" \n• Indeed, Mr. Sloman acknowledges that Mr. Oosterbaan had previously \nopined on this matter, stating: \nThis particular attack on this statute [18 U.S.C. § 2242(b)) \nhad been previously raised and thoroughly considered and \nrejected by . . . CEOS prior to the execution of the \n[Deferred Prosecution] Agreement [in September 2007]. \nId., p. 5 (emphasis added). \n• The statute Mr. Sloman referred to (§ 2422(b)) lies at the heart of the \nEpstein investigation. Thus, according t\n... [truncated, 2214 chars — for the full page use /api/corpus/document/EFTA00225378/282 or ?id=EFTA00225378&page=282]", "char_count": 2214}, {"efta_number": "EFTA00225378", "page_number": 283, "text_content": "Gmail - Fw: confidential communication \nPage 4 of 4 \nLetter from CEOS.TIF \n360K \nEFTA00225661\n", "char_count": 94}, {"efta_number": "EFTA00225378", "page_number": 284, "text_content": "Gmail - Fw: confidential communication \nPage 3 of 4 \ndeliberately lied about their age because they knew Mr. Epstein did not want anyone under 18 \nin his house directly undercuts the claim that Mr. Epstein willfully blinded himself as to their \nages. Willful blindness is not a substitute for evidence of knowledge nor is it a negligence \nstandard. It requires proof beyond reasonable doubt of deliberate intent and specific action to \nhide one's knowledge. There is absolutely no such evidence of that here, so it is not even a jury \nissue. Furthermore, willful ignorance cannot constitute the required mens rea for a crime of \nconspiracy or aiding and abetting. \nThrough the recent witness statements, we have also discovered another serious issue that \nimplicates the integrity of the federal investigation. We have learned that FBI Special Agent \nKurkendayl attempted to convince these adult women, now in their twenties, that they were in \nfact \"victims\" even though the women themselves strongly disagreed with this characterization. \nThis conduct, once again, goes to the heart of the integrity of the investigation. Ina sworn \nstatement, Ms. \nwas highly critical of the overreaching by federal law enforceMent officers \nin this case. She testified—in no uncertain terms—that she does not, and never did, feel like a \n\"victim,\" despite the fact that the FBI repeatedly tried to convince her otherwise. \nI am mindful of the fact that we have a state court date of July 8 on which either to enter a plea \nor to commence trial. As I review the trial options with Mr. Epstein, I certainly want to make sure \nI do everything within my power to obviate a need for trial through a reasonable alternative \nresolution. Although it is clear that CEOS is not directing a prosecution here, and has stated \nonly that you have the authority to commence such a prosecution, I am well aware that the \ndecision whether to proceed, subject to any further process in Washington, is now within your \ndiscretion. I\n... [truncated, 3050 chars — for the full page use /api/corpus/document/EFTA00225378/284 or ?id=EFTA00225378&page=284]", "char_count": 3050}, {"efta_number": "EFTA00225378", "page_number": 285, "text_content": "Gmail - Fw: confidential communication \nPage 2 of 4 \nparagraph, that he cannot conclude that a prosecution by you in this case \"would be an abuse \nof discretion\" is hardly an endorsement that you move forward. \nMoreover, as you know, Drew made clear that the scope of his review did not extend to the \nother significant issues we have raised with you, such as the undo interest by some members of \nyour staff with the financial and civil aspects of this matter, or with the inappropriate discussion \none member of your Office had with a Senior reporter at the New York Times. (In fact, I have \nmet with that reporter and have reviewed copious notes of his conversation with Mr. Weinstein). \nAt this stage, we have no alternative but to raise our serious concerns regarding the issues \nDrew refused to address with the Deputy or, if necessary, the Attorney General, because we \nbelieve those issues have significantly impacted the investigation and any recommendation by \nyour staff to proceed with an indictment. That being said, it would obviously be much more \nconstructive and efficient if we could resolve this matter directly with you in the advance of \nfurther proceedings in Washington. \nBecause it is clear that national policy, as determined by Main Justice, is not driving this case, \nthe resolution of this matter is squarely, and solely, your responsibility. I know you want to do \nthe right thing, and it is because you have made clear to me on several occasions that you will \nalways look at all of the relevant and material fads that I call the following to your attention. \nNew information that has come to light strongly suggests that the facts of this case cannot \npossibly implicate a federal prosecutorial priority. Due to established state procedures and \nfollowing the initiation of multiple civil lawsuits, Mr. Epstein's counsel was able to take limited \ndiscovery of certain women in this matter. The sworn statements provided by these women all \nconfirm that federal prosecut\n... [truncated, 4317 chars — for the full page use /api/corpus/document/EFTA00225378/285 or ?id=EFTA00225378&page=285]", "char_count": 4317}, {"efta_number": "EFTA00225378", "page_number": 286, "text_content": "Gmail - Fw: confidential communication \nPage 1 of 4 \nsil \nAnn Marie Villafana< \nFw: confidential communication \n1 message \nVillafana, Ann Marie C. (USAFLS) < Ann.Marie.C.Villafana@usdoj.gov> \nThu, May 22, 2008 at \n3:38 AM \n \nOriginal Message \nFrom: Acosta, Alex (USAFLS) \nTo: Sloman, Jeff (USAFLS); Campos, Cyndee (USAFLS); Villafana, Ann Marie C. (USAFLS) \nSent: Mon May 19 12:40:32 2008 \nSubject: FW: confidential communication \nFor your records. \nFrom: Jay Lefkowitz [mailto:JLefkowitz@kirkland.com] \nSent: Monday, May 19, 2008 10:54 AM \nTo: Acosta, Alex (USAFLS) \nSubject: confidential communication \nDear Alex: \nI am writing to you because I have just received the attached letter from Drew Oosterbaan. In \nlight of that letter, and given the critical new evidence discussed below, I would like to request a \nmeeting with you, mindful of our July 8 deadline, at your earliest opportunity. Given your \npersonal involvement in this matter to date, and the fact that at this juncture it is clear that \nCEOS has referred the matter back to you, I respectfully request that you not shunt me off to \none of your staff. You and I have both spent a great deal of time on this matter, and I know that \nwe both would like to resolve this matter in a way that bestows integrity both on the Department \nand the process. \nIn our prior discussions, you expressed that you were \"not unsympathetic\" to our various \nfederalism concerns, but stated that because you serve within the \"unitary Executive,\" you.\nbelieved your hands were tied by Main Justice. You were also extremely gracious in stating that \nyou did not want the United States to be \"unfair\". Although CEOS limited its assessment to the \nfederal statutes your Office had brought forth and to the application of th6se laws to the facts as \npresented, it is abundantly clear from Drew's letter that Main Justice is not directing this \nprosecution. In fact, CEOS plainly acknowledged that a federal prosecution of Mr. Epstein \nwould involve a \"novel ap\n... [truncated, 2183 chars — for the full page use /api/corpus/document/EFTA00225378/286 or ?id=EFTA00225378&page=286]", "char_count": 2183}, {"efta_number": "EFTA00225378", "page_number": 287, "text_content": "JAY P. LEFKOWITZ, ESQ. \nMay 19, 2008 \nPAGE 6 OF 6 \nConclusion \nOn February 25, 2008,1 sent you an e-mail setting forth a timetable for moving forward in \nthe event that CEOS disagreed with your position. That time is now. As you know, my February 25' \nemail stated that I would give you one week to comply with the terms and conditions of the \nAgreement, as modified by the USA's December Irletter to Ms. Sanchez. In light of the upcoming \nMemorial Day weekend, I have decided to extend that timetable to the close of business on Monday, \nJune 2, 2008, which is a full two weeks. \nSincerely, \nR. Alexander Acosta \nUnited States Attorney \nBy: \nJeffrey H. Sloman \nFirst Assistant United States Attorney \ncc: \nR. Alexander Acosta \nUnited States Attorney \nA. Marie Villafana \nAssistant U.S. Attorney \nKaren Atkinson \nAssistant U.S. Attorney \nEFTA00225665\n", "char_count": 851}, {"efta_number": "EFTA00225378", "page_number": 288, "text_content": "JAY P. LEFKOWITZ, ESQ. \nMay 19, 2008 \nPAGE 5 OF 6 \nC. \n\"Mr. Epstein Does Not Believe He Is Guilty Of The Federal Charges Enumerated \nUnder Section 2255.\" \nAt our December 14, 2007 meeting at the U.S. Attorney's Office in Miami, counsel for \nEpstein announced, inter alia, that it was a \"profound injustice\" to require Epstein to register as a \nsex offender and reiterated that no federal crime, especially 18 U.S.C. Section 2422(6), had been \ncommitted since the statute is only violated if a telephone or means of interstate commerce is used \nto do the persuading or inducing. This particular attack on this statute had been previously raised and \nthoroughly considered and rejected by the SDFL and CEOS prior to the execution of the Agreement. \nYou also argued that the facts were inapplicable to the contemplated state statutes and that Epstein \nshould not have been allowed to have been induced into the Agreement because the facts were not \nwhat he understood them to be, It should be noted that the SDFL has never provided you with any \nevidence supportig its investigation. This is not, and has never been, an Alford plea situation (see \nNorth Carolina \nAlford, 400 U.S. 25, 91 S.Ct. 160 (1970)). Ultimately, you requested an \nindependent review. \nSubsequent to the above-mentioned meeting, the SDFL received three letters from you and/or \nMr. Starr which expanded on some of the themes announced in the December 14th meeting. \nEssentially, you portrayed the SDFL as trying to coerce a plea to unknown allegations and incoherent \ntheories. On December 17, 2007, you decreed that Epstein's conduct did not meet the requirements \nof solicitation of minors to engage in prostitution (Fl. Stat. Section 796.03) one of the enumerated \ncrimes Epstein had previously agreed to plead guilty to; that Epstein's conduct does not require \nregistration under Florida law; and the State Attorney's Office does not believe the conduct is \nregistrable. On December 21, 2007, you rejected the USA's proposed r\n... [truncated, 3077 chars — for the full page use /api/corpus/document/EFTA00225378/288 or ?id=EFTA00225378&page=288]", "char_count": 3077}, {"efta_number": "EFTA00225378", "page_number": 289, "text_content": "JAY P. LEFKOWITZ, ESQ. \nMay 19, 2008 \nPAGE 4 OF 6 \nB. \nMethod of Compensation and Notification. \nDuring this same time period, you and others, including the former Solicitor General of the \nUnited States Kenneth Starr, took issue with the implementation of the methodology of \ncompensation (hereinafter \"the 2255 provision\")) and the SDFL's intention to notify the victims \nunder 18 U.S.C. Section 3771 (you objected to victims being notified of time and place of Epstein's \nstate court sentencing hearing). In response, the SDFL offered, in my opinion, numerous and various \nreasonable modifications and accommodations which ultimately resulted in United States Attorney \nIL Alexander Acosta's December 19, 2007 letter to Lilly Ann Sanchez. In that letter, the United \nStates Attorney tried to eliminate all concerns which, quite frankly, the SDFL was not obligated to \naddress, let alone consider. He proposed the following language regarding the 2255 provision: \nC \n\"Any person, who while a minor, was a victim of a violation of an offense enumerated in \nTitle 18, United States Code, Section 2255, will have the same rights to proceed under \nSection 2255 as she would have had, if Mr. Epstein been tried federally and convicted of an \nenumerated offense. For purposes of implementing this paragraph, the United States shall \nprovide Mr. Epstein's attorneys with a list of individuals whom it was prepared to name in \nan Indictment as victims of an enumerated offense by Mr. Epstein. Any judicial authority \ninterpreting this provision, including any authority determining which evidentiary burdens \nif any a plaintiff must meet, shall consider that it is the intent of the parties to place these \nidentified victims in the same position as they would have been had Mr. Epstein been \nconvicted at trial. No more; no less.\" \nRegarding the issue of notice to the victims, USA Acosta proposed to notify them of the \nfederal resolution as required by law; however, \"[w]e will defer to the discretion o\n... [truncated, 2996 chars — for the full page use /api/corpus/document/EFTA00225378/289 or ?id=EFTA00225378&page=289]", "char_count": 2996}, {"efta_number": "EFTA00225378", "page_number": 290, "text_content": "JAY P. LEFKOWITZ, ESQ. \nMay 19, 2008 \nPAGE 3 OF 6 \nof the guilty plea and sentence no later than October 26, 2007; and (5) the start of the above-\nmentioned sentence no later than January 4, 2008. \nFurthermore, and significantly, Epstein agreed that he had the burden of ensuring compliance \nof the Agreement with the Palm Beach County State Attorney's Office and the Judge of the 15*\nJudicial Circuit and \"that the failure to do so will be a breach of the agreement\" (emphasis added). \nPost-Execution of the Agreement \nWithin weeks of the execution of the Agreement, you sought to delay the entry of Epstein's \nguilty plea and sentence. After the SDFL agreed to accommodate your request, counsel for Epstein \nbegan taking issue with the methodology of compensation, notification to the victims, and the issues \nthat had been previously considered and 'ejected during negotiations, i.e., that the conduct does not \nrequire registration and the contemplated state and federal statutes have no applicability to the instant \nmatter. \nA. \nDelay. \nThe Agreement required that \"Epstein shall use his best efforts to enter his guilty plea and \nbe sentenced not later than October 26, 2007. The United States has no objection to Epstein self-\nreporting to begin serving his sentence not later than January 4, 2008.\" Agreement, pages 4-5, \nparagraph I 1 (emphasis added). After the Agreement was executed, the SDFL accommodated your \nrequest to extend the October 26th plea deadline to November 20'° based upon, what seemed to be, \nreasonable scheduling conflict issues.' By early November, you represented that the presiding state \ncourt judge would not \"stagger the plea and sentencing as contemplated in the Agreement.\"Although \nthe Agreement clearly did not contemplate a staggered \"plea and sentencing,\" the SDFL again agreed \nto accommodate Epstein's request to appear in state court for plea and sentencing on January 4, \n2008.2\nI \"Accordingly, I have now confirmed with Mr. Epstein's Florida counsel t\n... [truncated, 2625 chars — for the full page use /api/corpus/document/EFTA00225378/290 or ?id=EFTA00225378&page=290]", "char_count": 2625}, {"efta_number": "EFTA00225378", "page_number": 291, "text_content": "JAY P. LEFKOWITZ, ESQ. \nMay 19, 2008 \nPAGE 2 OF 6 \nBackground \nThe Agreement was the product of months of negotiations. Specifically, you requested and \nreceived numerous meetings, at the highest levels of the SDFL and DOJ's Child Exploitation and \nObscenity Section (CEOS) concerning claims that (a) the investigation merely produced evidence \nof relatively innocuous sexual conduct with some minors who, unbeknownst to Epstein, \nmisrepresented their ages; (b) the authorities investigating Epstein engaged in misconduct; (c) the \ncontemplated federal statutes have no applicability to this matter; and (d) the federal authorities \ndisregarded the fundamental policy against federal intervention with state criminal proceedings. \nAfter careful review, the SDFL ultimately rejected those claims. Subsequent to its decision, however, \nbut before proceeding any further, the SDFL provided you with 30 days to appeal the decision to the \nAssistant Attorney General of the United States, Alice Fisher. As you recall, you chose to forego an \nappeal to AAG Fisher, and instead pursued a negotiated resolution which, ultimately, resulted in the \nexecution of the Agreement. \nThe Negotiation Phase \nDuring negotiations, you tried to avoid a resolution that called for incarceration and \nregistration as a sexual offender — both of which would be triggered by a successful federal \nprosecution. The SDFL believed and continues to believe that should this matter proceed to trial, \nyour client would be convicted of the federal statutes identified in the Agreement. In order to achieve \na global resolution, the SDFL indicated a willingness to defer to the State the length of incarceration; \nhowever, it remained adamant that Epstein register as a sex offender and that all victims identified \nduring the investigation remain eligible for compensation. In order to achieve this result, the parties \nconsidered two alternatives, a plea to federal charges that limited Epstein's sentencing exposure, or, \nas sug\n... [truncated, 3251 chars — for the full page use /api/corpus/document/EFTA00225378/291 or ?id=EFTA00225378&page=291]", "char_count": 3251}, {"efta_number": "EFTA00225378", "page_number": 292, "text_content": "U.S. Department of Justice \nUnited States Attorney \nSouthern District of Florida \nFern Assistant U.S. Attorney \nDELIVERY BY FACSIMILE \nJay P. Lefkowitz, Esq. \nKirkland & Ellis LLP \nCitigroup Center \n153 East 53rd Street \nNew York, New York 10022-4675 \nRe: \nJeffrey Epstein \nDear Mr. Lefkowitz, \n99 N.E. 4 Street \nMiami. FL 33132 \nOn 961.9110 \nMay 19, 2008 \nI am in receipt of your e-mail dated May 19, 2008 to the United States Attorney. The U.S. \nAttorney would like me to advise you that all communications and inquiries related to the Epstein \nmatter, will be handled by AUSA Marie Villafana and/or her supervisor, Karen Atkinson, so he does \nnot intend to respond to your e-mail or calls unless AUSA Villafana and/or her supervisors advise \nhim otherwise. Furthermore, you make reference to \"our July 8 deadline.\" Respectfully, the United \nStates Attorney's Office for the Southern District of Florida (\"SDFL\") has never agreed to any such \ndeadline. Should you decide to provide the SDFL with any additional information, please do so \nthrough AUSA Villafana, and, in her absence, AUSA Atkinson. \nOn September 24, 2007, your client, Jeffrey Epstein, in consultation with Gerald Lefcoun, \nEsq. and Lilly Ann Sanchez, Esq., as well as numerous other nationally-renowned lawyers, including \nbut not limited to Harvard Law Professor Alan Dershowitz, former Independent Counsel and \nSolicitor General of the United States Kenneth Starr, just to name a few, entered into a global \nresolution of state and federal liabilities faced by your client (\"the Agreement\") with the SDFL. \nAlthough you and other members of the defense team have since claimed that the Agreement was \nthe product of adhesion, the following facts demonstrate that Epstein knowingly and voluntarily \nentered into the Agreement in order to avoid a federal indictment regarding his sexual conduct \ninvolving minor victims. Despite the fact that by signing the Agreement, Epstein gave up the right \nto object to its provisions, the SD\n... [truncated, 2578 chars — for the full page use /api/corpus/document/EFTA00225378/292 or ?id=EFTA00225378&page=292]", "char_count": 2578}, {"efta_number": "EFTA00225378", "page_number": 293, "text_content": "05/19/08 MON 15:50 FAX 305 530 6440 \nEXECUTIVE OFFICE \nIiM001 \nTRANSMISSION OK \n********smss******* \n*s* \nTX REPORT \n*as \n4444441:4444********** \nTX/RX NO \n3494 \nCONNECTION TEL \n912124464900 \nSUBADDRESS \nCONNECTION ID \nST. TIME \n05/19 15:47 \nUSAGE T \n03'03 \nPGS. \n7 \nRESULT \nOK \nU.S. Department of Justice \nUnited Stoles Attorney \nSouthern District of Florida \nUNITED STATES ATTORNEY'S OFFICE \nSOUTHERN DISTRICT OF FLORIDA \n99 NE 4\" STREET \nMIAMI, FLORIDA 33132-2111 \nJeffrey H. Sloman \nFirst Assistant U.S. Attorney \n305 961 9299 \nCyndee Campos \nStaff Assistant \n305 961 9461 \n305 530-6444 fax \nFACSIMILE TRANSMISSION \nCOVER SHEET \nDATE: \nMay 19, 2008 \nTO: \nJay P. Lefkowitz, Esquire \nFAX NUMBER: \nSUBJECT: \nEpstein \nNUMBER OF PAGES, INCLUDING THIS PAGE: 7 \nEFTA00225671\n", "char_count": 772}]}