EFTA00224943 is a fifty-one-page table headed “EPSTEIN INVESTIGATION TIMELINE,” Bates-stamped EFTA00224943 to EFTA00224993 in Data Set 9.12 It is ruled into five columns (Date, To, From, “Re:” and “Exhibit #”). Five of its pages were read at the image (pp. 1, 2, 41, 50 and 51), and each carries the same three-part footer: “Privileged Confidential” at the left, “Page N of 51” at the centre, “Contains 6(e) Material” at the right.13452 The machine text of all fifty-one pages was then searched for that footer: all fifty-one carry the left legend, forty-eight carry the centre legend in the exact form “Page N of 51”, and all fifty-one carry a right-hand legend in the same footer slot, its characters damaged by the extraction on most of them.6 The same fifty-one pages were searched for “EXHIBIT A-1” and for the “EXHIBIT A-I” form the extraction produces; the string occurs on page 1, printed beneath the right-hand legend, and on no other page of the run.61 The earliest entry is dated 5/1/2006 and the latest 8/24/2011.12

It is a compiled chronology, not a record of events. Somebody built it, from a file, for a purpose, and decided what to enter and what to leave out. The exhibit itself says none of those things. No page of the fifty-one names an author, a compiler, a recipient, a proceeding or a date of compilation; the run opens on “Page 1 of 51” with the table already running and closes on “Page 51 of 51” with a single row and no signature block, certification or colophon.12 Everything this page states about who made it and why is established from other documents in the same production, and is identified as such below.

What the exhibit set identifies it as

The chronology is the first exhibit to the written response that Assistant United States Attorney A. Marie Villafaña made to the Department of Justice’s Office of Professional Responsibility in 2019.

That set has an index. It is a ten-page table headed “EXHIBITS TO WRITTEN RESPONSE OF A. MARIE VILLAFAÑA,” in Exhibit # / Date / Description columns, carrying its own footer: “PRIVILEGED and CONFIDENTIAL,” “Page N of 10,” “CONTAINS 6(e) MATERIAL.”78 Its numbered series runs from 1 to 91; then, alone between two solid black separator bars, in a section containing nothing else, comes a single row: “A-1”, no date, description “Timeline of Events.”9 Below the second bar the B-series begins at B-1 and runs to B-135, followed by a C-series.98 A-1 is a set of one.

The response was transmitted on May 10, 2019, and its exhibits went separately. A letter of that date on Baker Donelson letterhead, carrying the printed name and direct dial of Jonathan Biran, is addressed, under the subject line “Re: OPR Investigation Relating to Jeffrey Epstein Federal Criminal Investigation,” to Ms. Ingersoll at the U.S. Department of Justice, 950 Pennsylvania Avenue, N.W., Room 3266 — the Office of Professional Responsibility’s own address. Her name is blacked out in the address block, under a bar two text lines deep, and printed in the clear in the salutation five lines below it; the letter gives no forename.10 It opens: “Attached please find the written response of Assistant United States Attorney [redacted] to the letter of Jeffrey R. Ragsdale, dated April 2, 2019, regarding the criminal investigation of Jeffrey Epstein. [redacted] separately has sent you encrypted disks containing the exhibits referenced in her written response, and has emailed other exhibits that were not included on the disks.”10 The response itself is headed “STATEMENT OF [redacted] IN RESPONSE TO APRIL 2, 2019 LETTER FROM JEFFREY R. RAGSDALE,” runs to fifty-eight pages, and begins: “To the extent possible, I have provided all information relevant to your inquiry, including applicable documents.”11 Its author writes that she “organized the response to conform with the April 2, 2019 letter.”11 The index labels exhibit B-1 “Chart addressing Question B.2,” which is the one place the lettered series is expressly tied to a question in Ragsdale’s letter; this page does not extend that mapping to the A-series, which the index does not describe.9

The authority under which grand-jury material could be put in front of the subject attorney’s private counsel is a court order in the same production. On May 31, 2019, in FGJ 07-103 (WPB), U.S. District Judge Donald M. Middlebrooks entered a “SEALED ORDER GRANTING APPLICATION FOR PERMISSION TO DISCLOSE GRAND JURY MATERIAL,” finding that disclosure was sought “in connection with an administrative proceeding conducted by the Justice Department’s Office of Professional Responsibility (OPR) arising out of a decision by United States District Judge Kenneth A. Marra,” the case name that follows being blacked out, and that “the need for disclosure is greater than the need for continued secrecy.”12 The operative page authorises the U.S. Attorney’s Office for the Southern District of Florida and OPR to disclose “to attorney Jonathan Biran matters occurring before the grand jury” necessary to let the Assistant U.S. Attorney answer OPR’s written questions, prepare for its interview of her, and take part in it, and enters the order nunc pro tunc to cover the “May 10, 2019 Response to OPR’s written questions.”13 An accompanying protective order of the same date governs what may be held. Its second numbered paragraph, which runs from the foot of the order’s first page onto its second, is blacked out at every personal name on the image: “The government and [black box]hall make efforts to minimize the amount of grand jury material produced to or maintained b[black box]hall not be given copies of subpoenas, documents produced in response to subpoenas, transcripts, proposed or completed indictments, prosecution memoranda, or items prepared for use in front of the grand jury, but these items may be shown to [black box]d discussed in preparation sessions and during interviews.”14

Two things about that order are worth stating plainly. It was entered three weeks after the response and its exhibits went to OPR, which is what the nunc pro tunc language cures.1310 And it does not explain the shape of the chronology: the exhibit set includes subpoenas and grand-jury transcripts as exhibits in their own right. The index lists “Subpoenas to [black box] and research re 6001 immunity” at 15, and eight separate “Transcript of [black box] Testimony” entries between 17 and 29. A ninth transcript entry, at 22, reads “Transcript of #37 Testimony,” which is a numeric designation and not a redaction. So the categories the protective order withheld from counsel are not the categories the timeline leaves undocumented.7 On the evidence of the index, then, the protective order does not account for the blank column. What does account for it, this page does not establish.

The fifth column is a concordance, and most of it is empty

The “Exhibit #” column is not decoration. Its values key to the index of the response’s exhibit set, and every value this page checked matches.

On the first page the 5/1/2006 row, “Letter urging State Attorney to proceed with probable cause affidavits and case filing packages or to recuse himself,” from Michael S. Reiter, Chief of Police for Town of Palm Beach, to State Attorney Barry E. Krischer, carries a 1; index exhibit 1 is “Letter from [redacted]” dated 5/1/2006.17 The 5/23/2006 row, “File Opening Documents for Operation Leap Year,” carries a 2; index exhibit 2 is “File Opening Documents,” 5/23/2006.17 The 7/26/2006 row, “South Florida Sun-Sentinel Article Regarding Chief Reiter’s referral of case to FBI,” carries a 7; index exhibit 7, 7/26/2006, reads “South Florida Sun-Sentinel Article Regarding [redacted] referral of case to FBI.”17 On the second page the 9/26/2006 memo row carries a 16 against index exhibit 16, “Memo regarding Changes to Child Exploitation Statutes in Title 18,” 9/26/2006; the 8/24/2006 and 10/24/2006 rows both carry a 9, against a single index entry 9 spanning 8/24/2006–10/24/2006.37 Page 41 shows the concordance reaching the lettered series: three of its rows carry B-69, B-70 and B-71.4

Most rows carry nothing. Across the four pages of this exhibit counted at the image, pp. 1, 2, 41 and 51, 52 rows carry a date and a description; 15 carry a value in the Exhibit # column and 37 are blank.1342 A fifth page was read at the image and is not in that total: page 50 carries fifteen dated rows and no value in the Exhibit # column at all.5 This page did not count the rows of the remaining forty-six pages, and does not extrapolate. What the counted pages show is that the compiler entered events into the chronology that she did not put paper behind in the response. On page 1 the unnumbered rows are the ten grand-jury subpoenas of 8/2/2006 (Colonial Bank, Washington Mutual, Capital One, Chase, Hyperion Air, JEGE, David Neville Rodgers, DTG Operations d/b/a Dollar Rent-a-car, Royal Palm Beach Community High School and the Custodian of Records of the 15th Judicial District), together with a further subpoena of 8/15/2006 whose recipient is blacked out.1 On page 41, thirteen of sixteen rows are unnumbered, including the 7/22/2008 row that records the office’s internal exchange over Michael Tein’s announced plan to stay the civil suits, an exchange separately documented on the July 22, 2008 notice of breach page.4

Why most rows carry no exhibit number, the documents do not settle. The response’s own opening offers one explanation, and it is not an editorial one: “Due to the passage of time, updates to various software and hardware, and the crash of my work laptop several years ago, I no longer have every piece of relevant material and my memory may be imperfect.”11 Whether that accounts for the whole of the blank column, or whether entries were left unnumbered for other reasons as well, four counted pages cannot show. What they do show is that the chronology and the exhibit set are not the same document: the chronology is the map, and the numbered column marks which parts of the map the response put paper behind.

The same exhibit, produced twice, redacted to two standards

The chronology appears twice in this release. It is produced standalone as EFTA00224943, and again, page for page, inside the 294-page compilation EFTA00225378, where its fifty-one pages occupy printed pages 51 to 101, the first of them Bates-stamped EFTA00225428 and the forty-first EFTA00225468.1516 The text layers of the two runs agree page by page within ordinary extraction noise.

The redactions do not agree. Compared at 400 dpi, page for page:

On page 1 of 51, the standalone copy prints the 5/1/2006 row’s correspondents in the clear, “State Attorney Barry E. Krischer” under To and “Michael S. Reiter, Chief of Police for Town of Palm Beach” under From, and prints “Chief Reiter’s referral of case to FBI” in the 7/26/2006 row.1 The second copy of the same page blacks out the whole To cell of the 5/1/2006 row, blacks out the officer’s name in the From cell of both the 5/1/2006 and the 7/24/2006 rows leaving only “Police for Town of Palm Beach” standing, and blacks out the name in the 7/26/2006 row, leaving “South Florida Sun-Sentinel Article Regarding [black box] al of case to FBI.”15 The one redaction the two copies share on that page is the 8/15/2006 subpoena recipient.115

On page 41 of 51 the divergence is total. The standalone copy carries no redaction anywhere on the page.4 The second copy carries a single continuous black column down the entire To field, from the 7/21/2008 rows to the 8/5/2008 row, with further boxes through the From and “Re:” columns.16 The 7/22/2008 row that the standalone copy prints as “Emails between A. M. Villafaña, A. Acosta, J. Sloman, R. Senior, K. Atkinson, E. Nesbitt Kuyrkendall, and J. Richards regarding 7/21/2008 letter from M. Tein announcing plan to stay the civil suits against J. Epstein…” survives in the second copy only as “Emails between [black box] Tein announcing plan to stay the civil suits against J. Epstein…”; neither quotation is carried past that point.416

What the second copy leaves standing on that page is as legible as what it removes: “Goldberger,” “Tein,” “Roy Black,” “B. Reinhart,” “R. Black and J. Goldberger” and “Letter from Brad Edwards” are all printed in the clear on the redacted copy, in the same rows and often in the same sentences from which the government correspondents have been struck.16 Eight entries on the second page of the index to the exhibit set take the same shape: a private attorney named in the clear (Gerald Lefcourt, Alan Dershowitz, Roy Black, Lilly Ann Sanchez, Jay Lefkowitz) facing a correspondent blacked out across a “Letter from X to [black box]” or an “Emails between [black box] and X.”17 That page is not uniform, though, and this page does not generalise from the eight: entry 45 on the same page names a government official in the clear, “regarding USA Acosta’s inquiry regarding the state grand jury investigation,” and entry 38 prints “as per Menchel recommendation” in the clear beside a blacked-out sender.17

This page makes no finding about why the two copies differ, and does not know whether they were reviewed by the same hands or at the same time. It records that one exhibit was produced twice under one release, that the two copies apply different redaction standards to the same government officials acting in their official capacities, and that this wiki’s page on document redaction integrity sets out the statutory bar on redaction “on the basis of embarrassment, reputational harm, or political sensitivity, including to any government official, public figure, or foreign dignitary.”

The chronology names what its own exhibits withhold

The pattern is not confined to the two copies of the timeline. In six instances counted below, each verified at the image on both sides, the chronology prints an official’s name in the clear where the exhibit it points to, or the index that lists it, blacks that name out.

Five are in the concordance itself. The timeline’s 7/26/2006 row names Chief Reiter as the subject of the newspaper article; the index entry for the very exhibit that row points to, exhibit 7, blacks the name out of an otherwise identical sentence.17 The same holds for index entries 1 and 6, against the timeline’s 5/1/2006 and 7/24/2006 rows; for index entry 9, “Emails between Jim Eisenberg and [black box],” against the timeline’s 8/24/2006 row, which gives both correspondents; and for index entry 10, “Emails between [black box] and Guy Lewis,” against the timeline’s 10/30/2006 and 10/31/2006 rows, which do the same.137

The sixth reaches an exhibit itself. The timeline’s 9/26/2006 row records a “Memo regarding changes to Child Exploitation Statutes in Title 18,” gives the Exhibit # as 16, names the author in the From column as “Villafaña,” and lists twelve recipients in the To column: Acosta, Mulvihill, Sloman, Noto, Waters, Lourie, Stefin, Atkinson, Garcia, Brown, Boscovich, Martinez.3 The memorandum itself is in the release, stamped “Exhibit 16” at the foot.18 It prints all twelve recipients in the clear, in a Department of Justice memorandum block under the subject “Changes to Child Exploitation Statutes in Title 18” and the date September 26, 2006. Its “From” field is a black box, followed by the standing word “AUSA.” A second black box covers the courtesy-copy line beneath it.18 The chronology supplies the author’s name that its own exhibit withholds.

Six instances are six instances. This page does not generalise from them to a claim about the production. It counted five index entries against two pages of the exhibit, and one exhibit against one row, and it did not audit the remaining forty-six pages of the exhibit or the remaining six pages of the index.

The exhibit is not uniformly unredacted, either. Its final page is a single row, 8/24/2011, recording an email from Richard Sudder to Wilfredo Ferrer (U.S. Attorney, SDFL), Robert O’Neill (U.S. Attorney, MDFL), Benjamin Greenberg (FAUSA, SDFL) and Lee Bentley (FAUSA, MDFL) “regarding Formal Notice of Office-wide Recusal of Southern District of Florida,” copying David Margolis of the Office of the Deputy Attorney General and three named officials of the Executive Office. It carries one redaction, over the forename of a fifth copy recipient whose surname is printed beside it.2 Page 51 gives Sudder no affiliation; the page before it does. The 8/1/2011 row on page 50 reads “Emails between Richard Sudder, Assistant General Counsel, Executive Office for United States Attorneys, and Benjamin Greenberg, First Assistant U.S. Attorney, Southern District of Florida, regarding Formal Notice of Office-wide Recusal of Southern District of Florida dated July 28, August 3, August 24 and August 29, 2011.”5 The 8/24/2011 row is the last the compiler entered, and it is the recusal of the district that ran the investigation. That page-50 row, though, names four recusal notices, the last of them dated August 29, 2011, five days after the chronology stops.

Limits of this page

This page does not name the compiler of EFTA00224943 on the authority of EFTA00224943, because the exhibit is silent as to who made it; it identifies the exhibit set from the index, the transmittal letter, the response and the court order named above, all in the same production. It does not determine when the table was compiled: the exhibit carries no date, its index entry carries no date, and its last entry precedes the response by nearly eight years. It does not identify any redacted individual, and it does not supply, from any other source, a name that the page it cites withholds. Where it reports that two copies of one page, or an index and the exhibit it lists, treat the same name differently, the name in question is in every instance a government official acting in an official capacity, printed in the clear by the producing party on the copy this page cites for it. It reports counts only for the five pages of the exhibit it read at the image and the four pages of the index it read at the image, and does not extend them. It makes no finding about why two copies of one exhibit were redacted differently. It does not treat any entry in the chronology as establishing the event it describes: each row is one office’s later description of a document, and several rows describe documents this page has not read.

Footnotes

  1. EFTA00224943 (Data Set 9), p. 1 of 51, Bates-stamped EFTA00224943: the heading “EPSTEIN INVESTIGATION TIMELINE”; the column rule “Date | To | From | Re: | Exhibit #”; the 5/1/2006 row (To “State Attorney Barry E. Krischer,” From “Michael S. Reiter, Chief of Police for Town of Palm Beach,” Re “Letter urging State Attorney to proceed with probable cause affidavits and case filing packages or to recuse himself,” Exhibit # 1); the 5/23/2006 row (“File Opening Documents for Operation Leap Year,” Exhibit # 2); the 7/24/2006 row (Exhibit # 6); the 7/26/2006 row (“South Florida Sun-Sentinel Article Regarding Chief Reiter’s referral of case to FBI,” Exhibit # 7); the ten 8/2/2006 subpoena rows, all with a blank Exhibit # cell; the 8/4/2006 and 8/11/2006 rows (Exhibit # 12 and 13); the 8/15/2006 row, whose recipient is covered by a black box; and the footer “Privileged Confidential / Page 1 of 51 / Contains 6(e) Material / EXHIBIT A-1.” Seventeen rows, six of them numbered. Read from the page image at 400 dpi. https://epstein-data.com/EFTA00224943 p.1. 2 3 4 5 6 7 8 9 10 11 12 13 14

  2. EFTA00224943, p. 51 of 51, Bates-stamped EFTA00224993: a single row, dated 8/24/2011, To “Wilfredo Ferrer (U.S. Attorney, SDFL), Robert O’Neill (U.S. Attorney, MDFL), Benjamin Greenberg (FAUSA, SDFL), and Lee Bentley (FAUSA, MDFL),” From “Richard Sudder,” Re “Email regarding Formal Notice of Office-wide Recusal of Southern District of Florida. Cc’s David Margolis (ODAG), Jay Macklin (USAEO), Thomas Anderson (USAEO), [black box] Tapken (USAEO), and James Read (USAEO)”; Exhibit # cell blank. Footer “Privileged Confidential / Page 51 of 51 / Contains 6(e) Material.” The single redaction on the page covers a forename. Read from the page image at 400 dpi. https://epstein-data.com/EFTA00224943 p.51. 2 3 4 5 6

  3. EFTA00224943, p. 2 of 51, Bates-stamped EFTA00224944: eighteen rows, six of them numbered (9, 16, 9, 10, 10, 11). The 8/24/2006 row (To “Villafaña,” From “Jim Eisenberg,” Exhibit # 9); the 9/26/2006 row (To “Acosta, Mulvihill, Sloman, Noto, Waters, Lourie, Stefin, Atkinson, Garcia, Brown, Boscovich, Martinez,” From “Villafaña,” Re “Memo regarding changes to Child Explotation Statutes in Title 18” [sic, as printed], Exhibit # 16); the 10/24/2006 row (Exhibit # 9); the 10/30/2006 and 10/31/2006 rows (From “Guy Lewis,” Exhibit # 10); the 11/8/2006 row (Exhibit # 11). No redaction appears on this page. Read from the page image at 400 dpi. The machine text of this page renders the Exhibit # values as stray characters and drops several entirely; they were counted from the image. https://epstein-data.com/EFTA00224943 p.2. 2 3 4 5

  4. EFTA00224943, p. 41 of 51, Bates-stamped EFTA00224983: sixteen rows, three of them numbered (B-69, B-70, B-71); no redaction anywhere on the page. Its 7/22/2008 row reads “Emails between A. M. Villafaña, A. Acosta, J. Sloman, R. Senior, K. Atkinson, E. Nesbitt Kuyrkendall, and J. Richards regarding 7/21/2008 letter from M. Tein announcing plan to stay the civil suits against J. Epstein…”; the row runs on past that point and is not quoted further here. Other rows print “Goldberger,” “Tein,” “Roy Black,” “Lee, Acosta,” “Sloman,” “Kuyrkendall,” “Atkinson” and “Email re: Letter from Brad Edwards.” Read from the page image at 400 dpi. https://epstein-data.com/EFTA00224943 p.41. 2 3 4 5 6

  5. EFTA00224943, p. 50 of 51, Bates-stamped EFTA00224992: fifteen dated rows, none of them carrying a value in the Exhibit # column, and no redaction anywhere on the page. Its last row, dated 8/1/2011, has empty To and From cells and reads “Emails between Richard Sudder, Assistant General Counsel, Executive Office for United States Attorneys, and Benjamin Greenberg, First Assistant U.S. Attorney, Southern District of Florida, regarding Formal Notice of Office-wide Recusal of Southern District of Florida dated July 28, August 3, August 24 and August 29, 2011.” Footer “Privileged Confidential / Page 50 of 51 / Contains 6(e) Material.” Read from the page image at 400 dpi. https://epstein-data.com/EFTA00224943 p.50. 2 3

  6. EFTA00225378, p. 41, Bates-stamped EFTA00225418: “EXHIBITS TO WRITTEN RESPONSE OF A. MARIE VILLAFAÑA,” in Exhibit # / Date / Description columns, footer “PRIVILEGED and CONFIDENTIAL / Page 1 of 10 / CONTAINS 6(e) MATERIAL.” Entries 1 to 32. Entry 1, 5/1/2006, “Letter from [black box]”; entry 2, 5/23/2006, “File Opening Documents”; entry 6, 7/24/2006, “Letter from [black box] to victims informing them of FBI investigation”; entry 7, 7/26/2006, “South Florida Sun-Sentinel Article Regarding [black box] referral of case to FBI”; entry 9, 8/24/2006–10/24/2006, “Emails between Jim Eisenberg and [black box]”; entry 10, 10/30/2006–10/31-2006, “Emails between [black box] and Guy Lewis regarding Lewis’ respresentation of Epstein” [sic]; entry 15, 11/13/06–1/22/07, “Subpoenas to [black box] and research re 6001 immunity”; entry 16, 9/26/2006, “Memo regarding Changes to Child Exploitation Statutes in Title 18”; entries 17, 18, 20, 21, 24, 25, 27 and 29, “Transcript of [black box] Testimony,” and entry 22, “Transcript of #37 Testimony.” Read from the page image at 400 dpi. https://epstein-data.com/EFTA00225378 p.41. 2 3 4 5 6 7 8

  7. EFTA00225378, p. 50, Bates-stamped EFTA00225427: the same index, “Page 10 of 10,” running B-125 to B-135, then a separator bar, then C-1 to C-7. Read from the page image at 400 dpi. https://epstein-data.com/EFTA00225378 p.50. 2

  8. EFTA00225378, p. 44, Bates-stamped EFTA00225421: the same index, “Page 4 of 10,” entries 79 to 91, then a solid black separator bar, then a single row “A-1” with an empty Date cell and the description “Timeline of Events,” then a second separator bar, then “B-1 | Chart addressing Question B.2” and the B-series continuing B-2 to B-13. Read from the page image at 400 dpi. https://epstein-data.com/EFTA00225378 p.44. 2 3

  9. EFTA00225378, p. 164, Bates-stamped EFTA00225541: letter on Baker Donelson letterhead, “JONATHAN BIRAN,” dated May 10, 2019, marked “VIA EMAIL ONLY,” addressed to a recipient whose name is covered by a black box above “U.S. Department of Justice / 950 Pennsylvania Avenue, N.W. – Room 3266 / Washington, D.C. 20530,” under “Re: OPR Investigation Relating to Jeffrey Epstein Federal Criminal Investigation.” The black box covers the addressee’s name in the address block only: the salutation printed below the subject line reads “Dear Ms. Ingersoll:” in the clear. The desk rendered this page and ruled that the addressee, receiving a subject attorney’s written response at the Office of Professional Responsibility’s own address in the course of that office’s inquiry, is a government official acting in an official capacity; her surname is therefore given as the letter prints it, and no forename is supplied because the letter gives none. Quoted sentences as in the text, with black boxes marked [redacted]. Read from the page image at 400 dpi. https://epstein-data.com/EFTA00225378 p.164. 2 3

  10. EFTA00225378, p. 106, Bates-stamped EFTA00225483: “STATEMENT OF [black box] IN RESPONSE TO APRIL 2, 2019 LETTER FROM JEFFREY R. RAGSDALE,” footer “Page 1 of 58.” Opening paragraph: “To the extent possible, I have provided all information relevant to your inquiry, including applicable documents. Due to the passage of time, updates to various software and hardware, and the crash of my work laptop several years ago, I no longer have every piece of relevant material and my memory may be imperfect. I have organized the response to conform with the April 2, 2019 letter from Jeffrey R. Ragsdale to [black box].” Its first footnote states: “With regard to the exhibits, whenever possible, I have used copies of original documents or ‘scanned’ originals that were made at the time… The fact that something does not contain a signature does not mean that it is a draft, it just means that it was printed from the electronic version and I no longer have (or never had) a copy of the original.” Read from the page image at 400 dpi. https://epstein-data.com/EFTA00225378 p.106. 2 3

  11. EFTA00225378, p. 102, Bates-stamped EFTA00225479: “UNITED STATES DISTRICT COURT / SOUTHERN DISTRICT OF FLORIDA / FGJ 07-103(WPB) / U.S. District Judge Donald M. Middlebrooks / IN RE: GRAND JURY PROCEEDINGS / SEALED ORDER GRANTING APPLICATION FOR PERMISSION TO DISCLOSE GRAND JURY MATERIAL,” findings (1) to (5), including that disclosure is “in connection with an administrative proceeding conducted by the Justice Department’s Office of Professional Responsibility (OPR) arising out of a decision by United States District Judge Kenneth A. Marra in the matter of” — the case name following is covered by two black boxes — and that “the need for disclosure is greater than the need for continued secrecy.” Read from the page image at 400 dpi. https://epstein-data.com/EFTA00225378 p.102.

  12. EFTA00225378, p. 103, Bates-stamped EFTA00225480: page 2 of the same order. “Accordingly, the United States Attorney’s Office for the Southern District of Florida, including Assistant United States Attorney A. [black box] and the Justice Department’s Office of Professional Responsibility may disclose to attorney Jonathan Biran matters occurring before the grand jury necessary to: (a) allow [black box] to respond to OPR’s written questions; (b) prepare for OPR’s interview of [black box] and (c) participate fully in OPR’s interview of [black box].” And: “To the extent that [black box] May 10, 2019 Response to OPR’s written questions and any drafts thereof disclosed any material that arguably referred to matters occurring before the grand jury, this Order is entered nunc pro tunc to authorize those disclosures to Mr. Biran.” Dated “this 31st day of May, 2019” over the printed name DONALD M. MIDDLEBROOKS, UNITED STATES DISTRICT JUDGE, with a clerk’s certification stamp dated 5/31/19. The Assistant U.S. Attorney’s surname is blacked out at every occurrence on this page. Read from the page image at 400 dpi. https://epstein-data.com/EFTA00225378 p.103. 2

  13. EFTA00225378, p. 104, Bates-stamped EFTA00225481, and p. 105, Bates-stamped EFTA00225482: “SEALED PROTECTIVE ORDER,” in FGJ 07-103(WPB) before U.S. District Judge Donald M. Middlebrooks, the two pages footed “Page 1 of 2” and “Page 2 of 2.” Numbered paragraph 2 begins on the first page and ends on the second, and every personal name in it is covered by a black box on the image: “The government and [black box]hall make efforts to minimize the amount of grand jury material produced to or maintained b[black box]hall not be given copies of subpoenas, documents produced in response to subpoenas, transcripts, proposed or completed indictments, prosecution memoranda, or items prepared for use in front of the grand jury, but these items may be shown to [black box]d discussed in preparation sessions and during interviews.” The stub letters left standing at the edges of the boxes are transcribed here as they print. Paragraph 1, on the first page, authorises the government “nunc pro tunc to produce to attorney Jonathan Biran of Baker Donelson grand jury material relevant to his representation of Assistant U.S. Attorney A. [black box]at is necessary to: (a) allow [black box] to respond to OPR’s written questions; (b) prepare for OPR’s interview of [black box]nd (c) participate fully in OPR’s interview o[black box]”. Paragraphs 3 to 6 on the second page carry five further black boxes over personal names. The second page is dated “this 31st day of May, 2019, at West Palm Beach, Florida,” carries a handwritten mark on the signature rule above the printed name DONALD M. MIDDLEBROOKS, UNITED STATES DISTRICT JUDGE, and carries a clerk’s certification stamp, “Certified to be a true and correct copy of the document on file, Angela E. Noble, Clerk, U.S. District Court, Southern District of Florida,” dated 5/31/19; the acknowledgement line beneath it, “I certify that I have read and agree to be bound by the terms of this Protective Order,” has an empty date and a black box over the name rule. Both pages read from the page image at 400 dpi. https://epstein-data.com/EFTA00225378 p.104, p.105.

  14. EFTA00225378 (Data Set 9), p. 51, Bates-stamped EFTA00225428: the same page of the same exhibit — heading “EPSTEIN INVESTIGATION TIMELINE,” footer “Privileged Confidential / Page 1 of 51 / Contains 6(e) Material / EXHIBIT A-1” — with black boxes over the To cell of the 5/1/2006 row, over the correspondent’s name in the From cells of the 5/1/2006 and 7/24/2006 rows (leaving “Police for Town of Palm Beach” and, on the second, two stub letters visible), and over the name in the 7/26/2006 row, which reads “South Florida Sun-Sentinel Article Regarding [black box] al of case to FBI.” The 8/15/2006 subpoena recipient is redacted here as in the standalone copy. Read from the page image at 400 dpi. https://epstein-data.com/EFTA00225378 p.51. 2 3

  15. EFTA00225378, p. 91, Bates-stamped EFTA00225468: the same page of the same exhibit, footer “Privileged Confidential / Page 41 of 51 / Contains 6(e) Material,” carrying a continuous black column down the whole To field from the 7/21/2008 rows through the 8/1/2008 row and a further block over the 8/2/2008 and 8/5/2008 To cells, with additional boxes in the From and “Re:” columns. Its 7/22/2008 row reads “Emails between [black box] Tein announcing plan to stay the civil suits against J. Epstein…”; the row runs on past that point and is not quoted further here. Left in the clear on this page: “Goldberger” (twice), “Tein,” “Roy Black,” “Brad Edwards,” “R. Black and J. Goldberger,” “B. Reinhart,” and the exhibit numbers B-69, B-70 and B-71. Read from the page image at 400 dpi. https://epstein-data.com/EFTA00225378 p.91. 2 3 4

  16. EFTA00225378, p. 42, Bates-stamped EFTA00225419: the same index, “Page 2 of 10,” entries 33 to 51. Eight entries pair a named private attorney with a redacted correspondent: 33 and 35, “Letter from Gerald Lefcourt and Alan Dershowitz to [black box]”; 34, “Letter from Roy Black to [black box]”; 40, “Letter from Lilly Ann Sanchez to [black box]”; 41, “Letter from [black box] to Lilly Ann Sanchez”; 47, “Emails from [black box] to Gerald Lefcourt”; 49 and 51, “Emails between [black box] and Jay Lefkowitz.” Not every name on the page falls that way: entry 45 reads “Emails between[black box] [black box]egarding USA Acosta’s inquiry regarding the state grand jury investigation,” and entry 38 reads “Email from[black box] summarizing proposed plea terms as per Menchel recommendation.” Read from the page image at 400 dpi. https://epstein-data.com/EFTA00225378 p.42. 2

  17. EFTA00226396 (Data Set 9), p. 29, Bates-stamped EFTA00226424: a Department of Justice “Memorandum” form, Subject “Changes to Child Exploitation Statutes in Title 18,” Date September 26, 2006, To “R. Alexander Acosta / Thomas Mulvihill / Jeffrey Sloman / Kenneth Noto / Robert Waters / Andrew Lourie / Roger Stefin / Karen Atkinson / Rolando Garcia / Bruce Brown / Richard Boscovich / Barbara Martinez,” all twelve printed in the clear. The “From” field is a black box followed by the printed word “AUSA”; a second black box covers the “cc:” line beneath it. The foot of the page carries the mark “Exhibit 16.” Body opens: “On July 27, 2006, Congress enacted the Adam Walsh Child Protection and Safety Act of 2006.” Read from the page image at 400 dpi. https://epstein-data.com/EFTA00226396 p.29. 2