rom: Sent: To: Subject: RE: Epstein Thanks. ants you and Si in on the conference call, too, which means that we can't do the call until August 20th -- after the deadline we have already set. I don't know if I should say something or just wait patiently. What do you think? The agents and I were planning to go to New York on the 20th to track down the assistants and talk to other folks. Tracking: 10 EFTA00179797 Recipient Read Lour*. Andrew (USAFLS) Read: 817/2007 4:06 PM 11 EFTA00179798 From: A. Salter [mailto:acsalter@tds.com] Sent: Friday, May 18, 2007 2:33 PM To: Villafana, Ann Marie C. (USAFLS) Subject: RE: Possible Retainer for a Federal Criminal Investigation/Prosecution Hi, I just faxed over a signed contract. However, I'm not sure what kind of consultation you are looking for, but generally if there are a lot of records, it takes more than 6 hours to read and report on them. In any case, I'm happy to set up a phone conference to get started. Is there anything you want to send me first in terms of records, or are there questions that you have that you are hoping I can speak to? Next week I am gone Tuesday and Wednesday but here the other days. Anna Salter From: Villafana, Ann Marie C. (USAFLS) [mailto:Ann.Marle.C.Villarana@usdoj.goid Sent: Friday, May 18, 2007 1:00 PM To: acsalter@annasaiter.com Subject: FW: Possible Retainer for a Federal Criminal Investigation/Prosecution Hi Dr. Salter: After a lot of paperwork, my office has finally gotten the procurement for you to serve as a consultant on my case. I understand that the contract was sent to you and I wondered if you had received it, As I mentioned. the case is not yet indicted, so there is no firm timeline in place. The FBI Agents and I would like to consult with you prior to the final presentation to the grand jury so that we can include some of your information as part of that presentation. Can you let me know about the contract and also when you might be available for a telephone conference? Perhaps we could do a short one to go over the background of the case and then I could send you some materials that we could discuss during a longer conference. Thank you Ibr your assistance. A. Marie Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach. FL 33401 Phone 561 209-1047 Fax 561 820-8777 From: A, Salter imallto:acsalter@tds.coril Sent: Wednesday, April 18, 2007 8:27 AM To: Villafana, Ann Marie C. (USAFLS) Subject: RE: Possible Retainer for a Federal Criminal Investigation/Prosecution Hi, These are all things 1 could testify about, Can you tell me the time-line? I charge $250/hour for everything: reading records, testifying, etc. For traveling I charge from the time I leave the house until I arrive at the hotel, and then again the next day from the time I leave the hotel until I return to the hotel or to my home. I don't ask for a retainer. If that's acceptable, please give me a call at 608-238.8223 at your convenience. Anna Salter 164 EFTA00179799 PS That email address is having trouble, Please send emails to acsalter@tds.net. From: Villafana, Ann Marie C. (USAF'S) (mailto:Ann.Marle.C.Villafana@usdoj.gov] Sent: Monday, April 16, 2007 10:50 AM To: acsalter@annasalter.com Subject: Possible Retainer for a Federal Criminal Investigation/Prosecution Dear Dr. Salter: I am a federal prosecutor in West Palm Beach, Florida, and the District-wide coordinator of child exploitation cases for the U.S. Attorneys Office for the Southern District of Florida. I have been reviewing your book Predators: Pedophiles Rapists, & Other Sex Offenders and have found it immensely informative. I am considering undertaking a prosecution, and I am hoping that you would consider serving as an expert consultant and possible witness for the case. The types of issues that I am hoping you can address include: 1. Why victims do not report sexual abuse and, when discovered, why it may take several sessions for a victim to disclose all of the sexual activity that took place. 2. Different types of paraphilia in particular, describing a predator's interest in post-pubescent children (many people are asking why we should prosecute someone who didn't go after really young children). 3. Traits of psychopathy. 4. Effects of abuse on victims. When you have a chance, would you mind calling or e-mailing me? My direct dial number is shown below. You also can contact Special Agent Nesbitt Kuyrkendall, with the FBI, at 561 822-5946. Thank you. A. Marie VIM:fart Assistant U.S. Attorney 561 209-1047 Fax 56i 820-8777 ann.marie.c.villafana@usdoj.gov 165 EFTA00179800 Villafana, Ann Marie C. (USAFLS) From: A. Salter [acsalter@tds.corn] Sent: Friday, May 18, 2007 3:08 PM To: Villafana, Ann Marie C. (USAFLS) Subject: RE: Possible Retainer for a Federal Criminal Investigation/Prosecution How about 9 am central time? I am still confused, however. Are you expecting me to fly to Florida to testify? Anna From: VIHelena, Ann Marie C. (USAFLS) [mailto:Ann.Marie.C.Villafana@usdoj.gov] Sent: Friday, May 18, 2007 2:02 PM To: acsalter@annasalter.com Subject: FW: Possible Retainer for a Federal Criminal Investigation/Prosecution Hi Ur. Salter - This really won't be a record-intensive case. How about if we talk on Monday and I can Pill you in on what the case involves and where I think you can really help us. I am hoping you can help educate the jury on issues related to the victims and the perpetrator. I do not have any appointments scheduled for Monday. so any time that day will work for me. Just let me know when and what number I should use to call you. Thank you again. P.S. I keep trying to send mail to your tds.com e-mail address and it is returned to me as undeliverable. A. Marie Villafalia Assistant U.S. Attorney 500 S. Australian Ave. Suite 400 West Palm Beach, FL 33401 Phone 561 209-1047 Fax 561 820-8777 From: A. Salter [mallto:acsalter@tds.com] Sent: Friday, May 18, 2007 2:33 PM To: Villafana, Ann Marie C. (USAFLS) Subject: RE: Possible Retainer for a Federal Criminal Investigation/Prosecution Hi, I just faxed over a signed contract. However, I'm not sure what kind of consultation you are looking for, but generally if there are a lot of records, it takes more than 6 hours to read and report on them. In any case, I'm happy to set up a phone conference to get started. Is there anything you want to send me first in terms of records, or are there questions that you have that you are hoping I can speak to? Next week I am gone Tuesday and Wednesday but here the other days. Anna Salter From: Villafana, Ann Marie C. (USAFLS) [mailto:Ann.Marie.C.VIllafana@usdoj.gov] Sent: Friday, May 18, 2007 1:00 PM To: acsalter@annasalter.com Subject: FW: Possible Retainer for a Federal Criminal Investigation/Prosecution 166 EFTA00179801 Hi Dr. Salter: Alter a lot of paperwork. my office has finally gotten the procurement for you to serve as a consultant on my ease. I understand that the contract was sent to you and I wondered if you had received it. As I mentioned, the case is not yet indicted, so there is no firm timeline in place. The FBI Agents and I would like to consult with you prior to the final presentation to the grand jury so that we can include some of your information as part of that presentation. Can you let me know about the contract and also when you might be available for a telephone conference? Perhaps we could do a short one to go over the background of the case and then I could send you some materials that we could discuss during a longer conference. Thank you for your assistance. A. Mark Vingfaila Assistant U.S. Attorney 500 S. Australian Ave. Suite 400 West Palm Beach, FL 33401 Phone 561 209-1047 Fax 561 820-8777 From: A. Salter [mallto:acsalter@tds.com] Sent: Wednesday, April 18, 2007 8:27 AM To: Villafana, Ann Marie C. (USAFLS) Subject: RE: Possible Retainer for a Federal Criminal Investigation/Prosecution Hi, These are all things I could testify about. Can you tell me the time-line? I charge $250/hour for everything: reading records, testifying, etc. For traveling I charge from the time I leave the house until I arrive at the hotel, and then again the next day from the time I leave the hotel until I return to the hotel or to my home. I don't ask for a retainer. If that's acceptable, please give me a call at 608-238.8223 at your convenience. Anna Salter PS That email address is having trouble. Please send emails to acsalter@tds.net. From: Villafana, Ann Marie C. (USAFLS) [mallto:Ann.Marie.C.Villafana@usdoj.gov] Sent: Monday, April 16, 2007 10:50 AM To: acsalter@annasalter.com Subject: Possible Retainer for a Federal Criminal Investigation/Prosecution Dear Dr. Salter: I am a federal prosecutor in West Palm Beach, Florida, and the District-wide coordinator of child exploitation cases for the U.S. Attorney's Office for the Southern District of Florida. I have been reviewing your book, Predators: Pedophiles Rapists. & Other Sex Offenders, and have found it immensely informative. I am considering undertaking a prosecution, and I am hoping that you would consider serving as an expert consultant and possible witness for the case. The types of issues that I am hoping you can address include: 1. Why victims do not report sexual abuse and, when discovered, why it may take several sessions for a victim to disclose all of the sexual activity that took place. 167 EFTA00179802 2. Different types of paraphilia -- in particular, describing a predators interest in post-pubescent children (many people are asking why we should prosecute someone who didn't go after really young children). 3. Traits of psychopathy. 4. Effects of abuse on victims. When you have a chance, would you mind calling or e-mailing me? My direct dial number is shown below. You also can contact Special Agent Nesbitt Kuyrkendall, with the FBI, at 561 822-5946. Thank you. A. Marie Villafatla Assistant U.S. Attorney 561 209-1047 Fax 561 820-8777 ann.marie.e.villafana@usdoj.gov 168 EFTA00179803 Villafana, Ann Marie C. (USAFLS) From: Villafana, Ann Marie C. (USAFLS) Sent: Friday, May 18, 2007 3:02 PM To: 'acsalter@annasalter.com' Subject: FW: Possible Retainer for a Federal Criminal Investigation/Prosecution Hi Dr. Salter — This really won't be a record-intensive case. How about if we talk on Monday and I can fill you in on what the case involves and where I think you can really help us. I am hoping you can help educate the jury on issues related to the victims and the perpetrator. I do not have any appointments scheduled for Monday. so any time that day will work for me. Just let me know when and what number I should use to call you. Thank you again. P.S. I keep trying to send mail to your tds.com e-mail address and it is returned to me as undeliverable. A. Mark Villeffaila Assistant U.S. Attorney 500 S. Australian Ave. Suite 400 West Palm Beach, FL 33401 Phone 561 209-1047 Fax 561 820-8777 From: A. Salter [mailto:acsalter@tds.com] Sent: Friday, May 18, 2007 2:33 PM To: Villafana, Ann Marie C. (USAFLS) Subject: RE: Possible Retainer for a Federal Criminal Investigation/Prosecution Hi, I just faxed over a signed contract. However, I'm not sure what kind of consultation you are looking for, but generally if there are a lot of records, it takes more than 6 hours to read and report on them. In any case, I'm happy to set up a phone conference to get started. Is there anything you want to send me first in terms of records, or are there questions that you have that you are hoping I can speak to? Next week I am gone Tuesday and Wednesday but here the other days. Anna Salter From: Villafana, Ann Marie C. (USAFLS) [mallto:Ann.Marle.C.Vlllafana@usdoj.gov] Sent: Friday, May 18, 2007 1:00 PM To: acsalter@annasalter.com Subject: FW: Possible Retainer for a Federal Criminal Investigation/Prosecution Hi Dr. Salter: Alter a lot of paperwork. my office has Finally gotten the procurement for you to serve as a consultant on my case. I understand that the contract was sent to you and I wondered if you had received it. As I mentioned, the case is not yet indicted. so there is no firm timeline in place. The FBI Agents and I would like to consult with you prior to the final presentation to the grand jury so that we can include some of your information as part of that presentation. 169 EFTA00179804 Can you let me know about the contract and also when you might he available for a telephone conference? Perhaps we could do a short one to go over the background of the case and then I could send you some materials that we could discuss during a longer conference. Thank you for your assistance. A. Marie Walla Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 Phone 561 209-1047 Fax 561 820-8777 From: A. Salter [mailto:acsalter@tds.com] Sent: Wednesday, April 18, 2007 8:27 AM To: Villafana, Ann Marie C. (USAFLS) Subject: RE: Possible Retainer for a Federal Criminal Invest1gation/Prosecution Hi, These are all things I could testify about. Can you tell me the time-line? I charge $250/hour for everything: reading records, testifying, etc. For traveling I charge from the time I leave the house until I arrive at the hotel, and then again the next day from the time I leave the hotel until I return to the hotel or to my home. I don't ask for a retainer. If that's acceptable, please give me a call at 608-238-8223 at your convenience. Anna Salter PS That email address is having trouble. Please send emails to acsalter@lds.net. From: Villafana, Ann Marie C. (USAFLS) [mallto:Ann.Marie.C.Villafana@usdoj.gov] Sent: Monday, April 16, 2007 10:50 AM To: acsalter@annasalter.com Subject: Possible Retainer for a Federal Criminal Investigation/Prosecution Dear Dr. Salter: I am a federal prosecutor in West Palm Beach, Florida, and the District-wide coordinator of child exploitation cases for the U.S. Attorney's Office for the Southern District of Florida. I have been reviewing your book Predators: Pedophiles Rapists. & Other Sex Offenders and have found it immensely informative. I am considering undertaking a prosecution, and I am hoping that you would consider serving as an expert consultant and possible witness for the case. The types of issues that I am hoping you can address include: 1. Why victims do not report sexual abuse and, when discovered, why it may take several sessions for a victim to disclose all of the sexual activity that took place. 2. Different types of paraphilia -- in particular, describing a predators interest in post-pubescent children (many people are asking why we should prosecute someone who didn't go after really young children). 3. Traits of psychopathy. 4. Effects of abuse on victims. 170 EFTA00179805 When you have a chance, would you mind calling or e-mailing me? My direct dial number is shown below. You also can contact Special Agent Nesbitt Kuyrkendall, with the FBI, at 561 822-5946. Thank you. A. Marie Villafaiia Assistant U.S. Attorney 561 209-1047 Fax 561 820-8777 ann.maric.c.villalana@usdoj.gov 171 EFTA00179806 Villafana, Ann Marie C. (USAFLS) From: Villafana, Ann Marie C. (USAFLS) Sent: Friday, May 18, 2007 3:01 PM To: A. Salter Subject: RE: Possible Retainer for a Federal Criminal Investigation/Prosecution Hi Dr. Salter — This really won't be a record-intensive case. How about if we talk on Monday and I can fill you in on what the case involves and where I think you can really help us. I am hoping you can help educate the jury on issues related to the victims and the perpetrator. I do not have any appointments scheduled for Monday. so any time that day will work for me. Just let me know when and what number I should use to call you. Thank you again. A. Marie Villafirtia Assistant U.S. Attorney 500 S. Australian Ave. Suite 400 West Palm Beach. FL 33401 Phone 561 209-1047 Fax 561 820-8777 From: A. Salter [mallto:acsalter@tds.com] Sent: Friday, May 18, 2007 2:33 PM To: Villafana, Ann Marie C. (USAFLS) Subject: RE: Possible Retainer for a Federal Criminal Investigation/Prosecution Hi, I just faxed over a signed contract. However, I'm not sure what kind of consultation you are looking for, but generally if there are a lot of records, it takes more than 6 hours to read and report on them. In any case, I'm happy to set up a phone conference to get started. Is there anything you want to send me first in terms of records, or are there questions that you have that you are hoping I can speak to? Next week I am gone Tuesday and Wednesday but here the other days. Anna Salter From: Villafana, Ann Marie C. (USAFLS) [rnalito:Ann.Marle.C.VillafanaOusdoj.gov) Sent: Friday, May 18, 2007 1:00 PM To: acsalter@annasalter.com Subject: FW: Possible Retainer for a Federal Criminal Investigation/Prosecution Hi Dr. Salter: After a lot of paperwork, my office has finally gotten the procurement for you to serve as a consultant on my case. 1 understand that the contract was sent to you and I wondered if you had received it. As I mentioned. the case is not yet indicted, so there is no fine timeline in place. The FBI Agents and I would like to consult with you prior to the final presentation to the grand jury so that we can include some of your information as part of that presentation. Can you let me know about the contract and also when you might be available for a telephone conference? Perhaps we could do a short one to go over the background of the case and then I could send you some materials that we could discuss during a longer conference. 172 EFTA00179807 Thank you for your assistance. A. Marie Vi Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Reach, FL 33401 Phone 561 209-1047 Fax 561 820-8777 From: A. Salter [mailto:acsalter@tds.com] Sent: Wednesday, April 18, 2007 8:27 AM To: Villafana, Ann Marie C. (USAFLS) Subject: RE: Possible Retainer for a Federal Criminal Investigation/Prosecution Hi, These are all things I could testify about. Can you tell me the time-line? I charge $250/hour for everything: reading records, testifying, etc. For traveling I charge from the time I leave the house until I arrive at the hotel, and then again the next day from the time I leave the hotel until I return to the hotel or to my home. I don't ask for a retainer. If that's acceptable, please give me a call at 608-238.8223 at your convenience. Anna Salter PS That email address is having trouble. Please send emails to acsalterelds.net. From: Villafana, Ann Marie C. (USAFLS) (mailto:Ann.Marie.C.Villafana@usdo].gov] Sent: Monday, April 16, 2007 10:50 AM To: acsalter@annasalter.com Subject: Possible Retainer for a Federal Criminal Investigation/Prosecution Dear Dr. Salter: I am a federal prosecutor in West Palm Beach, Florida, and the District-wide coordinator of child exploitation cases for the U.S. Attorney's Office for the Southern District of Florida. I have been reviewing your book Predators: Pedophiles Rapists. & Other Sex Offenders and have found it immensely informative. I am considering undertaking a prosecution, and I am hoping that you would consider serving as an expert consultant and possible witness for the case. The types of issues that I am hoping you can address include: 1. Why victims do not report sexual abuse and, when discovered, why it may take several sessions for a victim to disclose all of the sexual activity that took place. 2. Different types of paraphilia -- in particular, describing a predator's interest in post-pubescent children (many people are asking why we should prosecute someone who didn't go after really young children). 3. Traits of psychopathy. 4. Effects of abuse on victims. When you have a chance, would you mind calling or e-mailing me? My direct dial number is shown below. You also can contact Special Agent Nesbitt Kuyrkendall, with the FBI, at 561 822-5946. Thank you. 173 EFTA00179808 A. Marie Malaita Assistant U.S. Attorney 561 209-1047 Fax 561 820-8777 a faa_ t usdo*.ov 174 EFTA00179809 Villafana, Ann Marie C. (USAFLS) From: A. Salter facsalter@tds.comj Sent: Friday, May 18.2007 2:33 PM To: Villafana, Ann Marie C. (USAFLS) Subject: RE: Possible Retainer for a Federal Criminal Investigation/Prosecution HI, I just faxed over a signed contract. However, I'm not sure what kind of consultation you are looking for, but generally if there are a tot of records, it takes more than 6 hours to read and report on them. In any case, I'm happy to set up a phone conference to get started. Is there anything you want to send me first in terms of records, or are there questions that you have that you are hoping I can speak to? Next week I am gone Tuesday and Wednesday but here the other days. Anna Salter From: Villafana, Ann Marie C. (USAFLS) rmallto:Ann.Marle.C.VIllafanaeusd4gov] Sent: Friday, May 18, 2007 1:00 PM To: acsalter@annasalter.com Subject: FW: Possible Retainer for a Federal Criminal Investigation/Prosecution Hi Dr. Salter: After a lot of paperwork, my office has finally gotten the procurement for you to serve as a consultant on my case. I understand that the contract was sent to you and I wondered if you had received it. As I mentioned, the case is not yet indicted. so there is no firm timeline in place. The FBI Agents and I would like to consult with you prior to the final presentation to the grand jury so that we can include some of your information as part of that presentation. Can you let me know about the contract and also when you might be available for a telephone conference? Perhaps we could do a short one to go over the background of the case and then I could send you some materials that we could discuss during a longer conference. Thank you for your assistance. .4. Marie Yilliffafia Assistant U.S. Attorney 500 S. Australian Ave. Suite 400 West Palm Beach, FL 33401 Phone 561 209-1047 Fax 561 820-8777 From: A. Salter (mailto:acsalter@tds.com] Sent: Wednesday, April 18, 2007 8:27 AM To: Villafana, Ann Marie C. (USAFLS) Subject: RE: Possible Retainer for a Federal Criminal Investigation/Prosecution Hi, These are all things I could testify about. Can you tell me the time-line? 175 EFTA00179810 I charge $250/hour for everything: reading records, testifying, etc. For traveling I charge from the time I leave the house until I arrive at the hotel, and then again the next day from the time I leave the hotel until I return to the hotel or to my home. I don't ask for a retainer. If that's acceptable, please give me a call at 608-238-8223 at your convenience. Anna Salter PS That email address is having trouble. Please send emails to acsalteretds.net. From: Villafana, Ann Marie C. (USAFLS) [mailto:Ann.Marie.C.Villafana@usdoj.goy] Sent: Monday, April 16, 2007 10:50 AM To: acsalter@annasalter.com Subject: Possible Retainer for a Federal Criminal Investigation/Prosecution Dear Dr. Salter: I am a federal prosecutor in West Palm Beach, Florida, and the District-wide coordinator of child exploitation cases for the U.S. Attorney's Office for the Southern District of Florida. I have been reviewing your book Predators: Pedophiles Rapists. & Other Sex Offenders, and have found it immensely informative. I am considering undertaking a prosecution, and I am hoping that you would consider serving as an expert consultant and possible witness for the case. The types of issues that I am hoping you can address include: 1. Why victims do not report sexual abuse and, when discovered, why it may take several sessions for a victim to disclose all of the sexual activity that took place. 2. Different types of paraphilia -- in particular, describing a predator's interest in post-pubescent children (many people are asking why we should prosecute someone who didn't go after really young children). 3. Traits of psychopathy. 4. Effects of abuse on victims. When you have a chance, would you mind calling or e-mailing me? My direct dial number is shown below. You also can contact Special Agent Nesbitt Kuyrkendall, with the FBI, at 561 822-5946. Thank you. A. Marie Villafaila Assistant U.S. Attorney 561 209-1047 Fax 561 820-8777 ann.marie.c.villafanaausdolcov 176 EFTA00179811 Villafana, Ann Marie C. (USAFLS) From: Villafana, Ann Marie C. (USAFLS) Sent: Friday, May 18, 2007 2:00 PM To: 'acsalter@annasalter.com' Subject: FW: Possible Retainer for a Federal Criminal Investigation/Prosecution Ili Dr. Salter: After a lot of paperwork, my office has finally gotten the procurement for you to serve as a consultant on my case. I understand that the contract was sent to you and I wondered if you had received it. As I mentioned, the case is not yet indicted, so there is no firm timeline in place. The FBI Agents and I would like to consult with you prior to the final presentation to the grand jury so that we can include some of your information as part of that presentation. Can you let me know about the contract and also when you might be available for a telephone conference? Perhaps we could do a short one to go over the background of the case and then I could send you some materials that we could discuss during a longer conference. Thank you for your assistance. A. Marie Villa/≥tha Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, Ft 33401 Phone 561 209-1047 Fax 561 820-8777 From: A. Salter [mailto:acsalter@tds.com) Sent: Wednesday, April 18, 2007 8:27 AM To: Villafana, Ann Marie C. (USAFLS) Subject: RE: Possible Retainer for a Federal Criminal Investigation/Prosecution Hi, These are all things I could testify about. Can you tell me the time-line? I charge $250/hour for everything: reading records, testifying, etc. For traveling I charge from the time I leave the house until I arrive at the hotel, and then again the next day from the time I leave the hotel until I return to the hotel or to my home. I don't ask for a retainer. If that's acceptable, please give me a call at 608-238-8223 at your convenience. Anna Salter PS That email address is having trouble. Please send emails to acsalteratds.net. From: Villafana, Ann Marie C. (USAFLS) [mallto:Ann.Marle.C.Villafana@usdoi.gov] Sent: Monday, April 16, 2007 10:50 AM To: acsalter@annasalter.com Subject: Possible Retainer for a Federal Criminal Investigation/Prosecution Dear Dr. Salter: 177 EFTA00179812 I am a federal prosecutor in West Palm Beach, Florida, and the District-wide coordinator of child exploitation cases for the U.S. Attorney's Office for the Southern District of Florida. I have been reviewing your book Predators: Pedophiles Rapists. & Other Sex Offenders, and have found it immensely informative. I am considering undertaking a prosecution, and I am hoping that you would consider serving as an expert consultant and possible witness for the case. The types of issues that I am hoping you can address include: 1. Why victims do not report sexual abuse and, when discovered, why it may take several sessions for a victim to disclose all of the sexual activity that took place, 2. Different types of paraphilia -- in particular, describing a predator's interest in post-pubescent children (many people are asking why we should prosecute someone who didn't go after really young children). 3. Traits of psychopathy. 4. Effects of abuse on victims. When you have a chance, would you mind calling or e-mailing me? My direct dial number is shown below. You also can contact Special Agent Nesbitt Kuyrkendall, with the FBI, at 561 822-5946. Thank you. A. Marie Villafaila Assistant U.S. Attorney 561 209-1047 Fax 561 820-8777 ann.marie.e.villafana@usdoi.goy 178 EFTA00179813 Villafana, Ann Marie C. (USAFLS) From: Menchel, Matthew (USAFLS) Sent: Monday, May 14, 2007 10:52 AM To: Villafana, Ann Marie C. (USAFLS); Lourie, Andrew (USAFLS) Subject: Re: Operation Leap Year Marie, You will not have approval to go forward tomorrow with an indictment or to poceed by complaint. Alex has your memo and lefcourt's letter but he is out of the district at the US Attorney's conference for the next several days. I'm having trouble understanding - given how long this case has been pending - what the rush is. This is obviously a very significant case and alex wants to take his time making sure he is comfortable before proceeding. Sent from my BlackBerry Wireless Handheld Original Message From: Villafana, Ann Marie C. (USAFLS) <AVillafana@usa.doj.gov> To: Lourie, Andrew (USAFLS) <ALourie@usa.doj.gov>; Menchel, Matthew (USAFLS) <MMenchel@usa.doj.gov> Sent: Mon May 14 10:38:15 2007 Subject: Operation Leap Year Good morning: I just received a call that Epstein's plane is flying from the Virgin Islands to Newark now, so it looks like Epstein is going to show up for his court appearance tomorrow. Can you let me know if the indictment is going tomorrow or, if not, whether we are authorized to proceed by Complaint? Thank you. A. Marie Villafaha Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 Phone 561 209-1047 Fax 561 820-8777 179 EFTA00179814 Villafana, Ann Marie C. (USAFLS) From: Villafana, Ann Marie C. (USAFLS) Sent: Monday, May 14, 2007 10:38 AM To: Lourie, Andrew (USAFLS); Menchel, Matthew (USAFLS) Subject: Operation Leap Year Good morning: I just received a call that Epstein's plane is flying from the Virgin Islands to Newark now, so it looks like Epstein is going to show up for his court appearance tomorrow. Can you let me know if the indictment is going tomorrow or, if not, whether we arc authorized to proceed by Complaint? Thank you. A. Marie Villafatia Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Reach, FL 33401 Phone 561 209-1047 Fax 561 820-8777 Tracking: 180 EFTA00179815 Recipient Read Lourie. Andrew (USAFLS) Read: 5/14/2007 10:52 NA Menchel. Matthew (USAFLS) Read: 5/14/2007 10:52 AM 181 EFTA00179816 Villafana, Ann Marie C. (USAFLS) From: Menchel, Matthew (USAFLS) Sent: Friday, May 11, 2007 2:09 PM To: Villafana, Ann Marie C. (USAFLS); Lourie, Andrew (USAFLS) Subject: RE: Marie, Is the pros memo the same as the earlier version that Andy emailed me? Also you reference Appendix A in your memo but it wasn't attached to my first memo. Thanks, Matt From: Villafana, Ann Marie C. (USAFLS) Sent: Wednesday, May 09, 2007 5:36 PM To: Lourie, Andrew (USAFLS) Cc: Menchel, Matthew (USAFLS) Subject: RE: Hi Andy and Matt Toni and I finalized the forfeiture provisions this afternoon. so here is the indictment with the forfeiture language and another copy of the pros memo. Andy — I will sign the indictment and add it to the packet. Thanks. « File: 070507 Indictment with Forfeiture.wpd » « File: Pros Memo 5-1.07.wpd » .4. Marie Villalaiia Assistant U.S. Attorney 500 S. Australian Ave. Suite 400 West Palm Beach, FL 33401 Phone 561 209-1047 Fax 561 820-8777 From: Lourie, Andrew (USAFLS) Sent: Wednesday, May 09, 2007 5:17 PM To: Villafana, Ann Marie C. (USAFLS) Subject: Pls email me pros memo. Thanks. 182 EFTA00179817 Villafana, Ann Marie C. (USAFLS) From: Yera, E.J. (USAFLS) Sent: Thursday, May 10, 2007 9:53 AM To: Villafana, Ann Marie C. (USAFLS) Subject: RE: AM - This is so wrong - on so many levels - that I don't know where to begin. From: Villafana, Ann Marie C. (USAFLS) sent: Thursday, May 10, 2007 9:51 AM To: Yera, EJ. (USAFLS) Subject: FW: Your guidance is sorely needed. A. Metric. l'ilhOna Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach. FL 33401 Phone 561 209.1047 Fax 561 820.8777 From: Lourle, Andrew (USAFLS) Sent: Thursday, May 10, 2007 9:49 AM To: Villafana, Ann Marie C. (USAFLS) Subject: marie I believe that Epstein's attys are scared of the victims they don't know. Epstein has no doubt told them that there were many. Thus I believe the frist indictment should contain only the victims they have nothing on at all. We can add in the other ones that have myspace pages and prior testimony in a superseder. I think for the first strike we should make all their nightmare's come true. Thoughts? 183 EFTA00179818 Villafana, Ann Marie C. (USAFLS) From: Laurie, Andrew (USAFLS) Sent: Thursday, May 10, 2007 9:49 AM To: Villafana, Ann Marie C. (USAFLS) marie I believe that Epstein's attys are scared of the victims they don't know. Epstein has no doubt told them that there were many. Thus I believe the frist indictment should contain only the victims they have nothing on at all. We can add in the other ones that have myspace pages and prior testimony in a superseder. I think for the first strike we should make all their nightmare's come true. Thoughts? 184 EFTA00179819 Villafana, Ann Marie C. (USAFLS) From: Vi'latrine, Ann Marie C. (USAFLS) Sent: Monday, May 07. 2007 3:41 PM To: Lourie, Andrew (USAFLS) Cc: Barnes, Antonia (USAFLS) Subject: Revised Indictment Hi Andy —I caught a few typos today in the indictment, so here is a revised version (they didn't change any of the counts). don't think you sent the indictment to Matt Menchel yet, but if you want me to send it to him, please let me know. Thank you. 070507 IndIctment.wpd A. Marie Villafaffa Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 Phone 561 209-1047 Fax 561 820-8777 Tracking: 185 EFTA00179820 Recipient Loune. Mdrew (USAFLS) Barnes. Antonia (USAFLS) 186 Read Read: 5/8(2007 12:37 PM EFTA00179821 Villafana, Ann Marie C. (USAFLS) From: Villafana, Ann Marie C. (USAFLS) Sent: Thursday, May 03, 2007 4:29 PM To: Crespo, Rosita (USAFLS) Cc: Ball, Shawn (USAFLS) Subject: FW: Litigative Consultant SOW Ili Rosita — Here is the amended Memo. The case is highly sensitive because of the large number of identifiable minors, so l have been very succinct. If you have any questions, you can call me at my direct dial (shown below). Thank you. Ut Consultant SOW short.wpd A. Marie Width Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 Phone 561 209-1047 Fax 561 820-8777 From: Ball, Shawn (USAFLS) Sent: Wednesday, May 02, 2007 3:19 PM To: Vlllafana, Ann Marie C. (USAFLS) Subject: FW: Litigative Consultant SOW From: Crespo, Roslta (USAFLS) Sent: Wednesday, May 02, 2007 3:16 PM To: Ball, Shawn (USAFLS) Subject: Litigative Consultant SOW Shawn, Attach Is the SOW for Litigative Consultant. Add the information needed and return via email. You need to add a brief summary of case. Thanks. Tracking: 187 EFTA00179822 Recipient Crespo, Rana (USAFLS) Ball, Shawn (USAFLS) 188 Read Read: 5/4/2007 8:08 AM EFTA00179823 Villafana, Ann Marie C. (USAFLS) From: Braden, Myesha Sent: Thursday, May 03, 2007 12:05 PM To: Villafana, Ann Marie C. (USAFLS) Cc: Almanza, Paul Subject: RE: 2423(c) and 2423(d) A. Marie, Paul Almanza asked that I respond to your inquiry. Without knowing all of your facts, it does not appear to me that you can use the statue in the ways that you describe. Regarding the first question, I believe that the language of the statute clearly criminalizes engaging in illicit sexual conduct WHILE traveling in foreign commerce. The entire legislative history of the statute shows that it was designed to combat international sex tourism. Also the 'travels in .. . and engages" language bears this out. However, it is not necessary to use 2423(c) to charge him if you know that his intent was to engage in sex with minors. If that is the case, you should charge 2423(b) because it is design to address BOTH interstate and foreign travel for the purpose of illicit sex. Regarding the second question, I must respond with two questions. Can you prove that she arranged the travel and appointments for her own commercial or financial advantage? It sounds like she just doing what her boss in her legitimate job requested of her without additional benefit beyond her standard pay. If that is the case, you will have a great amount of difficulty proving the elements of your case. Can you prove that she purposely arranged appointments with underage prostitutes? Because 2423(f) defines illicit sexual conduct in two ways, both limiting the focus to sexual activity with minors, this is an important issue in deciding whether to charge the assistant. It is also an issue in determining whether your target will be able to raise the affirmative defense provided in 2423(g). If you'd like to give me a call to talk more about this, please feel free to do so. Good luckl Myesha Myeaha K. Braden U.S. Department of Justice Criminal Division - CEOS (202) 514.6037 From: Villafana, Ann Marie C. (USAFLS) priallto:Ann.Marle.C.Villafana@usdoj.gov] Sent: Thursday, May 03, 2007 10:47 AM To: Almanza, Paul Subject: 2423(c) and 2423(d) Hi Paul — Sorry to bother you. I am charging a case where a man traveled from out of state (and, on one occasion, from outside the country) to Palm Beach County to engage in prostitution with minors. First question: The man clearly traveled in "foreign commerce" when he traveled from outside the U.S. directly to Palm Beach county, and he is a U.S. citizen. Do you think that we could charge 2423(c) even though the sexual activity occurred in the U.S.? Second question: Do you know of anyone who has charged 2423(d)? The man's personal assistant set up the appointments with the prostitutes and also was in charge of organizing his travel, so I think a 2423(d) charge is warranted. One question is whether we should charge a separate count for each trip? Or charge only one count covering the entire 18-month period of activity? 189 EFTA00179824 As always, thank you! A. Marie Villafaffa Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 Phone 561 209-1047 Fax 561 820-8777 190 EFTA00179825 Villafana, Ann Marie C. (USAFLS) From: Villafana, Ann Marie C. (USAFLS) Sent: Thursday, May 03, 2007 10:47 AM To: Almanza, Paul Subject: 2423(c) and 2423(d) Iii Paul — Sorry to bother you. 1 am charging a case where a man traveled from out of state (and, on one occasion, from outside the country) to Palm Beach County to engage in prostitution with minors. First question: The man clearly traveled in "foreign commerce" when he traveled from outside the U.S. directly to Palm Beach county, and he is a U.S. citizen. Do you think that we could charge 2423(c) even though the sexual activity occurred in the U.S.? Second question: Do you know of anyone who has charged 2423(d)? The man's personal assistant set up the appointments with the prostitutes and also was in charge of organizing his travel, so I think a 2423(d) charge is warranted. One question is whether we should charge a separate count for each trip? Or charge only one count covering the entire I8-month period of activity? As always, thank you! A. Marie Villafalia Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 Phone 561 209-1047 Fax 561 820-8777 191 EFTA00179826 Villafana, Ann Marie C. (USAFLS) From: Villafana, Ann Marie C. (USAFLS) Sent: Wednesday, May 02, 2007 2:40 PM To: Bail, Shawn (USAFLS) Subject: Emaiting: Xpert Statement of Work Lit Consult.wpd Attachments: Xpert Statement of Work Lit Consult.wpd Hi Shawn -- I changed it a bit. Thanks. The message is ready to be sent with the following file or link attachments: Xpert Statement of Work lit Consult.wpd Note: To protect against computer viruses, e-mail programs may prevent sending or receiving certain types of file attachments. Check your e-mail security settings to determine how attachments are handled. 192 EFTA00179827 Villafana, Ann Marie C. (USAFLS) From: Villafana, Ann Marie C. (USAFLS) Sent: Tuesday, May 01, 2007 5:14 PM To: Sloman, Jeff (USAFLS) Subject: Your call Hi Jeff -- I got your message. I had already sent some stuff to Barbara, so I think she has what she and Alex need. If not, please let me know. The big indictment package was turned in today, so hopefully Matt will have it by Thursday. May 15th is our target date. Thanks. A. Mark Villafana Assistant U.S. Attorney 500 S. Australian Ave, Ste 400 West Palm Beach, FL 33401 56! 820-8711 Fax 561 820-8777 ann.marie.c.villafana®usdoi.gov 193 EFTA00179828 Villafana, Ann Marie C. (USAFLS) From: Villafana, Ann Marie C. (USAFLS) Sent: Monday, April 23, 2007 7:56 PM To: Schultz, Anne (USAFLS) Cc: Yera, E.J. (USAFLS) Subject: RE: Eleventh Circuit Pattern Jury Instructions Hi Annie -- The current version of the jury instruction for violating 18 USC 2422(b) (Offense Instruction 80) is currently drafted for the charge of ATTEMPTED enticement of a minor. Because attempt is a specific intent crime, an attempt requires that the defendant specifically intend to entice someone under 18, and the current pattern instruction includes a willfulness requirement. For the completed offense, however, the defendant only needs to knowingly use a computer to entice someone, and then the government has to prove that the person actually is under 18. The current pattern jury instruction also does not discuss enticement into prostitution. So, the instruction for a completed offense should read: First: That the Defendant knowingly used [the mail] [a computer] [describe other interstate facility as alleged in indictment] to persuade, induce, entice, or coerce an individual to engage in [prostitution] [sexual activity], as charged; Second: That the individual whom the defendant enticed was less than eighteen (18) years of age at the time of the charged offense; And [for cases not involving enticement into prostitution] Third: That the Defendant and the individual engaged in sexual activity for which the Defendant could have been charged with a criminal offense under the law of [identify the state]. EJ and I have gone through all the cases on this for an upcoming indictment, so getting the 11th Circuit's attention would be wonderful. If you want the analysis, please let me know. Thanks. A. Marie Malaita Assistant U.S. Attorney 561 209-1047 Fax 561 820-8777 ann.marie.c.villafana®usdqj.gov From: Schultz, Anne (USAFLS) Sent: Monday, April 23, 2007 11.29 AM To: USAFIS-AUSAs District Cc Curnlck, Janis (USAFLS) Subject Eleventh Circuit Pattern Jury Instructions Judge Mlddlebrooks Informed me on Friday that the Committee that reviews the Eleventh Circuit Pattern Jury Instructions will be meeting next week at the Eleventh Circuit Judicial Conference. The Committee will soon begin reviewing the current instructions, and Judge Middlebrooks has requested our input. If you have suggestions about the instructions as a whole please relay them to me within the next two days so that I can pass our general comments on to Judge Mlddlebrooks before the Judicial Conference. If you have any suggestions as to individuals or groups that the 197 EFTA00179829 Committee should contact for input regarding the instructions, please give me that information in the next two days as well. I would also like your thoughts on instructions that need to be revised or added. While all thoughts are welcome, it would really help if you attached instructions that you think should be included in the Pattern Instructions. Tracking: 198 EFTA00179830 Recipient Schanz. Anne (USAFLS) Yew. E J (USAFLS) 199 Road Read: 4/24/2007 9:13 AM EFTA00179831 Villafana, Ann Marie C. (USAFLS) From: Richards, Jason R. (Jason.Richards2©ic.fbi.gov] Sent: Friday, April 20, 2007 6:21 PM To: Villafana, Ann Marie C. (USAFLS) Cc: genekuyrkendall©msn.com Attachments: Epstein Ssheet.xls Hey Marie, Here's the draft spreadsheet you requested (Jennifer Siciliano's data still needs to be added). Have a good weekend. Jason 200 EFTA00179832 Villafana, Ann Marie C. (USAFLS) From: Villafana, Ann Marie C. (USAFLS) Sent: Friday, April 20, 2007 12:32 PM To: acsalter@tds.net Subject: FW: Possible Retainer for a Federal Criminal Investigation/Prosecution Eli Anna -- My secretary, Shawn Ball, will be calling to get your Social Security number, etc., so we can get funding approved. (I don't want to take up a lot of your time and then get into a fight with my Office.) I'll call you on Monday? A. Marie Villafafia Assistant U.S. Attorney 561 209-1047 Fax 561 820-8777 ann.maric.c.villafanzi(intisdoi.gov From: A. Salter [mailto:acsalter@tds.corn] Sent: Wednesday, April 18, 2007 8:27 AM To: Villafana, Ann Marie C. (USAFLS) Subject: RE: Possible Retainer for a Federal Criminal Investigation/Prosecution Hi, These are all things I could testify about. Can you tell me the time-line? I charge $250/hour for everything: reading records, testifying, etc. For traveling I charge from the time I leave the house until I arrive at the hotel, and then again the next day from the time I leave the hotel until I return to the hotel or to my home. I don't ask for a retainer. If that's acceptable, please give me a call at 608-238-8223 at your convenience. Anna Salter PS That email address is having trouble. Please send emails to acsalteretds.net. From: Villafana, Ann Marie C. (USAFLS) [mallto:Ann.Marie.C.Villafana@usdej.gov] Sent: Monday, April 16, 2007 10:50 AM To: acsalter@annasalter.com Subject: Possible Retainer for a Federal Criminal Investigation/Prosecution Dear Dr. Salter: I am a federal prosecutor in West Palm Beach, Florida, and the District-wide coordinator of child exploitation cases for the U.S. Attorney's Office for the Southern District of Florida. I have been reviewing your book, Predators: Pedophiles Rapists. & Other Sex Offenders, and have found it immensely informative. I am considering undertaking a prosecution, and I am hoping that you would consider serving as an expert consultant and possible witness for the case. The types of issues that I am hoping you can address include: 201 EFTA00179833 1. Why victims do not report sexual abuse and, when discovered, why it may take several sessions for a victim to disclose all of the sexual activity that took place. 2. Different types of paraphilia -- in particular, describing a predator's interest in post-pubescent children (many people are asking why we should prosecute someone who didn't go after really young children). 3. Traits of psychopathy. 4. Effects of abuse on victims. When you have a chance, would you mind calling or e-mailing me? My direct dial number is shown below. You also can contact Special Agent Nesbitt Kuyrkendall, with the FBI, at 561 822-5946. Thank you. A. Marie Villafaila Assistant U.S. Attorney 561 209-1047 Fax 561 820-8777 ann.marie.c.villafana(eausdoi.gov 202 EFTA00179834 Villafana, Ann Marie C. (USAFLS) From: Villafana, Ann Marie C. (USAFLS) Sent: Friday, April 20, 2007 12:31 PM To: A. Salter Subject: RE: Possible Retainer for a Federal Criminal Investigation/Prosecution Hi Anna -- My secretary, Shawn Ball, will be calling to get your Social Security number, etc., so we can get funding approved. (I don't want to take up a lot of your time and then get into a fight with my Office.) I'll call you on Monday? A. Marie Villnjaria Assistant U.S. Attorney 561 209-1047 Fax 561 820-8777 ann.marie.c.villafana@usdoi.gov From: A. Salter [mallto:acsalter@tds.com] Sent: Wednesday, April 18, 2007 8:27 AM To: Villafana, Ann Marie C. (USAFLS) Subject: RE: Possible Retainer for a Federal Criminal Investigation/Prosecution Hi, These are all things I could testify about. Can you tell me the time-line? I charge $250/hour for everything: reading records, testifying, etc. For traveling I charge from the time I leave the house until I arrive at the hotel, and then again the next day from the time I leave the hotel until I return to the hotel or to my home. I don't ask for a retainer. If that's acceptable, please give me a call at 608-238-8223 at your convenience. Anna Salter PS That email address is having trouble. Please send emails to acsalter6tds.net. From: Vlllafana, Ann Marie C. (USAFLS) (mailto:Ann.Marle.C.VIllafana@usdoj.gov] Sent: Monday, April 16, 2007 10:50 AM To: acsalter@annasalter.com Subject: Possible Retainer for a Federal Criminal Investigation/Prosecution Dear Dr. Salter: I am a federal prosecutor in West Palm Beach, Florida, and the District-wide coordinator of child exploitation cases for the U.S. Attorney's Office for the Southern District of Florida. I have been reviewing your book Predators: Pedophiles, Rapists. & Other Sex Offenders and have found it immensely informative. I am considering undertaking a prosecution, and I am hoping that you would consider serving as an expert consultant and possible witness for the case. The types of issues that I am hoping you can address include: 203 EFTA00179835 1. Why victims do not report sexual abuse and, when discovered, why it may take several sessions for a victim to disclose all of the sexual activity that took place. 2. Different types of paraphilia -- in particular, describing a predators interest in post-pubescent children (many people are asking why we should prosecute someone who didn't go after really young children). 3. Traits of psychopathy. 4. Effects of abuse on victims. When you have a chance, would you mind calling or e-mailing me? My direct dial number is shown below. You also can contact Special Agent Nesbitt Kuyrkendall, with the FBI, at 561 822-5946. Thank you. A. Mark Vilkfidia Assistant U.S. Attorney 561 209-1047 Fax 561 820-8777 ann.marie.c.villatimaAusdoj.gov 204 EFTA00179836 Villafana, Ann Marie C. (USAFLS) From: Villafana, Ann Marie C. (USAFLS) Sent: Monday, April 16, 2007 5:25 PM To: Ortiz, Eliasib Subject: FW: Possible Retainer for a Federal Criminal Investigation/Prosecution Hi Junior -- Here are the questions that I have raised for the potential expert. Thank you. The types of issues that I am hoping the expert can address include: I. Why victims do not report sexual abuse and, when discovered, why it may take several sessions for a victim to disclose all of the sexual activity that took place. 2. Different types of paraphilia -- in particular, describing a predator's interest in post-pubescent children (many people are asking why we should prosecute someone who didn't go after really young children). 3. Traits of psychopathy. 4. Effects of abuse on victims. Thank you. A. Marie Walla Assistant U.S. Attorney 561 209-1047 Fax 561 820-8777 ann.marie.clillafana©usdoidzov 205 EFTA00179837 Villafana, Ann Marie C. (USAFLS) From: Villafana, Ann Marie C. (USAFLS) Sent: Monday, April 16, 2007 12:07 PM To: Williams, Doncella Cc: Ball, Shawn (USAFLS) Subject: RE: Haley Robson and Tatum Miller Thank you so much! Shawn -- Can you prepare the final subpoenas? A. Marie Villafafia Assistant U.S. Attorney 561 209-1047 Fax 561 820-8777 ann. marie.c.villafana@usdoj.gov From: Williams, Doncella Sent: Monday, April 16, 2007 12:03 PM To: Villafana, Ann Marie C. (USAFLS) Cc: Bannon, John Subject: Haley Robson and Tatum Miller The immunity authorization letters for witness Haley Robson and Tatum Miller has been faxed to your office at 561-820- 8777. Doncella Williams Legal Assistant Witness Immunity Unit 202-514-5541 206 EFTA00179838 Villafana, Ann Marie C. (USAFLS) From: Villafana, Ann Marie C. (USAFLS) Sent: Monday, April 16, 2007 11:50 AM To: acsalter@annasalter.com Subject: Possible Retainer for a Federal Criminal Investigation/Prosecution Dear Dr. Salter: I am a federal prosecutor in West Palm Beach, Florida, and the District-wide coordinator of child exploitation cases for the U.S. Attorney's Office for the Southern District of Florida. I have been reviewing your book Predators: Pedophiles Rapists. & Other Sex Offenders, and have found it immensely informative. I am considering undertaking a prosecution, and I am hoping that you would consider serving as an expert consultant and possible witness for the case. The types of issues that I am hoping you can address include: 1. Why victims do not report sexual abuse and, when discovered, why it may take several sessions for a victim to disclose all of the sexual activity that took place. 2. Different types of paraphilia -- in particular, describing a predator's interest in post-pubescent children (many people are asking why we should prosecute someone who didn't go after really young children). 3. Traits of psychopathy. 4. Effects of abuse on victims. When you have a chance, would you mind calling or e-mailing me? My direct dial number is shown below. You also can contact Special Agent Nesbitt Kuyrkendall, with the FBI, at 561 822-5946. Thank you. A. Marie Villafalia Assistant U.S. Attorney 561 209-1047 Fax 561 820-8777 ann.marie.c.villafana@usdelgov 207 EFTA00179839 Villafana, Ann Marie C. (USAFLS) From: Villafana, Ann Marie C. (USAFLS) Sent: Tuesday, March 27, 2007 2:32 PM To: Lourie, Andrew (USAFLS) Subject: RE: Hi Andy -- Thank you. The letter went out earlier today. I put a copy in your box. A. Marie Villafafia Assistant U.S. Attorney 500 S. Australian Ave, Ste 400 West Palm Beach, FL 33401 561 820-8711 Fax 561 820-8777 ann.marie.c.villafana@usdoi.gov From: Lourie, Andrew (OWLS) Sent: Monday, March 26, 2007 4:21 PM To: Morena, Mn Marie C. (USAFLS) Subject: I told Dutko we would send him a kastigar letter this week . He said he would try to bring her in next week unless he had issues with the letter. Basically we should just tell him we are giving him 6001 immunity. Also, I was thinking that senoiors in High School start turning 18 in January. So that if you are getting massages from High School students during a school year between September and January, you can be assured none of them are 18. And even by graduation in June, 5/6 of the students in a Highschool will be under 18. Tracking: 209 EFTA00179840 Recipient Read Lourie, Andrew (USAF1S) Deleted: 413/2007 11:25 AM 210 EFTA00179841 Villafana, Ann Marie C. (USAFLS) From: Villafana, Ann Marie C. (USAFLS) Sent: Friday, March 23, 2007 9:22 AM To: Cassella, Stefan Subject: RE: memory lane Thank you, thank you, thank you! A. Marie Villufaira Assistant U.S. Attorney 500 S. Australian Ave, Ste 400 West Palm Beach, Ff. 33401 561 820-8711 Fax 561 820-8777 ann.marie.c.yillafanaausdoj.goy From: Casselia, Stefan Sent: Thursday, March 22, 2007 5:24 PM To: Vlllafana, Ann Marie C. (USAFLS) Subject: FW: memory lane FYI Stef From: Harbin, Harry Sent: Thursday, March 22, 2007 4:46 PM To: Cassella, Stefan Subject: RE: memory lane Your memory is correct: United States >1 Tobon-Builes, 706 F.2d 1092 (11th Cir. 1982) Conviction aff'd. Tobon's criminal liability stems not from any duty on his part to file CTRs but from his willful act of concealment of material facts so as to cause financial institutions to fail in their duty to file. The panel found support for this holding in 18 U.S.C. § 2(b) under which a person is punishable as a principal if they cause an unwitting and therefore innocent intermediary to commit the offense. An authority of more general application is 18 USC § 2(b) on which Tobon-Builes relied — which is a bit different from the "aiding and abetting" principal embodied in § 2(a). Harry From: Cassella, Stefan Sent: Thursday, March 22, 2007 4:37 PM To: Harbin, Harry Subject: memory lane Harry, 211 EFTA00179842 Am I correct that Tobon-Builes was the 11th Circuit case holding that a smurf could be convicted of causing (aiding and abetting) a financial institution to fail to file a CTR? Do you think that an AUSA in Florida could rely on that case to argue that a person using a money remitter to send money from New York to Florida to finance a prostitution offense is guilty of causing the remitter to violate 1960b1C? Stef • EFTA00179843 Villafana, Ann Marie C. (USAFLS) From: Cassella, Stefan Sent: Thursday, March 22, 2007 5:24 PM To: Villafana, Ann Marie C. (USAFLS) Subject: FW: memory lane FYI Stet From: Harbin, Harry Sent: Thursday, March 22, 2007 4:46 PM To: Cassella, Stefan Subject: RE: memory lane Your memory is correct: United States'. Tobon-Builes, 706 F.2d 1092 (11th Cir. 1982) Conviction aft d. Tobon's criminal liability stems not from any duty on his part to file CTRs but from his willful act of concealment of material facts so as to cause financial institutions to fail in their duty to file. The panel found support for this holding in 18 U.S.C. § 2(b) under which a person is punishable as a principal if they cause an unwitting and therefore innocent intermediary to commit the offense. An authority of more general application is 18 USC § 2(b) on which Tobon-Builes relied — which is a bit different from the "aiding and abetting" principal embodied in § 2(a). Harry From: Cassella, Stefan Sent: Thursday, March 22, 2007 4:37 PM To: Harbin, Harry Subject: memory lane Harry, Am I correct that Tobon-Builes was the 11° Circuit case holding that a smurf could be convicted of causing (aiding and abetting) a financial institution to fail to file a CTR? Do you think that an AUSA in Florida could rely on that case to argue that a person using a money remitter to send money from New York to Florida to finance a prostitution offense is guilty of causing the remitter to violate 1960b1C? Stef 213 EFTA00179844 Villafana, Ann Marie C. (USAFLS) From: Cassella, Stefan Sent: Thursday, March 22, 2007 4:14 PM To: Villafana, Ann Marie C. (USAFLS) Subject: RE: A Money Laundering Question Aside from cases where there is a representation as to the nature of the money by a law enforcement agent (sting cases; 1956(a)(3)), or cases involving the international transfer of funds (intl money laundering; 1956(a)(2)(A)), all money laundering offenses under 1956 and 1957 require proof that the money actually was SUA proceeds. There is no provision, in other words, for "reverse money laundering" — i.e., the process of sending money from one place to another for the purpose of promoting a future criminal act. This is a problem in our money laundering statutes that we've asked Congress to fix. (Ironically, the State of Florida has a state reverse money laundering statute that might apply to your facts.) There are some other possibilities, however. If the money was sent via a money remitter, there could be a violation of 1960(b)(1)(C) (sending funds through a money remitting business knowing that they were intended to be used for an illegal purpose). Also, since the end result of this transaction was the promotion of a prostitution offense, you could have a violation of 1952 (using a facility in interstate commerce to promote a state prostitution offense). Please let me know if either of these work for you. Stef From: VIllafana, Ann Marie C. (USAFLS) (mallto:Ann.Marie.C.VIllafana@usdol.gov] Sent: Thursday, March 22, 2007 4:00 PM To: Cassella, Stefan Subject: RE: A Money Laundering Question Thank you, Stef. I must admit that your answer doesn't make me happy. Do you think that there is any other type of money laundering that I could charge? A. Marie Villafafia Assistant U.S. Attorney 500 S. Australian Ave, Ste 400 West Palm Beach, FL 33401 561 820-8711 Fax 561 820-8777 ann.marie.c.villafana rr usdoi.gov From: Cassella, Stefan Sent: Thursday, March 22, 2007 3:10 PM To: VIllafana, Ann Marie C. (USAFLS) Subject: RE: A Money Laundering Question Marie, We have always taken the position that a sting offense — i.e., a violation of 1956a3 — requires proof of a representation that the property involved in the transaction was either A) SUA proceeds, or B) property used to facilitate. In other words, contrary to your construction of the statute, we think the representation element applies to both of the phrases that follow, and not just to the proceeds. I could go into detail regarding the elements of 1956(a)(3) and its legislative history if 214 EFTA00179845 necessary (we did a memo on this to counsel for one of the agencies many years ago), but I think the reason you haven't found any case law on this is that we've discouraged bringing any prosecutions based on this reading of the statute. I suspect that this is not what you were hoping to hear, but that's how we see it. Good luck with this, Stef From: Villafana, Ann Marie C. (USARS) [mailto:Ann.Marie.C.VIllafana@usdoi.gov] Sent: Thursday, March 22, 2007 12:50 PM To: Cassella, Stefan Subject: A Money Laundering Question Hi Stefan -- One of our ICE Agents recommended that I contact you with this question. I have a target who transfers funds from a bank account in New York to a bank account in Florida. The target then asks his assistant in Florida to withdraw cash from the Florida account to pay underage prostitutes here in Florida. I would like to charge money laundering under 1956(a)(3XA): "Whoever, with the intent (A) to promote the carrying on of specified unlawful activity; ... conducts or attempts to conduct a financial transaction involving . .. property used to conduct or facilitate specified unlawful activity, shall be fined under this title or imprisoned for not more than 20 years or both." I read the statute as NOT requiring either the use of criminal proceeds or an attempt to conceal the transactions, but I haven't found any cases that involve purely promotional money laundering. Can you help? Thank you so much. A. Marie VIllafalfa Assistant U.S. Attorney 500 S. Australian Ave, Ste 400 West Palm Beach, FL 33401 561 820-8711 Fax 561 820-8777 ann.marie.c.villafana@usdoi.gov 215 EFTA00179846 Villafana, Ann Marie C. (USAFLS) From: Cassella, Stefan Sent: Thursday, March 22, 2007 3:10 PM To: Villafana, Ann Mare C. (USAFLS) Subject: RE: A Money Laundering Question Marie, We have always taken the position that a sting offense — i.e., a violation of 1956a3 — requires proof of a representation that the property involved in the transaction was either A) SUA proceeds, or B) property used to facilitate. In other words, contrary to your construction of the statute, we think the representation element applies to both of the phrases that follow, and not just to the proceeds. I could go into detail regarding the elements of 1956(a)(3) and its legislative history if necessary (we did a memo on this to counsel for one of the agencies many years ago), but I think the reason you haven't found any case law on this is that we've discouraged bringing any prosecutions based on this reading of the statute. I suspect that this is not what you were hoping to hear, but that's how we see it. Good luck with this, Stef From: Villafana, Ann Marie C. (USAFLS) [mailto:Ann.Marle.CVillafana@usdolgov] Sent: Thursday, March 22, 2007 12:50 PM To: Cassella, Stefan Subject: A Money Laundering Question Hi Stefan -- One of our ICE Agents recommended that I contact you with this question. I have a target who transfers funds from a bank account in New York to a bank account in Florida. The target then asks his assistant in Florida to withdraw cash from the Florida account to pay underage prostitutes here in Florida. I would like to charge money laundering under I956(aX3XA): "Whoever, with the intent (A) to promote the carrying on of specified unlawful activity; ... conducts or attempts to conduct a financial transaction involving . .. property used to conduct or facilitate specified unlawful activity, shall be fined under this title or imprisoned for not more than 20 years or both." I read the statute as NOT requiring either the use of criminal proceeds or an attempt to conceal the transactions, but I haven't found any cases that involve purely promotional money laundering. Can you help? Thank you so much. A. Marie Malaita Assistant U.S. Attorney 500 S. Australian Ave, Ste 400 West Palm Beach, FL 33401 561 820-8711 8777 illafana©usdoj.gov 216 EFTA00179847 Villafana, Ann Marie C. (USAFLS) From: Villafana, Ann Marie C. (USAFLS) Sent: Tuesday, January 30, 2007 9:04 AM To: Lourie, Andrew (USAFLS) Subject: RE: Epstein Hi Andy -- I got a little side-tracked with the Judge Zloch thing, but I am going to try to spend all day today and tomorrow on the Epstein pros memo. In the meantime, Shawn is making you a copy of the stuff that Gerald Lefcourt sent and a copy of the final Palm Beach police report. That doesn't include the interviews conducted by FBI, but it gives a good overview. Junior Ortiz from FBI would like to attend the meeting. Let me know if you have any objection to that. Maybe Junior can come over at 1:00 on Thursday so we can do a "pre-meeting meeting" A. Marie Villafalia Assistant U.S. Attorney 500 S. Australian Ave, Ste 400 West Palm Beach, FL 33401 561 820-8711 Fax 561 820-8777 imn.marie.c.villafanaQusdoi.gov From: lourie, Andrew (USAFLS) Sent: Monday, January 29, 2007 4:55 PM To: Villafana, Ann Marie C. (USAFLS) Subject: Epstein Can I get a draft pros memo and anything else you think I should read before our meeting? 235 EFTA00179848 Villafana, Ann Marie C. (USAFLS) From: Villafana, Ann Marie C. (USAFLS) Sent: Thursday, January :11, 2007 3:48 PM To: lourie, Andrew (USAFLS) Subject: Lilly Ann Sanchez Andy -- I just spoke with Lilly. They are going to give me nothing. I just get to listen to the pitch and hear about how the girls are liars and drug users. And the earliest that they can come to see me is the week after our "goal date." A. Marie VIIlafalia Assistant U.S. Attorney 500 S. Australian Ave, Ste 400 West Palm Beach, FL, 33401 561 820-8711 • Fax 561 820-8777 ann,marie.c.villafana(ausduj.gov Tracking: 236 EFTA00179849 Recipient Lourie, Andrew (USAFLS) Vera, E.J. (USAFLS) 237 Read Read: /111/2007 4:00 PM EFTA00179850 Villafana, Ann Marie C. (USAFLS) From: VIHelena, Ann Marie C. (USAFLS) Sent: Wednesday, January 10, 2007 7:26 AM To: Lourie, Andrew (USAFLS) Subject: RE: TIC with Lilly Ann Sanchez Hi Andy -- I send Lilly a letter telling her that, as I mentioned in my earlier correspondence, I wanted to review the documents that she promised before we met and if she wanted me to review things before I made a presentation to the grand jury she should send them sooner rather than later. She just wants to "make a pitch" and not provide any information. I want the documents not the pitch. A. Marie Villafttha Assistant U.S. Attorney 500 S. Australian Ave, Ste 400 West Palm Beach, FL 33401 561 820-8711 Fax 561 820-8777 ann.marie.c.villafana@usdoi.gov From: Lourie, Andrew (USAFLS) Sent•. Tuesday, January 09, 2007 5:20 PM To: tAllarana, Ann Marie C. (USAFLS) Subject: T/C with Lilly Ann Sanchez Marie, Lilly Ann Sanchez called me. Based on her last conversation with you she was concerned an indictment was imminent and wanted to confirm that she would be given an opportunity to come in before and present the results of their own investigation to us and make a pitch, She said once they had an opportunity to do that, if we wanted to interview Epstein, that would be a possibility. I told her that she would be given the opportunity to do what she requested. Tracking: 238 EFTA00179851 Recipient Read Laurie, Andrew (USAFLS) Read: 111112007 11:48 AM Yeta, E.J. (USAFLS) Read: 111012007 7:38 AM eihasib.orilzecti.gov 239 EFTA00179852 Villafana, Ann Marie C. (USAFLS) From: Villafana, Ann Marie C. (USAFLS) Sent: Monday, December 11, 2006 3:25 PM To: 'Robert Blackburn Esq. (blackburnr@sec.gov)' Subject: Meeting re Epstein Hi Robert -- As promised, I am following up with you. Two FBI agents and I are traveling to New York on Thursday morning and will be there through Sunday. I remember that you are presenting an indictment on Friday, but is there any chance we could talk on Friday afternoon or early evening? And can you recommend a government-approved hotel? Thank you so muchi A. Marie Villafalia Assistant U.S. Attorney Southern District of Florida 500 S. Australian Ave, Ste 400 West Palm Beach, FL 33401 561 820-8711 Fax 561820-8777 From: Magma, Mn Made C. (USAFLS) Sent: Thursday, November 30, 2006 3:55 FM To: Robert Blackburn Esq. (bladtbunflosec.goo) Subject: Our discuss on Hi Robert -- Thank you for taking the time to speak with me today. I will follow up with you next week. All of my contact info is below. A. Marie Villafafia Assistant U.S. Attorney Southern District of Florida 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 561209-1047 Fax 561 820-8777 ann.marie.c.yillafantitguscioluoy 241 EFTA00179853 Villafana, Ann Marie C. (USAFLS) From: Villafana, Ann Marie C. (USAFLS) Sent: Thursday, November 30, 2006 3:55 PM To: Robert Blackburn Esq. (blackburnr@sec.gov) Subject: Our discussion Contacts: Robert Blackburn Esq. Hi Robert -- Thank you for taking the time to speak with me today. I will follow up with you next week, All of my contact info is below. A. Marie VIMilano Assistant U.S. Attorney Southern District of Florida 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 561 209-1047 Fax 561 820-8777 annmarietc.villafana@usdoi.gov 245 EFTA00179854 Villafana, Ann Marie C. (USAFLS) From: Villafana, Ann Marie C. (USAFLS) Sent: Tuesday, October 14, 2008 5:36 PM To: Lee, Dexter (USAFLS) Subject: Re: Letter from Brad Edwards Hi Dexter. I have lost my patience with Mr. Edwards. He clearly is trying to use our litigation to affect the civil suits against Epstein. His letter states that he still wants to work out a resolution of our case but I think that everyone agrees that he has no remedy so I don't know what our incentive is to work with him anymore given his aggressive tactics. I agree with your strategy. From: Lee, Dexter (USAFLS) To: Villafana, Ann Marie C. (USAFLS) Sent: Tue Oct 14 15:13:34 2008 Subject: Letter from Brad Edwards Marie, Today I received the attached letter from Brad Edwards, concerning the partially "false" statements made in the declaration accompanying our initial response to the victims' petition. Edwards doesn't seem to know there's a difference between incorrect and false. As far as stipulating, I think we go forward with our initial strategy, the only relevant facts are that Epstein was charged in state court, pled guilty, and is now in jail. Dexter «edwards_itr_100908.pdf» 3 EFTA00179855 Villafana, Ann Marie C. (USAFLS) From: Lee, Dexter (USAFLS) Sent: Tuesday, October 14,2008 3:14 PM To: Villafana, Ann Marie C. (USAFLS) Subject: Letter from Brad Edwards Marie, Today I received the attached letter from Brad Edwards, concerning the partially "false" statements made in the declaration accompanying our initial response to the victims' petition. Edwards doesn't seem to know there's a difference between incorrect and false. As far as stipulating, I think we go forward with our initial strategy, the only relevant facts are that Epstein was charged in state court, pled guilty, and is now in jail. Dexter edwards_it _100 908.pdf 4 EFTA00179856 Villafana, Ann Marie C. (USAFLS) From: viliatana, Ann Marie C. (USAFLS) Sent: Friday, October 10, 2008 10:18 AM To: Acosta, Alex (USAFLS); &omen, Jeff (USAFLS); Senior, Robert (USAFLS); Lee, Dexter (USAF'S); Atkinson, Karen (USAFLS); Garcia, Rolando (USAFLS) Subject: Epstein Press Coverage FYI — httr/Avww.palmbeachdailynews.comtnews/contentinews/2908/10/09/enstein1010.html A. Mark lalkfaila Assistant U.S. Attorney 500 S. Australian Ave. Suite 400 West Palm Beach, FL 33401 Phone 561 209-1047 Fax 561 820-8777 5 EFTA00179857 Villafana, Ann Marie C. (USAFLS) From: Villafana, Ann Marie C. (USAFLS) Sent: Wednesday, October 08, 2008 2:17 PM To: Acosta, Alex (USAFLS); Sloman, Jeff (USAFLS); Senior, Robert (USAFLS); Atkinson, Karen (USAFLS) Cc: Lee, DexteriUSAFL8); Garcia, Rolando (USAFLS) Subject: Jane Does United States Hi all — Here is the pleading that Dexter and 1 filed today in response to the Jane Does' Motion to Unseal the Non-Prosecution Agreement. Although the Petitioners' Motion asserts that they would provide notice of the motion to Epstein's attorneys, I think it would be prudent for us to send a copy to Roy and Jay. Please let me know if you agree. Thank you. Once Judge Marra decides this motion, I think we should move to dismiss the petition, otherwise Brad Edwards will try to use the case as a never-ending "wishing well" to keep making more and more outrageous requests of Judge Marra. DE29_081008_R p to Motn Unsea A. Marie VIllafafia Assistant U.S. Attorney 561 209-1047 Fax 561 820-8777 Tracking: 10 EFTA00179858 Recipient Read Acesla, Alex (USAFLS) Read: 10/8/2008 3:46 PM Sloman, Jed (USAFLS) Read: 10/8/2008 2:29 PM Senior, Robert (USAFLS) Read: 10/8/2008 2:46 PM Atkinson, Karen (USAFLS) Lee, Dexter (USAFLS) Read: 10/8/2008 2:17 PM Garda, Rolando (USAFLS) Read: 1018/2008 3:50 PM 11 EFTA00179859 Villafana, Ann Marie C. (USAFLS) From: Villafana, Ann Marie C. (USAFLS) Sent: Tuesday, October 07, 2008 4:53 PM To: Lee, Dexter (USAFLS) Subject: Response to Motn to Unseal.doc 111 Dexter I made some changes, including trying to explain a bit more about how I was not misleading the court or the victims when I sent out the first notification letter. Let me know what you think and I can file it today, if you like. I think the deadline is Thursday. Thank you! a Response to An to Unseal.doc 12 EFTA00179860 Villafana, Ann Marie C. (USAFLS) From: Villafana, Ann Marie C. (USAFLS) Sent: Tuesday, October 07, 2008 3:20 PM To: Kuyrkendat E N. (FBI) Subject: Letters to LegAtts I-li Nesbitt — Just checking to see if they went out. The lawyers are coming up on Friday to interview some victims, and I would love to be able to tell them that we know where Molly is and anyone else whom we are missing. Thank you. A. Marie Villajana Assistant U.S. Attorney 561 209-1047 Fax 561 820-8777 13 EFTA00179861 Villafana, Ann Marie C. (USAFLS) From: Villafana, Ann Marie C. (USAFLS) Sent: Monday, October 06, 2008 2:34 PM To: Lee, Dexter (USAFLS) Subject: Did you ever file the response in Jane Doe I United States? If not, I will Bic it today. 'thanks. A. Marie Villafana Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 Phone 561 209-1047 Fax 561 820-8777 14 EFTA00179862 Villafana, Ann Marie C. (USAFLS) From: Lee, Dexter (USAFLS) Sent: Saturday, September 27, 2008 7:31 PM To: Villafana, Ann Marie C. (USAFLS) Subject: Draft Response to Motion to Unseal Marie, Here is my first attempt at a response to Edwards' motion to unseal. Please feel free to make any corrections. Dexter victim_opp_Mot_ unseal.wpd 21 EFTA00179863 Villafana, Ann Marie C. (USAFLS) From: Lee, Dexter (USAFLS) Sent: Thursday, September 25, 2008 7:38 PM To: Villafana, Ann Marie C. (USAFLS) Subject: Victims' Motion to Unseal Marie, Edward's motion to unseal is rather odd, since the non-prosecution agreement was never filed under seal in the district court litigation. The reason the document is not public is because the parties entered into a confidentiality provision, not because the U.S. government filed it under seal. The purpose of the protective order was to preserve the confidentiality of the agreement, as the signatory parties envisioned. Dexter 23 EFTA00179864 Villafana, Ann Marie C. (USAFLS) From: Villafana, Ann Marie C. (USAFIS) Sent: Tuesday. September 23, 2008 3:04 PM To: Kuyrkendall, E N. (FBI) Subject: RE: Yarbrough and Epstein stories Attachments: image001,gif There aren't any attachments. The paper is quoting from part of Tein's motion to stay all of the civil suits. In that motion, Tein said that Epstein could still be subjected to federal prosecution if he violates any of the terms of his state agreement (like not serving his whole time or failing to register, etc., etc.) A. Marie Villafaila Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 Phone 561 209-1047 Fax 561 820-8777 From: Kuyrkendall, E N. (FBI) Sent Tuesday, September 23, 2008 2:58 PM To: Villafana, Ann Marie C. (USAFLS) Subject: Re: Yarbrough and Epstein stories I can't open attachment. What plea violation are they talking about? From: Villafana, Ann Marie C. (USAFIS) To: Yera, E.J. (USAFLS); Richards, Jason R.; Kuyrkendall, E N. Sent: Tue Sep 23 14:50:56 2008 Subject: Yarbrough and Epstein stories FYI — From the Palm Beach Post: WEST PALM BEACH - A federal judge sentenced Marion Yarbrough to 40 years in prison Friday for sexually abusing a 15-year-old West Palm Beach girl. According to the U.S. Attorney's Office, Yarbrough, of Kentucky, met the girl on a Web-based social site and arranged to have a Greyhound bus ticket wired to her. The girl traveled to Tennessee, and Yarbrough took her by car to Kentucky and repeatedly sexually abused her. U.S. District Court Judge Kenneth A. Marra also ordered Yarbrough to register as a sex offender and to have no unsupervised contact with children. Yarbrough previously had been charged in Kentucky with sexually abusing three other minors. From Palm Beach Daily News: Plea deal violation could net federal charges for convicted sex offender Jeffrey Epstein Click-2-Lister EFTA00179865 By MICHELE DARGAN Daily News Staff Writer Saturday, September 20, 2008 Convicted sex offender Jeffrey Epstein still faces the possibility of federal criminal charges if he violates any of the terms of his state plea agreement, according to federal court documents. Although it was widely reported that federal prosecutors had agreed to drop their investigation of Epstein under his plea bargain, the documents show that the U.S. Attorney's Office agreed only to defer prosecution while Epstein completes his sentence. Under the terms of the federal deferred-prosecution agreement, Epstein will have to comply with court orders and restrictions even up to 90 days after he completes the house arrest that will follow his 18-month jail term. Epstein, 55, pleaded guilty June 30 to two felony counts: soliciting prostitution and procuring a person under 18 for prostitution. He is serving 18 months in jail to be followed by 12 months house arrest. In addition to the criminal charges, there are nine federal and six state lawsuits pending against Epstein, all containing similar allegations: that Epstein, through his employees and assistants, brought minor girls to his Palm Beach home at 358 El Brillo Way for erotic massages and sometimes sex. If Epstein violates any of the conditions of his state plea agreement during his sentence and up to 90 days after, the U.S. Attorney's Office "reserves the right to indict (or unseal an existing indictment against) Mr. Epstein," according to federal court documents filed by Epstein attorney Michael Tein. Tein filed the documents in support of a motion asking U.S. District Judge Kenneth Marra to stay proceedings in a federal lawsuit by one of Epstein's victims until after Epstein completes all conditions of his sentence plus the three months. If the lawsuit is not postponed, anything Epstein says in his defense could be used against him in a federal prosecution, Tein argued. Marra denied the motion. "The court sees no reason to delay this litigation for the next 33 months," he wrote. "After all, defendant is in control of his own destiny — it is up to him (and him alone) whether the plea agreement reached with the State of Florida is breached. If defendant does not breach the agreement, then he should have no concerns regarding his Fifth Amendment right against self-incrimination." Under the conditions of his plea agreement, Epstein must register as a sex offender for life. While he is serving the 12 months of house arrest at his Palm Beach home, Epstein must: * Observe a 10 p.m. to 6 a.m. curfew. * Have no unsupervised contact with anyone younger than 18. * Neither view, own nor possess pornographic or sexual materials. 25 EFTA00179866 As a convicted sex offender, he will not be allowed to live within 1,000 feet of a school, playground or other place where children gather. The federal deferred-prosecution agreement, which is tied to his state plea agreement, is under seal, but Tein's motion provided glimpses into the sealed agreement. Paperwork filed by Tein discloses that "under the agreement, the USAO presently retains the continuing right to indict Mr. Epstein—or w unseal 'any' already-existing federal 'charges' that may already have been handed up by the federal grand jury and sealed — should he breach any of its provisions." The Tein motion also indicates that the U.S. Attorney's agreement with Epstein requires that: * The grand jury's subpoenas remain outstanding. • The parties must maintain their evidence. * Any existing charges will not be dismissed until after Epstein has "fulfilled all the terms and conditions of the agreement." The agreement also includes "a promise not to prosecute defendant Sarah Kellen only if Epstein successfully fulfills all the terms and conditions of the state agreement." Kellen, Epstein's former assistant, was investigated for bringing the girls up to the room in his Palm Beach home where Epstein was waiting and for paying the girls afterward. She has not been charged. Tein did not return calls on Friday. Alicia Valle, special counsel to the U.S. Attorney, said via e-mail that the U.S. Attorney's Office had no comment on the agreement. Hollywood attorney Brad Edwards is representing some of the victims in state and federal court. Marra recently granted Edwards' motion that he and two of his clients be allowed to see the sealed agreement. Edwards — who is under orders by the judge not to discuss the contents of the agreement — says he intends to file a motion to unseal the agreement to the public. "The public does have a right to know the terms of the agreement," Edwards said. "These are very unusual circumstances where a prosecutor and a criminal defendant enter into a confidential agreement for the purpose of keeping it from the public." Miami attorney Jeffrey Herman, who represents six of the "Jane Does" in federal lawsuits, agreed. "We anticipate trying to get that document unsealed," he said. "I think its appropriate and should be seen, particularly by the victims, but 1 also think that the public should see it, too." From Sun-Sentinel: Kentucky man to serve 40 years for sexually abusing West Palm Beach girl, 15 EFTA00179867 Kentucky man to serve 40 years for abusing girl By Missy Diaz i South Florida Sun-Sentinel A Kentucky man will spend 40 years in federal prison followed by a lifetime on supervised release for sexually abusing a 15-year-old West Palm Beach girl he met over the Internet. U.S. District Judge Kenneth Marra also ordered Marion Yarbrough to register as a sex offender and have no unsupervised contact with children. Yarbrough, 35, met the teen last year on the mobile social networking site itsmy.com. During a series of online chats, Yarbrough told the girl he was 21. After chatting for several days, he wired the victim a Greyhound bus ticket to Tennessee, where he picked her up and drove her back to Kentucky. For two weeks, Yarbrough repeatedly sexually abused the teen, according to the U.S. Attorney's Office. Yarbrough had previously been charged in Kentucky with sexually abusing three other minors. At the time of his arrest in this case, he had charges pending for the rape of a 12-year-old Kentucky girl. He is to be returned to Kentucky to face those charges. A. Marie Villafafia Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 Phone 561 209-1047 Fax 561 820-8777 27 EFTA00179868 Villafana, Ann Marie C. (USAFLS) From: Villafana, Ann Marie C. (USAFLS) Sent: Friday, September 19, 2008 4:06 PM To: Wile, Alicia (USAFLS); Acosta, Alex (USAFLS); Sloman, Jeff (USAFLS) Subject: RE: Working on a story on deadline re: Jeffrey Epstein I certainly don't want to talk to her. I am just finishing a press release for you on another case. You should have it soon. ,4. Marie VitWalla Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Reach, FL 33401 Phone 561 209-1047 Fax 561 820-8777 From: Valle, Alicia (USAFLS) Sent: Friday, September 19, 2008 2:33 PM To: Villafana, Ann Marie C. (USAFLS); Acosta, Alex (USAFLS) Subject: FW: Working on a story on deadline re: Jeffrey Epstein I am going to be calling her back with a big no comment. unless I get different instructions from you about what's in the public record. From: Michele Dargan (maiito:mdargan@pbdallynews.com] Sent: Friday, September 19, 2008 2:31 PM To: Valle, Alicia (USAFLS) Subject: Working on a story on deadline re: Jeffrey Epstein Alicia, I'm working on a story about the federal non-prosecution agreement that Is part and parcel of the state plea agreement with Jeffrey Epstein. I'd like to know why the U.S. Attorney's Office decided not to prosecute Epstein - because I do know, according to court records, that if he violates any portion of his state agreement that he can be federally prosecuted. I wanted to know if I could speak with AUSA A. Marie Villafana for an answer to this question, since she was the AUSA on the case. I am on deadline for today. Thank you, Michele Michele Dargan, staff writer Palm Beach Daily News (561) 820-3863 phone (561) 655-4594 fax Tracking: 31 EFTA00179869 Recipient Read Wee, Alicia (USAFLS) Read: 9/19(2008 4:07 PM Acosta, Alex (USAFLS) Read: 9119/2008 4:07 PM Sloman, Jed (USAFLS) 32 EFTA00179870 Villafana, Ann Marie C. (USAFLS) From: Villafana, Ann Marie C. (USAFLS) Sent: Thursday, September 18, 2008 1:27 PM To: Atkinson, Karen (USAFLS) Subject: RE: My letter to the Bar Thank you, ma'am. A. Marie Viilafaila Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 Phone 561 209-1047 Fax 561 820-8777 From: Atkinson, Karen (USAFLS) Sent: Thursday, September 18, 2008 1:24 PM To: Villafana, Ann Marie C. (USAFLS) Subject: RE: My letter to the Bar It looks good to me. I would have no changes. K From: VIllafana, Ann Marie C. (OWLS) Sent: Thursday, September 18, 2008 1:18 PM To: Senior, Robert (USAFLS); Atkinson, Karen (USAFLS); Sloman, Jeff (USAFLS) Subject: My letter to the Bar Did you all have a chance to take a look? Any changes or suggestions? And do you want me to show it to anyone else before it goes out? Thanks. (Here it is again in case you lost my other e-mail.) <.< File: Florida Bar Ltr re Ethics Opinion.wpd >> A. Marie Villafana Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 Phone 561 209-1047 Fax 561 820-8777 39 EFTA00179871 Villafana, Ann Marie C. (USAFLS) Front Villafana, Ann Marie C. (USAFLS) Sent: Thursday, September 18, 2008 1:18 PM To: Senior, Robed (USAFLS); Atkinson, Karen (USAFLS); Sloman, Jeff (USAFLS) Subject: My letter to the Bar Did you all have a chance to take a look? Any changes or suggestions? And do you want me to show it to anyone else before it goes out? Thanks. (Here it is again in case you lost my other c-mail.) Florida Bar Ltr re Ethics Opin... A. Marie Villafaffa Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 Phone 561 209-1047 Fax 561 820-8777 Tracking: 40 EFTA00179872 Recipient Senior. Robed (USAFLS) Atkinson. Karen (USAFLS) Siemer). Jeff (USAFLS) 41 Read Read: 9/1912008 11:50 AM Read: 9/18/2008 1:34 PM EFTA00179873 Villafana, Ann Marie C. (USAFLS) From: Villafana, Ann Marie C. (USAFLS) Sent: Thursday, September 18, 20081:17 PM To: kezell@podhurst.com Subject: My letter to the Bar Hi Katherine — Did you have a chance to review the letter? Do you have any changes or suggestions? I would like to send it out today, if possible. Thank you. A. Marie Villafalla Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 Phone 561 209-1047 Fax 561 820-8777 42 EFTA00179874 Villafana, Ann Marie C. (USAFLS) From: Villafana, Ann Marie C. (USAFLS) Sent: Wednesday. September 17, 2008 5:06 PM To: Slomen, Jeff (USAFLS); Atkinson, Karen (USAFLS); Senior, Robert (USAFLS) Subject: Letter to Florida Bar Hi all — I have drafted the attached. Dexter is out of town, so do you want anyone else to take a took before I send it out? I have talked to one of Bob J.'s partners, and they are also drafting a letter. Florida Bar Ltr re Ethics Opin... A. Marie Villafaila Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 Phone 561 209-1047 Fax 561 820-8777 Tracking: 44 EFTA00179875 Recipient Sloman, Jeff (USAFLS) Atkinson, Karen (USAFLS) Senior. Robert (USAFLS) 45 Read Read: 9/17/2008 6:09 PM Read: 9117/2008 5:09 PM EFTA00179876 Villafana, Ann Marie C. (USAFLS) From: Senior, Robert (USAFLS) Sent: Wednesday, September 17, 2008 11:25 AM To: Villafana, Ann Mane C. (USAFLS); Acosta, Alex (USAFLS); Sloman, Jeff (USAFLS); Lee, Dexter (USAFLS); Atkinson, Karen (USAFLS) Cc: Garcia, Rojpndo (USAFLS) Subject: RE: State 1 Jeffrey Epstein Given the non-disclosure agreement, aren't we left with telling the SAO that we have agreed to not disclose so it wouldn't be proper for us to now agree that unsealing is appropriate. Ultimately, it's the SAO's call because they will get the Florida Public Records Act request and they were not a signatory to the agreement. We should also notify defense counsel so that they can take whatever actions they believe are appropriate. Wait till others have had a chance to weigh in on this issue. From: Villafana, Ann Marie C. (USAFLS) Sent: Wednesday, September 17, 2008 10:50 AM To: Acosta, Alex (USAFLS); Sloman, Jeff (USAFLS); Senior, Robert (USAFLS); Lee, Dexter (USAFLS); Atkinson, Karen (USAFLS) Cc: Garcia, Rolando SAFLS) Subject: FW: State I Jeffrey Epstein Will it never end? Barry Krisher sent the e-mail below to Rolando this morning. How would you like to handle this issue? A. Marie YilWalla Assistant U.S. Attorney 500 S. Australian Ave. Suite 400 West Palm Beach, FL 33401 Phone 561 209-1047 Fax 561 820-8777 From: Garcia, Rolando (USAFLS) Sent: Wednesday, September 17, 2008 10:48 AM To: Villafana, Ann nrie C, (USAFLS) Subject: FW: State g Jeffrey Epstein From: Barry Krischer [malito:BkrischeOsalS.state.aus] Sent: Wednesday, September 17, 2008 10:46 AM To: Garcia, Rolando LLISAFLS) Subject: FW: State Jeffrey Epstein Please advise how you would like us to proceed. The agreement referred to is the Federal Non-Prosecution agreement sealed in the file by the judge at the time of the Epstein plea. From: Lanna Belohlavek Sent: Tuesday, September 16, 2008 4:21 PM To: Barry Krlscher Subject: FW: State', Jeffrey Epstein 53 EFTA00179877 How to proceed? Lanna From: Bryce Albu (mallto:bryce@reederandreeder.com) Sent: Tuesday, September 16, 2008 3:52 PM To: Lanna Belohlavek Cc: Martin Ree4pr Subject: State.. Jeffrey Epstein Ms. Belohlavek, We represent The Palm Beach Daily News. The newspaper recently discovered that a non-prosecution agreement (and an addendum thereto) was filed under seal pursuant to an agreed order entered in the above-referenced case. Because the records are sealed, we cannot assess the propriety of the decision to seal them or even whether the newspaper is interested in the information contained therein. I was hoping you would discuss with me the nature of the agreement and the basis for sealing it so that we can advise our client on whether it should pursue an order unseating the agreement. Please call me at your earliest convenience. Very truly yours, C. Bryce Albu Reeder & Reeder P.A. 250 S. Central Blvd., Suite 200 Jupiter, FL 33458 Direct Dial: (561) 575-9721 Facsimile: (561) 575-9765 brvce@reederandreeder.com 54 EFTA00179878 Villafana, Ann Marie C. (USAFLS) From: Sloman, Jeff (USAFLS) Sent: Wednesday, September 17, 2008 11:22 AM To: Villafana, Ann Marie C. (USAFLS); Acosta, Atex (USAFLS); Senior. Robert (USAFLS); Lee, Dexter (USAFLS); Atkinson, Karen (USAFLS) Cc: Garcia, Rondo (USAFLS) Subject: RE: State Jeffrey Epstein I have reviewed the Agreement. We have no obligation to seek its continued searing. Per my conversation with Marie, she is going to notify lack Goldberger that he has yet to file the remainder of the Agreement and that the unsealing issue is between him/Epstein and the SAO's office. From: Villafana, Ann Marie C. (USAFLS) Sent: Wednesday, September 17, 2008 10:50 AM To: Acosta, Alex (USAFLS); Sloman, Jeff (USAFLS); Senior, Robert (USAFLS); Lee, Dexter (USAFLS); Atkinson, Karen (USAFLS) Cc: Garcia, Rolando SAFLS) Subject: FW: State g Jeffrey Epstein Will it never end? Barry Krisher sent the e-mail below to Rolando this morning. How would you like to handle this issue? A. Marie Villafaha Assistant U.S. Attorney 500 S. Australian Ave. Suite 400 West Palm Beach, FL 33401 Phone 561 209-1047 Fax 561 820-8777 From: Garcia, Rolando (USAFLS) Sent: Wednesday, September 17, 2008 10:48 AM To: Villafana, Ann Mfe C. (USAFLS) Subject: FW: State I Jeffrey Epstein From: Barry Krlscher imailto:Bkrtsche@sa15.state.flus] Sent: Wednesday, September 17, 2008 10:46 AM To: Garcia, Rolando UJSAFLS) Subject: FW: State Jeffrey Epstein Please advise how you would like us to proceed. The agreement referred to is the Federal Non-Prosecution agreement sealed in the file by the judge at the time of the Epstein plea. From: Lanna Belohlavek Sent: Tuesday, September 16, 2008 4:21 PM To: Barry Krlscher Subject: FW: State g Jeffrey Epstein How to proceed? Lanna 55 EFTA00179879 From: Bryce Albu (mailto:bryce@reederandreeder.com) Sent: Tuesday, September 16, 2008 3:52 PM To: Lanna Belohlavek Cc: Martin Reed Subject: State Jeffrey Epstein Ms. Belohlavek, We represent The Palm Beach Daily News. The newspaper recently discovered that a non-prosecution agreement (and an addendum thereto) was filed under seal pursuant to an agreed order entered in the above-referenced case. Because the records are sealed, we cannot assess the propriety of the decision to seal them or even whether the newspaper is interested in the information contained therein. I was hoping you would discuss with me the nature of the agreement and the basis for sealing it so that we can advise our client on whether it should pursue an order unsealing the agreement. Please call me at your earliest convenience. Very truly yours, C. Bryce Albu Reeder & Reeder P.A. 250 S. Central Blvd., Suite 200 Jupiter, FL 33458 Direct Dial: (561) 575-9721 Facsimile: (561) 575-9765 bryceereederandreeder.com 56 EFTA00179880 Villafana, Ann Marie C. (USAFLS) From: Villafana, Ann Marie C. (USAFLS) Sent: Wednesday, September 17, 200810:50 AM To: Acosta, Alex (USAFLS); Sloman, Jeff (USAFLS); Senior, Robert (USAFLS); Lee, Dexter (USAFLS); Atkinson, Karen (USAFLS) Cc: Garcia, Roapndo (USAFLS) Subject: FW: State t Jeffrey Epstein Will it never end? Barry Krisher sent the e-mail below to Rolando this morning. How would you like to handle this issue? A. Marie Villafaiia Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 Phone 561 209-1047 Fax 561 820-8777 From: Garcia, Rolando (USAFLS) Sent: Wednesday, September 17, 2008 10:48 AM To: Villafana, Ann Vie C. (USAFLS) Subject: FW: State N. Jeffrey Epstein From: Barry Krischer [mailto:Bkrische@saastate.flus) Sent: Wednesday, September 17, 2008 10:46 AM To: Garcia, Rolando ip SAKS) Subject: FW: State a Jeffrey Epstein Please advise how you would like us to proceed. The agreement referred to is the Federal Non-Prosecution agreement sealed in the file by the judge at the time of the Epstein plea. From: Lanna Belohlavek Sent: Tuesday, September 16, 2008 4:21 PM To: Barry Krischer Subject: FW: State 1. Jeffrey Epstein How to proceed? Lanna From: Bryce Albu [mailto:bryce@reederandreeder.com] Sent: Tuesday, September 16, 2008 3:52 PM To: Lanna Belohlavek Cc: Martin Ree r Subject: States Jeffrey Epstein Ms. Belohlavek, We represent The Palm Beach Daily News. The newspaper recently discovered that a non-prosecution agreement (and an addendum thereto) was filed under seal pursuant to an agreed order entered in the above-referenced case. Because the records are sealed, we cannot assess the propriety of the decision to seal them or even whether the newspaper is 57 EFTA00179881 interested in the information contained therein, I was hoping you would discuss with me the nature of the agreement and the basis for sealing it so that we can advise our client on whether it should pursue an order unsealing the agreement. Please call me at your earliest convenience. Very truly yours, C. Bryce Albu Reeder & Reeder P.A. 250 S. Central Blvd., Suite 200 Jupiter, FL 33458 Direct Dial: (581) 575-9721 Facsimile: (561) 575-9765 bnrceereederandreeder.com Tracking: 58 EFTA00179882 Recipient Road Acosta, Alex (USAFLS) Read: 9/17/2008 10:51 AM Sloman, Jeff (USAFLS) Read: 9/17/2008 10:54 AM Senior, Robert (USAFLS) Read: 9/17/2008 11:11 AM Lee. Gainer (USAFLS) Read: 9/19/2008 9:59 AM Atkinson, Karen (USAFLS) Garcia. Rolando (USAFLS) Read: 9/17/2008 10:51 AM 59 EFTA00179883 Villafana, Ann Marie C. (USAFLS) From: Garcia, Rolando (USAFLS) Sent: Wednesday, September 17, 2008 10:48 AM To: Villafana, Jinn Marie C. (USAFLS) Subject: FW: State/. Jeffrey Epstein From: Barry Krischer [mailto:Bkrische@sa15.state.fl. us) Sent: Wednesday, September 17, 2008 10:46 AM To: Garcia, Rolando,LUSAFLS) Subject: FW: State'. Jeffrey Epstein Please advise how you would like us to proceed. The agreement referred to is the Federal Non-Prosecution agreement sealed in the file by the judge at the time of the Epstein plea. From: Lanna Belohlavek Sent: Tuesday, September 16, 2008 4:21 PM To: Barry Krischer Subject: FW: State.. Jeffrey Epstein How to proceed? Lanna From: Bryce Albu [mailto:bryce@reederandreeder.com] Sent: Tuesday, September 16, 2008 3:52 PM To: Lanna Beloblavek Cc: Martin R r Subject: State l. Jeffrey Epstein Ms. Belohlavek, We represent The Palm Beach Daily News. The newspaper recently discovered that a non-prosecution agreement (and an addendum thereto) was filed under seal pursuant to an agreed order entered in the above-referenced case. Because the records are sealed, we cannot assess the propriety of the decision to seal them or even whether the newspaper is interested in the information contained therein. I was hoping you would discuss with me the nature of the agreement and the basis for sealing it so that we can advise our client on whether it should pursue an order unsealing the agreement. Please call me at your earliest convenience. Very truly yours, C. Bryce Albu Reeder & Reeder P.A. 250 S. Central Blvd., Suite 200 Jupiter, FL 33458 Direct Dial: (561) 575-9721 Facsimile: (561) 575-9765 brvceOreederandreeder.com 60 EFTA00179884 Villafana, Ann Marie C. (USAFLS) From: ViHelena, Ann Marie C. (USAFLS) Sent: Wednesday, September 17, 2008 10:43 AM To: Acosta, Alex (USAFLS); Sloman, Jeff (USAFLS); Senior, Robert (USAFLS); Lee, Dexter (USAFLS); Atkinson, Karen (USAFLS) Subject: Communications from Jeff Herman re Epstein matter Hi all — Today, Jeff and Dexter should receive hard copies of a letter I received from Jeff Herman yesterday. (Karen received her copy yesterday.) I had not intended to do much with it, but today I received a fax from Bob Josefsberg attaching a letter that he had received from Herman. I have scanned and attached both of the letters to this e-mail. In light of the two letters, I would like to get permission to contact the Florida Bar for a written staff opinion on the issue. I could only ask them to address the issue of my contacting the victims, but I recommend that we ask Bob if he wants to submit a written request at the same time regarding whether he can contact the victims. I will note that, for those girls who we knew were represented, all communications were directed to their attorneys, and Bob J. knows that he cannot contact those girls directly. Can you let me know if you have any objection to this? And, Dexter, are you willing to review my written request before it goes out? Thank you. 080916 Ltr from 080915 Ltr from 4erman to Jose...Herman to A. Marie Villafafia Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 Phone 561 209-1047 Fax 561 820-8777 Tracking: 61 EFTA00179885 Recipient Read Acosta, Alex (USAFLS) Read: 9117/2008 10:44 AM Stoman. Jeff (USAFLS) Read: 9/17/2008 1051 AM Senior, Robed (USAFLS) Read: 9/17/2008 11:26 AM Lee. Dexter (USAFLS) Read: 9/19/2008 9:56 Mt Atkinson. Karen (USAFLS) Kuyrkendall, E N. (FBI) Richards, Jason R. (FBI) 62 EFTA00179886 Villafana, Ann Marie C. (USAFLS) From: Kuyrkendall, E N. (FBI) Sent: Monday, September 15, 2008 2:59 PM To: Villafana, Ann Marie C. (USAFLS) Subject: Re: Do you know what school F.P. or A.H, attend? Both attended RPBHS. Spoke with AH - her address is 1423 Devil's Dip, Tallahasse FL 32308. I'll work on OH. From: Villafana, Ann Marie C. (USAFLS) To: Kuyrkendall, E N. Sent: Mon Sep 15 14:56:07 2008 Subject: Do you know what school F.P. or A.H. attend? A. Marie Vilify-aft Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, Fl, 33401 Phone 561 209-1047 Fax 561 820-8777 64 EFTA00179887 Villafana, Ann Marie C. (USAFLS) From: Kuyrkendall, E N. (FBI) Sent: Monday, September 15, 2008 10:55 AM To: Villafana, Ann Marie C. (USAFLS) Subject: Re: Megan D Megan is going to come by your office tomorrow @ 200 to rcve her letter. I told her that u would leave it with the guard if u were unable to meet with her. From: Villafana, Ann Marie C. (USAFLS) To: Pamela Wynn Cc: Richards, Jason R.; Kuyrkendall, E N. Sent: Mon Sep 15 10:32:11 2008 Subject: RE: Hearing on Yarbrough's Motion to Continue We are on for 1:00 tomorrow in front of Judge Marra. Pam —I will see you there! A. Marie Villafana Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach. FL 33401 Phone 561 209- I 047 Fax 561 820-8777 From: Pamela Wynn (maiito:pam@pamelawynn.com) Sent: Monday, September 15, 2008 10:03 AM To: Villafana, Ann Marie C. (USAFLS) Subject: RE: Hearing on Yarbrough's Motion to Continue Let me know the time & I will be there! Wasnt this previously set in Altle77777 Pamela S. Wynn Attorney at Law 1530 North Federal Highway Post Office Box 1374 Lake Worth, FL 33460 Telephone (561) 588.8611 Facsimile (888) 771.0107 www.oamelawvnn•com This message may contain confidential, privileged, and/or proprietary information. It is intended solely for the adressee(s) Indicated above. Redistribution is forbidden without the permission from the sender. If you are not the intended recipient, you are hereby notified that any review, use, dissemination, distribution or duplication of this communication is strictly prohibited. If you are not the intended recipient, please contact the sender by reply email and destroy all copies of the original message. This e-mall message, without warrant or warning, and despite US law as set forth in the Foreign Intelligence Surveillance Act of 1978, may be subject to monitoring by the United States National Security Agency and/or the Department of Defense. Information contained herein may be used against any senders or recipients, now or in the future, in a public trial or secret tribunal 65 EFTA00179888 This communication does not constitute an agreement to represent the recipient and in no way shall be construed to create an attorney-client relationship where one has not already been contracted Until a retainer has been paid and a retainer agreement has been signed, this office does not represent you. Thank you. Subject: Hearing on Yarbrough's Motion to Continue Date: Mon, 15 Sep 2008 09:58:48 -0400 From: Ann.Marle.C.Villafana(thusdoligoy To: .Kuyrkendall(alc.fbi.uoy; )ason.fklchards2(alc.fblxiov; PameDamelawynn.com HI all — I had a message from Irene, )udge Marra's deputy, asking to set a hearing on the motion to continue for some time around lunch tomorrow (Tuesday). I don't know whether Pam got a similar message, but I am hoping that you can attend. He wants sixty more days, which is just absurd. When I get a final time, I will let you all know. Thanks. A. Marie Villafana Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 Phone 561 209-1047 Fax 561 820-8777 66 EFTA00179889 Villafana, Ann Marie C. (USAFLS) From: VIHelena, Ann Marie C. (USAFLS) Sent: Friday, September 12, 2008 12:34 PM To: jenn.siciliano@gmailcorn Subject: Victim Notification Letter Dear Jennifer — Please review the attached letter. If you have questions, I encourage you to contact Attorney Bob Josefsberg. His contact information is included in the letter. With warmest regards, Marie Final Victim Notification -- 1.. A. Marie Villafaitia Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 Phone 561 209-1047 Fax 561 820-8777 67 EFTA00179890 Villafana, Ann Marie C. (USAFLS) From: Villafana, Ann Marie C. (USAFLS) Sent: Friday, September 12, 200811:04 AM To: Sloman, Jeff (USAFLS); Senior, Robert (USAFLS); Acosta, Alex (USAFLS); Atkinson, Karen (USAFLS); Lee, Dexter (USAFLS); Jacobus, Wendy (USAFLS) Subject: Epstein —FYI Hi all —Three quick things. FBI received a FOIA request from Mike Tein asking for everything — evidence, 302s, handwritten notes, etc. FBI received a Florida Sunshine law request from Ted Leopold. Epstein was in the newspaper yesterday because Jeff Herman filed two new lawsuits. FBI counsel is responding to the two requests. Wendy and Dexter — Just wanted to let you know so you are on the lookout. I assume that we will receive similar requests. Thank you. A. Marie Villafaila Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 Phone 561 209-1047 Fax 561 820-8777 Tracking: 69 EFTA00179891 Recipient Read SionIan, Jeff (USAFLS) Read: 9/12/2008 11:50 AM Senior, Robert (USAFLS) Read: 9/12/2008 11:68 AM Acosta, Alex (USAFLS) Read: 9/12/2008 11:38 AM Atkinson, Karen (USAFLS) Read: 9/12/2008 12:44 PM Lee, Dexter (USAFLS) Read: 9/12/200811'15 AM Jacobus, Wendy (USAFLS) Read: 9/12/2008 11:26 AM 69 EFTA00179892 Villafana, Ann Marie C. (USAFLS) From: Roe, Susan (USAWAW) Sent: Monday, September 08, 2008 2:10 PM To: \Natant Ann Marie C. (USAFLS) Subject: RE: epstein Hi and thanks very much The suggestion of civil rights is really interesting since we have his employees who were coconspirators and I think I'll work on it more. And yes they ALL flew through Ft Lauderdale, changing plans there for the Bahamas. I have a phone meeting this morning with Bruce Lyons — we're going to offer his client immunity and put her in al I am concerned about him knowing a lot but she's an appropriate one to hear from. Thanks From: Villafana, Ann Made C (USAFL.5) Sent: Friday, September 05, 2008 11:39 AM To: Roe, Susan (USAWAW) Subject RE: epsteln Iii Susan — Sorry I didn't respond sooner. Epstein entered into a state plea agreement and a federal NonProsecution Agreement. We have a confidentiality provision in our Non-Prosecution Agreement, so I'm not sure I can send it to you. I can definitely say that Epstein will not talk to anyone. He is still facing a possibility of federal prosecution if he doesn't abide by the terms of our agreement and he is facing a slew of civil suits, and he would just never turn in one of his friends unless it meant a big benefit for him. Alexandra Gelber has some familiarity with my case and Drew Oosterbaan (the Chief) was a great ally during the prosecution, so 1 would recommend trying them. I worked with Myesha Braden at times throughout the investigation and she was amazing, but she is in the Civil Rights section now. If you think there is a way to bring a civil rights claim, (if you can find a co-conspirator you can probably do it), then definitely shoot her an e-mail. Any chance that either Copperfield or the victim flew to the Bahamas via South Florida (Miami, Ft Lauderdale or West Palm)? Then I could pitch in. If you have more facts or more victims and want me to think creatively about charging decisions, let me know. A. Marie Villafafia Assistant U.S. Attorney 561 209-1047 Fax 561 820-8777 From: Roe, Susan (USAWAW) Sent: Friday, September 05, 2008 2:08 PM To: %Helena, Ann Marie C (USAFLS) Subject: epstein 70 EFTA00179893 HI Hope you're well and not under water. (1) Any chance you could send me a copy of Epstein's guilty plea ? And do you think he would ever talk about copperfield? (2) Do you have the name of someone good and helpful in DO) who really knows the sexual and/or violent crimes stuff? Thanks We're still working on Copperfield — lots of acts but concerns about applicable lawl Susie Roe 71 EFTA00179894 Villafana, Ann Marie C. (USAFLS) From: Sloman, Jeff (USAFLS) Sent: Friday, September OS, 2008 5:58 PM To: Villafana, Ann Marie C. (USAFLS) Subject: RE: Thank you You deserved itl Original Message From: Villafana, Ann Marie C. (USAFLS) Sent: Friday, September 05, 2008 5:45 PM To: Sloman, Jeff (USAFLS); Senior, Robert (USAFLS) Subject: Thank you Dear Bob and Jeff: I wanted to thank you for the generous award today. It was completely unexpected. I didn't even know that I had been nominated until Wednesday and Lynn just admitted today that she nominated me. I want you to know that your support over the last 2 years means more to me than an award ever could. Thank you for your kindness and generosity. Have a nice weekend and I will speak with you soon. M 73 EFTA00179895 Villafana, Ann Marie C. (USAFLS) From: Villafana, Ann Marie C. (USAFLS) Sent: Friday, September 05, 2008 5:45 PM To: Sloman, Jeff (USAFLS); Senior, Robed (USAFLS) Subject: Thank you Dear Bob and Jeff: I wanted to thank you for the generous award today. It was completely unexpected. I didn't even know that I had been nominated until Wednesday and Lynn just admitted today that she nominated me. I want you to know that your support over the last 2 years means more to me than an award ever could. Thank you for your kindness and generosity. Have a nice weekend and I will speak with you soon. M 74 EFTA00179896 Villafana, Ann Marie C. (USAFLS) From: Villafana, Ann Marie C. (USAFLS) Sent: Wednesday, September 03, 2008 12:23 PM To: Ball, Shawn (USAFLS) Subject: MySpace Contact Hi Shawn: Here is the MySpace page info: ettowewe.mvseace comrstkacex Dear Shasdy: I am writing on behalf of Marie Villafana, the Assistant U.S. Attorney in West Palm Beach who prosecuted the Jeffrey Epstein case. She needs to provide you with information regarding the resolution of the case, including the name and contact information of an attorney who can advise you and represent you for free in connection with any civil claim you want to make against Mr. Epstein. Can you please provide her with a telephone number and an e-mail address? She can be reached at ann.marie.c.villafanaOusdoj.gov. Thank you. A Marie Villaftiffa Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 Phone 561 209-1047 Fax 561 820-8777 75 EFTA00179897 Villafana, Ann Marie C. (USAFLS) From: Villafana, Ann Marie C. (USAFLS) Sent: Wednesday, September 03, 2008 12:22 PM To: Lee, Dexter (USAFLS) Cc: Kuyrkendall, E N. (FBI); Richards, Jason R. (FBI) Subject: Brad Edwards Iii Dexter- Brad Edwards just called me. Here is what he would like me to do: I. Tell him the names of all of the victims. 2. Tell him the name of every witness we interviewed. 3. Turn over the statements of all of the people listed in (I) and (2). 4. Ask the Palm Beach County Jail to provide us with all of Epstein's e-mails and phone calls, 5. I stopped listening to the rest. I told him "no" to all of the above. When he complained, I reminded him that he has subpoena power and he can get most of this stuff from Epstein. I also asked him why I hadn't received any signed Protective Orders except his, and he said he hadn't shown a copy of it to anyone else yet. I sent him a letter (1 am sending a copy to you via inter-office) reminding him to send me the signed Protective Orders as he receives them, and telling him that he needs to sit down with you and me soon to decide how to resolve the case. A. Marie Villafana Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 Phone 561 209-1047 Fax 561 820-8777 Tracking: 76 EFTA00179898 Recipient lee. Dexter (USAFIS) Evokers:MU, E N. (F89 Richards. Jason R. (F81) 77 Road Read: 9/312008 1:30 PM EFTA00179899 Villafana, Ann Marie C. (USAFLS) From: Sloman, Jeff (USAFLS) Sent: Wednesday, September 03, 2008 11:47 AM To: Villafana, Ann Marie C. (USAFLS) Subject: RE: Hello No problem. Hope you're feeling better. We had a great time in Central New York. Aside from Syracuse and the campus, we took a side trip to the Finger Lakes which was beautiful. Hopefully, we'll get a chance to get to Ithaca on another trip. Nicole seems to be doing well but it's too early to tell and it hasn't even turned cold yet. From: Villafana, Ann Marie C. (USAFLS) Sent: Wednesday, September 03, 2008 10:13 AM To: Sloman, Jeff (USAFLS) Subject: Hello Ili Jeff— I am sorry that I was so distracted yesterday. I have been having awful migraines for the last four days. I never heard about the trip to Syracuse. Is your daughter enjoying it so far? And is she prepared for the dreaded "lake effect snow"? A. Marie Villain& Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 Phone 561 209-1047 Fax 561 820-8777 78 EFTA00179900 Villafana, Ann Marie C. (USAFLS) From: Kuyrkendall, E N. (FBI) Sent: Tuesday, September 02, 2008 5:45 PM To: Vil'arena. Ann Marie C. (USAFLS) Subject: Re: Missing Contact Info for some of the victims Marie, wait on sending the letters to the addresses u rc'vd from Twiler. I will attempt to verify and get up todate. I know some are nolonger good. In MM 2mrow AM. Call u soon From: Villafana, Ann Made C. (USAFLS) To: Kuyrkendall, E N. Sent: Tue Sep 02 13:55:48 2008 Subject: RE: Missing Contact Info for some of the victims Hi Nesbitt — There are 7 girls that we need info for. Thanks. A. Marie Vs1kflaiia Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 Phone 561 209-1047 Fax 561 820-8777 From: Kuyrkendall, E N. (FBI) Sent: Tuesday, September 02, 2008 1:52 PM To: Villafana, Ann Marie C. (USAFLS) Subject: Re; Missing Contact Info for some of the victims Yes, I will try to reach out to dad. ni forward once I get it. From: Villafana, Ann Marie C. (USAFLS) To: Kuyrkendall, E N.; Smith, Twiler I; Richards, Jason R. Sent: Tue Sep 02 13:50:51 2008 Subject: Missing Contact Info for some of the victims I think that I am still missing contact info for Ashley Megan Lauren Alex Danielle Courtney L. 79 EFTA00179901 Leigh A. Marie Vilferiae Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 Phone 561 209-1047 Fax 561 820-8777 80 EFTA00179902 Villafana, Ann Marie C. (USAFLS) From: Kuyrkendall, E N. (FBI) Sent: Tuesday, September 02, 2008 1:52 PM To: Villafana, Ann Marie C. (USAFLS) Subject: Re: Missing Contact Info for some of the victims Yes, I will try to reach out to dad. I" 11 forward once I get it. From: Villafana, Ann Marie C. (USAF) To: Kuyrkendall, E N.; Smith, TMler il; Richards, Jason R. Sent: Tue Sep 02 13:50:51 2008 Subject: Missing Contact Info for some of the victims I think that I am still missing contact info for Ashley Megan Lauren Alex Danielle Courtney L. Leigh A. Marie Villafaita Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 Phone 561 209-1047 Fax 561 820-8777 81 EFTA00179903 Villafana, Ann Marie C. (USAFLS) From: Senior, Robert (USAFLS) Sent: Tuesday, September 02, 2008 1:33 PM To: Vil!scene, Ann Marie C. (USAFLS); Sloman, Jeff (USAFLS) Cc: Atkinson, Karen (USAFLS) Subject: RE: Please make sure that you are sitting down when you read this. Something is up. No, I don't want copies of the letters. Thx. Bob From: Villafana, Ann Marie C. (USAFLS) Sent: Tuesday, September 02, 2008 1:30 PM To: Sloman, Jeff (USAFLS); Senior, Robert (USAFLS) Cc: Atkinson, Karen (USAFLS) Subject: Please make sure that you are sitting down when you read this. I spoke with Bob J. this morning, and it looks like Roy has come into the picture again as the voice of reason. « File: 080902 Lefkowitz Ltr to Villafana.pdf » Do you want copies of the victim notification letters as they go out? 82 EFTA00179904 Villafana, Ann Marie C. (USAFLS) From: Sent: To: Cc: Subject: Villafana, Ann Marie C. (USAFLS) Tuesday, September 02, 2008 1:30 PM Sloman, Jeff (USAFLS); Senior, Robert (USAFLS) Atkinson, Karen (USAFLS) Please make sure that you are sitting down when you read this. I spoke with Bob J. this morning, and it looks like Roy has come into the picture again as the voice of reason. 080902 kowitz Ltr to Villa Do you want copies of the victim notification letters as they go out? Tracking: 83 EFTA00179905 Redolent Read Sloman, Jeff (USAFLS) Read: 9/2/2008 1:48 PM Senior, Robert (USAFLS) Read: 912(20081:31 PM Allinson. Karen (USAFLS) Rkhards, Jason R. (FBI) Kuyrkendall, E N. (FBI) 84 EFTA00179906 Villafana, Ann Marie C. (USAFLS) From: Villafana, Ann Marie C. (USAFLS) Sent: Tuesday, September 02, 2008 12:44 PM To: Lee, Dexter (USAFLS) Cc: Senior, Robert (USAFLS); Sloman, Jeff (USAFLS) Subject: RE: Revised Notification to Victims regarding right to see Epstein agreement. Hi Dexter — Jay's complaint was that we were "advertising" the fact that the victims are now entitled to see the agreement, and he saw that as a breach of the confidentiality clause. I agree with you that this is just an extra step that the victims have to take to get the agreement, but I think it balances Epstein's complaints with the Court's desire that we inform the victims. A. Marie Villain& Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 Phone 561 209-1047 Fax 561 820-8777 From: Lee, Dexter (USAFLS) Sent: Tuesday, September 02, 2008 12:36 PM To: VIHelena, Ann Marie C. (USAFLS) Cc: Senior, Robert (USAFLS); Sloman, Jeff (USAFLS) Subject: RE: Revised Notification to Victims regarding right to see Epstein agreement. Marie, Does Epstein's lawyer not want the victims to know that an agreement exists? It seems they are imposing an additional barrier, since the victims' lawyer will be able to review the order signed by Judge Marra. Once the attorney does that, I'm certain the attorney will want to obtain a copy of the Agreement. I'm not sure how this achieves any objective for Epstein, but if they're satisfied with that language, that's fine. As long as the victims know there is an agreement between Epstein and the U.S. Government, I believe we have complied with Judge Marra's order. Dexter From: Viliafana, Ann Marie C. (USAFLS) Sent: Tuesday, September 02, 2008 12:19 PM To: Lee, Dexter (USAFLS) Cc: Senior, Robert (USAFLS); Sloman, Jeff (USAFLS) Subject: Revised Notification to Victims regarding right to see Epstein agreement. Hi Dexter — In light of the complaint of Mr. Epstein's counsel regarding my earlier notification language, I have revised it as follows: "In addition, there has been litigation between the United States and two other victims regarding the disclosure of the entire agreement between the United States and Mr. Epstein. Mr. Josefsberg can provide further 87 EFTA00179907 guidance on this issue or, if Ms. Robson has selected another attorney to represent her in the context of civil litigation, that attorney can review the Court's order in the matter of In re Jane Does 1 and 2, S.D. Fl. Court File No. 08-80736-CIV-MARRA, and advise her accordingly." What do you think? This was my original language: "In addition, a judge has ordered that the United States make available to any designated victim (and/or her attorney) a copy of the actual agreement between Mr. Epstein and the United States, so long as the victim (and/or her attorney) reviews, signs, and agrees to be bound by a Protective Order entered by the Court. If Ms. Robson would like to review the Agreement, please let me know, and I will forward a copy of the Protective Order for her signature." Thanks. A. Marie Ville:fa& Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 Phone 561 209-1047 Fax 561 820-8777 Tracking: as EFTA00179908 Recipient Read Lee. Dexter (USAFLS) Read: 9/212008 12:46 PM Senior. Robed (USAFLS) Read: 9/2/2008 12:57 PM Slornan. Jet( (USAFLS) Read: 9/2(2008 1:09 PM 89 EFTA00179909 Villafana, Ann Marie C. (USAFLS) From: Lee, Dexter (USAFLS) Sent: Tuesday, September 02, 2008 12:38 PM To: Villafana, Ann Marie C. (USAFLS) Cc: Senior, Robert (USAFLS); Sloman, Jeff (USAFLS) Subject: RE: Revised Notification to Victims regarding right to see Epstein agreement. Marie, Does Epstein's lawyer not want the victims to know that an agreement exists? It seems they are imposing an additional barrier, since the victims' lawyer will be able to review the order signed by Judge Marra. Once the attorney does that, I'm certain the attorney will want to obtain a copy of the Agreement.' I'm not sure how this achieves any objective for Epstein, but if they're satisfied with that language, that's fine. As long as the victims know there is an agreement between Epstein and the U.S. Government, I believe we have complied with Judge Marra's order. Dexter From: Vlllafana, Ann Marie C. (USAFLS) Sent: Tuesday, September 02, 2008 12:19 PM To: Lee, Dexter (USAFLS) Cc: Senior, Robert (USAFLS); Sloman, Jeff (USAFLS) Subject: Revised Notification to Victims regarding right to see Epstein agreement. Hi Dexter — In light of the complaint of Mr. Epstein's counsel regarding my earlier notification language, I have revised it as follows: "In addition, there has been litigation between the United States and two other victims regarding the disclosure of the entire agreement between the United States and Mr. Epstein. Mr. Joscfsberg can provide further guidance on this issue or, if Ms. Robson has selected another attorney to represent her in the context of civil litigation, that attorney can review the Court's order in the matter of In re Jane Does 1 and 2, S.D. Fl. Court File No. 08-80736-C1V-MARRA, and advise her accordingly." What do you think? This was my original language: "In addition, a judge has ordered that the United States make available to any designated victim (and/or her attorney) a copy of the actual agreement between Mr. Epstein and the United States, so long as the victim (and/or her attorney) reviews, signs, and agrees to be bound by a Protective Order entered by the Court. If Ms. Robson would like to review the Agreement, please let me know, and I will forward a copy of the Protective Order for her signature." Thanks. A. Marie tinkle:Fla Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 Phone 561 209-1047 Fax 561 820-8777 90 EFTA00179910 91 EFTA00179911 Villafana, Ann Marie C. (USAFLS) From: Viliafana, Ann Marie C. (USAFLS) Sent: Tuesday, September 02, 2008 12:19 PM To: Lee, Dexter (USAFLS) Cc: Senior, Robert (USAFLS); Stamen, Jeff (USAFLS) Subject: Revised Notification to Victims regarding right to see Epstein agreement. Hi Dexter — In light of the complaint of Mr. Epstein's counsel regarding my earlier notification language, I have revised it as follows: "In addition, there has been litigation between the United States and two other victims regarding the disclosure of the entire agreement between the United States and Mr. Epstein. Mr. Josefsberg can provide further guidance on this issue or, if Ms. Robson has selected another attorney to represent her in the context of civil litigation, that attorney can review the Court's order in the matter of In re Jane Does 1 and 2, S.D. Fl. Court File No. 08-80736-CIV-MARRA, and advise her accordingly." What do you think? This was my original language: "In addition, a judge has ordered that the United States make available to any designated victim (and/or her attorney) a copy of the actual agreement between Mr. Epstein and the United States, so long as the victim (and/or her attorney) reviews, signs, and agrees to be bound by a Protective Order entered by the Court. If Ms. Robson would like to review the Agreement, please let me know, and I will forward a copy of the Protective Order for her signature." Thanks. A. Marie Villafaffa Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 Phone 561 209-1047 Fax 561. 820-8777 Tracking: 92 EFTA00179912 Recipient Read Lee. Dexter (USAFLS) Read: 9(21200812:25 PM Senbr, Robed (USAFLS) Read: 9/2/2008 12:24 PM SVOIM1A, Jeff (USAFLS) Read: 912120081:08 PM 93 EFTA00179913 Villafana, Ann Marie C. (USAFLS) From: Senior, Robert (USAFLS) Sent: Tuesday, September 02, 2008 11:48 AM To: Sloman, Jeff (USAFLS); Villafana, Ann Marie C. (USAFLS); Atkinson, Karen (USAFLS) Cc: Kuyrkendall, E N. (FBI); Richards, Jason R. (FBI) Subject: RE: No response from Jay I don't have an objection either. From: Siornan, Jeff (USAFLS) Sent: Tuesday, September 02, 2008 11:04 AM To: Viltafana, Ann Marie C. (USAFLS); Senior, Robert (USAFLS); Atkinson, Karen (USAFLS) Cc: Kuyrkendall, E N. (FBI); Richards, Jason R. (FBI) Subject: RE: No response from Jay I'll defer to Bob but I do not. From: Villafana, Ann Marie C. (USAFLS) Sent: Tuesday, September 02, 2008 10:52 AM To: Senior, Robert (USAFLS); Sloman, Jeff (USAFLS); Atkinson, Karen (USAFLS) Cc: Kuyrkendall, E N. (FBI); Richards, Jason R. (FBI) Subject: No response from Jay Hi all — Hope you had a nice weekend. Jay and Roy have not responded to my last letter. I spoke with Bob Josefsberg today, and he has a lot of great ideas. He spoke with Roy last week and it sounds like they are working out the details, but no documents have been signed. I would like to send the letters out to the victims today. Do you have any objection? Thanks. A. Marie Villafana Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 Phone 561 209-1047 Fax 561 820-8777 94 EFTA00179914 Villafana, Ann Marie C. (USAFLS) From: Sloman, Jeff (USAFLS) Sent: Tuesday, September 02, 2008 11:04 AM To: Villafana, Ann Marie C. (USAFLS); Senior, Robert (USAFLS); Atkinson, Karen (USAFLS) Cc: Kuyrkendall, E N. (FBI); Richards, Jason R, (FBI) Subject: RE: No response from Jay I'll defer to Bob but I do not. From: Villafana, Ann Marie C. (USAFLS) Sent: Tuesday, September 02, 2008 10:52 AM To: Senior, Robert (USAFLS); Sloman, Jeff (USAFLS); Atkinson, Karen (USAFLS) Cc: Kuyrkendall, E N. (FBI); Richards, Jason R. (FBI) Subject: No response from Jay Hi all -- Hope you had a nice weekend. Jay and Roy have not responded to my last letter. I spoke with Bob Josefsberg today, and he has a lot of great ideas. He spoke with Roy last week and it sounds like they are working out the details, but no documents have been signed. I would like to send the letters out to the victims today. Do you have any objection? Thanks. A. Marie Villafana Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 Phone 56I 209-1047 Fax 561 820-8777 95 EFTA00179915 Villafana, Ann Marie C. (USAFLS) From: Villafana, Ann Marie C. (USAFLS) Sent: Tuesday, September 02, 2008 10:59 AM To: Senior, Robert (USAFLS) Subject: RE: No response from Jay Correct. He complained about my description of the litigation, even though I quoted directly from the agreement, and he did not want me to disclose the fact that Judge Marra ordered us to make the full agreement available to all of the victims. He also didn't answer my question about which lawyer should be cc'd on the letter. A. Marie Villain& Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 Phone 561 209-1047 Fax 561 820-8777 From: Senior, Robert (USAFLS) Sent: Tuesday, September 02, 2008 10:54 AM To: Villafana, Ann Marie C. (USAFIS) Subject: RE: No response from Jay Jay hasn't "approved" the letters I presume ? From: Villafana, Ann Marie C. (USAFLS) Sent Tuesday, September 02, 2008 10:52 AM To: Senior, Robert (USAFLS); Sloman, Jeff (USAFIS); Atkinson, Karen (USAFIS) Cc: Kuyrkendall, E N. (FBI); Richards, Jason R. (FBI) Subject: No response from Jay Hi all — Hope you had a nice weekend. Jay and Roy have not responded to my last letter. I spoke with Bob Josefsberg today, and he has a lot of great ideas. He spoke with Roy last week and it sounds like they are working out the details, but no documents have been signed. I would like to send the letters out to the victims today. Do you have any objection? Thanks. A. Marie Villafafia Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 Phone 561 209-1047 Fax 561 820-8777 96 EFTA00179916 97 EFTA00179917 Villafana, Ann Marie C. (USAFLS) From: Viflafana, Ann Marie C. (USAFLS) Sent: Tuesday, September 02, 2008 10:52 AM To: Senior, Robert (USAFLS); Sloman, Jeff (USAFLS); Atkinson, Karen (USAFLS) Cc: Kuyrkendall, E N. (FBI); Richards, Jason FL (FBI) Subject: No response from Jay Hi all - Hope you had a nice weekend. Jay and Roy have not responded to my last letter. I spoke with Bob Josefsberg today, and he has a lot of great ideas. He spoke with Roy last week and it sounds like they are working out the details, but no documents have been signed. 1 would like to send the letters out to the victims today. Do you have any objection? Thanks. A. Marie Villafana Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 Phone 561 209-1047 Fax 561 820-8777 Tracking: 98 EFTA00179918 Recipient Read Senior, Robert (USAFLS) Read: 912/200810:52 AM Stamen. Jett (USAFLS) Read: 9/2/2008 1104 AM Atkinson, Karen (USAFLS) Kuyrkendall, E N. (FBI) Richards. Jason R. (FBI) 99 EFTA00179919 Villafana, Ann Marie C. (USAFLS) From: Vigalena, Ann Marie C. (USAFLS) Sent: Tuesday, SepWilber 02, 2008 10:50 AM To: Smith, Twileral(F80; Kuyrkendall, E N. (FBI); Richards, Jason R. (FBI) Subject: Felicia Importance: High Hi Twila — Sorry I didn't get back to you last week. Can you tell Felicia that she can contact Bob Josefsberg at 305 632-9230. He can represent her in civil litigation or settlement and she will not have to pay his fees. I am preparing a letter to go out today, so if she can wait a day or two, we will get it to her as soon as possible. Thank you. A. Marie Villain& Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 Phone 561 209-1047 Fax 561 820-8777 100 EFTA00179920 Villafana, Ann Marie C. (USAFLS) From: Villafana, Ann Marie C. (USAFLS) Sent: Thursday, August 28, 2008 4:10 PM To: Campos, Cyndee (USAFLS) Subject: RE: addendum Thank you!! A. Marie V/ilalatia Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach. FL 33401 Phone 561 209-1047 Fax 561 820-8777 From: Campos, Cyndee (USAFLS) Sent: Thursday, August 28, 2008 4:07 PM To: Villafana, Ann Marie C. (USAFLS) Subject: addendum cc File: epstein addendum 10 30.pdf » Tracking: 101 EFTA00179921 Recipient Reed Campos. Cyndee (USAFLS) Read: 8/28/2008 4:12 PM 102 EFTA00179922 Recipient iefkowitz@kirkland.com Roy SLACK Atkinson, Karen (USAFLS) Acosta, Alex (USAFLS) Senior, Robert (USAFLS) Stamen, Jeff (USAFLS) 113 Read Read: 8/26/2008 1:38 PM Read: 8/26/2008 1:50 PM EFTA00179923 Villafana, Ann Marie C. (USAFLS) From: ViHelena, Ann Marie C. (USAFLS) Sent: Tuesday, August 28. 2008 1:24 PM To: Sloman, Jeff (USAFLS) Subject: RE: Letter to Jay Great. It is headed to you shortly. A. Marie Villafana Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 Phone 561 209-1047 Fax 561 820-8777 From: Sloman, Jeff (USAFLS) Sent: Tuesday, August 26, 2008 9:53 AM To: Vlllafana, Ann Marie C. (USAFLS) Cc: Acosta, Alex (USAFLS); Senior, Robert (USAFLS) Subject: RE: Letter to Jay Marie, It's fine with one suggestion. Near the end when you say "if it comes to our attention that Mr. Epstein has breached the terms of the Agreement, the Office intends to enforce its right to indict Mr. Epstein." How about softening it just a tad to "the Office intends to enforce its rights pursuant to the Agreement." Otherwise, you're good to go. Jeff From: Villafana, Ann Marie C. (USAFLS) Sent: Tuesday, August 26, 2008 9:22 AM To: Sloman, Jeff (USAFLS); Senior, Robert (USAFLS) Subject: Letter to Jay Hi guys — Is it alright to send out? I received one comment from Alex and have changed the letter to reflect that. Can you let me know if you have any other changes? I am off to mag court but shouldn't be gone too long. Thank you. << File: 080826 Villafana Ltr to Lefkowitz and Black with Acosta change.wpd >> A. Marie Yillafaffa Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 114 EFTA00179924 Phone 561209-1047 Fax 561 820-8777 115 EFTA00179925 Villafana, Ann Marie C. (USAFLS) From: Sent: To: Lefkowitz 08082600 .pdf A. Marie "141Watla Assistant V.S. Attorney 561 209-1047 Villafana, Ann Marie C. (USAFLS) Tuesday, August 26, 2008 1:09 PM Villafana, Ann Marie C. (USAFLS) 116 EFTA00179926 Villafana, Ann Marie C. (USAFLS) From: Sloman, Jeff (USAFLS) Sent: Tuesday, August 28, 2008 9:53 AM To: Vii(atone, Ann Marie C. (USAFLS) Cc: Acosta, Alex (USAFLS); Senior, Robert (USAFLS) Subject: RE: Letter to Jay Marie, It's fine with one suggestion. Near the end when you say "if it comes to our attention that Mr. Epstein has breached the terms of the Agreement, the Office intends to enforce its right to indict Mr. Epstein." How about softening it just a tad to "the Office intends to enforce its rights pursuant to the Agreement" Otherwise, you're good to go. Jeff From: VIllafana, Ann Made C. (USAFLS) Sent: Tuesday, August 26, 2008 9:22 AM To: Sloman, Jeff (USAFLS); Senior, Robert (USAFLS) Subject: Letter to lay Hi guys — Is it alright to send out? I received one comment from Alex and have changed the letter to reflect that. Can you let me know if you have any other changes? I am off to mag court but shouldn't be gone too long. Thank you. c< File: 080826 Villafana Ltr to Lefkowitz and slack with Acosta change.wpd >> A. Marie Villafaffa Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 Phone 561 209-1047 Fax 561 820-8777 117 EFTA00179927 Villafana, Ann Marie C. (USAFLS) From: Villafana, Ann Marie C. (USAFLS) Sent: Tuesday, August 26, 2008 9:22 AM To: Sloman, Jeff (USAFLS); Senior, Robert (USAFLS) Subject; Letter to Jay Hi guys — Is it alright to send out? I received one comment from Alex and have changed the letter to reflect that. Can you let me know if you have any other changes? I am off to mag court but shouldn't be gone too long. Thank you. 380826 Villafana Ltr to Lefkow,.. A. Marie Villafaffia Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 Phone 561 209-1047 Fax 561 820-8777 Tracking: us EFTA00179928 RoeIplont Sidman, Jeff (USAFLS) Senior, Robed (USAFLS) 119 Read Read: 8/2612008 9:45 AM Read: 8126/2008 9:43 AM EFTA00179929 Villafana, Ann Marie C. (USAFLS) From: Acosta, Alex (USAFLS) Sent: Monday, August 25, 2008 6:05 PM To: Villafana, Ann Marie C. (USAFLS); Sioman, Jeff (USAFLS); Senior, Robert (USAFLS); Atkinson, Karen (USAFLS) Subject: RE: Emailing: 080826 Villafana Ltr to Lefkowitz and Black.wpd It might be easier to ask them to provide Josefsberg the letter directly, so you don't have to deal with it. Original Message From: Villafana, Ann Marie C. (USAFLS) Sent: Monday, August 25, 2008 5:33 PM To: Acosta, Alex (USAFLS); Sloman, Jeff (USAFLS); Senior, Robert (USAFLS); Atkinson, Karen (USAFLS) Subject: Emailing: 080826 Villafana Ltr to Lefkowitz and Black.wpd Please let me know if you have any changes. Thank you. The message is ready to be sent with the following file or link attachments: 080826 Villafana Ltr to Lefkowitz and Black.wpd Note: To protect against computer viruses, e-mail programs may prevent sending or receiving certain types of file attachments. Check your e-mail security settings to determine how attachments are handled. 120 EFTA00179930 Villafana, Ann Marie C. (USAFLS) From: Villafana, Ann Mane C. (USAFLS) Sent: Monday, August 25, 2008 5:33 PM To: Acosta, Alex (USAFLS); Sloman, Jeff (USAFLS); Senior, Robert (USAFLS); Atkinson, Karen (USAFLS) Subject: Emailing: 080826 Villafana Ltr to Lefkowitz and Black.wpd Attachments: 080826 Villafana Ltr to Lefkowitz and Black.wpd Please let me know if you have any changes. Thank you. The message is ready to be sent with the following file or link attachments: 080826 Villafana Ltr to Lefkowitz and Black.wpd Note: To protect against computer viruses, e-mail programs may prevent sending or receiving certain types of file attachments. Check your e-mail security settings to determine how attachments are handled. Tracking: 121 EFTA00179931 Recipient Acosta. Alex (USAFLS) %omen, Jeff (USAFLS) Senior. Robert (USAFLS) Alkinson Karen (USAFLS) 122 Read Read: 8/25/2008 5:43 PM Read: 8/2512008 5:45 PM EFTA00179932 Villafana, Ann Marie C. (USAFLS) From: Villafana, Ann Marie C. (USAFLS) Sent: Monday, August 25, 2008 4:41 PM To: Sloman, Jeff (USAFLS) Subject: Bob Josefsberg Hi Jeff — He has not heard hack from Epstein's folks either. I will draft a letter to Jay regarding the victim list and will raise the issue again. Thanks. A. Marie Villafafla Assistant U1.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 Phone 561 209-1047 Fax 561 820-8777 Tracking: 123 EFTA00179933 Recipient Sloman, Jeff (IJSAFLS) 124 Read Read: 8/25/2008 4:41 PM EFTA00179934 Villafana, Ann Marie C. (USAFLS) From: Villafana, Ann Marie C. (USAFLS) Sent: Monday, August 25, 2008 2:20 PM To: Lee, Dexter (USAFLS) Subject: RE: Letter re Epstein and Protective Order Yes, that was my plan. I will send it out today. Thanks. A. Marie VillaJarin Assistant U.S. Attorney 500 5. Australian Ave, Suite 400 West Palm Beach, FL 33401 Phone 561 209-1047 Fax 561 820-8777 From: Lee, Dexter (USAFLS) Sent: Monday, August 25, 2008 2:18 PM To: Villafana, Ann Marie C. (USARS) Subject: RE: Letter re Epstein and Protective Order Marie, I have not sent Brad the Agreement, and would appreciate it if you could take care of that. Are we sending out parts I and II, and leaving out the December 2007 letter? Thanks. Dexter From: Villafana, Ann Marie C. (USAFLS) Sent: Monday, August 25, 2008 1:54 PM To: Lee, Dexter (USAFLS) Subject: RE: Letter re Epstein and Protective Order Hi Dexter — Thank you for your response. Did you ever send the agreement to Brad? Do you want me to do that? A. Marie Villegfana Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 Phone 561 209-1047 Fax 561 820-8777 From: Lee, Dexter (USAFLS) Sent: Monday, August 25, 2008 10:25 AM 125 EFTA00179935 To: Villafana, Ann Marie C. (USAFLS); Acosta, Alex (USAFLS); Sloman, Jeff (USAFLS); Senior, Robert (USAFLS); Atkinson, Karen (USAFLS) Subject: RE: Letter re Epstein and Protective Order Marie, During our telephonic hearing, I received the dear impression that Judge Marra wanted the other victims (non-parties to the Jane Doe litigation), would be given the opportunity to see the Agreement, subject to each one agreeing to be bound by the protective order. I believe It would be contrary to Judge Marra's intent for us to go through the trouble of creating a mechanism for the other non-party victims to have access to the Agreement, and then not tell them there is an Agreement. Also, does CVRA impose any obligation on us, Independent of what Judge Marra ordered, to advise the victims of the Agreement? Dexter From: Viliafana, Ann Marie C. (USAFLS) Sent: Monday, August 25, 2008 9:48 AM To: Acosta, Alex (USAFLS); Sloman, Jeff (USAFLS); Senior, Robert (USAFLS); Atkinson, Karen (USAFLS); Lee, Dexter (USAFLS) Subject Letter re Epstein and Protective Order Good morning, everyone. I have attached a letter from Jay Lefkowitz that came in by fax on Friday night. The good news is that they seem to be in agreement regarding Mr. Josefsberg. Most of the letter doesn't really require a comment, but I wanted to get Dexter's feedback regarding the notification to the victims of their right to see the agreement. Here is the language from my proposed victim notification letter: "In addition, a judge has ordered that the United States make available to any designated victim (and/or her attorney) a copy of the actual agreement between Mr. Epstein and the United States, so long as the victim (and/or her attorney) reviews, signs, and agrees to be bound by a Protective Order entered by the Court. If Ms. Robson would like to review the Agreement, please let me know, and I will forward a copy of the Protective Order for her signature." Lefkowitz objects, but I am wondering whether Dexter agrees that the spirit of our discussions with Judge Marra requires such a notification. If we make the entire agreement available to Mr. Josefsberg and he conveys that information to all of his clients, the concern becomes moot, I suppose. Lastly, from my discussion with Bob, it appears that the Office does not want to add to the list the names of victims identified after the date of signing the September agreement unless our investigation had provided enough information that we were prepared to include them in the indictment i.e., the New York girls — and that you do not want me to re-add Tatum Miller to the list, even though we have extensive corroboration of her involvement with Epstein. Can someone please confirm? Thank you all. << File: 080822 Lefkowitz ltr to Villafana.pdf>> 126 EFTA00179936 A. Marie Villafalla Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 Phone 561 209-1047 Fax 561 820-8777 Tracking: 127 EFTA00179937 Recipient Lee. Dexter (USAFLS) 128 Read Read: 8/25/2008 2:21 PM EFTA00179938 Villafana, Ann Marie C. (USAFLS) From: Villafana, Ann Marie C. (USAFLS) Sent: Monday, August 25, 2008 1:54 PM To: Lee, Dexter (USAFLS) Subject: RE: Letter re Epstein and Protective Order Hi Dexter — Thank you for your response. Did you ever send the agreement to Brad? Do you want me to do that? A. Marie Villafana Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 Phone 561 209-1047 Fax 561 820-8777 From: Lee, Dexter (USAFLS) Sent: Monday, August 25, 2008 10:25 AM To: Villafana, Ann Marie C. (USAFLS); Acosta, Alex (USAFLS); Sloman, Jeff (USAFLS); Senior, Robert (USAFLS); Atkinson, Karen (USAFLS) Subject: RE: Letter re Epstein and Protective Order Marie, During our telephonic hearing, I received the clear impression that Judge Marra wanted the other victims (non-parties to the Jane Doe litigation), would be given the opportunity to see the Agreement, subject to each one agreeing to be bound by the protective order. I believe it would be contrary to Judge Marra's intent for us to go through the trouble of creating a mechanism for the other non-party victims to have access to the Agreement, and then not tell them there is an Agreement. Also, does CVRA impose any obligation on us, independent of what Judge Marra ordered, to advise the victims of the Agreement? Dexter From: Villafana, Ann Marie C. (USAFLS) Sent: Monday, August 25, 2008 9:48 AM To: Acosta, Alex (USAFLS); Stamen, Jeff (USAFLS); Senior, Robert (USAFLS); Atkinson, Karen (USAFLS); Lee, Dexter (USAFLS) Subject: Letter re Epstein and Protective Order Good morning, everyone. I have attached a letter from Jay Lefkowitz that came in by fax on Friday night. The good news is that they seem to be in agreement regarding Mr. Josefsberg. Most of the letter doesn't really require a comment, but 1 129 EFTA00179939 wanted to get Dexter's feedback regarding the notification to the victims of their right to see the agreement. Here is the language from my proposed victim notification letter: "In addition, a judge has ordered that the United States make available to any designated victim (and/or her attorney) a copy of the actual agreement between Mr. Epstein and the United States, so long as the victim (and/or her attorney) reviews, signs, and agrees to be bound by a Protective Order entered by the Court. If Ms. Robson would like to review the Agreement, please let me know, and I will forward a copy of the Protective Order for her signature." Lefkowitz objects, but I am wondering whether Dexter agrees that the spirit of our discussions with Judge Marra requires such a notification. If we make the entire agreement available to Mr. Josefsberg and he conveys that information to all of his clients, the concern becomes moot, I suppose. Lastly, from my discussion with Bob, it appears that the Office does not want to add to the list the names of' victims identified after the date of signing the September agreement unless our investigation had provided enough information that we were prepared to include them in the indictment — i.e., the New York girls — and that you do not want me to re-add Tatum Miller to the list, even though we have extensive corroboration of her involvement with Epstein. Can someone please confirm? Thank you all. « File: 080822 Lefkowitz hr to Villafana.pdf >> A. Marie Villafalia Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 Phone 561 209-1047 Fax 561 820-8777 Tracking: 130 EFTA00179940 Recipient Lee. Dexter (USAFLS) 131 Read Read: 8/25/2008 2:17 PM EFTA00179941 Villafana, Ann Marie C. (USAFLS) From: Lee, Dexter (USAFLS) Sent: Monday, August 25, 2008 10:25 AM To: Villafana, Ann Marie C. (USAFLS); Acosta, Alex (USAFLS); Sloman, Jeff (USAFLS); Senior, Robert (USAFLS); Atkinson, Karen (USAFLS) Subject: RE: Letter re Epstein and Protective Order Marie, During our telephonic hearing, I received the clear impression that Judge Marra wanted the other victims (non-parties to the Jane Doe litigation), would be given the opportunity to see the Agreement, subject to each one agreeing to be bound by the protective order. I believe It would be contrary to Judge Marra's Intent for us to go through the trouble of creating a mechanism for the other non-party victims to have access to the Agreement, and then not tell them there is an Agreement. Also, does CVRA impose any obligation on us, independent of what Judge Marra ordered, to advise the victims of the Agreement? Dexter From: VIllafana, Ann Marie C. (MRS) Sent Monday, August 25, 2008 9:48 AM To: Acosta, Alex (USAFLS); Sloman, Jeff (USAFLS); Senior, Robert (USAFLS); Atkinson, Karen (USAFLS); Lee, Dexter (USAFLS) Subject: Letter re Epstein and Protective Order Good morning, everyone. I have attached a letter from Jay Lefkowitz that came in by fax on Friday night. The good news is that they seem to be in agreement regarding Mr. Josefsberg. Most of the letter doesn't really require a comment, but I wanted to get Dexter's feedback regarding the notification to the victims of their right to see the agreement. Here is the language from my proposed victim notification letter: "In addition, a judge has ordered that the United States make available to any designated victim (and/or her attorney) a copy of the actual agreement between Mr. Epstein and the United States, so long as the victim (and/or her attorney) reviews, signs, and agrees to be bound by a Protective Order entered by the Court. If Ms. Robson would like to review the Agreement, please let me know, and I will forward a copy of the Protective Order for her signature." Lefkowitz objects, but I am wondering whether Dexter agrees that the spirit of our discussions with Judge Marra requires such a notification. If we make the entire agreement available to Mr, Josefsberg and he conveys that information to all of his clients, the concern becomes moot, I suppose. Lastly, from my discussion with Bob, it appears that the Office does not want to add to the list the names of victims identified after the date of signing the September agreement unless our investigation had provided enough information that we were prepared to include them in the indictment — i.e., the New York girls — and that you do not want me to re-add Tatum Miller to the list, even though we have extensive corroboration of her involvement with Epstein. Can someone please confirm? 132 EFTA00179942 Thank you all. « File: 080822 Lefkowitz Itr to Villafana.pdf >> A. Marie Villafaila Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 Phone 561 209-1047 Fax 561 820-8777 133 EFTA00179943 Villafana, Ann Marie C. (USAFLS) F ram: Villafana, Ann Marie C. (USAFLS) Sent: Monday, August 25, 2008 9:48 AM To: Acosta, Alex (USAFLS); Stamen, Jeff (USAFLS); Senior, Robed (USAFLS); Atkinson, Karen (USAFLS); Lee, Dexter (USAFLS) Subject: Letter re Epstein and Protective Order Good morning, everyone. have attached a letter from Jay Lefkowitz that came in by fax on Friday night. The good news is that they seem to be in agreement regarding Mr. Josefsberg. Most of the letter doesn't really require a comment, but I wanted to get Dexter's feedback regarding the notification to the victims of their right to see the agreement. Here is the language from my proposed victim notification letter: "In addition, a judge has ordered that the United States make available to any designated victim (and/or her attorney) a copy of the actual agreement between Mr. Epstein and the United States, so long as the victim (and/or her attorney) reviews, signs, and agrees to be bound by a Protective Order entered by the Court. If Ms. Robson would like to review the Agreement, please let me know, and I will forward a copy of the Protective Order for her signature." Lefkowitz objects, but I am wondering whether Dexter agrees that the spirit of our discussions with Judge Main requires such a notification. If we make the entire agreement available to Mr. Josefsberg and he conveys that information to all of his clients, the concern becomes moot, I suppose. Lastly, from my discussion with Bob, it appears that the Office does not want to add to the list the names of victims identified after the date of signing the September agreement unless our investigation had provided enough information that we were prepared to include them in the indictment — i.e., the New York girls — and that you do not want me to re-add Tatum Miller to the list, even though we have extensive corroboration of her involvement with Epstein. Can someone please confirm? Thank you all. 080822 kowitz ltr to Villa A. Marie Villafafia Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 Phone 561 209-1047 Fax 561 820-8777 Tracking: 134 EFTA00179944 Recipient Read Acosta. Alex (USAFLS) Sloman. Jeff (USAFLS) Read: 8125/2008 9:56 AM Senior. Robert (USAFLS) Read: 8/25/2(108 9:49 AM Atkinson. Karen (USAFLS) Lee. Dexter (USAFLS) Read: 8/25/2008 10:11 AM 135 EFTA00179945 Redolent letkowitzekIrkland.com Roy BLACK Atlemon, Karen (USAFLS) Sloman, Jeff (USAFLS) Senior, Robert (USAFLS) Acosta, Alex (USAFLS) 137 Read Read: 6a1/2006 6:35 PM Read: 8/21/2006 6:46 PM EFTA00179946 Villafana, Ann Marie C. (USAFLS) From: Villafana, Ann Marie C. (USAFLS) Sent: Thursday, August 21, 20081:08 PM To: Senior, Robert (USAFLS): Sloman, Jeff (USAFLS) Subject: Emailing: 080820 Villafana Ltr to Lefkowitz and Black w Senior edits.wpd Attachments: 080820 Villafana Ltr to Lefkowitz and Black w Senior edits.wpd Here you go, Bob. Let me know if it looks alright. Thanks. The message is ready to be sent with the following file or link attachments: 080826 Villafana Ltr to Lefkowitz and Black w Senior edits.wpd Note: To protect against computer viruses, e-mail programs may prevent sending or receiving certain types of file attachments. Check your e-mail security settings to determine how attachments are handled. Tracking: 138 EFTA00179947 Recipient Road Senior, Robert (USAFLS) Read: 8121/2008 1:49 PM Sloman. Jed (USAFLS) Read: 8/21/2008 1:10 PM 139 EFTA00179948 Villafana, Ann Marie C. (USAFLS) From: Senior, Robert (USAFLS) Sent: Thursday, August 21, 2008 9:38 AM To: Villafana, Ann Marie C. (USAFLS); Sloman, Jeff (USAFLS) Subject: RE: Are these alright to send out to Jay and Roy? No. Sorry, have been tied up. I looked at everything yesterday but what you wrote and then got busy when your email came. From: Villafana, Ann Marie C. (USAFLS) Sent: Thursday, August 21, 2008 9:29 AM To: Senior, Robert (USAFLS); Sloman, Jeff (USAFLS) Subject: Are these alright to send out to Jay and Roy? <.< File: Amended Final Victim Notification -- Haley Robson final.wpd >> << File: 080820 Villafana Ltr to Lefkowitz and Black.wpd >> A. Marie Villafana Assistant U.S. Attorney 500 S. Australian Aye, Suite 400 West Palm Beach, FL 33401 Phone 561 209-1047 Fax 561 820-8777 140 EFTA00179949 Villafana, Ann Marie C. (USAFLS) From: Villafana, Ann Marie C. (USAFLS) Sent: Thursday, August 21, 2008 9:31 AM To: Lee, Dexter (USAFLS) Subject: Notification to other victims Hi Dexter — This is the language that I intend to include in the new victim notification letters. Can you let me know if it sounds alright? In addition, a judge has ordered that the United States make available to any designated victim (and/or her attorney) a copy of the actual agreement between Mr. Epstein and the United States, so long as the victim (and/or her attorney) reviews, signs, and agrees to be bound by a Protective Order entered by the Court. If Ms. Robson would like to review the Agreement, please let me know, and I will forward a copy of the Protective Order for her signature. A. Marie Villafalla Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 Phone 561 209-1047 Fax 561 820-8777 Tracking: 141 EFTA00179950 Recipient t.ee, Oexter (USARS) 142 Road Read 8/21/2008 9:38 AM EFTA00179951 Villafana, Ann Marie C. (USAFLS) From: Sent: To: Subject: Villafana, Ann Marie C. (USAFLS) Thursday, August 21, 2008 9:29 AM Senior, Robert (USAFLS); Sloman, Jeff (USAFLS) Are these alright to send out to Jay and Roy? Amended Final 380820 Villafana Victim Notificat... ltr to Lefkow... A. Marie Villafatia Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 Phone 561 209-1047 Fax 561 820-8777 Tracking: 143 EFTA00179952 Recipient Road Senior. Robed (USAFLS) Read: 8/21/2008 9:37 AM Sierran, Jeff (USAFLS) Read: 8/21/2008 12.23 PM 1+1 EFTA00179953 Vil!arena, Ann Made C. (USAFLS) From: Roe, Susan (USAWAW) Sent: Wednesday, August 20, 2008 5:54 PM To: Villafana, Ann Marie C. (USAFLS) Subject: sex criminals Hi Ann Marie, Well I'm still working on the Copperfield matter but some of the higher ups are very very uncomfortable with it. One question came up about his connection with Epstein . Do you think Epstein would ever talk or cooperate ? Any provision for that in his state plea agreement? How do I contact his lawyer/the state prosecutor/etc. Thanks and consider yourself lucky, I think, to have your famous offender off of your hands. Good luck with TS/Hurricane Fayl Susie Roe From WDWA but at the Nac this week. 145 EFTA00179954 Villafana, Ann Marie C. (USAFLS) From: Villafana, Ann Marie C. (USAFLS) Sent: Wednesday, August 20, 2008 4:35 PM To: Senior, Robert (USAFLS); Sloman, Jeff (USAFLS); Acosta, Alex (USAFLS); Atkinson, Karen (USAFLS) Subject: Emailing: Amended Final Victim Notification -- Haley Robson final.wpd Attachments: Amended Final Victim Notification -- Haley Robson final.wpd I have attached a draft amended victim notification, which I will enclose with the letter to Jay that I forwarded earlier, Please let me know if you have any questions or changes. Thank you. The message is ready to be sent with the following file or link attachments: Amended Final Victim Notification -- Haley Robson final.wpd Note: To protect against computer viruses, e-mail programs may prevent sending or receiving certain types of file attachments. Check your e-mail security settings to determine how attachments are handled, 146 EFTA00179955 Villafana, Ann Marie C. (USAFLS) From: Villafana, Ann Marie C. (USAFLS) Sent: Wednesday, August 20, 2008 4:25 PM To: Irene_Rivera©fisd.uscourts.gov Subject: RE: Proposed Order in Jane Doe 1 and 2 United States You are the best, my dear! I hope you did alright with the storm. Everyone here did fine. A. Marie Villafana Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 Phone 561 209-1047 Fax 561 820-8777 From: Irenejtivera@flsd.uscourts.gov (mailto:Irene_Rivera@fisd.uscourts.gov] Sent: Wednesday, August 20, 2008 4:20 PM To: Villafana, Ann Marie C. (USAFLS) Subject: Re: Proposed Order in Jane Doe 1 and 2 1 United States No need to refile it. The order is on the judge's desk waking to be signed. Irene Rivera Ferrante Judge Marra's Chambers West Palm Beach, FL (581)514-3765 "Vine, ana, Ann Marie C. (USAFLS)" <Ann.Marlez,V inefanaausdoi.aov> 0812012008 04:14 PM to <Irene Riveraensd.uscourte Goy, cc Subject Proposed Order in Jane Doe 1 and 21 Untied States Hi Irene — Dexter Lee forwarded a proposed protective order in the Jane Doe case on Friday, but we never received a signed order. I think it might be because he didn't formally file it via CM/ECF, so if you want me to re-file it, I will do so right away. Thank you! 147 EFTA00179956 A. Marie Villafaita Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 Phone 561 209-1047 Fax 561 820-8777 148 EFTA00179957 Villafana, Ann Marie C. (USAFLS) From: Villafana, Ann Marie C. (USAFLS) Sent: Wednesday, August 20, 2008 4:13 PM To: Irene_Rivera©fisd,uscourts.gov Subject: Proposed Order in Jane Doe 1 and 211. United States Hi Irene — Dexter Lee forwarded a proposed protective order in the Jane Doe case on Friday, but we never received a signed order. 1 think it might be because he didn't formally file it via CM/ECF, so if you want me to re-file it, I will do so right away. Thank you! A. Marie Villafafla Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 Phone 561 209-1047 Fax 56I 820-8777 149 EFTA00179958 Villafana, Ann Marie C. (USAFLS) From: ViHelena, Ann Marie C. (USAFLS) Sent: Wednesday, August 20, 2008 4:06 PM To: Lee, Dexter (USAFLS) Subject: Did you ever get the signed Protective Order from Judge Marra? Iii Dexter I am wondering if the Protective Order got lost in the shuffle. Let me know and I will contact his CRD to check up on it. Thank you. A. Marie Villafaha Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 Phone 561 209-1047 Fax 561 820-8777 Tracking: 150 EFTA00179959 Recipient lee, Dexter (USAFIS) 151 Read Read: 8f20(2008411 PM EFTA00179960 Villafana, Ann Made C. (USAFLS) From: Villafana, Ann Marie C. (USAFLS) Sent: Wednesday, August 20, 2008 3:47 PM To: Acosta, Alex (USAFLS); Sloman, Jeff (USAFLS); Senior, Robert (USAFLS); Atkinson, Karen (USAFLS) Subject: Emailing: 080820 Villafana Ltr to Lefkowitz and Black.wpd Attachments: 080820 Villafana Ltr to Lefkowitz and Black.wpd I have attached my proposed response to Jay Lefkowitz. Please let me know if you have any changes, I would like to try to get this out today, if possible. The message is ready to be sent with the following file or link attachments: 080820 Villafana Ltr to Lefkowitz and Black.wpd Note: To protect against computer viruses, e-mail programs may prevent sending or receiving certain types of file attachments. Check your e-mail security settings to determine how attachments are handled. Tracking: 152 EFTA00179961 Recipient Acosta, Alex (USAFLS) Sloman. Jeff (USAFLS) Senior, Robert (USAFLS) Atkinson, Karen (USAFLS) 153 Read Read: 8/20/2008 3:50 PM Read: 8/20/2008 4:17 PM EFTA00179962 Villafana, Ann Marie C. (USAFLS) From: Vittafana, Ann Marie C. (USAFLS) Sent: Wednesday, August 20, 2008 9:24 AM To:. Acosta, Alex (USAFLS); Sloman, Jeff (USAFLS); Senior, Robert (USAFLS), Atkinson, Karen (USAFLS) Subject: Response from Jay Letkowitz Hi all -Jay sent this by fax on Monday evening. I am off to mag court, but should be back around 11:30. My first thought is, if they wish to limit the list to those girls identified prior to the signing of the non-pros agreement, that is fine, but then I get to prosecute him on the rest. I am going to send Jay a quick e-mail telling him that I just got his fax because of the closure of the office and I will respond more fully this afternoon or tomorrow morning. 080818 kowitz Ltr to Villa A. Marie Villafafta Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 Phone 561 209-1047 Fax 561 820-8777 Tracking: 160 EFTA00179963 Recipient Acosta, Alex (USAFLS) Slomen, Jeff (USAFLS) Senior, Roben (USAFLS) Atkinson, Karen (USAFLS) Kuyrkendeli. E N (FBI) Richards, Jason R. (FBI) 161 Read Read: 8/20/2008 9:29 AM EFTA00179964 Villafana, Ann Marie C. (USAFLS) From: Villafana, Ann Marie C. (USAFLS) Sent: Wednesday, August 20, 2008 9:24 AM To: Acosta, Alex (USAFLS): Stoman, Jeff (USAFLS); Senior, Robert (USAFLS), Atkinson, Karen (USAFLS) Subject: Response from Jay Lefkowltz Hi all — Jay sent this by fax on Monday evening. I am off to mag court, but should be back around I I :30. My first thought is, if they wish to limit the list to those girls identified prior to the signing of the non-pros agreement, that is fine, but then I get to prosecute him on the rest. I am going to send Jay a quick e-mail telling him that I just got his fax because of the closure of the office and I will respond more fully this afternoon or tomorrow morning. 080818 kowla Ur to Villa A. Marie Villafafta Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 Phone 561 209-1047 Fax 561 820-8777 162 EFTA00179965 Villafana, Arm Marie C. (USAFLS) From: Villafana, Ann Marie C. (USAFLS) Sent: Tuesday, August 19, 2008 12:06 PM To: Sloman, Jeff (USAFLS) Subject: Bob J Hi Jeff, I hope your flight went alright. The wind up here has been awful. The Podhurst firm is closed today so I will try Bob tomorrow morning. Take care. 163 EFTA00179966 Villafana, Ann Marie C. (USAFLS) From: Villafana, Ann Marie C. (USAFLS) Sent: Monday, August 18, 2008 2:54 PM To: Sloman, Jeff (USAFLS) Subject: Are you free? Hi Jeff — I know that Miami is closed, but if you have a moment, can you give me a call at my desk? 561-209- 1047. Thanks. A. Marie Villafaha Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 Phone 561 209-1047 Fax 561 820-8777 Tracking: 164 EFTA00179967 Recipient Sioman. Jett (USAFI.S) t65 Read Read: 8118,2048 2:59 PM EFTA00179968 Villafana, Ann Marie C. (USAFLS) From: Kuyrkendall, E N. (FBI) Sent: Monday, August 18, 2008 12:43 PM To: Villafana, Ann Marie C. (USAFLS) Subject: Re: Victim List Sorry for the delay. I discussed with Jason, we believe that is everyone at least everyone that was forthcoming. It appears a FOIA has been filed. I'm trying to ensure no docs are provided a this time. It appears they were specific wanting JE's employees 302s. From: ViHelena, Ann Marie C. (USAFLS) To: Richards, Jason R.; Kuyrkendall, E N. Sent: Fri Aug 15 12:15:38 2008 Subject: Victim List Hi guys — if we were going to expand our list to include victims we know about but weren't ready to charge in an indictment, who would we include besides Tatum? A. Marie Villafafia Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 Phone 561 209-1047 Fax 561 820-8777 166 EFTA00179969 Villafana, Ann Marie C. (USAFLS) From: Lee, Dexter (USAFLS) Sent: Friday, August 15, 2008 4:53 PM To: Villafana, Ann Marie C. (USAFLS) Subject: FW: Jane Doe # 1 and # illr. United States, Case No. 08-80736-CIV-MARRA/JOHNSON Marie, I filed this earlier this afternoon. Dexter From: Lee, Dexter (USAFLS) Sent: Friday, August 15, 2008 3:23 PM To: imarra@fisd.uscoucts.gme Subject: Jane Doe # 1 and # 4. United States, Case No. 08-80736-C1V-MARRA/JOHNSON Hon. Kenneth A. Marra United States District Judge Dear Judge Marra: Pursuant to the Court's direction at the conclusion of yesterdays Status Conference, attached please find a proposed Order to Produce and Protective Order which has been reviewed and agreed to by counsel for petitioners and the government. Respectfully, Dexter A. Lee Assistant U.S. Attorney Protective Order_final.wpd 167 EFTA00179970 Villafana, Ann Marie C. (USAFLS) From: Villafana, Ann Marie C. (USAFLS) Sent: Friday, August 15, 2008 4:51 PM To: Lee, Dexter (USAFLS) Subject: Filing the proposed order Hi Dexter— Are you going to file the proposed order? If not, please e-mail whatever the final, final is and I will file it with the Court. Thanks. A. Marie VillafaRa Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 Phone 561 209-1047 Fax 561 820-8777 168 EFTA00179971 Villafana, Ann Marie C. (USAFLS) From: Villafana, Ann Marie C. (USAFLS) Sent: Friday, August 15, 2008 4:51 PM To: Stoman, Jeff (USAFLS) Subject: Got your message Sounds like good news. I'll call you on Monday unless a firestorm breaks over the weekend. .4. Marie Villafaha Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 Phone 561 209-1047 Fax 561 820-8777 Tracking: 169 EFTA00179972 Recipient Sloman, ae11(USAFLS) 170 Read Read: 8/15/2008 4:51 PM EFTA00179973 Recipient lelkowitz@klikland.com Roy BLACK Atkinson, Karen (USAFLS) Acosta, Alex (USAFLS) Stornan. Jeff (USAFLS) Senior, Robert (USAFLS) Lee. Dexter (USAFLS) 176 Road Read: 8/15/2008 2'13 PM Read: 8/15/2008 2:24 PM EFTA00179974 Villafana, Ann Marie C. (USAFLS) From: Lee, Dexter (USAFLS) Sent: Friday, August 15, 2008 2:05 PM To: Villafana, Ann Marie C. (USAFLS) Cc: Sloman, Jeff (USAFLS) Subject: RE: New proposed response to Jay Something which is a nullity lacks any legal import. If it has been withdrawn, then the item had import at one time, but it no longer does. If the December 2007 letter is viewed as an offer, there was no acceptance, or it has been rejected. Consequently, the offer no longer has an legal import. We are obligated to provide a copy of the non-prosecution agreement to petitioners, whatever that agreement is. If the December 2007 letter never became a part of the agreement, and the government and Epstein are in agreement as to that issue, then we can produce the September 2007 agreement and the addendum. Are we at that point? Dexter Original Message From: Villafana, Ann Marie C. (USAFLS) Sent: Friday, August 15, 2008 1:54 PM To: Lee, Dexter (USAFLS) Cc: Sloman, Jeff (USAFLS) Subject: FW: New proposed response to Jay Importance: High Dexter -- If we call it "a nullity" instead of "withdrawn" how does that affect the issue with the Jane Does? A. Marie Villafaha Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 Phone 561 209-1047 Fax 561 820-8777 Original Message From: Sloman, Jeff (USAFLS) Sent: Friday, August 15, 2008 1:52 PM To: Villafana, Ann Marie C. (USAFLS); Senior, Robert (USAFLS); Acosta, Alex (USAFLS); Lee, Dexter (USAFLS); Atkinson, Karen (USAFLS) Subject: RE: New proposed response to Jay Marie, Please substitute the word "withdrawn" in the first sentence with "a nullity" 179 EFTA00179975 Jeff Original Message From: Villafana, Ann Marie C. (USAFLS) Sent: Friday, August 15, 2008 1:49 PM To: Senior, Robert (USAFLS); Acosta, Alex (USAFLS); Sloman, Jeff (USAFLS); Lee, Dexter (USAFLS); Atkinson, Karen (USAFLS) Subject: RE: New proposed response to Jay Here is my proposal after speaking with Jeff. Dear Jay and Roy: Thank you for your response to my earlier e-mail. Our communications with Mr. Black and later with Mr. Lefkowitz were solely to determine what Mr. Epstein considered to be the terms of the Non-Prosecution Agreement. We appreciate your answering our question with finality. You have now made clear that Mr. Epstein did not accept the December modification, and accordingly, the offer to make that modification is hereby withdrawn. Pursuant to our Agreement, I will prepare an Amended Notification that contains the names of additional identified victims. As you know, Judge Davis had selected the Podhurst firm to serve as the attorney representative for the victims. Assuming that Mr. Josefsberg is still amenable to the appointment, we will provide him with the victim list so that he may begin his service. Finally, as you are aware, the United States has been ordered to produce the Non-Prosecution Agreement. In accordance with that Order, we will produce the September Agreement with the October Addendum signed by your client. We understand that Mr. Goldberger did not provide the state court with a true copy of the complete Agreement, and he should take steps to correct that error. A. Marie Villafana Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 Phone 561 209-1047 Fax 561 820-8777 Original Message From: Senior, Robert (USAFLS) Sent: Friday, August 15, 2008 1:34 PM To: Acosta, Alex (USAFLS); Villafana, Ann Marie C. (USAFLS); Sloman, Jeff (USAFLS); Lee, Dexter (USAFLS); Atkinson, Karen (USAFLS) Subject: Re: New proposed response to Jay Shouldn't we formally withdraw the offer as opposed to considering it a nullity ? 180 EFTA00179976 Original Message From: Acosta, Alex (USAFLS) To: Villafana, Ann Marie C. (USAFLS); Sloman, Jeff (USAFLS); Senior, Robert (USAFLS); Lee, Dexter (USAFLS); Atkinson, Karen (USAFLS) Sent: Fri Aug 15 11:55:13 2008 Subject: RE: New proposed response to Day How about a slightly different version: Thank you for your response. Our communications with Roy Black and later with you were solely to determine what Mr. Epstein considered to be the terms of the Non-Prosecution Agreement. We appreciate your answering our question with finality. You have now made clear that Mr. Epstein did not accept the December modification, and accordingly, we will now consider that modification to be a nullity. Pursuant to our Agreement, I will prepare an Amended Notification that contains the name of additional identified victims. In accordance with Paragraph 78, please provide me with a proposed written submission to the Special Master by Monday afternoon. Finally, as you are aware, yhe United States has been ordered to produce the NonProsecution Agreement. In accordance with that Order, we will produce the September Agreement with the October Addendum signed by your client. We understand that Mr. Goldberg may not have provided the state court with a true copy of the complete Agreement, and he should take steps to correct that error. From: Villafana, Ann Marie C. (USAFLS) Sent: Friday, August 15, 2008 11:42 AM To: Acosta, Alex (USAFLS); Sloman, Jeff (USAFLS); Senior, Robert (USAFLS); Lee, Dexter (USAFLS); Atkinson, Karen (USAFLS) Subject: New proposed response to Jay Dear Day: Thank you for your response. Our communications with Roy Black and later with you were solely to determine what Mr. Epstein considered to be the terms of the Non-Prosecution Agreement. You have now made clear that Mr. Epstein did not accept the December modification and does not intend to perform the obligations set forth therein. The Office is not going to continue negotiating the terms of the Agreement. We only sought finality and you have answered our question. Accordingly, the December proposed modification is hereby withdrawn. The United States has been ordered to produce the Non-Prosecution Agreement and, in accordance with that Order, will produce the September Agreement with the October Addendum signed by your client. Mr. Goldberger should be advised that we 181 EFTA00179977 understand he has not provided the state court with a true copy of the complete Agreement, and he should take steps to correct that error. I will prepare an Amended Notification that contains the name of additional identified victims and will provide that to you promptly. In accordance with Paragraph 7B of the Agreement, please provide me with a proposed written submission to the Special Master by Monday afternoon. We will expect a showing of good faith in the selection of the attorney representative and all other terms of the Agreement and excessive delays, like those that have occurred in the past, will be considered a breach of that duty of good faith. Sincerely, A. Marie Villafaha Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 Phone 561 209-1047 Fax 561 820-8777 182 EFTA00179978 Villafana, Ann Marie C. (USAFLS) From: Villafana, Ann Marie C. (USAFLS) Sent: Friday, August 15, 2008 1:54 PM To: Lee, Dexter (USAFLS) Cc: Sloman, Jeff (USAFLS) Subject: FW: New proposed response to Jay Importance: High Dexter -- If we call it "a nullity" instead of "withdrawn" how does that affect the issue with the Jane Does? A. Marie Villafana Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 Phone 561 209-1047 Fax 561 820-8777 Original Message From: Sloman, Jeff (USAFLS) Sent: Friday, August 15, 2008 1:52 PM To: Villafana, Ann Marie C. (USAFLS); Senior, Robert (USAFLS); Acosta, Alex (USAFLS); Lee, Dexter (USAFLS); Atkinson, Karen (USAFLS) Subject: RE: New proposed response to Jay Marie, Please substitute the word "withdrawn" in the first sentence with "a nullity" Jeff Original Message From: Villafana, Ann Marie C. (USAFLS) Sent: Friday, August 15, 2008 1:49 PM To: Senior, Robert (USAFLS); Acosta, Alex (USAFLS); Sloman, Jeff (USAFLS); Lee, Dexter (USAFLS); Atkinson, Karen (USAFLS) Subject: RE: New proposed response to Jay Here is my proposal after speaking with Jeff. Dear Jay and Roy: Thank you for your response to my earlier e-mail. Our communications with Mr. Black and later with Mr. Lefkowitz were solely to determine what Mr. Epstein considered to be the terms of the Non-Prosecution Agreement. We appreciate your answering our question with finality. You have now made clear that Mr. Epstein 183 EFTA00179979 did not accept the December modification, and accordingly, the offer to make that modification is hereby withdrawn. Pursuant to our Agreement, I will prepare an Amended Notification that contains the names of additional identified victims. As you know, Judge Davis had selected the Podhurst firm to serve as the attorney representative for the victims. Assuming that Mr. Josefsberg is still amenable to the appointment, we will provide him with the victim list so that he may begin his service. Finally, as you are aware, the United States has been ordered to produce the Non-Prosecution Agreement. In accordance with that Order, we will produce the September Agreement with the October Addendum signed by your client. We understand that Mr. Goldberger did not provide the state court with a true copy of the complete Agreement, and he should take steps to correct that error. A. Marie Villafaha Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 Phone 561 209-1047 Fax 561 820-8777 Original Message From: Senior, Robert (USAFLS) Sent: Friday, August 15, 2008 1:34 PM To: Acosta, Alex (USAFLS); Villafana, Ann Marie C. (USAFLS); Sloman, Jeff (USAFLS); Lee, Dexter (USAFLS); Atkinson, Karen (USAFLS) Subject: Re: New proposed response to Jay Shouldn't we formally withdraw the offer as opposed to considering it a nullity ? Original Message From: Acosta, Alex (USAFLS) To: Villafana, Ann Marie C. (USAFLS); Sloman, Jeff (USAFLS); Senior, Robert (USAFLS); Lee, Dexter (USAFLS); Atkinson, Karen (USAFLS) Sent: Fri Aug 15 11:55:13 2008 Subject: RE: New proposed response to Jay How about a slightly different version: Thank you for your response. Our communications with Roy Black and later with you were solely to determine what Mr. Epstein considered to be the terms of the Non-Prosecution Agreement. We appreciate your answering our question with finality. You have now made clear that Mr. Epstein did not accept the December modification, and accordingly, we will now consider that modification to be a nullity. Pursuant to our Agreement, I will prepare an Amended Notification that contains the name of additional identified victims. In accordance with Paragraph 76, lel EFTA00179980 please provide me with a proposed written submission to the Special Master by Monday afternoon. Finally, as you are aware, yhe United States has been ordered to produce the NonProsecution Agreement. In accordance with that Order, we will produce the September Agreement with the October Addendum signed by your client. We understand that Mr. Goldberg may not have provided the state court with a true copy of the complete Agreement, and he should take steps to correct that error. From: Villafana, Ann Marie C. (USAFLS) Sent: Friday, August 15, 2008 11:42 AM To: Acosta, Alex (USAFLS); Sloman, Jeff (USAFLS); Senior, Robert (USAFLS); Lee, Dexter (USAFLS); Atkinson, Karen (USAFLS) Subject: New proposed response to Jay Dear Jay: Thank you for your response. Our communications with Roy Black and later with you were solely to determine what Mr. Epstein considered to be the terms of the Non-Prosecution Agreement. You have now made clear that Mr. Epstein did not accept the December modification and does not intend to perform the obligations set forth therein. The Office is not going to continue negotiating the terms of the Agreement. We only sought finality and you have answered our question. Accordingly, the December proposed modification is hereby withdrawn. The United States has been ordered to produce the Non-Prosecution Agreement and, in accordance with that Order, will produce the September Agreement with the October Addendum signed by your client. Mr. Goldberger should be advised that we understand he has not provided the state court with a true copy of the complete Agreement, and he should take steps to correct that error. I will prepare an Amended Notification that contains the name of additional identified victims and will provide that to you promptly. In accordance with Paragraph 7B of the Agreement, please provide me with a proposed written submission to the Special Master by Monday afternoon. We will expect a showing of good faith in the selection of the attorney representative and all other terms of the Agreement and excessive delays, like those that have occurred in the past, will be considered a breach of that duty of good faith. Sincerely, A. Marie Villafaha Assistant U.S. Attorney 500 5. Australian Ave, Suite 400 West Palm Beach, FL 33401 Phone 561 209-1047 185 EFTA00179981 Fax 561 820-8777 Tracking: 186 EFTA00179982 Recipient Read Lee, Oozier (USAFLS) Read: 811 5/2008 1:55 PM Stamen, Jeff (USAFLS) Read: 8/15/2008 1:57 PM 187 EFTA00179983 Villafana, Ann Marie C. (USAFLS) From: Sloman, Jeff (USAFLS) Sent: Friday, August 15, 2008 1:52 PM To: Villafana, Ann Marie C. (USAFLS); Senior, Robert (USAFLS); Acosta, Alex (USAFLS); Lee, Dexter (USAFLS); Atkinson, Karen (USAFLS) Subject: RE: New proposed response to Jay Marie, Please substitute the word "withdrawn" in the first sentence with "a nullity" Jeff Original Message From: Villafana, Ann Marie C. (USAFLS) Sent: Friday, August 15, 2008 1:49 PM To: Senior, Robert (USAFLS); Acosta, Alex (USAFLS); Sloman, Jeff (USAFLS); Lee, Dexter (USAFLS); Atkinson, Karen (USAFLS) Subject: RE: New proposed response to Jay Here is my proposal after speaking with Jeff. Dear Jay and Roy: Thank you for your response to my earlier e-mail. Our communications with Mr. Black and later with Mr. Lefkowitz were solely to determine what Mr. Epstein considered to be the terms of the Non-Prosecution Agreement. We appreciate your answering our question with finality. You have now made clear that Mr. Epstein did not accept the December modification, and accordingly, the offer to make that modification is hereby withdrawn. Pursuant to our Agreement, I will prepare an Amended Notification that contains the names of additional identified victims. As you know, Judge Davis had selected the Podhurst firm to serve as the attorney representative for the victims. Assuming that Mr. Josefsberg is still amenable to the appointment, we will provide him with the victim list so that he may begin his service. Finally, as you are aware, the United States has been ordered to produce the Non-Prosecution Agreement. In accordance with that Order, we will produce the September Agreement with the October Addendum signed by your client. We understand that Mr. Goldberger did not provide the state court with a true copy of the complete Agreement, and he should take steps to correct that error. A. Marie Villafana Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 Phone 561 209-1047 Fax 561 820-8777 188 EFTA00179984 Original Message From: Senior, Robert (USAFLS) Sent: Friday, August 15, 2008 1:34 PM To: Acosta, Alex (USAFLS); Villafana, Ann Marie C. (USAFLS); Sloman, Jeff (USAFLS); Lee, Dexter (USAFLS); Atkinson, Karen (USAFLS) Subject: Re: New proposed response to Jay Shouldn't we formally withdraw the offer as opposed to considering it a nullity ? Original Message From: Acosta, Alex (USAFLS) To: Villafana, Ann Marie C. (USAFLS); Sloman, Jeff (USAFLS); Senior, Robert (USAFLS); Lee, Dexter (USAFLS); Atkinson, Karen (USAFLS) Sent: Fri Aug 15 11:55:13 2008 Subject: RE: New proposed response to Jay How about a slightly different version: Thank you for your response. Our communications with Roy Black and later with you were solely to determine what Mr. Epstein considered to be the terms of the Non-Prosecution Agreement. We appreciate your answering our question with finality. You have now made clear that Mr. Epstein did not accept the December modification, and accordingly, we will now consider that modification to be a nullity. Pursuant to our Agreement, I will prepare an Amended Notification that contains the name of additional identified victims. In accordance with Paragraph 76, please provide me with a proposed written submission to the Special Master by Monday afternoon. Finally, as you are aware, yhe United States has been ordered to produce the NonProsecution Agreement. In accordance with that Order, we will produce the September Agreement with the October Addendum signed by your client. We understand that Mr. Goldberg may not have provided the state court with a true copy of the complete Agreement, and he should take steps to correct that error. From: Villafana, Ann Marie C. (USAFLS) Sent: Friday, August 15, 2008 11:42 AM To: Acosta, Alex (USAFLS); Sloman, Jeff (USAFLS); Senior, Robert (USAFLS); Lee, Dexter (USAFLS); Atkinson, Karen (USAFLS) Subject: New proposed response to Jay Dear Jay: 189 EFTA00179985 Thank you for your response. Our communications with Roy Black and later with you were solely to determine what Mr. Epstein considered to be the terms of the Non-Prosecution Agreement. You have now made clear that Mr. Epstein did not accept the December modification and does not intend to perform the obligations set forth therein. The Office is not going to continue negotiating the terms of the Agreement. We only sought finality and you have answered our question. Accordingly, the December proposed modification is hereby withdrawn. The United States has been ordered to produce the Non-Prosecution Agreement and, in accordance with that Order, will produce the September Agreement with the October Addendum signed by your client. Mr. Goldberger should be advised that we understand he has not provided the state court with a true copy of the complete Agreement, and he should take steps to correct that error. I will prepare an Amended Notification that contains the name of additional identified victims and will provide that to you promptly. In accordance with Paragraph 7B of the Agreement, please provide me with a proposed written submission to the Special Master by Monday afternoon. We will expect a showing of good faith in the selection of the attorney representative and all other terms of the Agreement and excessive delays, like those that have occurred in the past, will be considered a breach of that duty of good faith. Sincerely, A. Marie Villafana Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 Phone 561 209-1047 Fax 561 820-8777 190 EFTA00179986 Villafana, Ann Marie C. (USAFLS) From: Villafana, Ann Marie C. (USAFLS) Sent: Friday, August 15, 2008 1:49 PM To: Senior, Robert (USAFLS); Acosta, Alex (USAFLS); Sloman, Jeff (USAFLS); Lee, Dexter (USAFLS); Atkinson, Karen (USAFLS) Subject: RE: New proposed response to Jay Here is my proposal after speaking with Jeff. Dear Jay and Roy: Thank you for your response to my earlier e-mail. Our communications with Mr. Black and later with Mr. Lefkowitz were solely to determine what Mr. Epstein considered to be the terms of the Non-Prosecution Agreement. We appreciate your answering our question with finality. You have now made clear that Mr. Epstein did not accept the December modification, and accordingly, the offer to make that modification is hereby withdrawn. Pursuant to our Agreement, I will prepare an Amended Notification that contains the names of additional identified victims. As you know, Judge Davis had selected the Podhurst firm to serve as the attorney representative for the victims. Assuming that Mr. Josefsberg is still amenable to the appointment, we will provide him with the victim list so that he may begin his service. Finally, as you are aware, the United States has been ordered to produce the Non-Prosecution Agreement. In accordance with that Order, we will produce the September Agreement with the October Addendum signed by your client. We understand that Mr. Goldberger did not provide the state court with a true copy of the complete Agreement, and he should take steps to correct that error. A. Marie Villafaha Assistant U.S. Attorney 500 S. Australian Ave Suite 400 West Palm Beach, FL 33401 Phone 561 209-1047 Fax 561 820-8777 Original Message From: Senior, Robert (USAFLS) Sent: Friday, August 15, 2008 1:34 PM To: Acosta, Alex (USAFLS); Villafana, Ann Marie C. (USAFLS); Sloman, Jeff (USAFLS); Lee, Dexter (USAFLS); Atkinson, Karen (USAFLS) Subject: Re: New proposed response to Jay Shouldn't we formally withdraw the offer as opposed to considering it a nullity ? Original Message From: Acosta, Alex (USAFLS) 191 EFTA00179987 To: Villafana, Ann Marie C. (USAFLS); Sloman, Jeff (USAFLS); Senior, Robert (USAFLS); Lee, Dexter (USAFLS); Atkinson, Karen (USAFLS) Sent: Fri Aug 15 11:55:13 2008 Subject: RE: New proposed response to Jay How about a slightly different version: Thank you for your response. Our communications with Roy Black and later with you were solely to determine what Mr. Epstein considered to be the terms of the Non-Prosecution Agreement. We appreciate your answering our question with finality. You have now made clear that Mr. Epstein did not accept the December modification, and accordingly, we will now consider that modification to be a nullity. Pursuant to our Agreement, I will prepare an Amended Notification that contains the name of additional identified victims. In accordance with Paragraph 76, please provide me with a proposed written submission to the Special Master by Monday afternoon. Finally, as you are aware, yhe United States has been ordered to produce the NonProsecution Agreement. In accordance with that Order, we will produce the September Agreement with the October Addendum signed by your client. We understand that Mr. Goldberg may not have provided the state court with a true copy of the complete Agreement, and he should take steps to correct that error. From: Villafana, Ann Marie C. (USAFLS) Sent: Friday, August 15, 2008 11:42 AM To: Acosta, Alex (USAFLS); Sloman, Jeff (USAFLS); Senior, Robert (USAFLS); Lee, Dexter (USAFLS); Atkinson, Karen (USAFLS) Subject: New proposed response to Jay Dear Jay: Thank you for your response. Our communications with Roy Black and later with you were solely to determine what Mr. Epstein considered to be the terms of the Non-Prosecution Agreement. You have now made clear that Mr. Epstein did not accept the December modification and does not intend to perform the obligations set forth therein. The Office is not going to continue negotiating the terms of the Agreement. We only sought finality and you have answered our question. Accordingly, the December proposed modification is hereby withdrawn. The United States has been ordered to produce the Non-Prosecution Agreement and, in accordance with that Order, will produce the September Agreement with the October Addendum signed by your client. Mr. Goldberger should be advised that we understand he has not provided the state court with a true copy of the complete Agreement, and he should take steps to correct that error. I will prepare an 192 EFTA00179988 Amended Notification that contains the name of additional identified victims and will provide that to you promptly. In accordance with Paragraph 7B of the Agreement, please provide me with a proposed written submission to the Special Master by Monday afternoon. We will expect a showing of good faith in the selection of the attorney representative and all other terms of the Agreement and excessive delays, like those that have occurred in the past, will be considered a breach of that duty of good faith. Sincerely, A. Marie Villafaha Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 Phone 561 209-1047 Fax 561 820-8777 Tracking: 193 EFTA00179989 Recipient Read Senior, Robed (USAFLS) Read: 8/16/2008 1:55 PM Acosta, A/ex (USAFLS) Read: 8/15/20081:51 PM Sloman, Jeff (USAFLS) Read: 8/15/2008 1:49 PM Lee, Dexter (USAFLS) Read: 8/15/2008 1:54 PM Atkinson. Karen (USAFLS) 194 EFTA00179990