EFTA00179991

u • ect: Well, our victim notification letter has been filed in court Our victim notification letter has been filed in court in connection with one of the federal civil suits against Epstein. About 10 letters have gone out so far. The FBI's victim coordinator is updating the addresses on the rest and they will go out on Monday. Tracking: 445 EFTA00179991 Recipient Read Sloman, Jett (USAFLS) Read: 7/18/2008 4:63 PM Lee, Dexter (USAFLS) Read: 711812008 4:51 PM Kuyrkendall, E N. (FBI) Richards, Jason R. (FBI) Atkinson. Karen (USAFLS) 446 EFTA00179992 Villafana, Ann Marie C. (USAFLS) From: Villafana, Ann Marie C. (USAFLS) Sent: Thursday, July 17, 2008 6:22 PM To: Sloman, Jeff (USAFLS); Acosta, Alex (USAFLS); Atkinson, Karen (USAFLS) Cc: Richards, Jason (BOP); Nesbitt Kuyrkendall (E.Kuyrkendall@ic.fbi.gov) Subject: Tein Ltr 080717.pdf Hi all — I just faxed out the letter, here is the electronic version with the fax confirmation sheets. Tein Ltr 080717.pdf 447 EFTA00179993 Villafana, Ann Marie C. (USAFLS) From: Sent: To: Subject: Okey dokey. Sloman, Jeff (USAFLS) Thursday. July 17, 2008 3:11 PM Villafana, Ann Marie C. (USAFLS) RE: Emailing: 080717 Tein Ltr.wpd Original Message From: Villafana, Ann Marie C. (USAFLS) Sent: Thursday, July 17, 2008 3:02 PM To: Sloman, Jeff (USAFLS) Subject: Re: Emailing: 080717 Tein Ltr.wpd Hi jeff. I am still being held hostage at the county courthouse but I will revise and send tonight. Thanks. Original Message From: Sloman, Jeff (USAFLS) To: Villafana, Ann Marie C. (USAFLS); Acosta, Alex (USAFLS); Atkinson, Karen (USAFLS); Lee, Dexter (USAFLS) Sent: Thu Jul 17 14:51:28 2008 Subject: RE: Emailing: 080717 Tein Ltr.wpd Marie, Tein may be technically may be able Jeff trying to bait us into deferred/suspended. As to color in a bit. Let declaring the matter closed when it's a result, I've revised your draft which you me know what you think. Thanks, Original Message From: Villafana, Ann Marie C. (USAFLS) Sent: Thursday, July 17, 2008 11:38 AM To: Acosta, Alex (USAFLS); Sloman, Jeff (USAFLS); Atkinson, Karen (USAFLS); Lee, Dexter (USAFLS) Subject: Emailing: 080717 Tein Ltr.wpd Original Message From: Villafana, Ann Marie C. (USAFLS) Sent: Thursday, July 17, 2008 11:38 AM To: Acosta, Alex (USAFLS); Sloman, Jeff (USAFLS); Atkinson, Karen (USAFLS); Lee, Dexter (USAFLS) Subject: Emailing: 080717 Tein Ltr.wpd 448 EFTA00179994 Here it is. Feel free to revise. I have listed myself as the author, but it may be more powerful coming from someone else. The message is ready to be sent with the following file or link attachments: 080717 Tein Ltr.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. 449 EFTA00179995 Villafana, Ann Marie C. (USAFLS) From: Villafana, Ann Marie C. (USAFLS) Sent: Thursday, July 17, 2008 3:02 PM To: Sloman, Jeff (USAFLS) Subject: Re: Emailing: 080717 Tein Ltr.wpd Hi Jeff. I am still being held hostage at the county courthouse but I will revise and send tonight. Thanks. Original Message From: Sloman, Jeff (USAFLS) To: Villafana, Ann Marie C. (USAFLS); Acosta, Alex (USAFLS); Atkinson, Karen (USAFLS); Lee, Dexter (USAFLS) Sent: Thu Jul 17 14:51:28 2008 Subject: RE: Emailing: 080717 Tein Ltr.wpd Marie, Tein may be trying to bait us into declaring the matter closed when it's technically deferred/suspended. As a result, I've revised your draft which you may be able to color in a bit. Let me know what you think. Thanks, Jeff Original Message From: Villafana, Ann Marie C. (USAFLS) Sent: Thursday, July 17, 2008 11:38 AM To: Acosta, Alex (USAFLS); Sloman, Jeff (USAFLS); Atkinson, Karen (USAFLS); Lee, Dexter (USAFLS) Subject: Emailing: 080717 Tein Ltr.wpd Original Message From: Villafana, Ann Marie C. (USAFLS) Sent: Thursday, July 17, 2008 11:38 AM To: Acosta, Alex (USAFLS); Sloman, Jeff (USAFLS); Atkinson, Karen (USAFLS); Lee, Dexter (USAFLS) Subject: Emailing: 080717 Tein Ltr.wpd Here it is. Feel free to revise. I have listed myself as the author, but it may be more powerful coming from someone else. The message is ready to be sent with the following file or link attachments: 080717 Tein Ltr.wpd 450 EFTA00179996 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. 451 EFTA00179997 Villafana, Ann Marie C. (USAFLS) From: Villafana, Ann Marie C. (USAFLS) Sent: Thursday, July 17, 2008 1:31 PM To: Sloman, Jeff (USAFLS) Subject: Funny epstein story Well, jeff, epstein's pricey lawyers may have cost him $200 million. I reviewed the docket sheets for the 4 pending federal suits (they are all Jeff herman suits) and judge marra has issued orders to show cause why default judgments shouldn't be entered for all 4. Herman asked for $50 million in each one. Apparently epstein tried to avoid service and ignored the deadline when the complaints were mailed to him (thinking that was ineffective service). All I can say is, so much money, so little skill. 452 EFTA00179998 Villafana, Ann Marie C. (USAFLS) From: ViHelena, Ann Marie C. (USAFLS) Sent: Thursday, July 17, 2008 11:38 AM To: Acosta, Alex (USAFLS); Sloman, Jeff (USAFLS); Atkinson, Karen (USAFLS); Lee, Dexter (USAFLS) Subject: Emailing: 080717 Tein Ltr.wpd Attachments: 080717 Tein Ltr.wpd Here it is. Feel free to revise. I have listed myself as the author, but it may be more powerful coming from someone else. The message is ready to be sent with the following file or link attachments: 080717 Tein Ltr.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. 453 EFTA00179999 Villafana, Ann Marie C. (USAFLS) From: Villafana, Ann Marie C. (USAFLS) Sent: Thursday, July 17, 2008 10:14 AM To: Acosta, Alex (USAFLS) Subject: RE: Epstein's Court Filings Do you want to call me or should I call you? 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: Acosta, Alex (USAFLS) Sent: Thursday, July 17, 2008 9:49 AM To: Villafana, Ann Marie C. (USAFLS); Lee, Dexter (USAFLS); Sloman, Jeff (USAFLS); Castillo, Annette (USAFLS) Cc: Atkinson, Karen (USAFLS); Kuyrkendall, E N. (FBI); Richards, Jason R. (FBI) Subject: Re: Epstein's Court Filings Let's talk at 10 15. Original Message From: Villafana, Ann Marie C. (USAFLS) To: Lee, Dexter (USAFLS); Acosta, Alex (USAFLS); Sloman, Jeff (USAFLS) Cc: Atkinson, Karen (USAFLS); Kuyrkendall, E N. (FBI); Richards, Jason R. (FBI) Sent: Thu Jul 17 09:44:08 2008 Subject: Epstein's Court Filings Hi all - Here are the documents that Mike Tein filed in connection with one of the civil suits pending against Epstein in the District Court. Note that Judge Marra is assigned to all of the federal civil suits, and also is the judge on the suit filing against the United States. Tein filed these ex parte and under seal and claims that all of the civil litigation has to be stayed because "the federal criminal action" is still pending. He discloses that a federal indictment had been prepared and that grand jury proceedings had occurred. I am concerned that this contradicts what Dexter told the Court, namely that a federal prosecution was never contemplated. «DE24_080717_Notice of Pendency of Federal Case.pdf» «DE23_080717_Motn to File Ex Parte and Under Seal.pdf» A. Marie Villafaha Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 454 EFTA00180000 West Palm Beach, FL 33401 Phone 561 209-1047 Fax 561 820-8777 Tracking: 455 EFTA00180001 Recipient Acosta, Alex (USAF LS) Road Read: 7117(2008 10.21 AM 456 EFTA00180002 Villafana, Ann Marie C. (USAFLS) From: Villafana, Ann Marie C. (USAFLS) Sent: Thursday, July 17, 2008 10:01 AM To: Lee, Dexter (USAFLS) Subject: RE: Epstein's Court Filings Hey Dexter. I told Irene about Mr. Edwards' vacation, so all is well on that front. A. Marie ViOa%arJrr 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: Thursday, July 17, 2008 9:54 AM To: Villafana, Ann Mane C. (USAFLS); Acosta, Alex (USAFLS); Sloman, Jeff (USAFLS) Cc: Atkinson, Karen (USAFLS); Kuyrkendall, E N. (FBI); Richards, Jason R. (FBI) Subject: RE: Epstein's Court Filings My recollection is that I told the court no federal prosecution was contemplated by either party, in the event an agreement could be reached. We acknowledged at the hearing that the case had been referred to our office, and the FBI had conducted an investigation. I was attempting to distinguish Dean , where both the U.S. Attorney's Office and British Petroleum were negotiating a plea agreement, but it was clear there was going to be a federal prosecution, whether by a plea agreement or a litigated trial. Dexter From: Villafana, Ann Marie C. (USAFLS) Sent: Thursday, July 17, 2008 9:44 AM To: Lee, Dexter (USAFLS); Acosta, Alex (USAFLS); Sloman, Jeff (USAFLS) Cc: Atkinson, Karen (USAFLS); Kuyrkendall, E N. (FBI); Richards, Jason R. (FBI) Subject: Epstein's Court Filings Ili all — Here are the documents that Mike Tein filed in connection with one of the civil suits pending against Epstein in the District Court. Note that Judge Marra is assigned to all of the federal civil suits, and also is the judge on the suit filing against the United States. Tein filed these ex parte and under seal and claims that all of the civil litigation has to be stayed because "the federal criminal action" is still pending. He discloses that a federal indictment had been prepared and that grand jury proceedings had occurred. I am concerned that this contradicts what Dexter told the Court, namely that a federal prosecution was never contemplated. << File: DE24_080717 Notice of Pendency of Federal Casc.pdf >> << File: DE23_080717_Motn to File Ex Parte and Under Seal.pd—f >> 457 EFTA00180003 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: 458 EFTA00180004 Recipient Lee. Dexter (USAFLS) Road Read: 7117/2008 10:03 AM 459 EFTA00180005 Villafana, Ann Marie C. (USAFLS) From: Lee, Dexter (USAFLS) Sent: Thursday, July 17, 2008 9:54 AM To: Villafana, Ann Marie C. (USAFLS); Acosta, Alex (USAFLS); Sloman, Jeff (USAFLS) Cc: Atkinson, Karen (USAFLS); Kuyrkendall, E N. (FBI); Richards, Jason R. (FBI) Subject: RE: Epstein's Court Filings My recollection is that I told the court no federal prosecution was contemplated by either party, in the event an agreement could be reached. We acknowledged at the hearing that the case had been referred to our office, and the FBI had conducted an investigation. I was attempting to distinguish Dean,, where both the U.S. Attorney's Office and British Petroleum were negotiating a plea agreement, but it was clear there was going to be a federal prosecution, whether by a plea agreement or a litigated trial. Dexter From: Villafana, Ann Marie C. (USAFLS) Sent: Thursday, July 17, 2008 9:44 AM To: Lee, Dexter (USAFLS); Acosta, Alex (USAFLS); Sloman, Jeff (USAFLS) Cc: Atkinson, Karen (USAFLS); Kuyrkendall, E N. (FBI); Richards, Jason IL (FBI) Subject: Epstein's Court Filings Hi all — Here are the documents that Mike Tein filed in connection with one of the civil suits pending against Epstein in the District Court. Note that Judge Marra is assigned to all of the federal civil suits, and also is the judge on the suit filing against the United States. Tein filed these ex parte and under seal and claims that all of the civil litigation has to be stayed because "the federal criminal action" is still pending. He discloses that a federal indictment had been prepared and that grand jury proceedings had occurred. I am concerned that this contradicts what Dexter told the Court, namely that a federal prosecution was never contemplated. << File: DE24_080717_Notice of Pendency of Federal Case.pdf» << File: DE23_080717_Motn to File Ex Pane and Under Seal.pdf >> 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 460 EFTA00180006 Villafana, Ann Marie C. (USAFLS) From: Acosta, Alex (USAFLS) Sent: Thursday, July 17, 2008 9:49 AM To: Villafana, Ann Marie C. (USAFLS); Lee, Dexter (USAFLS); Sloman, Jeff (USAFLS); Castillo, Annette (USAFLS) Cc: Atkinson, Karen (USAFLS); Kuyrkendall, E N. (FBI); Richards, Jason R. (FBI) Subject: Re: Epstein's Court Filings Let's talk at 10 15. Original Message From: Villafana, Ann Marie C. (USAFLS) To: Lee, Dexter (USAFLS); Acosta, Alex (USAFLS); Sloman, Jeff (USAFLS) Cc: Atkinson, Karen (USAFLS); Kuyrkendall, E N. (FBI); Richards, Jason R. (FBI) Sent: Thu Jul 17 09:44:08 2008 Subject: Epstein's Court Filings Hi all - Here are the documents that Mike Tein filed in connection with one of the civil suits pending against Epstein in the District Court. Note that Judge Marra is assigned to all of the federal civil suits, and also is the judge on the suit filing against the United States. Tein filed these ex parte and under seal and claims that all of the civil litigation has to be stayed because "the federal criminal action" is still pending. He discloses that a federal indictment had been prepared and that grand jury proceedings had occurred. I am concerned that this contradicts what Dexter told the Court, namely that a federal prosecution was never contemplated. <<DE24_080717_Notice of Pendency of Federal Case.pdf» «DE23_080717_Motn to File Ex Parte and Under Seal.pdf» 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 461 EFTA00180007 Villafana, Ann Marie C. (USAFLS) From: Villafana, Ann Marie C. (USAFLS) Sent: Thursday, July 17, 2008 9:44 AM To: Lee, Dexter (USAFLS); Acosta, Alex (USAFLS); Sloman, Jeff (USAFLS) Cc: Atkinson, Karen (USAFLS); Kuyrkendall, E N. (FBI); Richards, Jason R. (FBI) Subject: Epstein's Court Filings Hi all - Here are the documents that Mike Tein filed in connection with one of the civil suits pending against Epstein in the District Court. Note that Judge Marra is assigned to all of the federal civil suits, and also is the judge on the suit filing against the United States. Tein filed these ex parte and under seal and claims that all of the civil litigation has to be stayed because "the federal criminal action" is still pending. He discloses that a federal indictment had been prepared and that grand jury proceedings had occurred. lam concerned that this contradicts what Dexter told the Court, namely that a federal prosecution was never contemplated. DE24_080717_NDE23_080717_M rice of Pendencyatn to File Ex Pa.. 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: 462 EFTA00180008 Recipient Read Lee, Dexter (USAFLS) Read: 7117120089:45 AM Acosta. Alex (USAFLS) Read: 7117/2008 9:45 AM Slomad Jeff (USAFLS) Read: 711712008 9:44 AM Atkinson. Karen (USAFLS) Kuyrkendall, E N. (FBI) Richards, Jason R. (FBI) Vera, E.J. (USAFLS) Read: 7/17/2008 10:00 AM 463 EFTA00180009 Villafana, Ann Marie C. (USAFLS) From: Villafana, Ann Marie C. (USAFLS) Sent: Tuesday, July 15, 2008 6:53 PM To: Sloman, Jeff (USAFLS); Valle, Alicia (USAFLS); Acosta, Alex (USAFLS); Lee, Dexter (USAFLS) Kuyrkendall, E N. (FBI): Richards, Jason R. (FBI); Atkinson, Karen (USAFLS) Emailing: webmmkepstein0715.htm Cc: Subject: Wow - these guys work fast. Here is the Palm Beach Daily News report re Epstein. webmmkepstein 0715.htm 474 EFTA00180010 Villafana, Ann Marie C. (USAFLS) From: Villafana, Ann Marie C. (USAFLS) Sent: Tuesday, July 15, 2008 8:33 PM To: Lee, Dexter (USAFLS) Subject: Stipulation in Word Perfect Format Hi Dexter— I have been called up for jury duty tomorrow (can you believe it?). So here is the stipulation in Word Perfect format. Nesbitt is going to contact you directly tomorrow with any changes and with the two missing dates. I will call Brad Edwards and let him know that you will be in touch tomorrow. I will bring my Blackberry with me, but don't know how much I will be able to check it. Thank you. Stlpulatlon.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 Tracking: 475 EFTA00180011 Recipient Lee. Dexter (USAR S) Read Read: 7/15/2008 6:36 PM 476 EFTA00180012 Villafana, Ann Marie C. (USAFLS) From: Villafana, Ann Marie C. (USAFLS) Sent: Tuesday, July 15, 2008 6:31 PM To: Kuyrkendall, E N. (FBI) Subject: RE: Stipulation in Jane Doe Case That is fine. Hope all is okay. I have jury duty tomorrow so can you e-mail Dexter directly? 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: Kuyrkendall, E N. (FBI) Sent: Tuesday, July 15, 2008 6:20 PM To: Villafana, Ann Marie C. (USAFLS) Subject: Re: Stipulation in Jane Doe Case Marie, I've been out on another matter. I will get that info to u first thing in the morn if that is ok. Original Message From: Villafana, Ann Marie C. (USAFLS) <Ann.Marie.C.Villafana@usdoj.gov> To: Lee, Dexter (USAFLS); Kuyrkendall, E N.; Richards, Jason R. Sent: Tue Jul 15 18:16:49 2008 Subject: Stipulation in Jane Doe Case Hi Nesbitt and Jason - Can you double check the facts and give me the two missing dates? Dexter - This is my draft. I will wait to hear back from you before I send it to Edwards. Thanks. <<Stipulation.pdf» A. Marie Villafatia Assistant U.S. Attorney 500 5. Australian Ave, Suite 400 West Palm Beach, FL 33401 477 EFTA00180013 Phone 561 209-1047 Fax 561 820-8777 478 EFTA00180014 Villafana, Ann Marie C. (USAFLS) From: Villafana, Ann Marie C. (USAFLS) Sent: Tuesday, July 15,2008 6:17 PM To: Lee, Dexter (USAFLS); Kuyrkendall, E N. (FBI); Richards, Jason R. (FBI) Subject: Stipulation in Jane Doe Case Ili Nesbitt and Jason — Can you double check the facts and give me the two missing dates? Dexter — This is my draft. I will wait to hear back from you before I send it to Edwards. Thanks. Stipulation.pdf A. Marie Villajafla Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 Phone 561 209-1047 Fax 561 820-8777 Tracking: 479 EFTA00180015 Recipient lee. Dexter (USAFLS) KuyrkendalL E N. (FBI) Ricttarde Jason R. (FBI) Road Read: 7/1512008 6:17 PM 480 EFTA00180016 Villafana, Ann Marie C. (USAFLS) From: Villafana, Ann Marie C. (USAFLS) Sent: Tuesday, July 15, 2008 4:35 PM To: Richards, Jason R. (FBI); Kuyrkendall, E N. (FBI) Subject: Date you met with C.W. Iii Jason and Nesbitt — Did you ever find your notes? Do you know what date you met with C.W.? and what city was the meeting in? 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 48t EFTA00180017 Villafana, Ann Marie C. (USAFLS) From: Villafana, Ann Marie C. (USAFLS) Sent: Tuesday, July 15, 2008 4:30 PM To: Valle, Alicia (USAFLS) Subject: RE: In Re Jane Doe - Call from Palm Beach Daily News We moved to have them sealed but the Judge denied the motion, so they arc all publicly available. A. Marie Villgjrina Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach. FL 33401 Phone 561 209-1047 Fax 561 820-8777 From: Valle, Alicia (USAFLS) Sent: Tuesday, July 15, 2008 4:27 PM To: Villafana, Ann Marie C. (USAFLS) Subject: RE: In Re Jane Doe - Call from Palm Beach Daily News None sealed, correct?? From: Villafana, Ann Marie C. (USAFLS) Sent: Tuesday, July 15, 2008 4:24 PM To: Valle, Alicia (USAFLS); Lee, Dexter (USAFLS) Cc: Sloman, Jeff (USAFLS); Acosta, Alex (USAFLS) Subject: RE: In Re Jane Doe - Call from Palm Beach Daily News Here is the scanned file-stamped copies of our filings. Along with the filings of the Jane Does from PACER. « File: DE2_080707_Cert of Emergency.pdf » « File: DE1_080707_Petition.pdf » « File: DE9_080711_Reply Brief.pdf » « File: In Re Jane Doe001.pdf » A. Marie VillaJatla Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach. FL 33401 Phone 561 209-1047 Fax 561 820-8777 From: Valle, Alida (USAFLS) Sent: Tuesday, July 15, 2008 4:22 PM To: Lee, Dexter (USAFLS) Cc: Villafana, Ann Marie C. (USAFLS); Sloman, Jeff (USAFLS); Acosta, Alex (USAFLS) Subject: RE: In Re Jane Doe - Call from Palm Beach Daily News 482 EFTA00180018 Ok — just got off the phone with her. Can you send me copies of the does. which I will forward to her? thanks. aov From: Lee, Dexter (USAFLS) Sent: Tuesday, July 15, 2008 2:15 PM To: Valle, Alicia (USAFLS) Cc: Villafana, Ann Marie C. (USAFLS); Sloman, Jeff (USAFLS); Acosta, Alex (USAFLS) Subject: In Re Jane Doe - Call from Palm Beach Daily News Alicia, I just received a phone call from Maggie Kacoha of the Palm Beach Daily News, (561) 820-3850, asking about the Jane Doe case. She told me they were tied up on Friday and unable to attend the hearing before Judge Marra. She said she had read the Sun Sentinel article and wanted to confirm that : (1) the government argued the court had no jurisdiction; and (2) the district court agreed. I gave her your name and said someone would be calling her back. I told her that the filings had all been unsealed and she could access them through PACER. I did confirm that the government argued the court did not have jurisdiction, but said the case was not over. I declined to make any other comments. When the hearing concluded last Friday, Judge Marra left it up to the parties to advise the court whether an evidentiary hearing was needed. If the answer is yes, then the court will schedule a hearing. If the answer is no, then I assume the court will go ahead and rule on the papers filed. If you need copies of what the government filed, please let me know. Thanks. Dexter Tracking: 483 EFTA00180019 Recipient Vs Alicia (USAFtS) Read Read: 7/1512008 4:40 PM 484 EFTA00180020 Villafana, Ann Marie C. (USAFLS) From: Villafana, Ann Marie C. (USAFLS) Sent: Tuesday, July 15, 20084:31 PM To: Valle, Alicia (USAFLS); Lee, Dexter (USAFLS) Subject: RE: In Re Jane Doe - Call from Palm Beach Daily News The motion has been taken under advisement. The parties are conferring to determine if an evidentiary hearing is necessary. 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 From: Valle, Alicia (USAFLS) Sent: Tuesday, July 15, 2008 4:25 PM To: VIllafana, Ann Marie C. (USAFLS); Lee, Dexter (USAFLS) Subject: RE: In Re Jane Doe - Call from Palm Beach Daily News Perfect — I will forward to her. So, in a nutshell, what was the result of the hearing on Friday? From: Villafana, Ann Marie C. (USAFLS) Sent: Tuesday, July 15, 2008 4:24 PM To: Valle, Alicia (USAFLS); Lee, Dexter (USAFLS) Cc: Sloman, Jeff (USAFLS); Acosta, Alex (USAFLS) Subject: RE: In Re Jane Doe - Call from Palm Beach Daily News Here is the scanned file-stamped copies of our filings. Along with the filings of the Jane Does from PACER. « File: DE2_080707_Cert of Emergency.pdf » « File: DE1_080707_PetItion.pdf » « File: DE9_080711_Reply Brief.pdf » « File: In Re Jane Doe001.pdf » 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: VaUe, AlIda (USAFLS) Sent: Tuesday, July 15, 2008 4:22 PM 485 EFTA00180021 To: Lee, Dexter (USAFLS) Cc: Villafana, Ann Marie C. (USAFLS); Sloman, Jeff (USAFLS); Acosta, Alex (USAFLS) Subject: RE: In Re Jane Doe - Call from Palm Beach Daily News Ok • - just got off the phone with her. Can you send me copies of the does, which I will forward to her? thanks, aov From: Lee, Dexter (USAFLS) Sent: Tuesday, July 15, 2008 2:15 PM To: Valle, Alicia (USAFLS) Cc: Villafana, Ann Marie C. (USAFLS); Sloman, Jeff (USAFLS); Acosta, Alex (USAFLS) Subject: In Re Jane Doe - Call from Palm Beach Daily News Alicia, I just received a phone call from Maggie Kacoha of the Palm Beach Daily News, (561) 820-3850, asking about the Jane Doe case. She told me they were tied up on Friday and unable to attend the hearing before Judge Marra. She said she had read the Sun Sentinel article and wanted to confirm that : (1) the government argued the court had no Jurisdiction; and (2) the district court agreed. I gave her your name and said someone would be calling her back. I told her that the filings had all been unsealed and she could access them through PACER. I did confirm that the government argued the court did not have jurisdiction, but said the case was not over. I declined to make any other comments. When the hearing concluded last Friday, Judge Marra left it up to the parties to advise the court whether an evidentiary hearing was needed. If the answer is yes, then the court will schedule a hearing. If the answer is no, then I assume the court will go ahead and rule on the papers filed. If you need copies of what the government filed, please let me know. Thanks. Dexter Tracking: 486 EFTA00180022 Recipient Road Valle, Alicia (USAF LS) Read: 7/15/2008 4:40 PM Lee, Dexter (USAFLS) Read: 7/15/2008 4:38 PM 487 EFTA00180023 Villafana, Ann Marie C. (USAFLS) From: Sent: To: Cc: Subject: Villafana, Ann Marie C. (USAFLS) Tuesday, July 15, 2008 4:24 PM Valle, Alicia (USAFLS); Lee, Dexter (USAFLS) Sloman, Jeff (USAFLS); Acosta, Alex (USAFLS) RE: In Re Jane Doe - Call from Palm Beach Daily News Here is the scanned file-stamped copies of our filings. Along with the filings of the Jane Does from PACER. DE2_080707_CeDE1_080707_PetDE9_080711_Re In Re Jane of Emergency.p. ition.pdf ply Brief.pdf Doe001.pdf A. Marie Villafana Assistant I.J.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach. FL 33401 Phone 561 209-1047 Fax 561 820-8777 From: Valle, Alicia (USAFLS) Sent: Tuesday, July 15, 2008 4:22 PM To: Lee, Dexter (USAFLS) Cc: Villafana, Ann Marie C. (USAFLS); Sloman, Jeff (USAFLS); Acosta, Alex (USAFLS) Subject: RE: In Re Jane Doe - Call from Palm Beach Daily News Ok — just got off the phone with her. Can you send me copies of the does, which I will forward to her? thanks, aov From: Lee, Dexter (USAFLS) Sent: Tuesday, July 15, 2008 2:15 PM To: Valle, Alicia (USAFLS) Cc: Villafana, Ann Marie C. (USAFLS); Sloman, Jeff (USAFLS); Acosta, Alex (USAFLS) Subject: In Re Jane Doe - Call from Palm Beach Daily News Alicia, I just received a phone call from Maggie Kacoha of the Palm Beach Daily News, (561) 820-3850, asking about the Jane Doe case. She told me they were tied up on Friday and unable to attend the hearing before Judge Marra. She said she had read the Sun Sentinel article and wanted to confirm that : (1) the government argued the court had no jurisdiction; and (2) the district court agreed. I gave her your name and said someone would be calling her back. I told her that the filings had all been unsealed and she could access them through PACER. I did confirm that the government argued the court did not have jurisdiction, but said the case was not over. I declined to make any other comments. 488 EFTA00180024 When the hearing concluded last Friday, Judge Marra left it up to the parties to advise the court whether an evidentiary hearing was needed. If the answer is yes, then the court will schedule a hearing. If the answer is no, then I assume the court will go ahead and rule on the papers filed. If you need copies of what the government filed, please let me know. Thanks. Dexter Tracking: 489 EFTA00180025 Recipient Read Vane, Alicia (USAFLS) Read: 7/15/2008 4:25 PM Lee, Dexter (USAFLS) Read: 7/1512008 4:36 PM Sidman. Jell (USAFLS) Read: 7115/2008 4:25 PM Acosta. Alex (USAFLS) 490 EFTA00180026 Villafana, Ann Marie C. (USAFLS) From: Villafana, Ann Marie C. (USAFLS) Sent: Tuesday, July 15, 2008 4:21 PM To: Lee, Dexter (USAFLS) Subject: RE: In Re Jane Doe - Call from Palm Beach Daily News Hi Dexter — Just got a voicemail from Brad. I will draft something up and will forward it to you before I send it over to him. 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 From: Lee, Dexter (USAFLS) Sent: Tuesday, July 15, 2008 3:44 PM To: Villafana, Ann Marie C. (USAFLS) Subject: RE: In Re Jane Doe - Call from Palm Beach Daily News Marie, I have heard nothing from Edwards. My recollection is that you told him you would prepare a document for joint filing, once we agreed after the hearing that an evidentiary hearing was not necessary for either side. We were going to detail what occurred at the meeting between Nesbitt and Jason at Publix with C.W., and Edwards was going to provide C.W's perception of what she was told by Nesbitt and Jason. Dexter From: Villafana, Ann Marie C. (USAFLS) Sent: Tuesday, July 15, 2008 3:09 PM To: Lee, Dexter (USAFLS) Subject: RE: In Re Jane Doe - Call from Palm Beach Daily News Hi Dexter — I lave you heard any more from Mr. Edwards? I don't like to keep Judge Marra waiting. He is our nicest judge, so I like to be as responsive as possible. 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 491 EFTA00180027 From: Lee, Dexter (USAFLS) Sent: Tuesday, July 15, 2008 2:15 PM To: Valle, Alicia (USAFLS) Cc: Villafana, Ann Marie C. (USAFLS); Sloman, Jeff (USAFLS); Acosta, Alex (USAFLS) Subject: In Re Jane Doe - Call from Palm Beach Daily News Alicia, I just received a phone call from Maggie Kacoha of the Palm Beach Daily News, (561) 820.3850, asking about the Jane Doe case. She told me they were tied up on Friday and unable to attend the hearing before Judge Marra. She said she had read the Sun Sentinel article and wanted to confirm that : (1) the government argued the court had no jurisdiction; and (2) the district court agreed. I gave her your name and said someone would be calling her back. I told her that the filings had all been unsealed and she could access them through PACER. I did confirm that the government argued the court did not have jurisdiction, but said the case was not over. I declined to make any other comments. When the hearing concluded last Friday, Judge Marra left it up to the parties to advise the court whether an evidentiary hearing was needed. If the answer is yes, then the court will schedule a hearing. If the answer is no, then I assume the court will go ahead and rule on the papers filed. If you need copies of what the government filed, please let me know. Thanks. Dexter Tracking: 492 EFTA00180028 Recipient Lee. Dexter (USAFLS) Read Read: 7(15/2008 4:36 PM 493 EFTA00180029 Villafana, Ann Marie C. (USAFLS) From: Lee, Dexter (USAFLS) Sent: Tuesday, July 15, 2008 3:44 PM To: Villafana, Ann Marie C. (USAFLS) Subject: RE: In Re Jane Doe - Call from Palm Beach Daily News Marie, I have heard nothing from Edwards. My recollection is that you told him you would prepare a document for joint filing, once we agreed after the hearing that an evidentiary hearing was not necessary for either side. We were going to detail what occurred at the meeting between Nesbitt and Jason at Publix with C.W., and Edwards was going to provide C.W's perception of what she was told by Nesbitt and Jason. Dexter From: VIHelena, Ann Marie C. (USAFLS) Sent: Tuesday, July 15, 2008 3:09 PM To: Lee, Dexter (USAFLS) Subject: RE: In Re Jane Doe - Call from Palm Beath Daily News Hi Dexter — Have you heard any more from Mr. Edwards? I don't like to keep Judge Marra waiting. He is our nicest judge, so I like to be as responsive as possible. 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 From: Lee, Dexter (USAFLS) Sent: Tuesday, July 15, 2008 2:15 PM To: Valle, Alicia (USAFLS) Cc: Villafana, Ann Mane C. (USAFLS); Sloman, Jeff (USAFLS); Acosta, Alex (USAFLS) Subject: In Re Jane Doe - Call from Palm Beach Daily News Alicia, I just received a phone call from Maggie Kacoha of the Palm Beach Daily News, (561) 820-3850, asking about the Jane Doe case. She told me they were tied up on Friday and unable to attend the hearing before Judge Marra. She said she had read the Sun Sentinel article and wanted to confirm that : (1) the government argued the court had no jurisdiction; and (2) the district court agreed. I gave her your name and said someone would be calling her back. I told her that the filings had all been unsealed and she could access them through PACER. I did confirm that the government argued the court did not have jurisdiction, but said the case was not over. I declined to make any other comments. 494 EFTA00180030 When the hearing concluded last Friday, Judge Marra left it up to the parties to advise the court whether an evidentiary hearing was needed. If the answer is yes, then the court will schedule a hearing. If the answer is no, then I assume the court will go ahead and rule on the papers filed. If you need copies of what the government filed, please let me know. Thanks. Dexter 495 EFTA00180031 Villafana, Ann Marie C. (USAFLS) From: Villafana, Ann Marie C. (USAFLS) Sent: Tuesday, July 15, 2008 3:09 PM To: Lee, Dexter (USAFLS) Subject: RE: In Re Jane Doe - Call from Palm Beach Daily News Hi Dexter -- Have you heard any more from Mr. Edwards? I don't like to keep Judge Marra waiting. He is our nicest judge, so I like to he as responsive as possible. A. Marie Ili!Walla Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FI, 33401 Phone 56I 209-1047 Fax 561 820-8777 From: Lee, Dexter (USAFLS) Sent: Tuesday, July 15, 2008 2:15 PM To: Valle, Alicia (USAFLS) Cc: VIllafana, Ann Marie C. (USAFLS); Sloman, Jeff (USAFLS); Acosta, Alex (USAFLS) Subject: In Re Jane Doe - Call from Palm Beach Daily News Alicia, I just received a phone call from Maggie Kacoha of the Palm Beach Daily News, (561) 820-3850, asking about the Jane Doe case. She told me they were tied up on Friday and unable to attend the hearing before Judge Marra. She said she had read the Sun Sentinel article and wanted to confirm that : (1) the government argued the court had no jurisdiction; and (2) the district court agreed. I gave her your name and said someone would be calling her back. I told her that the filings had all been unsealed and she could access them through PACER. I did confirm that the government argued the court did not have jurisdiction, but said the case was not over. I declined to make any other comments. When the hearing concluded last Friday, Judge Marra left it up to the parties to advise the court whether an evidentiary hearing was needed. If the answer is yes, then the court will schedule a hearing. If the answer is no, then I assume the court will go ahead and rule on the papers filed. If you need copies of what the government filed, please let me know. Thanks. Dexter Tracking: 496 EFTA00180032 Recipient Lee, Dexter (USAFLS) Read Read: 7/15/2008 3'.41 PM 497 EFTA00180033 Villafana, Ann Marie C. (USAFLS) From: Lee, Dexter (USAFLS) Sent: Tuesday, July 15, 2008 2:15 PM To: Valle, Alicia (USAFLS) Cc: Villafana, Ann Marie C. (USAFLS); Sloman, Jeff (USAFLS); Acosta, Alex (USAFLS) Subject: In Re Jane Doe - Call from Palm Beach Daily News Alicia, I just received a phone call from Maggie Kacoha of the Palm Beach Daily News, (561) 820.3850, asking about the Jane Doe case. She told me they were tied up on Friday and unable to attend the hearing before Judge Marra. She said she had read the Sun Sentinel article and wanted to confirm that : (1) the government argued the court had no jurisdiction; and (2) the district court agreed. I gave her your name and said someone would be calling her back. I told her that the filings had all been unsealed and she could access them through PACER. I did confirm that the government argued the court did not have jurisdiction, but said the case was not over. I declined to make any other comments. When the hearing concluded last Friday, Judge Marra left it up to the parties to advise the court whether an evidentiary hearing was needed. If the answer is yes, then the court will schedule a hearing. If the answer is no, then I assume the court will go ahead and rule on the papers filed. If you need copies of what the government filed, please let me know. Thanks. Dexter 498 EFTA00180034 Villafana, Ann Marie C. (USAFLS) From: Villafana, Ann Marie C. (USAFLS) Sent: Tuesday, July 15, 2008 1:26 PM To: Richards, Jason R. (FBI) Subject: RE: Calls Hi Jason -- Yes, that is fine, unless I am selected for jury duty, which seems unlikely. 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: Richards, Jason R. (FBI) Sent: Tuesday, July 15, 2008 1:02 PM To: Villafana, Ann Marie C. (USAFLS) Subject: Re: Calls Are you available to meet with Aris and her mom on Thur. at 3:30. Julia was very uncooperative with Twila today. Original Message From: Villafana, Ann Marie C. (USAFLS) <Ann.Marie.C.Villafana@usdoj.gov> To: Richards, Jason R. Sent: Tue Jul 15 12:00:40 2008 Subject: Re: Calls Hi jason. I am out of the office right now. It is jason at south carolina victim's action network (www.scvan.org) and pauline mandel at maryland crime victims' services (www.mdcrimevictims.org) Original Message From: Richards, Jason R. (FBI) To: Villafana, Ann Marie C. (USAFLS) Sent: Tue Jul 15 11:32:17 2008 Subject: Re: Calls Call me when you get a chance. Twila on hold re: notifications. Any word from Marra? 499 EFTA00180035 Original Message From: Villafana, Ann Marie C. (USAFLS) <Ann.Marie.C.Villafana@usdoj.gov) To: Kuyrkendall, E N.; Richards, Jason R.; Smith, Twiler I. Sent: Mon Jul 14 16:16:08 2008 Subject: FW: Calls Hi all -- Wasn't sure this went through last time. On another note, do you guys have an office in Ft Pierce? 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: Villafana, Ann Marie C. (USAFLS) Sent: Monday, July 14, 2008 2:14 PM To: Kuyrkendall, E N. (FBI); Richards, Jason R. (FBI) Subject: Calls Hi guys. I am stuck in the rain. If you want to start calling here are my thoughts. We are calling to inform you about the resolution of the Epstein investigation and to thank you for your help. Mr Epstein pled guilty to one child sex offense that will require him to register as a sex offender for life and received a sentence of 18 months imprisonment followed by one year of home confinement. Mr Epstein also made a concession regarding the payment of restitution. All of these terms are set out in a letter that AUSA Villafana is going to send out. Do you have a lawyer? Get name and address. If not where do you want letter sent? If you have questions when you receive the letter, please understand that we cannot provide legal advice but the lawyers at the following victims rights organizations are able to help you at no cost to you. (Provide the names and phone numbers) Also ask about counseling and let them know that counseling is still available even though the investigation is closed. 500 EFTA00180036 Villafana, Ann Marie C. (USAFLS) From: Richards, Jason R. (FBI) Sent: Tuesday, July 15, 2008 1:02 PM To: Villafana, Ann Marie C. (USAFLS) Subject: Re: Calls Are you available to meet with Aris and her mom on Thur. at 3:30. Julia was very uncooperative with Twila today. Original Message From: Villafana, Ann Marie C. (USAFLS) <Ann.Marie.C.Villafana@usdoj.gov> To: Richards, Jason R. Sent: Tue Jul 15 12:00:40 2008 Subject: Re: Calls Hi Jason. I am out of the office right now. It is jason at south carolina victim's action network (www.scvan.org) and pauline mandel at maryland crime victims' services (www.mdcrimevictims.org) Original Message From: Richards, Jason R. (FBI) To: Villafana, Ann Marie C. (USAFLS) Sent: Tue Jul 15 11:32:17 2008 Subject: Re: Calls Call me when you get a chance. Twila on hold re: notifications. Any word from Marra? Original Message From: Villafana, Ann Marie C. (USAFLS) <Ann.Marie.C.Villafana@usdoj.gov> To: Kuyrkendall, E N.; Richards, Jason R.; Smith, Twiler I. Sent: Mon Jul 14 16:16:08 2008 Subject: FW: Calls Hi all -- Wasn't sure this went through last time. On another note, do you guys have an office in Ft Pierce? 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 501 EFTA00180037 Original Message From: Villafana, Ann Marie C. (USAFLS) Sent: Monday, July 14, 2008 2:14 PM To: Kuyrkendall, E N. (FBI); Richards, Jason R. (FBI) Subject: Calls Hi guys. I am stuck in the rain. If you want to start calling here are my thoughts. We are calling to inform you about the resolution of the Epstein investigation and to thank you for your help. Mr Epstein pled guilty to one child sex offense that will require him to register as a sex offender for life and received a sentence of 18 months imprisonment followed by one year of home confinement. Mr Epstein also made a concession regarding the payment of restitution. All of these terms are set out in a letter that AUSA Villafana is going to send out. Do you have a lawyer? Get name and address. If not where do you want letter sent? If you have questions when you receive the letter, please understand that we cannot provide legal advice but the lawyers at the following victims rights organizations are able to help you at no cost to you. (Provide the names and phone numbers) Also ask about counseling and let them know that counseling is still available even though the investigation is closed. 502 EFTA00180038 Villafana, Ann Marie C. (USAFLS) From: Villafana, Ann Marie C. (USAFLS) Sent: Tuesday, July 15, 2006 12:01 PM To: Richards, Jason R. (FBI) Subject: Re: Calls Hi jason. I am out of the office right now. It is jason at south carolina victim's action network (www.scvan.org) and pauline mandel at maryland crime victims' services (www.mdcrimevictims.org) Original Message From: Richards, Jason R. (FBI) To: Villafana, Ann Marie C. (USAFLS) Sent: Tue Jul 15 11:32:17 2008 Subject: Re: Calls Call me when you get a chance. Twila on hold re: notifications. Any word from Marra? Original Message From: Villafana, Ann Marie C. (USAFLS) <Ann.Marie.C.Villafana@usdoj.gov> To: Kuyrkendall, E N.; Richards, Jason R.; Smith, Twiler I. Sent: Mon Jul 14 16:16:08 2008 Subject: FW: Calls Hi all -- Wasn't sure this went through last time. On another note, do you guys have an office in Ft Pierce? 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: Villafana, Ann Marie C. (USAFLS) Sent: Monday, July 14, 2008 2:14 PM To: Kuyrkendall, E N. (FBI); Richards, Jason R. (FBI) Subject: Calls Hi guys. I am stuck in the rain. If you want to start calling here are my thoughts. 503 EFTA00180039 We are calling to inform you about the resolution of the Epstein investigation and to thank you for your help. Mr Epstein pled guilty to one child sex offense that will require him to register as a sex offender for life and received a sentence of 18 months imprisonment followed by one year of home confinement. Mr Epstein also made a concession regarding the payment of restitution. All of these terms are set out in a letter that AUSA Villafana is going to send out. Do you have a lawyer? Get name and address. If not where do you want letter sent? If you have questions when you receive the letter, please understand that we cannot provide legal advice but the lawyers at the following victims rights organizations are able to help you at no cost to you. (Provide the names and phone numbers) Also ask about counseling and let them know that counseling is still available even though the investigation is closed. 5Q4 EFTA00180040 Villafana, Ann Marie C. (USAFLS) From: Richards, Jason R. (FBI) Sent: Tuesday, July 15,200B 11:32 AM To: Villafana, Ann Marie C. (USAFLS) Subject: Re: Calls Call me when you get a chance. Twila on hold re: notifications. Any word from Marra? Original Message From: Villafana, Ann Marie C. (USAFLS) <Ann.Marie.C.Villafana@usdoj.gov> To: Kuyrkendall, E N.; Richards, Jason R.; Smith, Twilerli. Sent: Mon Jul 14 16:16:08 2008 Subject: FW: Calls Hi all -- Wasn't sure this went through last time. On another note, do you guys have an office in Ft Pierce? 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: Villafana, Ann Marie C. (USAFLS) Sent: Monday, July 14, 2008 2:14 PM To: Kuyrkendall, E N. (FBI); Richards, Jason R. (FBI) Subject: Calls Hi guys. I am stuck in the rain. If you want to start calling here are my thoughts. We are calling to inform you about the resolution of the Epstein investigation and to thank you for your help. Mr Epstein pled guilty to one child sex offense that will require him to register as a sex offender for life and received a sentence of 18 months imprisonment followed by one year of home confinement. Mr Epstein also made a concession regarding the payment of restitution. All of these terms are set out in a letter that AUSA Villafana is going to send out. Do you have a lawyer? Get name and address. If not where do you want letter sent? If you have questions when you receive the letter, please understand that we cannot provide legal advice but the lawyers at the following victims rights organizations are able to help you at no cost to you. (Provide the names and 505 EFTA00180041 phone numbers) Also ask about counseling and let them know that counseling is still available even though the investigation is closed. 506 EFTA00180042 Villafana, Ann Marie C. (USAFLS) From: Richards, Jason R. (FBI) Sent: Tuesday, July 15, 2008 11:12 AM To: Villafana, Ann Marie C. (USAFLS) Subject: Re: Calls Hi Marie, do you have the names and numbers of the pro bono attorneys available for the victims? Original Message From: Villafana, Ann Marie C. (USAFLS) <Ann.Marie.C.Villafana@usdoj.gov> To: Kuyrkendall, E N.; Richards, Jason R.; Smith, Twiler Sent: Mon Jul 14 16:16:08 2008 Subject: FW: Calls Hi all -- Wasn't sure this went through last time. On another note, do you guys have an office in Ft Pierce? 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: Villafana, Ann Marie C. (USAFLS) Sent: Monday, July 14, 2008 2:14 PM To: Kuyrkendall, E N. (FBI); Richards, Jason R. (FBI) Subject: Calls Hi guys. I am stuck in the rain. If you want to start calling here are my thoughts. We are calling to inform you about the resolution of the Epstein investigation and to thank you for your help. Mr Epstein pled guilty to one child sex offense that will require him to register as a sex offender for life and received a sentence of 18 months imprisonment followed by one year of home confinement. Mr Epstein also made a concession regarding the payment of restitution. All of these terms are set out in a letter that AUSA Villafana is going to send out. Do you have a lawyer? Get name and address. If not where do you want letter sent? If you have questions when you receive the letter, please understand that we cannot provide legal advice but the lawyers at the following victims rights organizations are able to help you at no cost to you. (Provide the names and 507 EFTA00180043 phone numbers) Also ask about counseling and let them know that counseling is still available even though the investigation is closed. 508 EFTA00180044 Villafana, Ann Marie C. (USAFLS) From: Villafana, Ann Marie C. (USAFLS) Sent: Monday, July 14, 2008 4:54 PM To: Lee, Dexter (USAFLS) Cc: Atkinson, Karen (USAFLS) Subject: RE: Conversation with Mike Tein Thank you, Dexter. A. Marie Vi 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, July 14, 2008 4:53 PM To: Villafana, Ann Marie C. (USAFLS) Subject: Conversation with Mike Tein Marie, Mike Tein called this afternoon, wanting to confirm details he had read in the newspaper. I told him that Judge Marra had not dismissed the victims' petition, and explained the parties were determining whether an evidentiary hearing was necessary. He asked if both Jane Doe No. 1 and No. 2 were present in court, and I told him yes. lie also asked if the government's response would be available on PACER. I told him that, since the court had denied our motion to seal, the government's response would be unsealed and placed on the docket. Dexter Tracking: 509 EFTA00180045 Recipient Lee, Dexter (USAFLS) Atkinson, Karen (USAFLS) Read Read: 7(14/2008 5:02 PM 510 EFTA00180046 Villafana, Ann Marie C. (USAFLS) From: Lee, Dexter (USAFLS) Sent: Monday, July 14, 2008 4:53 PM To: Villafana, Ann Marie C. (USAFLS) Subject: Conversation with Mike Tein Marie, Mike Tein called this afternoon, wanting to confirm details he had read in the newspaper. I told him that Judge Marra had not dismissed the victims' petition, and explained the parties were determining whether an evidentiary hearing was necessary. He asked if both Jane Doe No. 1 and No. 2 were present in court, and I told him yes. He also asked if the government's response would be available on PACER. I told him that, since the court had denied our motion to seal, the government's response would be unsealed and placed on the docket. Dexter 511 EFTA00180047 Villafana, Ann Marie C. (USAFLS) From: Villafana, Ann Marie C. (USAFLS) Sent: Monday, July 14, 2008 4:16 PM To: Kuyrkendall, E N. (FBI): Richards, Jason R. (FBI); Smith, Twiler, I (FBI) Subject: FW: Calls Hi all -- Wasn't sure this went through last time. On another note, do you guys have an office in Ft Pierce? 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: Villafana, Ann Marie C. (USAFLS) Sent: Monday, July 14, 2008 2:14 PM To: Kuyrkendall, E N. (FBI); Richards, Jason R. (FBI) Subject: Calls Hi guys. I am stuck in the rain. If you want to start calling here are my thoughts. We are calling to inform you about the resolution of the Epstein investigation and to thank you for your help. Mr Epstein pled guilty to one child sex offense that will require him to register as a sex offender for life and received a sentence of 18 months imprisonment followed by one year of home confinement. Mr Epstein also made a concession regarding the payment of restitution. All of these terms are set out in a letter that AUSA Villafana is going to send out. Do you have a lawyer? Get name and address. If not where do you want letter sent? If you have questions when you receive the letter, please understand that we cannot provide legal advice but the lawyers at the following victims rights organizations are able to help you at no cost to you. (Provide the names and phone numbers) Also ask about counseling and let them know that counseling is still available even though the investigation is closed. 512 EFTA00180048 Villafana, Ann Marie C. (USAFLS) From: Villafana, Ann Marie C. (USAFLS) Sent: Monday, July 14, 2008 2:14 PM To: Kuyrkendall, E N. (FBI); Richards, Jason R. (FBI) Subject: Calls Hi guys. I am stuck in the rain. If you want to start calling here are my thoughts. We are calling to inform you about the resolution of the Epstein investigation and to thank you for your help. Mr Epstein pled guilty to one child sex offense that will require him to register as a sex offender for life and received a sentence of 18 months imprisonment followed by one year of home confinement. Mr Epstein also made a concession regarding the payment of restitution. All of these terms are set out in a letter that AUSA Villafana is going to send out. Do you have a lawyer? Get name and address. If not where do you want letter sent? If you have questions when you receive the letter, please understand that we cannot provide legal advice but the lawyers at the following victims rights organizations are able to help you at no cost to you. (Provide the names and phone numbers) Also ask about counseling and let them know that counseling is still available even though the investigation is closed. 573 EFTA00180049 Villafana, Ann Marie C. (USAFLS) From: Villafana, Ann Marie C. (USAFLS) Sent: Monday, July 14, 2008 12:17 PM To: Lee, Dexter (USAFLS) Cc: Atkinson, Karen (USAFLS) Subject: RE: Jane Doe Hearing Vii Dexter - I haven't heard any more from Jack and I haven't received any faxes, so perhaps the storm has passed. If you would like to call him, his phone number is 561.659.8300. A. Mark> Vinglaita Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach. 1:1, 33401 Phone 561 209-1047 Fax 561 820-8777 From: Lee, Dexter (USAFLS) Sent: Monday, July 14, 2008 10:20 AM To: Villafana, Ann Marie C. (USAFLS) Subject: RE: Jane Doe Hearing Marie, I left early on Friday since I had to take care of some matters before my Air Force reserve duty at Homestead AFB this weekend. If you want me to participate in a conference with Mr. Goldberger, I will be happy to do so. Dexter From: Villafana, Ann Marie C. (USAFLS) Sent: Friday, July 11, 2008 3:04 PM To: Lee, Dexter (USAFLS) Subject: RE: Jane Doe Hearing HI Dexter — I really think you should be on this call with Jack Goldberger, if you feel a response is required. A. Marie Villafana Assistant U.S. Attorney 561 209-1047 From: Lee, Dexter (USAFLS) Sent: Friday, July 11, 2008 2:33 PM To: Herd, Klm (USAE0); Neal, Kristina (USAEO); Acosta, Alex (USAFLS); Sloman, Jeff (USAFLS) Cc: Villafana, Ann Marie C. (USAFLS); Jacobus, Wendy (USAFLS) Subject: Jane Doe Hearing 514 EFTA00180050 Colleagues, The hearing this morning lasted 45 minutes. Judge Marra first heard argument from Brad Edwards, who harangued the government for permitting Epstein to get off with a light sentence in state court. He argued that the victims were entitled to be consulted before this agreement was reached, and the court should set the agreement aside. Edwards again argued that the rights in section 3771(a) accrue prior to the filing of any charges. In my portion of the argument, I advised the court of the status of Epstein's state case: (1) he entered pleas of guilty to two state charges on June 30, 2008; (2) he was sentenced to 18 months' incarceration and 1 year of community control; and (3) he was serving his sentence of incarceration. The court queried me on the Dean case and the government's position on when the rights in section 3371(a) applied. I distinguished Dean and argued that rights under 3771(a) does not accrue until a charge is filing in district court. I noted that the A/G's guidelines are applied with common sense, such that a victim claiming they were being threatened by a perpetrator would not be turned away since an indictment had not been returned. I also argued that 18 U.S.C. 3771 did not grant authority to the court to set aside the agreement in the instant case, since it was not a plea agreement filed with court, which it had the discretion to accept or reject. The court had questions regarding the completion of the agreement in September 2007, but the plea was not entered until June 30, 2008. I advised the court that Epstein's attorneys sought higher review of the agreement within the DOJ. As to the motion to seal the government's response, the court asked if that was necessary any more, since a public hearing had been held and much of what was filed had been discussed. I argued that the government had two bases for sealing: (1) protection of the privacy of the minor victims; and (2) confidentiality of negotiations with Epstein's attorneys and the confidentiality clause in the Agreement. Edwards waived any protection for his clients, two of whom were present in court (C.W. and T.M.) As to the confidentiality, the court found that the discussions regarding the potential impeachment of the victims because of the availability of relief under 18 U.S.C. 2255 had already been discussed at the hearing. I argued that the exact clause in the agreement pertaining to section 2255 had been cited In the notification letters to C.W. and S.R., which were filed, and the government had agreed to notify Epstein before making any disclosure. The court stated that the disclosure was being done pursuant to Its order, not by the government's action. I told the court the government wanted to register its objection. The court ordered the government's response, Marie's declaration, and the attachments, unsealed. Also, Edwards filed a reply, which is also a public record document. The court noted that, since Epstein had entered his plea and was sentenced, this was no longer an emergency. Both parties agreed. The court wanted to know if any evidentiary hearing need to be held. Since there is a dispute over what the FBI agents told C.W. In September 2007, I asked the court to permit the parties to speak to determine if there are any factual disputes which require a hearing. The court agreed. There was a reporter from the Sun Sentinel present in the audience. Dexter Tracking: 515 EFTA00180051 Recipient Read Lee. Dexter (USAFLS) Read: 7/14/2008 12:17 PM Atkinson. Karen (USAFLS) Read: 7/14/2008 12:48 PM 516 EFTA00180052 Villafana, Ann Marie C. (USAFLS) From: Lee, Dexter (USAFLS) Sent: Monday, July 14, 2008 10:20 AM To: Villafana, Ann Marie C. (USAFLS) Subject: RE: Jane Doe Hearing Marie, I left early on Friday since I had to take care of some matters before my Air Force reserve duty at Homestead AFB this weekend. If you want me to participate in a conference with Mr. Goldberger, I will be happy to do so. Dexter From: Villafana, Ann Marie C. (USAFLS) Sent: Friday, July 11, 2008 3:04 PM To: Lee, Dexter (USAFLS) Subject: RE: Jane Doe Hearing Hi Dexter — I really think you should be on this call with Jack Goldberger, if you feel a response is required. A. Marie Villafafla Assistant U.S. Attorney 561 209- I 047 From: Lee, Dexter (USAFLS) Sent: Friday, July 11, 2008 2:33 PM To: Herd, Kim (USAEO); Neal, Kristina (USAEO); Acosta, Alex (USAFLS); Sloman, Jeff (USAFLS) Cc: Villafana, Ann Marie C. (USAFLS); Jacobus, Wendy (USAFLS) Subject: Jane Doe Hearing Colleagues, The hearing this morning lasted 45 minutes. Judge Marra first heard argument from Brad Edwards, who harangued the government for permitting Epstein to get off with a light sentence in state court. He argued that the victims were entitled to be consulted before this agreement was reached, and the court should set the agreement aside. Edwards again argued that the rights in section 3771(a) accrue prior to the filing of any charges. In my portion of the argument, I advised the court of the status of Epstein's state case: (1) he entered pleas of guilty to two state charges on June 30, 2008; (2) he was sentenced to 18 months' incarceration and 1 year of community control; and (3) he was serving his sentence of incarceration. The court queried me on the Dean case and the government's position on when the rights in section 3371(a) applied. I distinguished Dean and argued that rights under 3771(a) does not accrue until a charge is filing in district court. I noted that the A/G's guidelines are applied with common sense, such that a victim claiming they were being threatened by a perpetrator would not be turned away since an Indictment had not been returned. I also argued that 18 U.S.C. 3771 did not grant authority to the court to set aside the agreement in the instant case, since it was not a plea agreement filed with court, which it had the discretion to accept or reject. The court had questions regarding the completion of the agreement in September 2007, but the plea was not 517 EFTA00180053 entered until June 30, 2008. I advised the court that Epstein's attorneys sought higher review of the agreement within the D01. As to the motion to seal the government's response, the court asked if that was necessary any more, since a public hearing had been held and much of what was filed had been discussed. I argued that the government had two bases for sealing: (1) protection of the privacy of the minor victims; and (2) confidentiality of negotiations with Epstein's attorneys and the confidentiality clause in the Agreement. Edwards waived any protection for his clients, two of whom were present in court (C.W. and T.M.) As to the confidentiality, the court found that the discussions regarding the potential impeachment of the victims because of the availability of relief under 18 U.S.C. 2255 had already been discussed at the hearing. I argued that the exact clause in the agreement pertaining to section 2255 had been cited in the notification letters to C.W. and S.R., which were filed, and the government had agreed to notify Epstein before making any disclosure. The court stated that the disclosure was being done pursuant to its order, not by the government's action. I told the court the government wanted to register its objection. The court ordered the government's response, Marie's declaration, and the attachments, unsealed. Also, Edwards filed a reply, which is also a public record document. The court noted that, since Epstein had entered his plea and was sentenced, this was no longer an emergency. Both parties agreed. The court wanted to know if any evidentiary hearing need to be held. Since there is a dispute over what the FBI agents told C.W. in September 2007, I asked the court to permit the parties to speak to determine if there are any factual disputes which require a hearing. The court agreed. There was a reporter from the Sun Sentinel present in the audience. Dexter 518 EFTA00180054 Villafana, Ann Marie C. (USAFLS) From: Villafana, Ann Marie C. (USAFLS) Sent: Friday, July 11, 2008 3:04 PM To: Lee, Dexter (USAFLS) Subject: RE: Jane Doe Hearing Hi Dexter — I really think you should be on this call with Jack Goldberger, if you feel a response is required. A. Marie Viligfafia Assistant U.S. Attorney 561 209-1047 From: Lee, Dexter (USAFLS) Sent: Friday, July 11, 2008 2:33 PM To: Herd, Kim (USAEO); Neal, Kristina (USAEO); Acosta, Alex (USAFLS); Sloman, Jeff (USAFLS) Cc: Villafana, Ann Marie C. (USAFLS); Jacobus, Wendy (USAFLS) Subject: Jane Doe Hearing Colleagues, The hearing this morning lasted 45 minutes. Judge Marra first heard argument from Brad Edwards, who harangued the government for permitting Epstein to get off with a light sentence in state court. He argued that the victims were entitled to be consulted before this agreement was reached, and the court should set the agreement aside. Edwards again argued that the rights in section 3771(a) accrue prior to the filing of any charges. In my portion of the argument, I advised the court of the status of Epstein's state case: (1) he entered pleas of guilty to two state charges on June 30, 2008; (2) he was sentenced to 18 months' incarceration and 1 year of community control; and (3) he was serving his sentence of incarceration. The court queried me on the Dean case and the government's position on when the rights in section 3371(a) applied. I distinguished Dean and argued that rights under 3771(a) does not accrue until a charge is filing in district court. I noted that the A/G's guidelines are applied with common sense, such that a victim claiming they were being threatened by a perpetrator would not be turned away since an indictment had not been returned. I also argued that 18 U.S.C. 3771 did not grant authority to the court to set aside the agreement in the instant case, since it was not a plea agreement filed with court, which it had the discretion to accept or reject. The court had questions regarding the completion of the agreement in September 2007, but the plea was not entered until June 30, 2008. I advised the court that Epstein's attorneys sought higher review of the agreement within the Dal. As to the motion to seal the government's response, the court asked if that was necessary any more, since a public hearing had been held and much of what was filed had been discussed. I argued that the government had two bases for sealing: (1) protection of the privacy of the minor victims; and (2) confidentiality of negotiations with Epstein's attorneys and the confidentiality clause in the Agreement. Edwards waived any protection for his clients, two of whom were present in court (C.W. and T.M.) As to the confidentiality, the court found that the discussions regarding the potential impeachment of the victims because of the availability of relief under 18 U.S.C. 2255 had already been discussed at the hearing. I argued that the exact clause in the agreement pertaining to section 2255 had been cited in the notification letters to C.W. and S.R., which were filed, and the government had agreed to notify Epstein before making any disclosure. The court stated that the disclosure was being done pursuant to its order, not by the government's action. I told the court the government wanted to register Its objection. 520 EFTA00180055 The court ordered the government's response, Marie's declaration, and the attachments, unsealed. Also, Edwards filed a reply, which is also a public record document. The court noted that, since Epstein had entered his plea and was sentenced, this was no longer an emergency. Both parties agreed. The court wanted to know if any evidentiary hearing need to be held. Since there is a dispute over what the FBI agents told C.W. In September 2007, I asked the court to permit the parties to speak to determine if there are any factual disputes which require a hearing. The court agreed. There was a reporter from the Sun Sentinel present in the audience. Dexter Tracking: 521 EFTA00180056 Recipient Lee. Dexter (USAFLS) Reed Read: 7/14/2008 8:52 AM 522 EFTA00180057 Villafana, Ann Marie C. (USAFLS) From: Lee, Dexter (USAFLS) Sent: Friday, July 11, 2008 2:33 PM To: Herd, Kim (USAEO); Neal, Kristina (USAEO); Acosta, Alex (USAFLS); Sloman, Jeff (USAFLS) Cc: Villafana, Ann Marie C. (USAFLS); Jacobus, Wendy (USAFLS) Subject: Jane Doe Hearing Colleagues, The hearing this morning lasted 45 minutes. Judge Marra first heard argument from Brad Edwards, who harangued the government for permitting Epstein to get off with a light sentence in state court. He argued that the victims were entitled to be consulted before this agreement was reached, and the court should set the agreement aside. Edwards again argued that the rights in section 3771(a) accrue prior to the filing of any charges. In my portion of the argument, I advised the court of the status of Epstein's state case: (1) he entered pleas of guilty to two state charges on June 30, 2008; (2) he was sentenced to 18 months' incarceration and 1 year of community control; and (3) he was serving his sentence of incarceration. The court queried me on the Dean case and the government's position on when the rights in section 3371(a) applied. I distinguished Dean and argued that rights under 3771(a) does not accrue until a charge is filing in district court. I noted that the A/G's guidelines are applied with common sense, such that a victim claiming they were being threatened by a perpetrator would not be turned away since an indictment had not been returned. I also argued that 18 U.S.C. 3771 did not grant authority to the court to set aside the agreement in the instant case, since it was not a plea agreement filed with court, which it had the discretion to accept or reject. The court had questions regarding the completion of the agreement in September 2007, but the plea was not entered until June 30, 2008. I advised the court that Epstein's attorneys sought higher review of the agreement within the DOJ. As to the motion to seal the government's response, the court asked if that was necessary any more, since a public hearing had been held and much of what was filed had been discussed. I argued that the government had two bases for sealing: (1) protection of the privacy of the minor victims; and (2) confidentiality of negotiations with Epstein's attorneys and the confidentiality clause in the Agreement. Edwards waived any protection for his clients, two of whom were present in court (C.W. and T,M.) As to the confidentiality, the court found that the discussions regarding the potential impeachment of the victims because of the availability of relief under 18 U.S.C. 2255 had already been discussed at the hearing. I argued that the exact clause in the agreement pertaining to section 2255 had been cited in the notification letters to C.W. and S.R., which were filed, and the government had agreed to notify Epstein before making any disclosure. The court stated that the disclosure was being done pursuant to its order, not by the government's action. I told the court the government wanted to register its objection. The court ordered the government's response, Marie's declaration, and the attachments, unsealed. Also, Edwards filed a reply, which is also a public record document. The court noted that, since Epstein had entered his plea and was sentenced, this was no longer an emergency. Both parties agreed. The court wanted to know if any evidentiary hearing need to be held. Since there is a dispute over what the FBI agents told C.W. in September 2007, I asked the court to permit the parties to speak to determine if there are any factual disputes which require a hearing. The court agreed. There was a reporter from the Sun Sentinel present in the audience. Dexter 523 EFTA00180058 Villafana, Ann Marie C. (USAFLS) From: Villafana, Ann Marie C. (USAFLS) Sent: Friday, July 11, 2008 2:18 PM To: Kuyrkendall, E N. (FBI) Subject: RE: Notice of Disclosure I am at 209-1021 A. Marie Villafana Assistant U.S. Attorney 561 209-1047 Original Message From: Kuyrkendall, E N. (FBI) Sent: Friday, July 11, 2008 2:17 PM To: Villafana, Ann Marie C. (USAFLS) Subject: Re: Notice of Disclosure We are calling your office. Original Message From: Villafana, Ann Marie C. (USAFLS) <Ann.Marie.C.Villafana@usdoj.gov> To: Kuyrkendall, E N.; Richards, Jason R. Sent: Fri Jul 11 14:15:19 2008 Subject: FW: Notice of Disclosure Are you sure you are still with me? A. Marie Villafana Assistant U.S. Attorney 561 209-1047 From: Villafana, Ann Marie C. (USAFLS) Sent: Friday, July 11, 2008 1:42 PM To: Atkinson, Karen (USAFLS); Lee, Dexter (USAFLS) Subject: FW: Notice of Disclosure I'm not going to call him by myself, so who wants to join me? 524 EFTA00180059 A. Marie Villafaha Assistant U.S. Attorney 561 209-1047 From: Jack Goldberger [mailto:jgoldberger@agwpa.com] Sent: Friday, July 11, 2008 1:18 PM To: Villafana, Ann Marie C. (USAFLS) Subject: RE: Notice of Disclosure Please call me in regard to this Jack goldberger From: Villafana, Ann Marie C. (USAFLS) [mailto:Ann.Marie.C.Villafana@usdoj.gov] Sent: Friday, July 11, 2008 12:01 PM To: Jack Goldberger Cc: Lee, Dexter (USAFLS); Atkinson, Karen (USAFLS) Subject: Notice of Disclosure Dear Mr. Goldberger: Today, Dexter Lee and I appeared before Judge Marra in connection with a suit filed by C.W. and T.M. asserting that their rights as victims were breached by our failure to consult with them before entering into the Non-Prosecution Agreement. In response to their petition, I filed a Declaration under seal that included the victim notification letters provided to their attorney, Brad Edwards. At today's hearing, and over our objection, Judge Marra denied our motion to seal and unsealed the declaration. Accordingly, one piece of the Non￾Prosecution Agreement, specifically the paragraph that is quoted in the victim notification letters, has been disclosed. A. Marie Villafana Assistant U.S. Attorney 561 209-1047 525 EFTA00180060 Villafana, Ann Marie C. (USAFLS) From: Villafana, Ann Marie C. (USAFLS) Sent: Friday, July 11, 2008 2:15 PM To: Kuyrkendall, E N. (FBI); Richards, Jason R. (FBI) Subject: FW: Notice of Disclosure Are you sure you are still with me? A. Marie ViWalla Assistant U.S. Attorney 561 209-1047 From: Villafana, Ann Marie C. (USAFLS) Sent: Friday, July 11, 2008 1:42 PM To: Atkinson, Karen (USAFLS); Lee, Dexter (USAFLS) Subject: FW: Notice of Disclosure I'm not going to call him by myself, so who wants to join me? A. Marie Vilinfant, Assistant U.S. Attorney 561 209-1047 From: Jack Goldberger [mallto:jgoldberger@agwpa.corn] Sent: Friday, July 11, 2008 1:18 PM To: Villafana, Ann Marie C. (USAFLS) Subject: RE: Notice of Disclosure Please call me in regard to this Jack goldberger From: Villafana, Ann Marie C. (USAFLS) (mailto:Ann.Marle.C.Villafana@usdoj.goy] Sent: Friday, July 11, 2008 12:01 PM To: Jack Goldberger Cc: Lee, Dexter (USAFLS); Atkinson, Karen (USAFLS) Subject: Notice of Disclosure Dear Mr. Goldberger: Today, Dexter Lee and I appeared before Judge Marra in connection with a suit filed by C.W. and T.M. asserting that their rights as victims were breached by our failure to consult with them before entering into the Non-Prosecution Agreement. In response to their petition, I filed a Declaration under seal that included the victim notification letters provided to their attorney, Brad Edwards. At today's hearing, and over our objection, Judge Marra denied our motion to seal and unsealed the declaration. Accordingly, one piece of the Non￾Prosecution Agreement, specifically the paragraph that is quoted in the victim notification letters, has been disclosed. A. Marie Villidatia Assistant U.S. Attorney 526 EFTA00180061 561 209-1047 527 EFTA00180062 Villafana, Ann Marie C. (USAFLS) From: Villafana, Ann Marie C. (USAFLS) Sent: Friday, July 11, 20081:42 PM To: Atkinson, Karen (USAFLS); Lee, Dexter (USAFLS) Subject: FW: Notice of Disclosure I'm not going to call him by myself, so who wants to join me? A. Marie VUlafafa Assistant U.S. Attorney 561 209-1047 From: Jack Goldberger [mailtolgoldberger@agwpa.com] Sent: Friday, July 11, 2008 1:18 PM To: Villafana, Ann Marie C. (USAFLS) Subject: RE: Notice of Disdosure Please call me in regard to this Jack goldberger From: Villafana, Ann Marie C. (USAFLS) [Inallto:Ann.Marie.C.Villafana@usdo).gov] Sent: Friday, July 11, 2008 12:01 PM To: lack Goldberger Cc: Lee, Dexter (USAFLS); Atkinson, Karen (USAFLS) Subject: Notice of Disclosure Dear Mr. Goldberger: Today, Dexter Lee and I appeared before Judge Marra in connection with a suit tiled by C.W. and T.M. asserting that their rights as victims were breached by our failure to consult with them before entering into the Non-Prosecution Agreement. In response to their petition, I filed a Declaration under seal that included the victim notification letters provided to their attorney, Brad Edwards. At today's hearing, and over our objection, Judge Marra denied our motion to seal and unsealed the declaration. Accordingly, one piece of the Non￾Prosecution Agreement, specifically the paragraph that is quoted in the victim notification letters, has been disclosed. A. Marie Yinajana Assistant U.S. Attorney 561 209-1047 Tracking: 528 EFTA00180063 Recipient Read Atkinson, Karen (USAFLS) Read: 7/11/2008 2:55 PM Lee, Dexter (USAFLS) Read: 7/11/2008 2:05 PM 529 EFTA00180064 Villafana, Ann Marie C. (USAFLS) From: Kuyrkendall, E N. (FBI) Sent: Friday, July 11, 2008 12:25 PM To: Villafana, Ann Marie C. (USAFLS) Subject: Re: Notice of Disclosure No, but I'll be sure to look in tomorrows Sun Sent for the much deserve praise for our hard work. Hey for the record we can't break up the team now so we will be here for any tar and feathering:) Original Message From: Villafana, Ann Marie C. (USAFLS) <Ann.Marie.C.Villafana@usdoj.gov> To: Kuyrkendall, E N. Sent: Fri Jul 11 12:17:02 2008 Subject: RE: Notice of Disclosure No, thanks, I want to spend the next year investigating Matt and Lilly. Did Jason show you the press release that I found? A. Marie Villafafia Assistant U.S. Attorney 500 5. Australian Ave, Suite 400 West Palm Beach, FL 33401 Phone 561 209-1047 Fax 561 820-8777 Original Message From: Kuyrkendall, E N. (FBI) Sent: Friday, July 11, 2008 12:03 PM To: Villafana, Ann Marie C. (USAFLS) Subject: Re: Notice of Disclosure All Jason and I can say is unbelievable. This is going to be a big mess. Jason and I r taking the next year off want to join us in Cabo? Original Message From: Villafana, Ann Marie C. (USAFLS) <Ann.Marie.C.Villafana@usdoj.gov> To: Jack Goldberger <jgoldberger@agwpa.com> Cc: Lee, Dexter (USAFLS); Atkinson, Karen (USAFLS) Sent: Fri Jul 11 11:55:14 2008 Subject: Notice of Disclosure Dear Mr. Goldberger: Today, Dexter Lee and I appeared before Judge Marra in connection with a suit filed by C.W. and T.M. asserting that their rights as victims were breached by our failure to consult with them before entering into the Non-Prosecution Agreement. In response to their petition, I filed a Declaration under seal that 531 EFTA00180065 included the victim notification letters provided to their attorney, Brad Edwards. At today's hearing, and over our objection, Judge Marra denied our motion to seal and unsealed the declaration. Accordingly, one piece of the Non￾Prosecution Agreement, specifically the paragraph that is quoted in the victim notification letters, has been disclosed. A. Marie Villafana Assistant U.S. Attorney 561 209-1047 532 EFTA00180066 Villafana, Ann Marie C. (USAFLS) From: Villafana, Ann Marie C. (USAFLS) Sent: Friday, July 11, 2008 12:17 PM To: Kuyrkendall, E N. (FBI) Subject: RE: Notice of Disclosure No, thanks, I want to spend the next year investigating Matt and Lilly. Did Jason show you the press release that I found? A. Marie VillafaAa 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: Kuyrkendall, E N. (FBI) Sent: Friday, July 11, 2008 12:03 PM To: Villafana, Ann Marie C. (USAFLS) Subject: Re: Notice of Disclosure All Jason and I can say is unbelievable. This is going to be a big mess. Jason and I r taking the next year off want to join us in Cabo? Original Message From: Villafana, Ann Marie C. (USAFLS) <Ann.Marie.C.Villafana@usdoj.gov> To: Jack Goldberger <jgoldberger@agwpa.com> Cc: Lee, Dexter (USAFLS); Atkinson, Karen (USAFLS) Sent: Fri Jul 11 11:55:14 2008 Subject: Notice of Disclosure Dear Mr. Goldberger: Today, Dexter Lee and I appeared before Judge Marra in connection with a suit filed by C.W. and T.M. asserting that their rights as victims were breached by our failure to consult with them before entering into the Non-Prosecution Agreement. In response to their petition, I filed a Declaration under seal that included the victim notification letters provided to their attorney, Brad Edwards. At today's hearing, and over our objection, Judge Marra denied our motion to seal and unsealed the declaration. Accordingly, one piece of the Non￾Prosecution Agreement, specifically the paragraph that is quoted in the victim notification letters, has been disclosed. A. Marie Villafana Assistant U.S. Attorney 533 EFTA00180067 561 209-1047 534 EFTA00180068 Villafana, Ann Marie C. (USAFLS) From: Sloman, Jeff (USAFLS) Sent: Friday, July 11, 2008 11:58 AM To: Villafana, Ann Marie C. (USAFLS) Subject: RE: Notice of Disclosure Marie, I have another question about today's hearing. Please call me at my desk. Thanks, Jeff 305-961.9299 From: Villafana, Ann Marie C. (USAFLS) Sent: Friday, July 11, 2008 11:55 AM To: Jack Goldberger Cc: Lee, Dexter (USAFLS); Atkinson, Karen (USAFLS) Subject: Notice of Disclosure Dear Mr. Goldberger: Today, Dexter Lee and I appeared before Judge Marra in connection with a suit filed by C.W. and T,M. asserting that their rights as victims were breached by our failure to consult with them before entering into the Non-Prosecution Agreement. In response to their petition, I filed a Declaration under seal that included the victim notification letters provided to their attorney, Brad Edwards. At today's hearing, and over our objection, Judge Marra denied our motion to seal and unsealed the declaration. Accordingly, one piece of the Non-Prosecution Agreement, specifically the paragraph that is quoted in the victim notification letters, has been disclosed. A. Marie Villafaila Assistant U.S. Attorney 561 209-1047 535 EFTA00180069 Recipient Read 'Jack Goldberger' Lee, Dexter (USAFLS) Read: 711112008 2:05 PM Atkinson, Karen (USAFLS) Read: 7/11/2008 11:58 AM Kuytkendall, E N. (FBI) Acosta, Alex (USAFLS) Read: 7/11/2008 12:01 PM Richards, Jason R. (FBI) Sloman, Jeff (USAFLS) Read: 7/111200811:56 AM 537 EFTA00180070 Villafana, Ann Marie C. (USAFLS) From: Villafana, Ann Marie C. (USAFLS) Sent: Friday, July 11, 2008 11:55 AM To: 'Jack Goldberger Cc: Lee, Dexter (USAFLS); Atkinson, Karen (USAFLS) Subject: Notice of Disclosure Dear Mr. Goldberger: Today, Dexter Lee and I appeared before Judge Marra in connection with a suit filed by C.W. and T.M. asserting that their rights as victims were breached by our failure to consult with them before entering into the Non-Prosecution Agreement. In response to their petition, I filed a Declaration under seal that included the victim notification letters provided to their attorney, Brad Edwards. At today's hearing, and over our objection, Judge Marra denied our motion to seal and unsealed the declaration. Accordingly, one piece of the Non-Prosecution Agreement, specifically the paragraph that is quoted in the victim notification letters, has been disclosed. A. Marie Villafaifa Assistant U.S. Attorney 561 209-1047 Tracking: 538 EFTA00180071 Recipient 'Jack Goldberger Lee. Dexter (USAFLS) Atkinson, Karen (USAFLS) Kuyrkendall, E N. (FBI) Acosta. Alex (USAFLS) Richards, Jason R. (FBI) Simian. Jeff (USAFLS) Read Read: 7111/2008 2:05 PM Read: 7/11/2008 12:01 PM Read: 7111/2008 11:56 AM 539 EFTA00180072 Villafana, Ann Marie C. (USAFLS) From: Villafana, Ann Marie C. (USAFLS) Sent: Friday, July 11, 2008 11:25 AM To: Acosta, Alex (USAFLS); Sloman, Jeff (USAFLS) Subject: Just got back from Epstein hearing Importance: High We need to talk. Dexter, Karen and I are at 561 209-1021 A. Marie Val!aloft Assistant U.S. Attorney 561 209-1047 Tracking: EFTA00180073 Redolent Road Acosta, Alex (USAFLS) Read: 7/1112008 12:01 PM Siouan, Jeff (USAFLS) Read: 7/11/2008 11:51 AM 541 EFTA00180074 Villafana, Ann Marie C. (USAFLS) From: Kuyrkendall, E N. (FBI) Sent: Thursday, July 10, 2008 5:34 PM To: Villafana, Ann Marie C. (USAFLS) Subject: Re: Proposed response to Goldberger's letter Looks great! He will try to push u for more but I agree with your stance to provide him with only the info we have agreed to in the NPAgreemt(no more no less) as our position is not to be involved in the civil process. Hey and thanks for understdng the position of notification(Jason and I had some extentive debate on the matter). See u tomorrow. Original Message From: Villafana, Ann Marie C. (USAFLS) <Ann.Marie.C.Villafana@usdoj.gov> To: Acosta, Alex (USAFLS); Sloman, Jeff (USAFLS); Atkinson, Karen (USAFLS) Cc: Kuyrkendall, E N.; Richards, Jason R. Sent: Thu Jul 10 17:12:26 2008 Subject: Proposed response to Goldberger's letter «080710 Response to Goldberger ltr re notification.wpd» Please let me know if this is alright to fax out today. I can see no reason for us to disclose any of the additional information that they have requested. The message is ready to be sent with the following file or link attachments: 080710 Response to Goldberger ltr re notification.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. 542 EFTA00180075 Villafana, Ann Marie C. (USAFLS) From: Sloman, Jeff (USAFLS) Sent: Thursday, July 10,2008 5:15 PM To: Villafana, Ann Marie C. (USAFLS); Acosta, Alex (USAFLS); Atkinson, Karen (USAFLS) Cc: Kuyrkendall, E N. (FBI); Richards, Jason R. (FBI) Subject: Re: Proposed response to Goldberger's letter Fine Original Message From: Villafana, Ann Marie C. (USAFLS) To: Acosta, Alex (USAFLS); Sloman, Jeff (USAFLS); Atkinson, Karen (USAFLS) Cc: Kuyrkendall, E N. (FBI); Richards, Jason R. (FBI) Sent: Thu Jul 10 17:12:26 2008 Subject: Proposed response to Goldberger's letter Please let me know if this is alright to fax out today. I can see no reason for us to disclose any of the additional information that they have requested. The message is ready to be sent with the following file or link attachments: 080710 Response to Goldberger ltr re notification.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. 543 EFTA00180076 Villafana, Ann Marie C. (USAFLS) From: Villafana, Ann Marie C. (USAFLS) Sent: Thursday, July 10, 2008 5:12 PM To: Acosta, Alex (USAFLS); Sloman, Jeff (USAFLS); Atkinson, Karen (USAFLS) Cc: Kuyrkendall, E N. (FBI); Richards, Jason R. (FBI) Subject: Proposed response to Goldbergers letter Attachments: 080710 Response to Goldberger ltr re notification.wpd Please let me know if this is alright to fax out today. I can see no reason for us to disclose any of the additional information that they have requested. The message is ready to be sent with the following file or link attachments: 080710 Response to Goldberger ltr re notification.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. 544 EFTA00180077 Villafana, Ann Marie C. (USAFLS) From: Sent: To: Cc: Subject: Villafana, Ann Marie C. (USAFLS) Thursday, July 10, 2008 4:59 PM Acosta, Alex (USAFLS); Sloman, Jeff (USAFLS); Atkinson, Karen (USAFLS) Kuyrkendall, E N. (FBI): Richards, Jason R. (FBI) 080710 Goldberger Ltr to A Marie C Villafana Esquire.pdf Hi all -- This letter just arrived from Jack Goldberger. I will prepare a response. 080710 berger Ltr to A I. Here is the final victim list that is going out to Goldberger via certified mall this afternoon. 080710 Filial /ictim List for G.. P.S. This is the final version of the letter that I sent to Jack yesterday: 080709 L r to ;oldberger re No. 545 EFTA00180078 Villafana, Ann Marie C. (USAFLS) From: Villafana, Ann Marie C. (USAFLS) Sent: Thursday, July 10, 2008 9:47 AM To: Kuyrkendall, E N. (FBI) Subject: RE: Hearing on Jane Doe Petition Yes please. We should try to get as many notifications out as possible today. I am preparing a log. A. Marie Villafana Assistant U.S. Attorney 561 209-1047 Original Message From: Kuyrkendall, E N. (FBI) Sent: Thursday, July 10, 2008 9:36 AM To: Villafana, Ann Marie C. (USAFLS) Subject: Re: Hearing on Jane Doe Petition Do u still want us to come over this morning. Original Message From: Villafana, Ann Marie C. (USAFLS) <Ann.Marie.C.Villafana@usdoj.gov> To: Lee, Dexter (USAFLS) Cc: Acosta, Alex (USAFLS); Sloman, Jeff (USAFLS); Richards, Jason R.; Kuyrkendall, E N. Sent: Thu Jul 10 09:26:40 2008 Subject: Hearing on Jane Doe Petition Hi Dexter: I just received a message from Judge Marra's CRD. He would like to set a hearing for 10:15 tomorrow. Are you available? A. Marie Villafana Assistant U.S. Attorney 561 209-1047 547 EFTA00180079 Villafana, Ann Marie C. (USAFLS) From: Lee, Dexter (USAFLS) Sent: Thursday, July 10, 2008 9:34 AM To: Villafana, Ann Marie C. (USAFLS) Subject: RE: Hearing on Jane Doe Petition Marie, Can you call me at (305) 961-9320? I tried your number but I think you are working In another office. Thanks. Dexter From: Villafana, Ann Marie C. (USAFLS) Sent: Thursday, July 10, 2008 9:32 AM To: Lee, Dexter (USAFLS) Subject: RE: Hearing on Jane Doe Petition Thanks, Dexter. I will ask both Nesbitt and Jason to attend. What documents should I bring with me? And how much information is the office willing to share with the Judge if he asks, what I think will be the big question, namely: If this deal was signed in September. why didn't the victims receive notification until yesterday? A. Marie Villafilha Assistant U.S. Attorney 561 209-1047 From: Lee, Dexter (USAFLS) Sent: Thursday, July 10, 2008 9:28 AM To: Villafana, Ann Made C. (USAFLS) Cc: Acosta, Alex (USAFLS); Sloman, Jeff (USAFLS); Richards, Jason R. (FBI); Kuyrkendall, E N. (FBI) Subject: RE: Hearing on Jane Doe Petition Marie, I received the same call. I'll be there. From: Villafana, Ann Marie C. (USAFLS) Sent: Thursday, July 10, 2008 9:27 AM To: Lee, Dexter (USAFLS) Cc: Acosta, Alex (USAFLS); Sloman, Jeff (USAFLS); Richards, Jason R. (FBI); Kuyrkendall, E N. (FBI) Subject: Hearing on Jane Doe Petition Importance: High Hi Dexter: 548 EFTA00180080 I just received a message from Judge Marra's CRD. He would like to set a hearing for 10:15 tomorrow. Are you available? A. Marie Viliafcrna Assistant U.S. Attorney 561 209-1047 549 EFTA00180081 Villafana, Ann Marie C. (USAFLS) From: Villafana, Ann Marie C. (USAFLS) Sent: Thursday, July 10, 2008 9:32 AM To: Lee, Dexter (USAFLS) Subject: RE: Hearing on Jane Doe Petition Thanks. Dexter. I will ask both Nesbitt and Jason to attend. What documents should I bring with me? And how much information is the office willing to share with the Judge if he asks, what I think will be the big question. namely: if this deal was signed in September, why didn't the victims receive notification until yesterday? A. Marie I/Natalia Assistant U.S. Attorney 561 209-1047 From: Lee, Dexter (USAFLS) Sent: Thursday, July 10, 2008 9:28 AM To: VIllafana, Ann Marie C. (USAFLS) Cc: Acosta, Alex (USAFLS); Sloman, Jeff (USAFLS); Richards, Jason R. (FBI); Kuyrkendall, E N. (FBI) Subject: RE: Hearing on Jane Doe Petition Marie, I received the same call. I'll be there. From: Villafana, Ann Made C. (USAFLS) Sent: Thursday, July 10, 2008 9:27 AM To: Lee, Dexter (USAFLS) Cc: Acosta, Alex (USAFLS); Sloman, Jeff (USAFLS); Richards, Jason R. (FBI); Kuyrkendall, E N. (FBI) Subject: Hearing on Jane Doe Petition Importance: High Hi Dexter: I just received a message from Judge Marra's CRD. He would like to set a hearing for 10:15 tomorrow. Are you available? A. Marie Villafafia Assistant U.S. Attorney 561 209-1047 Tracking: 550 EFTA00180082 Recipient Lee. Dexter (USAFLS) Read Read: 7/10/2008 9:32 AM 551 EFTA00180083 Villafana, Ann Marie C. (USAFLS) From: Lee, Dexter (USAFLS) Sent: Thursday, July 10, 2008 9:28 AM To: Acosta, Alex (USAFLS); Sloman, Jeff (USAFLS); Jacobus, Wendy (USAFLS); Villafana, Ann Marie C. (USAFLS) Cc: Herd, Kim (USAEO); Neal, Kristina (USAEO) Subject: In Re Jane Doe - Hearing on July 11, 2008 at 10:15 a.m. Alex, I just received a call from Judge Marra's Chambers. He has scheduled a hearing on the victim's petition for Friday, July 11, 2008, at 10:15 a.m. Can we have the FBI case agent present at the hearing? Dexter 552 EFTA00180084 Villafana, Ann Marie C. (USAFLS) From: Sent: To: Cc: Subject: Importance: Hi Dexter: Villafana, Ann Marie C. (USAFLS) Thursday, July 10.2008 9:27 AM Lee, Dexter (USAFLS) Acosta, Alex (USAFLS); Sloman, Jeff (USAFLS); Richards, Jason R. (FBI); Kuyrkendall, E N. (FBI) Hearing on Jane Doe Petition High I just received a message from Judge Marra's CRD. He would like to set a hearing for 10:15 tomorrow. Are you available? A. Marie Villafana Assistant U.S. Attorney 561 209-1047 Tracking: 553 EFTA00180085 Recipient Read Lee, Dexter (USAFLS) Read: 711(/20089:28 AM Acosta, Alex (USAFLS) Read: 7/10/2008 9:48 AM Sloman, Jett (USAFLS) Read: 7/10/2008 9:33 AM Richards, Jason R. (FBI) By/Mendell, E N. (FBI) 554 EFTA00180086 Villafana, Ann Marie C. (USAFLS) From: Villafana, Ann Marie C. (USAFLS) Sent: Wednesday, July 09, 2008 9:21 PM To: Lee, Dexter (USAFLS) Subject: Re: Conversation with Chambers Hi dexter. I don't know what happened. I left at 4:00 and everything had already gone to the courthouse. Our clerk's office is the worst so I should have sent a courtesy copy directly to Judge Marra. I am sorry for the trouble. Original Message From: Lee, Dexter (USAFLS) To: Villafana, Ann Marie C. (USAFLS) Sent: Wed Jul 09 18:02:00 2008 Subject: Conversation with Chambers Marie, I really appreciate you faxing a copy of what we filed to me. At 4:45 p.m., I e-filed my entry of appearance. At approximately 5:15, I received a call from Robert Glass, Judge Marra's law clerk. He told me the Judge had received my notice of appearance, but was wondering what happened to the government's response. At that point, I told him that we had earlier hand-filed a motion to seal, the government's response, and your declaration. He told me he would go down to the Clerk's Office and retrieve it. At 5:25, Mr. Glass called again to tell me everyone at the Clerk's Office had gone home. Judge Marra was anxious to get the government's response, given the time constraints. I just completed faxing everything to Chambers. It never ceases to amaze me how one small glitch can render meaningless all the work done on a project. Dexter 556 EFTA00180087 Villafana, Ann Marie C. (USAFLS) From: Lee, Dexter (USAFLS) Sent: Wednesday, July 09, 2008 6:02 PM To: Villafana, Ann Marie C. (USAFLS) Subject: Conversation with Chambers Marie, I really appreciate you faxing a copy of what we filed to me. At 4:45 p.m., I e-filed my entry of appearance. At approximately 5:15, I received a can from Robert Glass, Judge Marra's law clerk. He told me the Judge had received my notice of appearance, but was wondering what happened to the government's response. At that point, I told him that we had earlier hand-filed a motion to seal, the government's response, and your declaration. He told me he would go down to the Clerk's Office and retrieve it. At 5:25, Mr. Glass called again to tell me everyone at the Clerk's Office had gone home. Judge Marra was anxious to get the government's response, given the time constraints. I just completed faxing everything to Chambers. It never ceases to amaze me how one small glitch can render meaningless all the work done on a project. Dexter 557 EFTA00180088 Villafana, Ann Marie C. (USAFLS) From: Villafana, Ann Marie C. (USAFLS) Sent: Wednesday, July 09, 2008 3:52 PM To: Lee, Dexter (USAFLS) Subject: RE: Governments Motion to Seal Everything is out. Copies will be sent to you via inter-office. Thank you, Dexter, as usual, you came to the rescue! Can ask one more favor? Will you e-file a notice of appearance? That way notices of hearings will come to both of us. I have to run to an appointment, but you can get me on the cell phone. Thanks. A. Marie Villeilaria Assistant U.S. Attorney 561 209-1047 From: Lee, Dexter (USAFLS) Sent: Wednesday, July 09, 2008 2:13 PM To: Villafana, Ann Marie C. (USAFLS) Subject: RE: Government's Motion to Seal Marie, Yes, both the response, your declaration, and the attachments to your declaration, are to be sealed. Dexter From: Villafana, Ann Marie C. (USAFLS) Sent Wednesday, July 09, 2008 2:06 PM To: Lee, Dexter (USAFLS) Subject: RE: Government's Motion to Seal Hi Dexter — You want to seal my declaration as well, right? Please let me know and i will change accordingly. Thanks. A. Marie Viligfaifa Assistant U.S. Attorney 561 209-1047 From: Lee, Dexter (USAFLS) Sent: Wednesday, July 09, 2008 1:47 PM To: Villafana, Ann Marie C. (USAFLS) Subject: Government's Motion to Seal EFTA00180089 Marie, In preparation for this afternoon's filing, I have prepared a motion to seal, which is attached. I did not include Epstein's name and made general assertions regarding the confidentiality of the negotiations. Please have someone sign both the motion to seal, and the government's response, for me. We then need to prepare a sealed document tracking sheet, to accompany the motion. An original and one copy of the sealed document should be placed in two separate envelopes, with the case number written on the outside. An original and one copy of the motion to seal should be filed with the Clerk. Thanks. Dexter « File: victim_Mot_seal.wpd » Tracking: 561 EFTA00180090 Recipient Lee. Dexter (USAFLS) Road Read: 7/9/2008 3:54 PM 562 EFTA00180091 Villafana, Ann Marie C. (USAFLS) From: Sent: To: Subject: Kuyrkendall, E N. (FBI) Wednesday, July 09, 2008 3:41 PM Villafana, Ann Marie C. (USAFLS) RE: Emailing: Final Victim Notification — Courtney Wild.wpd Looks good except for upper lefthand corner of 2nd page "Page 2 of 4". Is that correct? Other than that it looks fine. Re the Declaration : Hopefully u r referring to the three clients/victims of Mr. Edwards when you state that "...notice of which was provided to the victims on July 09, 2008, is ...." (We have not notified all victims on this date) Hey everything else looks great!I I I !I II I I I I See you in the morning let us know a time to be at your office. We will talk about notification process then. Jason and Nesbitt From: Villafana, Ann Marie C. (USAFLS) [Ann.Marie.0 Sent: Wednesday, July 09, 2008 3:18 PM To: Richards, Jason R.; Kuyrkendall, E N. Subject: FW: Emailing: Final Victim Notification -- .Villafana@usdoj.gov) Courtney Wild.wpd «Final Victim Notification -- Courtney Wild.wpd» Hi guys -- earlier. Does it look alright? A. Marie Villafaila Assistant U.S. Attorney 561 209-1047 I sent this Original Message From: Villafana, Ann Marie C. (USAFLS) Sent: Wednesday, July 09, 2008 1:24 PM To: Acosta, Alex (USAFLS); Sloman, Jeff (USAFLS); Lee, Dexter (USAFLS); Atkinson, Karen (USAFLS) Cc: Richards, Jason R. (FBI); Kuyrkendall, E N. (FBI) Subject: Emailing: Final Victim Notification -- Courtney Wild.wpd Attached please find my proposed final victim notification letter. addressed to Edwards' client, Courtney Wild. (Please note that all victims but one is now an adult and all of Mr. Edwards' clients are This is of the adults.) Please let me know if you would like any changes made. Also, Dexter, please let me know when it is safe to send to Mr. Edwards. The letter for S.R. will be identical. The message is ready to be sent with the following file or link attachments: 563 EFTA00180092 Final Victim Notification -- Courtney Wild.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. 564 EFTA00180093 Villafana, Ann Marie C. (USAFLS) From: Villafana, Ann Marie C. (USAFLS) Sent: Wednesday, July 09, 2008 3:24 PM To: Lee, Dexter (USAFLS) Subject: RE: Revised Draft with DOJ Edits I added 18 use 3509(d)(2). It says we don't even need to file a motion, but better safe than sorry. A. Marie VIIlalinla Assistant U.S. Attorney 561 209-1047 From: Lee, Dexter (USAFLS) Sent: Wednesday, July 09, 2008 3:10 PM To: Villafana, Ann Mane C. (USAFLS) Subject: RE: Revised Draft with DO) Edits Marie, Yes, we are ready to file. As far as statutory authority, we can cite the Privacy Act, 5 U.S.C. 552a, et. Seq. Also, are there any special victim-witness provisions regarding restrictions on disclosure of victims' names and personal identifying information? Dexter From: Villafana, Ann Marie C. (USAFLS) Sent: Wednesday, July 09, 2008 3:06 PM To: Lee, Dexter (USAFLS) Subject: RE: Revised Draft with DOJ Edits Hi Dexter — Does this mean your response is good to go? On the sealed document tracking form, is there a particular statute or rule that you think gives us the right to file under seal? Thank you. A. Marie Villa/bfla Assistant U.S. Attorney 561 209-1047 From: Lee, Dexter (USAFLS) Sent: Wednesday, July 09, 2008 3:04 PM To: Herd, Kim (USAEO); Villafana, Ann Marie C. (USAFLS); Acosta, Alex (USAFLS); Sloman, Jeff (USAFLS) Cc: Jacobus, Wendy (USAFLS); Rothenberg, Laurence E (SMO); Wood, Seth M (SMO); Neal, Kristin (USAEO); Manning, Katharine (USAEO) Subject: RE: Revised Draft with DO) Edits Kim, 565 EFTA00180094 Thanks to you, Kristina and Katherine for all your help. We'll let you know what happens. Dexter From: Herd, Kim (USAEO) Sent: Wednesday, July 09, 2008 3:02 PM To: Lee, Dexter (USAFLS); Villafana, Ann Marie C. (USAFLS); Acosta, Alex (USAFLS); Sloman, Jeff (USAFLS) Cc: Jacobus, Wendy (USAFLS); Rothenberg, Laurence E (SMO); Wood, Seth M (SMO); Neal, Kristina (USAEO); Manning, Katharine (USAEO) Subject: RE: Revised Draft with DO) Edits All — We have checked with OLP and they have cleared the language in your latest revision (per your e-mail below). Please let us know if you have additional questions. Thank you for your patience on this — Kim From: Lee, Dexter (USAFLS) Sent: Wednesday, July 09, 2008 2:26 PM To: Herd, Kim (USAEO); Neal, Kristina (USAEO); VIParana, Ann Marie C. (USAFLS); Acosta, Alex (USAFLS); Sloman, Jeff (USAFLS) Cc: Jacobus, Wendy (USAFLS) Subject: Revised Draft with DO) Edits Colleagues, Attached please find the latest revision, which includes the edits suggested by EOUSA. I have also incorporated the word "place", per Jeff's suggestion. For our DOJ colleagues, there is a new Section III, which goes into detail regarding the contact Marie had with the three victims. Also, as to whether Edwards raises the right to fairness being violated, I was referring to paragraph five of the emergency petition, which only alleges violations of the right to consultation, notice of public court proceedings, information regarding right to restitution, and notice of rights under the CVRA. A motion to seal has been prepared, seeking leave of the Court to seal the government's response, Marie's declaration, and the attachments to the declaration. Dexter Lee « File: victim_resp_USArev corrected_DOJedits.wpd » Tracking: 566 EFTA00180095 Recipient Lee, Dexter (USAFLS) Read Read: 719/2008 3:24 PM 567 EFTA00180096 Villafana, Ann Marie C. (USAFLS) From: Sent: To: Subject: Attachments: Villafana, Ann Marie C. (USAFLS) Wednesday, July 09, 2008 3:19 PM Richards, Jason R. (FBI); Kuyrkendall, E N. (FBI) FW: Emailing: Final Victim Notification -- Courtney VVild.wpd Final Victim Notification -- Courtney Wild.wpd Hi guys -- I sent this earlier. Does it look alright? A. Marie Villafana Assistant U.S. Attorney 561 209-1047 Original Message From: Villafana, Ann Marie C. (USAFLS) Sent: Wednesday, July 09, 2008 1:24 PM To: Acosta, Alex (USAFLS); Sloman, Jeff (USAFLS); Lee, Dexter (USAFLS); Atkinson, Karen (USAFLS) Cc: Richards, Jason R. (FBI); Kuyrkendall, E N. (FBI) Subject: Emailing: Final Victim Notification -- Courtney Wild.wpd Attached please find my proposed final victim notification letter. addressed to Edwards' client, Courtney Wild. (Please note that all victims but one is now an adult and all of Mr. Edwards' clients are This is of the adults.) Please let me know if you would like any changes made. Also, Dexter, please let me know when it is safe to send to Mr. Edwards. The letter for S.R. will be identical. The message is ready to be sent with the following file or link attachments: Final Victim Notification -- Courtney Wild.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. 568 EFTA00180097 Villafana, Ann Marie C. (USAFLS) From: Villafana, Ann Marie C. (USAFLS) Sent: Wednesday, July 09, 2008 3:13 PM To: Acosta, Alex (USAFLS); Sloman, Jeff (USAFLS); Atkinson, Karen (USAFLS) Cc: Kuyrkendall, E N. (FBI); Richards. Jason R. (FBI) Subject: Proposed Response to Jack Goldberger When you have a chance, please review. I don't think this has to go out today. I will not be sending Jack the "cc's" of the notification letters until they have all been sent. 080709 iberger Itr re not A. Marie Villafaila Assistant U.S. Attorney 561 209-1047 Tracking: 569 EFTA00180098 Recipient Acosta, Alex (USAFLS) Sloman. Jett (USAF LS) Atkinson, Karen (USAFLS) Kuyrkendall. E N. (FBI) Richards, Jason R. (FBI) Read Read: 7/1072008 9:47 AM Read: 7710/2008 11:16 AM 570 EFTA00180099 Villafana, Ann Marie C. (USAFLS) From: Lee, Dexter (USAFLS) Sent: Wednesday, July 09, 2008 3:10 PM To: Villafana, Ann Marie C. (USAFLS) Subject: RE: Revised Draft with DOJ Edits Marie, Yes, we are ready to file. As far as statutory authority, we can cite the Privacy Act, 5 U.S.C. 552a, et. Seq. Also, are there any special victim-witness provisions regarding restrictions on disclosure of victims' names and personal identifying information? Dexter From: Villafana, Ann Marie C. (USAFLS) Sent: Wednesday, July 09, 2008 3:06 PM To: Lee, Dexter (USAFLS) Subject: RE: Revised Draft with DO) Edits I li Dexter — Does this mean your response is good to go? On the sealed document tracking form, is there a particular statute or rule that you think gives us the right to file under seal? Thank you. .4. Alariv Assistant U.S. Attorney 561209-1047 From: Lee, Dexter (USAFLS) Sent: Wednesday, July 09, 2008 3:04 PM To: Herd, Klm (USAEO); Villafana, Ann Marie C. (USAFLS); Acosta, Alex (USAFLS); Sloman, Jeff (USAFLS) Cc: Jacobus, Wendy (USAFLS); Rothenberg, Laurence E (SMO); Wood, Seth M (SMO); Neal, Kristina (USAEO); Manning, Katharine (USAEO) Subject: RE: Revised Draft with DO) Edits Kim, Thanks to you, Kristina and Katherine for all your help. We'll let you know what happens. Dexter From: Herd, Kim (USAEO) Sent: Wednesday, July 09, 2008 3:02 PM To: Lee, Dexter (USAFLS); Villafana, Ann Marie C. (USAFLS); Acosta, Alex (USAFLS); Sloman, Jeff (USAFLS) Cc: Jacobus, Wendy (USAFLS); Rothenberg, Laurence E (SMO); Wood, Seth M (SMO); Neal, Kristina (USAEO); Manning, Katharine (USAEO) Subject: RE: Revised Draft with DO) Edits 571 EFTA00180100 All — We have checked with OLP and they have cleared the language in your latest revision (per your e-mail below). Please let us know if you have additional questions. Thank you for your patience on this — Kim From: Lee, Dexter (USAFLS) Sent: Wednesday, July 09, 2008 2:26 PM To: Herd, Kim (USAEO); Neal, Kristina (USAEO); Villafana, Ann Marie C. (USAFLS); Acosta, Alex (USAFLS); Sloman, Jeff (USAFLS) Cc: Jacobus, Wendy (USAFLS) Subject: Revised Draft with DO) Edits Colleagues, Attached please find the latest revision, which includes the edits suggested by EOUSA. I have also incorporated the word "place", per Jeff's suggestion. For our DOJ colleagues, there Is a new Section III, which goes into detail regarding the contact Marie had with the three victims. Also, as to whether Edwards raises the right to fairness being violated, I was referring to paragraph five of the emergency petition, which only alleges violations of the right to consultation, notice of public court proceedings, information regarding right to restitution, and notice of rights under the CVRA. A motion to seal has been prepared, seeking leave of the Court to seal the government's response, Marie's declaration, and the attachments to the declaration. Dexter Lee « File: victIm_resp_USArev corrected_DOJedits.wpd » 572 EFTA00180101 Villafana, Ann Marie C. (USAFLS) From: Villafana, Ann Marie C. (USAFLS) Sent: Wednesday, July 09, 2008 3:07 PM To: Acosta, Alex (USAFLS); Sloman, Jeff (USAFLS) Cc: Lee, Dexter (USAFLS) Subject: Victim Notification Letter Importance: High Hi all — We need to get everything ready to go to court by 4:00. It looks like the response and my declaration are ready to go, but I need to send the notification letters to Edwards before everything can be filed. Can you please review and give me your comments? Thank you. Final Victim gotification -- C... A. Marie Villafana Assistant U.S. Attorney 561 209-1047 Tracking: 573 EFTA00180102 Recipient Acosta. Alex (USAFLS) Sloman, Jeff (USAFLS) Lee. Dexter (USAFLS) Road Read: 7/10/2008 10:35 AM Read: 7/8/2008 3:10 PM 574 EFTA00180103 Villafana, Ann Marie C. (USAFLS) From: Villafana, Ann Marie C. (USAFLS) Sent: Wednesday, July 09, 2008 3:06 PM To: Lee, Dexter (USAFLS) Subject: RE: Revised Draft with DOJ Edits Hi Dexter — Does this mean your response is good to go? On the sealed document tracking form, is there a particular statute or rule that you think gives us the right to tile under seal? Thank you. A. Alarie Assistant U.S. Attorney 561 209-1047 From: Lee, Dexter (USAFLS) Sent: Wednesday, July 09, 2008 3:04 PM To: Herd, Kim (USAEO); Villafana, Ann Marie C. (USAFLS); Acosta, Alex (USAFLS); Sloman, Jeff (USAFLS) Cc: Jacobus, Wendy (USAFLS); Rothenberg, Laurence E (SMO); Wood, Seth M (SMO); Neal, Kristina (USAEO); Manning, Katharine (USAEO) Subject: RE: Revised Draft with DO) Edits Kim, Thanks to you, Kristina and Katherine for all your help. We'll let you know what happens. Dexter From: Herd, Kim (USAEO) Sent: Wednesday, July 09, 2008 3:02 PM To: Lee, Dexter (USAFLS); Villafana, Ann Marie C. (USAFLS); Acosta, Alex (USAFLS); Sloman, Jeff (USAFLS) Cc: Jacobus, Wendy (USAFLS); Rothenberg, Laurence E (SMO); Wood, Seth M (SMO); Neal, Kristina (USAEO); Manning, Katharine (USAEO) Subject: RE: Revised Draft with DO) Edits All — We have checked with OLP and they have cleared the language in your latest revision (per your e-mail below). Please let us know if you have additional questions. Thank you for your patience on this — Kim From: Lee, Dexter (USAFLS) Sent: Wednesday, July 09, 2008 2:26 PM To: Herd, Kim (USAEO); Neal, Kristina (USAEO); Villafana, Ann Marie C. (USAFLS); Acosta, Alex (USAFLS); Sloman, Jeff (USAFLS) 575 EFTA00180104 Cc: Jacobus, Wendy (USAFLS) Subject: Revised Draft with DO) Edits Colleagues, Attached please find the latest revision, which includes the edits suggested by EOUSA. I have also incorporated the word "place", per Jeff's suggestion. For our DOJ colleagues, there is a new Section Ill, which goes into detail regarding the contact Marie had with the three victims. Also, as to whether Edwards raises the right to fairness being violated, I was referring to paragraph five of the emergency petition, which only alleges violations of the right to consultation, notice of public court proceedings, information regarding right to restitution, and notice of rights under the CVRA. A motion to seal has been prepared, seeking leave of the Court to seal the government's response, Marie's declaration, and the attachments to the declaration. Dexter lee « File: victim_resp_USArev corrected_Daledits.wpd » Tracking: 576 EFTA00180105 Recipient Lee, Dexter (USAFLS) Read Read: 7/9/2008 3:06 PM i 577 EFTA00180106 Villafana, Ann Marie C. (USAFLS) From: Lee, Dexter (USAFLS) Sent: Wednesday, July 09, 2008 3:04 PM To: Herd, Kim (USAEO); Villafana, Ann Marie C. (USAFLS); Acosta, Alex (USAFLS); Sloman, Jeff (USAFLS) Cc: Jacobus, Wendy (USAFLS); Rothenberg, Laurence E (SMO); Wood, Seth M (SMO); Neal, Kristina (USAEO); Manning, Katharine (USAEO) Subject: RE: Revised Draft with DOJ Edits Kim, Thanks to you, Kristina and Katherine for all your help. We'll let you know what happens. Dexter From: Herd, Kim (USAEO) Sent: Wednesday, July 09, 2008 3:02 PM To: Lee, Dexter (USAFLS); Villafana, Ann Marie C. (USAFLS); Acosta, Alex (USAFLS); Sloman, Jeff (USAFLS) Cc: Jacobus, Wendy (USAFLS); Rothenberg, Laurence E (SMO); Wood, Seth M (St4O); Neal, Kristina (USAEO); Manning, Katharine (USAEO) Subject: RE: Revised Draft with DO) Edits All - We have checked with OLP and they have cleared the language in your latest revision (per your email below). Please let us know if you have additional questions. Thank you for your patience on this — Kim From: Lee, Dexter (USAFLS) Sent: Wednesday, July 09, 2008 2:26 PM To: Herd, Kim (USAEO); Neal, Kristina (USAEO); Villafana, Ann Marie C. (USAFLS); Acosta, Alex (USAFLS); Sloman, Jeff (USAFLS) Cc: Jacobus, Wendy (USAFLS) Subject: Revised Draft with DO) Edits Colleagues, Attached please find the latest revision, which includes the edits suggested by EOUSA. I have also incorporated the word "place", per Jeff's suggestion. For our DOJ colleagues, there is a new Section III, which goes into detail regarding the contact Marie had with the three victims. Also, as to whether Edwards raises the right to fairness being violated, I was referring to paragraph five of the emergency petition, which only alleges violations of the right to consultation, notice of public court proceedings, information regarding right to restitution, and notice of rights under the CVRA. 578 EFTA00180107 A motion to seal has been prepared, seeking leave of the Court to seal the government's response, Marie's declaration, and the attachments to the declaration. Dexter Lee « File: victIm_resp_USArev corrected_Daledits.wpd » 579 EFTA00180108 Villafana, Ann Marie C. (USAFLS) From: Villafana, Ann Marie C. (USAFLS) Sent: Wednesday, July 09, 2008 2:52 PM To: Lee, Dexter (USAFLS) Subject: RE: Latest Version Do you anticipate any more changes? A. Marie ViIlataisa Assistant U.S. Attorney 561 209-1047 From: Lee, Dexter (USAFLS) Sent: Wednesday, July 09, 2008 2:48 PM To: Villafana, Ann Marie C. (USAFLS) Subject: Latest Version Marie, We're getting close to game time. Here is my corrected version, which takes out deferred prosecution. Please use this version as the one you will be filing. Make the latest changes to this document. Thanks. Dexter « File: victim_resp_USArev corrected_Daledits(1445).wpd » Tracking: 580 EFTA00180109 Recipient Lee, Dexter (USAFLS) Read Read: 7/9/2008 3:00 PM 581 EFTA00180110 Villafana, Ann Marie C. (USAFLS) From: Lee, Dexter (USAFLS) Sent: Wednesday, July 09, 2008 2:48 PM To: Villafana, Ann Marie C. (USAFLS) Subject: Latest Version Marie, We're getting close to game time. Here Is my corrected version, which takes out deferred prosecution. Please use this version as the one you will be filing. Make the latest changes to this document. Thanks. Dexter victim_resp_USA ev corrected_D.. 582 EFTA00180111 Villafana, Ann Marie C. (USAFLS) From: Villafana, Ann Marie C. (USAFLS) Sent: Wednesday, July 09, 2008 2:48 PM To: Kuyrkendall, E N. (FBI) Subject: RE: Declaration Looks Greatllllllllllll Attachments: Villafana Declaration-v2 final.wpd Thanks. Here it is with your changes. Can you read through once more. Thank you! .4. Alone (elan Assistant U.S. Attorney 561 209-1047 From: Kuyrkendall, E N. (FBI) Sent: Wednesday, July 09, 2008 2:44 PM To: Villafana, Ann Marie C. (USAFLS) Subject: Declaration Looks Greatifillffl 1111 Jason and I have finished and It looks greatIIIIIIIIIIIIIIIIIII EFTA00180112 Villafana, Ann Marie C. (USAFLS) From: Villafana, Ann Marie C. (USAFLS) Sent: Wednesday, July 09, 2008 2:42 PM To: Lee, Dexter (USAFLS); Acosta, Alex (USAFLS) Subject: Emailing: victim_resp_USArev corrected_DOJedits.wpd Attachments: victim_resp_USArev corrected_DOJedits.wpd Alex and Dexter -- I caught a couple of typos and made one substantive change. Nesbitt says she can't remember whether she handed Courtney's letter to her or if it was mailed after the interview, so I have changed it to say C.W.'s letter was "provided" by the FBI. I will make the same change in my Declaration. I think I made the change that Alex wanted on page 3, but please take a look. Thanks. The message is ready to be sent with the following file or link attachments: victim_resp_USArev corrected_DOJedits.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: 584 EFTA00180113 Recipient Lee, Dexter (USAFIS) Acosta, Alex (OWLS) Read Read: 7/9/2008 2:45 PM 585 EFTA00180114 Villafana, Ann Marie C. (USAFLS) From: Kuyrkendall, E N. (FBI) Sent: Wednesday, July 09, 2008 2:38 PM To: Villafana, Ann Marie C. (USAFLS) Subject: RE: Emailing: Villafana Declaration•v2 final.wpd Marie, Paragraph 7: Should be changed to something similar to this: opening hostile to the prosecution of Epstein. The FBI attempted to interview S.R. in October 2007, at which time she refused to provide any information regarding Jeffrey Epstein (302 of refusal Oct 2, 2007) Paragraph 8: agreement was signed, four victims were contacted and these provision (we spoke to all four of them in person) Still reading but looks good thus far From: Villafana, Ann Marie C. (USAFLS) [Ann.Marie.C.Villafana@usdoj.gov] Sent: Wednesday, July 09, 2008 2:17 PM To: Kuyrkendall, E N.; Richards, Jason R. Subject: Emailing: Villafana Declaration-v2 final.wpd «Villafana Declaration-v2 final.wpd» Sorry if I seem cranky, I am just getting changes from 12 people at once. The message is ready to be sent with the following file or link attachments: Villafana Declaration-v2 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. 586 EFTA00180115 Villafana, Ann Marie C. (USAFLS) From: Acosta, Alex (USAFLS) Sent: Wednesday, July 09, 2008 2:37 PM To: Lee, Dexter (USAFLS); Herd, Kim (USAEO); Neal, Kristina (USAEO); Villafana, Ann Marie C. (USAFLS); Sloman, Jeff (USAFLS) Cc: Jacobus, Wendy (USAFLS) Subject: RE: Revised Draft with DOJ Edits am just reading this. I am very concerned, because I have repeatedly edited the phrase "deferred prosecution" and replaced it with an "agreement to defer federal prosecution in favor of prosecution by the State of Florida." The phrase is now back on page 3. I send the email only to make clear that there is a difference. This is not a deferred federal prosecution. There was a state case, that case was prosecuted, and in light of state guilty plea federal government has agreed not to pursue a state prosecution as well. This matters, because the victims have the opportunity to have their rights vindicated in state court as well. Not a big deal, but just want to make sure the distinction remains clear in any subsequent drafts. From: Lee, Dexter (USAFLS) Sent: Wednesday, July 09, 2008 2:26 PM To: Herd, Klm (USAEO); Neal, Kristina (USAEO); VIllafana, Ann Marie C. (USAFLS); Acosta, Alex (USAFLS); Sloman, Jeff (USAFLS) Cc: Jacobus, Wendy (USAFLS) Subject: Revised Draft with DO) Edits Colleagues, Attached please find the latest revision, which includes the edits suggested by EOUSA. I have also incorporated the word "place", per Jeff's suggestion. For our DOJ colleagues, there is a new Section III, which goes into detail regarding the contact Marie had with the three victims. Also, as to whether Edwards raises the right to fairness being violated, I was referring to paragraph five of the emergency petition, which only alleges violations of the right to consultation, notice of public court proceedings, information regarding right to restitution, and notice of rights under the CVRA. A motion to seal has been prepared, seeking leave of the Court to seal the government's response, Marie's declaration, and the attachments to the declaration. Dexter Lee « File: victim_resp_USArev corrected_DOJedits.wpd » 587 EFTA00180116 Villafana, Ann Marie C. (USAFLS) From: Lee, Dexter (USAFLS) Sent: Wednesday, July 09, 2008 2:28 PM To: Herd, Kim (USAEO); Neal, Kristina (USAEO); Villafana, Ann Marie C. (USAFLS); Acosta, Alex (USAFLS); Sloman, Jeff (USAFLS) Cc: Jacobus, Wendy (USAFLS) Subject: Revised Draft with DOJ Edits Colleagues, Attached please find the latest revision, which includes the edits suggested by EOUSA. I have also incorporated the word "place", per Jeff's suggestion. For our DOJ colleagues, there is a new Section III, which goes into detail regarding the contact Marie had with the three victims. Also, as to whether Edwards raises the right to fairness being violated, I was referring to paragraph five of the emergency petition, which only alleges violations of the right to consultation, notice of public court proceedings, information regarding right to restitution, and notice of rights under the CVRA. A motion to seal has been prepared, seeking leave of the Court to seal the government's response, Marie's declaration, and the attachments to the declaration. Dexter Lee victim_resp_USA •ev corrected_D.. 588 EFTA00180117 Villafana, Ann Marie C. (USAFLS) From: Villafana, Ann Marie C. (USAFLS) Sent: Wednesday, July 09, 2008 2:17 PM To: Kuyrkendall, E N. (FBI); Richards, Jason R. (FBI) Subject: Emailing: Villafana Declaration-v2 final.wpd Attachments: Villafana Declaration-v2 final.wpd Sorry if I seem cranky, I am just getting changes from 12 people at once. The message is ready to be sent with the following file or link attachments: Villafana Declaration-v2 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. 589 EFTA00180118 Villafana, Ann Marie C. (USAFLS) From: Lee, Dexter (USAFLS) Sent: Wednesday, July 09, 2008 2:13 PM To: Villafana, Ann Marie C. (USAFLS) Subject: RE: Government's Motion to Seal Marie, Yes, both the response, your declaration, and the attachments to your declaration, are to be sealed. Dexter From: Villafana, Ann Marie C. (USAFLS) Sent: Wednesday, July 09, 2008 2:06 PM To: Lee, Dexter (USAFLS) Subject: RE: Government's Motion to Seal Eli Dexter — You want to seal my declaration as well, right? Please let me know and I will change accordingly. Thanks. A. Marie Vinafitna Assistant U.S. Attorney 561 209.1047 From: Lee, Dexter (USAFLS) Sent: Wednesday, July 09, 2008 1:47 PM To: Villafana, Ann Marie C. (USAFLS) Subject: Government's Motion to Seal Marie, In preparation for this afternoon's filing, I have prepared a motion to seal, which is attached. I did not Include Epstein's name and made general assertions regarding the confidentiality of the negotiations. Please have someone sign both the motion to seal, and the government's response, for me. We then need to prepare a sealed document tracking sheet, to accompany the motion. An original and one copy of the sealed document should be placed in two separate envelopes, with the case number written on the outside. An original and one copy of the motion to seal should be filed with the Clerk. Thanks. Dexter « File: victim_Mot_seal.wpd » 590 EFTA00180119 Villafana, Ann Marie C. (USAFLS) From: Villafana, Ann Marie C. (USAFLS) Sent: Wednesday, July 09, 2008 2:06 PM To: Lee, Dexter (USAFLS) Subject: RE: Government's Motion to Seal Hi Dexter— You want to scat my declaration as well. right? Please let me know and I will change accordingly. Thanks. A. Marie lieJuda? Assistant U.S. Attorney 561 209-1047 From: Lee, Dexter (USAFLS) Sent: Wednesday, July 09, 2008 1:47 PM To: Villafana, Ann Marie C. (USAFLS) Subject: Government's Motion to Seal Marie, In preparation for this afternoon's filing, I have prepared a motion to seal, which is attached. I did not include Epstein's name and made general assertions regarding the confidentiality of the negotiations. Please have someone sign both the motion to seal, and the government's response, for me. We then need to prepare a sealed document tracking sheet, to accompany the motion. An original and one copy of the sealed document should be placed in two separate envelopes, with the case number written on the outside. An original and one copy of the motion to seal should be filed with the Clerk. Thanks. Dexter << File: victim_Mot_seal.wpd » Tracking: 591 EFTA00180120 Recipient Lee, Dexter (USAFLS) Read Reed: 7/912008 2:13 PM 592 EFTA00180121 Villafana, Ann Marie C. (USAFLS) From: Lee. Dexter (USAFLS) Sent: Wednesday, July 09, 2008 1:49 PM To: Acosta, Alex (USAFLS); Villafana, Ann Marie C. (USAFLS); Sloman, Jeff (USAFLS) Cc: Jacobus, Wendy (USAFLS) Subject: RE: Latest Version That was a typographical error, which Marie caught. It has been corrected. Dexter From: Acosta, Alex (USAFLS) Sent: Wednesday, July 09, 2008 1:48 PM To: Lee, Dexter (USAFLS); Villafana, Ann Marie C. (USAFLS); Sloman, Jeff (USAFLS) Cc: Jacobus, Wendy (USAFLS) Subject: RE: Latest Version This version states that Edwards "did make the contact." I thought he had NOT made the contact to provide the state with information? (2d to last paragraph) From: Lee, Dexter (USAFLS) Sent: Wednesday, July 09, 2008 12:08 PM To: Villafana, Ann Marie C. (USAFLS); Acosta, Alex (USAFLS); Sloman, Jeff (USAFLS) Cc: Jacobus, Wendy (USAFLS) Subject: Latest Version Colleagues, Attached please find the latest version of the government's response. I have added a new Section III, which details the efforts made by Marie in maintaining contact with T.M., C.W., and S.R. Dexter « Flle: vIctim_resp_USArev corrected (3).wpd » 593 EFTA00180122 Villafana, Ann Marie C. (USAFLS) From: Acosta, Alex (USAFLS) Sent: Wednesday, July 09, 2008 1:48 PM To: Lee, Dexter (USAFLS); Villafana, Ann Marie C. (USAFLS); Sloman, Jeff (USAFLS) Cc: Jacobus, Wendy (USAFLS) Subject: RE: Latest Version This version states that Edwards "did make the contact." I thought he had NOT made the contact to provide the state with information? (2d to last paragraph) From: Lee, Dexter (USAFLS) Sent: Wednesday, July 09, 2008 12:08 PM To: Villafana, Ann Marie C. (USAFLS); Acosta, Alex (USAFLS); Sloman, Jeff (USAFLS) Cc: Jacobus, Wendy (USAFLS) Subject: Latest Version Colleagues, Attached please find the latest version of the government's response. I have added a new Section III, which details the efforts made by Marie in maintaining contact with T.M., C.W., and S.R. Dexter « File: victim_resp_USArev corrected (3).wpd » 595 EFTA00180123 Villafana, Ann Marie C. (USAFLS) From: Lee, Dexter (USAFLS) Sent: Wednesday, July 09, 2008 1:47 PM To: Villafana, Ann Marie C. (USAFLS) Subject: Government's Motion to Seal Marie, In preparation for this afternoon's filing, I have prepared a motion to seal, which is attached. I did not include Epstein's name and made general assertions regarding the confidentiality of the negotiations. Please have someone sign both the motion to seal, and the government's response, for me. We then need to prepare a sealed document tracking sheet, to accompany the motion. An original and one copy of the sealed document should be placed In two separate envelopes, with the case number written on the outside. An original and one copy of the motion to seal should be filed with the Clerk. Thanks. Dexter Ell victim Mot seal. wpd 596 EFTA00180124 Villafana, Ann Marie C. (USAFLS) From: Villafana, Ann Marie C. (USAFLS) Sent: Wednesday, July 09, 2008 1:24 PM To: Acosta, Alex (USAFLS); Sloman, Jeff (USAFLS); Lee, Dexter (USAFLS); Atkinson, Karen (USAFLS) Cc: Richards, Jason R. (FBI); Kuyrkendall, E N. (FBI) Subject: Emailing: Final Victim Notification -- Courtney Wild.wpd Attachments: Final Victim Notification -- Courtney Wild.wpd Attached please find my proposed final victim notification letter. This is addressed to Edwards' client, Courtney Wild. (Please note that all of the victims but one is now an adult and all of Mr. Edwards' clients are adults.) Please let me know if you would like any changes made. Also, Dexter, please let me know when it is safe to send to Mr. Edwards. The letter for S.R. will be identical. The message is ready to be sent with the following file or link attachments: Final Victim Notification -- Courtney Wild.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: 597 EFTA00180125 Recipient Read Acosta. Alex (USAFLS) Read: 7/9/2008 1:27 PM soman, Jeff (USAFLS) Read: 7/9/2008 1:35 PM Lee. Dexter (USAFLS) Read: 719/20081:35 PM Atkinson, Karen (USAFL$) Read: 7/10/200811:18 AM Richards, Jason R (FBI) Kuyrkendall. E N. (FBI) 598 EFTA00180126 Villafana, Ann Marie C. (USAFLS) From: Villafana, Ann Marie C. (USAFLS) Sent: Wednesday, July 09, 2008 1:19 PM To: Lee, Dexter (USAFLS); Herd, Kim (USAEO); Neal, Kristina (USAEO) Cc: Manning, Katharine (USAEO) Subject: RE: Victim Notification The Notification specifically provided that each victim would receive a copy with the names of all other victims redacted. We also have provided the list only by hand delivery to counsel for Mr. Epstein with a cover sheet advising them that disclosing the names to anyone could violate federal and/or state law. That cover sheet will accompany the victim notification even when it is sent to the victims themselves. A. Marie Vingfitna Assistant U.S. Attorney 561 209- I 0,17 From: Lee, Dexter (USAFLS) Sent: Wednesday, July 09, 2008 1:17 PM To: Herd, Kim (USAEO); Neal, Kristina (USAEO) Cc: Manning, Katharine (USAEO); Villafana, Ann Marie C. (USAFLS) Subject: RE: Victim Notification Kim, The consensus is that there's nothing to talk to Edwards about because the agreement has been signed and the federal case is over. We will not be reaching out to Edwards to get an extension. As to the draft notice, Epstein's lawyers raised a similar concern. Dexter From: Herd, Kim (USAEO) Sent: Wednesday, July 09, 2008 1:07 PM To: Lee, Dexter (USAFLS); Neal, Kristina (USAEO) Cc: Manning, Katharine (USAEO) Subject: RE: Victim Notification Our concern is that the list of individuals contains the names of minors. Have you thought about just listing initials? Or not providing the entire list to each victim? Also — any word from victim counsel on an extension? From: Lee, Dexter (USAFLS) Sent: Wednesday, July 09, 2008 12:29 PM To: Herd, Kim (USAEO); Neal, Kristina (USAEO) Subject: FW: Victim Notification 599 EFTA00180127 From: %/Malone, Ann Marie C. (USAFLS) Sent: Tuesday, July 08, 2008 5:37 PM To: Acosta, Alex (USAFLS); Lee, Dexter (USAFLS) Subject: Victim Notification Hi Alex and Dexter — Here is the proposed notification that was provided to Epstein's counsel last week. << File: Victim Identification and Notification Final with Goldberger sig revised.wpd >> Assuming that they don't sign it tomorrow, I would remove the bottom portion that calls for Epstein's signature and incorporate some instructional language along with notice that Jack Goldberger is the contact person for any civil litigation. A. Marie Villafafla Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 Phone 561 209-1047 Fax 561 820-8777 Tracking: 600 EFTA00180128 Recipient Read Lee, Dexter (USAFLS) Read: 719120081:19 PM Herd, Kim (USAEO) Read: 7/9/2008 1:19 PM Neal, Krishna (USAEO) Read: 719/20081:32 PM Manning, Katharine (USAEO) Road: 7/9120081:40 PM 601 EFTA00180129 Villafana, Ann Marie C. (USAFLS) From: Villafana, Ann Marie C. (USAFLS) Sent: Wednesday, July 09, 2008 1:04 PM To: Acosta, Alex (USAFLS); Sloman, Jeff (USAFLS); Atkinson. Karen (USAFLS) Cc: Kuyrkendall, E N. (FBI); Richards, Jason R. (FBI) Subject: Response to Goldberger Letter Here are my thoughts: I. Notification only by mail: For those girls who are currently not represented (or for whom we do not know of any representation), we intend to contact the victims by telephone to tell them of the resolution and to get mailing addresses to send the written notification or to determine if they have secured counsel to send it to them. For the girls who are represented, contact will be made by telephone followed by the mailing of the notification. I think a "live" thank you is the least that is required at this point and a "check in" to make sure that girls who need counseling are getting it. (FBI has already arranged counseling for several girls.) In any written response to Mr. Goldberger, I would simply ignore this request. 2. Separate mailings: I have no objection to this change. The notice was drafted the way it was so that Epstein would only have to sign one document rather than 33. Since he isn't going to sign any, that change is fine with me. 3. Notification limited to the information on the first page of the draft notification: In light of Epstein's refusal to sign the acknowledgement, I think some additional explanation is required. I will prepare that revision and send to you shortly. 4. Eliminate the Acknowledgement portion: I have no objection to this. 5. Supplement the notification with our previous statement that we are not vouching for the veracity of any claim: I would reject this request and, in our response to Goldberger, state that we have limited our list to those whom we were prepared to name in an indictment and, accordingly, we believe that there is proof beyond a reasonable doubt that each was a victim of Epstein's. 6. Explain why the acknowledgement is required: In our response to Goldberger, I think we should explain that the acknowledgement language was meant to create a means for proving the existence of the agreement without having to provide copies of the Non-Prosecution Agreement, which contains a confidentiality clause. While I have no objection to revising the language, I think that Epstein's position will lead to litigation regarding the need to disclose the full agreement, which is contrary to the parties' interest in confidentiality. I agree that we cannot force him to sign the acknowledgement, but he must accept the consequences of that decision. 7. Names of pro bono lawyers and information regarding their communication: I have already advised Mr. Goldberger that I will provide him with the names and contact information of attorneys who represent the victims, so I have no objection to that. I also have no objection to telling him that they were recommended by the Crime Victims Rights Advocacy Group based upon a referral from the Justice Department. Other than that, I have no intention of disclosing any "communications" that I had with them. I will take a crack at revising the victim notifications and drafting a response to Goldberger. Any other thoughts I should incorporate? A. Marie VIllafaffa Assistant U.S. Attorney 561 209-1047 Tracking: 604 EFTA00180130 Recipient Road Acosta. Alex (USAFLS) Read: 7/912008 1:26 PM Sloman. Jefl (USAFLS) Read: 7f9/2008 1:05 PM Atkinson, Karen (USAFLS) Kuyrkendall. E N. (FBI) Richards. Jason R. (FBI) 605 EFTA00180131 Villafana, Ann Marie C. (USAFLS) From: Villafana, Ann Marie C. (USAFLS) Sent: Wednesday, July 09, 2008 12:42 PM To: Lee, Dexter (USAFLS); Acosta, Alex (USAFLS); Sloman, Jeff (USAFLS) Cc: Atkinson, Karen (USAFLS) Subject: Emailing: Villafana Declaration-v2 final.wpd Attachments: Villafana Declaration-v2 final.wpd Hi all -- I think this includes everyone's thoughts. If any changes are needed, please let me know. The message is ready to be sent with the following file or link attachments: Villafana Declaration-v2 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. 606 EFTA00180132 Villafana, Ann Marie C. (USAFLS) From: Villafana, Ann Marie C. (USAFLS) Sent: Wednesday, July 09, 200812:34 PM To: Lee, Dexter (USAFLS) Cc: Acosta, Alex (USAFLS) Subject: RE: Victim Notification Ili Dexter — Jack Goldberger's response just arrived — I am sending it in a separate e-mail. I need to revise the letter and make sure Alex and Jeff approve before it goes out, so it won't be ready until later this afternoon. I just need to make sure that it goes out before I file my Declaration, since I swear that it has gone out to Attorney Edwards. Thanks. A. Marie Iffilafafla Assistant U.S. Attorney 561 209-1047 From: Lee, Dexter (USAFLS) Sent: Wednesday, July 09, 2008 12:28 PM To: Villafana, Ann Marie C. (USAFLS); Acosta, Alex (USAFLS) Subject: RE: Victim Notification Marie, DOJ wanted us to hold off sending this out until we get clearance to file our document this afternoon. Will that pose any problems? Dexter From: Villafana, Ann Marie C. (USAFLS) Sent: Tuesday, July 08, 2008 5:37 PM To: Acosta, Alex (USAFLS); Lee, Dexter (USAFLS) Subject: Victim Notification Hi Alex and Dexter— Here is the proposed notification that was provided to Epstein's counsel last week. << File: Victim Identification and Notification Final with Goldberger sig revised.wpd >> Assuming that they don't sign it tomorrow, I would remove the bottom portion that calls for Epstein's signature and incorporate some instructional language along with notice that Jack Goldberger is the contact person for any civil litigation. A. Marie Yillafafia Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 Phone 561 209-1047 607 EFTA00180133 Fax 561 820-8777 Tracking: 608 EFTA00180134 Recipient Red Lee. Dexter (USAFLS) Read: 7/9)2008 12:35 PM Acosta, Alex (USAFLS) Read: 7/9/2008 1:25 PM 609 EFTA00180135 Villafana, Ann Marie C. (USAFLS) From: Villafana, Ann Marie C. (USAFLS) Sent: Wednesday, July 09, 2008 12:35 PM To: Acosta, Alex (USAFLS); Sloman, Jeff (USAFLS); Atkinson, Karen (USAFLS) Cc: Kuyrkendall, E N. (FBI); Richards, Jason R. (FBI); Lee, Dexter (USAFLS) Subject: FW: Jeffrey Epstein -- Response from Jack Goldberger Attachments: Letter to A. Marie Villafana dated 070908.pdf Attached please find Jack Goldberger's response to my letter. A. Marie Villafaha Assistant U.S. Attorney 561 209-1047 Original Message From: Nira Alanis [mailto:nalanis@agwpa.com) Sent: Wednesday, July 09, 2008 12:28 PM To: Villafana, Ann Marie C. (USAFLS) Subject: Jeffrey Epstein This attachment has been sent to you on behalf of Jack A. Goldberger, Esquire. Regards, Nayanira Alanis, Legal Assistant Atterbury, Goldberger & Weiss, P.A. 250 Australian Avenue South Suite 1400 West Palm Beach, FL 33401 T#561-659-8300 F#561-835-8691 Tracking: 610 EFTA00180136 Recipient Read Acosta, Alex (USAFLS) Read: 7/9/20081:26 PM &omen. Jeff (USAFLS) Read: 7/9120081:32 PM Atkinson. Karen (USAFLS) Read: 7/10/2008 11:14 AM Kuyrkendaff, E N. (FBI) Richards. Jason R. (FBI) Lee, Dexter (USAFLS) Read: 7/912008 12:35 PM 611 EFTA00180137 Villafana, Ann Marie C. (USAFLS) From: Lee, Dexter (USAFLS) Sent: Wednesday, July 09, 2008 12:28 PM To: Villafana, Ann Marie C. (USAFLS); Acosta. Alex (USAFLS) Subject: RE: Victim Notification Marie, DOJ wanted us to hold off sending this out until we get clearance to file our document this afternoon. Will that pose any problems? Dexter From: 1/Marano, Ann Marie C. (USAFLS) Sent: Tuesday, July 08, 2008 5:37 PM To: Acosta, Alex (USAFLS); Lee, Dexter (USAFLS) Subject: Victim Notification Hi Alex and Dexter — Here is the proposed notification that was provided to Epstein's counsel last week. << File: Victim Identification and Notification Final with Goldberger sig revised.wpd >> Assuming that they don't sign it tomorrow, I would remove the bottom portion that calls for Epstein's signature and incorporate some instructional language along with notice that Jack Goldberger is the contact person for any civil litigation. 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 613 EFTA00180138 Villafana, Ann Marie C. (USAFLS) From: Villafana, Ann Marie C. (USAFLS) Sent: Wednesday, July 09, 2008 12:22 PM To: Acosta, Alex (USAFLS); Lee, Dexter (USAFLS) Cc: Sloman, Jeff (USAFLS); Atkinson, Karen (USAFLS) Subject: Revised Declaration I removed the sentence about why the Palm Beach Police contacted FBI for assistance. I notice that the language regarding my securing pro bono counsel for C.W. was removed. I think it shows how far we went out of our way to protect the victims, especially Mr. Edwards' clients. Is it alright to put it back in? A. Marie Villafacia Assistant U.S, Attorney 561 209-1047 Tracking: 614 EFTA00180139 Recipient Read Acosta. Alex (USAFLS) Read: 7/9/2008 1:25 PM Lee, Dexter (USAFLS) Read: 7/9/2008 12:22 PM Sloman, Jeff (USAFLS) Read: 71912008 2:05 PM Atkinson. Karen (USAFLS) 615 EFTA00180140 Villafana, Ann Marie C. (USAFLS) From: Villafana, Ann Marie C. (USAFLS) Sent: Wednesday, July 09, 2008 12:15 PM To: Lee, Dexter (USAFLS) Subject: Emailing: victim_resp_USArev corrected (3).wpd Attachments: victim_resp_USArev corrected (3).wpd Hi Dexter -- I caught one date error and an important "not" in the last section - - as far as I know, Edwards did NOT make contact with the State Attorney's Office. The message is ready to be sent with the following file or link attachments: victim_resp_USArev corrected (3).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. 616 EFTA00180141 Villafana, Ann Marie C. (USAFLS) From: Lee, Dexter (USAFLS) Sent: Wednesday, July 09, 2008 12:08 PM To: Villafana, Ann Marie C. (USAFLS); Acosta, Alex (USAFLS); Sloman, Jeff (USAFLS) Cc: Jacobus, Wendy (USAFLS) Subject: Latest Version Colleagues, Attached please find the latest version of the government's response. I have added a new Section III, which details the efforts made by Marie in maintaining contact with T.M., C.W., and S.R. Dexter vIctim_resp_USA rev corrected (... 617 EFTA00180142 Villafana, Ann Marie C. (USAFLS) From: Villafana, Ann Marie C. (USAFLS) Sent: Wednesday, July 09, 2008 12:00 PM To: Acosta, Alex (USAFLS); Lee, Dexter (USAFLS); Sloman, Jeff (USAFLS) Cc: Jacobus, Wendy (USAFLS) Subject: RE: Brad Edwards' End Game I have talked to Brad and his heart seems to be in the right place, he just has gotten himself a bit too worked up over this. The agents and I (and Karen, I think) would be happy to meet with him and his clients. The problem is that there is nothing to discuss -- the agreement has already been signed and our investigation is closed. In light of that, I don't think a meeting would satisfy him because he seems to believe that his petition can undo what has been done. 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: Acosta, Alex (USAFLS) Sent: Wednesday, July 09, 2008 11:56 AM To: Lee, Dexter (USAFLS); Villafana, Ann Marie C. (USAFLS); Sloman, Jeff (USAFLS) Cc: Jacobus, Wendy (USAFLS) Subject: Re: Brad Edwards' End Game Not at all. We need to file today. Original Message From: Lee, Dexter (USAFLS) To: Villafana, Ann Marie C. (USAFLS); Acosta, Alex (USAFLS); Sloman, Jeff (USAFLS) Cc: Jacobus, Wendy (USAFLS) Sent: Wed Jul 09 11:52:46 2008 Subject: Brad Edwards' End Game Marie, Alex and Jeff, I have just spoken with Kim Herd at EOUSA regarding clearance to argue that no rights to consultation accrue until after charges have been filed. The argument is being considered by Criminal Division and OLP. Kim wanted to know what Edwards' objective in this case is, and whether he would agree to meet and try to resolve this. I told Kim that the only way to avoid our filing at 5:00 p.m. today is if Edwards' agree to a joint enlargement of time. 618 EFTA00180143 How reasonable do you think Edwards is? Dexter Tracking: 619 EFTA00180144 Recipient Reed Acosta, Alex (USAFLS) Read: 7/9200812:01 PM Lee, Dexter (USAFLS) Read: 7/9/2008 12:01 PM Stomas, Jett (USAFLS) Read: 7/9/2008 12:00 PM Jacobus, Wendy (USAFLS) Read: 7/9/200812:12 PM 620 EFTA00180145 Villafana, Ann Marie C. (USAFLS) From: Acosta, Alex (USAFLS) Sent: Wednesday, July 09, 2008 11:56 AM To: Lee, Dexter (USAFLS); Villafana, Ann Marie C. (USAFLS); Sloman, Jeff (USAFLS) Cc: Jacobus, Wendy (USAFLS) Subject: Re: Brad Edwards' End Game Not at all. We need to file today. Original Message From: Lee, Dexter (USAFLS) To: Villafana, Ann Marie C. (USAFLS); Acosta, Alex (USAFLS); Sloman, Jeff (USAFLS) Cc: Jacobus, Wendy (USAFLS) Sent: Wed Jul 09 11:52:46 2008 Subject: Brad Edwards' End Game Marie, Alex and Jeff, I have just spoken with Kim Herd at EOUSA regarding clearance to argue that no rights to consultation accrue until after charges have been filed. The argument is being considered by Criminal Division and OLP. Kim wanted to know what Edwards' objective in this case is, and whether he would agree to meet and try to resolve this. I told Kim that the only way to avoid our filing at 5:00 p.m. today is if Edwards' agree to a joint enlargement of time. How reasonable do you think Edwards is? Dexter 621 EFTA00180146 Villafana, Ann Marie C. (USAFLS) From: Lee. Dexter (USAFLS) Sent: Wednesday, July 09, 2008 11:53 AM To: Villafana, Ann Marie C. (USAFLS); Acosta, Alex (USAFLS); Sloman, Jeff (USAFLS) Cc: Jacobus, Wendy (USAFLS) Subject: Brad Edwards' End Game Marie, Alex and Jeff, I have just spoken with Kim Herd at EOUSA regarding clearance to argue that no rights to consultation accrue until after charges have been filed. The argument is being considered by Criminal Division and OLP. Kim wanted to know what Edwards' objective in this case is, and whether he would agree to meet and try to resolve this. I told Kim that the only way to avoid our filing at 5:00 p.m. today is if Edwards' agree to a joint enlargement of time. How reasonable do you think Edwards is? Dexter 622 EFTA00180147 Villafana, Ann Marie C. (USAFLS) From: Villafana, Ann Marie C. (USAFLS) Sent: Wednesday, July 09. 2008 11:49 AM To: Sloman, Jeff (USAFLS); Lee, Dexter (USAFLS); Acosta, Alex (USAFLS) Cc: Atkinson, Karen (USAFLS); Jacobus, Wendy (USAFLS) Subject: RE: Emailing: victim_resp_USArev corrected.wpd Attachments: image001.png Here is the language from the Agreement. I will leave it to you to interpret whether disclosing part of the substance of the Agreement requires sealing or otherwise. The parties anticipate that this agreement will not be made p public record. If the United States receives a Freedom of In Act request or any compulsory process commanding the dis the agreement, it will provide notice to Epstein before nu disclosure. A. Marie Villafafia Assistant U.S. Attorney 561 209-1047 ---Original Message----- From: Sloman, Jeff (USAFLS) Sent: Wednesday, July 09, 2008 9:57 AM To: Lee, Dexter (USAFLS); Villafana, Ann Marie C. (USAFLS); Acosta, Alex (USAFLS) Cc: Atkinson, Karen (USAFLS); Jacobus, Wendy (USAFLS) Subject: RE: Emailing: victim Jesp_USArev corrected.wpd Doesn't the confidentiality provision obligate us to file it under seal? Original Message--- From: Lee, Dexter (USAFLS) Sent: Wednesday, July 09, 2008 9:53 AM To: Villafana, Ann Marie C. (USAFLS); Acosta, Alex (USAFLS) Cc: Atkinson, Karen (USAFLS); Sloman, Jeff (USAFLS); Jacobus, Wendy (USAFLS) Subject: RE: Emailing: victim_resp_USArev corrected.wpd Alex and Jeff, Do you have any preference for filing under seal or a public filing? If we can protect the identities of the minor victims in a public filing, that is one less reason to tile it under seal. The other considerations are the government's confirmation that Epstein was under federal investigation, and the confidentiality provision in the deferral of prosecution agreement with Epstein. It's actually easier to file it electronically, and the general policy is that documents filed in court are public. Dexter ----Original Message 623 EFTA00180148 From: Villafana, Ann Marie C. (USAFLS) Sent: Wednesday, July 09, 2008 9:23 AM To: Lee, Dexter (USAFLS); Acosta, Alex (USAFLS) Cc: Atkinson, Karen (USAFLS); Sloman, Jeff (USAFLS); Jacobus, Wendy (USAFLS) Subject: RE: Emailing: victim_resp_USArev corrected.wpd I was planning to redact all of that information prior to scanning it and attaching Exhibit Stickers. I think we should do so even if this is filed under seal. A. Marie Villafacta Assistant U.S. Attorney 561 209-1047 Original Message-- From: Lee, Dexter (USAFLS) Sent: Wednesday, July 09, 2008 9:22 AM To: Villafana, Ann Marie C. (USAFLS); Acosta, Alex (USAFLS) Cc: Atkinson, Karen (USAFLS); Sloman, Jeff (USAFLS); Jacobus, Wendy (USAFLS) Subject: RE: Emailing: victim_resp_USArev corrected.wpd Marie, I will sign the response. Since this case involves girls who were minors when the crimes were committed, and there is a confidentiality provision in the deferral of prosecution agreement with Epstein, I believe this should be filed under seal. Otherwise, we'll have to go through each letter and excise the names, addresses, and other identifying information on the three girls. Dexter ----Original Message From: Villafana, Ann Marie C. (USAFLS) Sent: Wednesday, July 09, 2008 9:1 I AM To: Lee, Dexter (USAFLS); Acosta, Alex (USAFLS) Cc: Atkinson, Karen (USAFLS); Sloman, Jeff (USAFLS) Subject: Emailing: victim_resp_USArev corrected.wpd Dexter and Alex -- I fixed a couple of typos and entered the correct information about the dates when the letters were sent. I also included the information about all three of Edwards' clients, T.M., C.W., and S.R. At the end, I also corrected the information regarding the notifications of the victims about the change of plea. I called Edwards on Friday, but I'm not sum whether we spoke that day or if he called me over the weekend. And the agents and I didn't start making calls together until Monday after the hearing. So I notified Edwards to inform his three clients, and PBPD tried to notify six victims, I think. I didn't want the court to think that we tried to notify all 33 girls. I will make similar changes to my declaration and send that to you shortly. Also, I notice there is no signature block. Do you want me to sign and file? Or will you do that, Dexter? Thanks. The message is ready to be sent with the following file or link attachments: victim_resp_USArev corrected.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: 624 EFTA00180149 Recipient Read Slomen. Jeff (USAFLS) Read: 719/2008 11:49 AM Lee. Dexter (USAFLS) Read: 7/9/2008 11:49 AM Acosta, Alex (USAFLS) Read: 7/9/2008 11:55 AM Atkinson, Karen (USAFLS) Jacobus. Wendy (USAFLS) Read: 7/9/2008 12:29 PM 625 EFTA00180150 Villafana, Ann Made C. (USAFLS) From: Acosta, Alex (USAFLS) Sent: Wednesday, July 09, 2008 10:38 AM To: Villafana, Ann Marie C. (USAFLS); Lee, Dexter (USAFLS) Cc: Atkinson, Karen (USAFLS); Sloman, Jeff (USAFLS) Subject: RE: Emailing: Villafana Declaration-v2 final.wpd A few thoughts: 1. bottom of page 5/ top of page 6 -- were we talk about the "Throughout the negotiations, ... recompense." Should we cite to Decl para 8? 2. Next para -- cite to para 8 should be cite to para 10. 3. Right before the next para starting with On Friday, should we discuss the content of para 9, where the same attorney that now complains had an opportunity to communicate with our office and didn't. What I find particularly compelling about that point is that Edwards had, or should have had, knowledge of this agreement because his clients were told of the agreement previously. Cite para 8. In fact, maybe this should be a separate argument III -- he, or his clients, had prior knowledge and didn't complain until now. Thoughts? 4. In para 2 of the declaration, do we need the last sentence hitting the State Attorney? Original Message From: Villafana, Ann Marie C. (USAFLS) Sent: Wednesday, July 09, 2008 9:22 AM To: Acosta, Alex (USAFLS); Lee, Dexter (USAFLS) Cc: Atkinson, Karen (USAFLS); Sloman, Jeff (USAFLS) Subject: Emailing: Villafana Declaration-v2 final.wpd Attached is the revised declaration. Please let me know if any other changes are required. I am off to Court but should be back by 11:30. Thank you. The message is ready to be sent with the following file or link attachments: Villafana Declaration-v2 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. 626 EFTA00180151 Villafana, Ann Marie C. (USAFLS) From: Sloman, Jeff (USAFLS) Sent: Wednesday, July 09, 2008 9:57 AM To: Lee, Dexter (USAFLS); Villafana, Ann Marie C. (USAFLS); Acosta, Alex (USAFLS) Cc: Atkinson, Karen (USAFLS): Jacobus, Wendy (USAFLS) Subject: RE: Emailing: victim_resp_USArev corrected.wpd Doesn't the confidentiality provision obligate us to file it under seal? Original Message From: Lee, Dexter (USAFLS) Sent: Wednesday, July 09, 2008 9:53 AM To: Villafana, Ann Marie C. (USAFLS); Acosta, Alex (USAFLS) Cc: Atkinson, Karen (USAFLS); Sloman, Jeff (USAFLS); Jacobus, Wendy (USAFLS) Subject: RE: Emailing: victim_resp_USArev corrected.wpd Alex and Jeff, Do you have any preference for filing under seal or a public filing? If we can protect the identities of the minor victims in a public filing, that is one less reason to file it under seal. The other considerations are the government's confirmation that Epstein was under federal investigation, and the confidentiality provision in the deferral of prosecution agreement with Epstein. It's actually easier to file it electronically, and the general policy is that documents filed in court are public. Dexter Original Message From: Villafana, Ann Marie C. (USAFLS) Sent: Wednesday, July 09, 2008 9:23 AM To: Lee, Dexter (USAFLS); Acosta, Alex (USAFLS) Cc: Atkinson, Karen (USAFLS); Sloman, Jeff (USAFLS); Jacobus, Wendy (USAFLS) Subject: RE: Emailing: victim_resp_USArev corrected.wpd I was planning to redact all of that information prior to scanning it and attaching Exhibit Stickers. I think we should do so even if this is filed under seal. A. Marie Villafaha Assistant U.S. Attorney 561 209-1047 Original Message From: Lee, Dexter (USAFLS) Sent: Wednesday, July 09, 2008 9:22 AM To: Villafana, Ann Marie C. (USAFLS); Acosta, Alex (USAFLS) 627 EFTA00180152 Cc: Atkinson, Karen (USAFLS); Sloman, Jeff (USAFLS); Jacobus, Wendy (USAFLS) Subject: RE: Emailing: victim_resp_USArev corrected.wpd Marie, I will sign the response. Since this case involves girls who were minors when the crimes were committed, and there is a confidentiality provision in the deferral of prosecution agreement with Epstein, I believe this should be filed under seal. Otherwise, we'll have to go through each letter and excise the names, addresses, and other identifying information on the three girls. Dexter Original Message From: Villafana, Ann Marie C. (USAFLS) Sent: Wednesday, July 09, 2008 9:11 AM To: Lee, Dexter (USAFLS); Acosta, Alex (USAFLS) Cc: Atkinson, Karen (USAFLS); Sloman, Jeff (USAFLS) Subject: Emailing: victim_resp_USArev corrected.wpd Dexter and Alex -- I fixed a couple of typos and entered the correct information about the dates when the letters were sent. I also included the information about all three of Edwards' clients, T.M., C.W., and S.R. At the end, I also corrected the information regarding the notifications of the victims about the change of plea. I called Edwards on Friday, but I'm not sure whether we spoke that day or if he called me over the weekend. And the agents and I didn't start making calls together until Monday after the hearing. So I notified Edwards to inform his three clients, and PBPD tried to notify six victims, I think. I didn't want the court to think that we tried to notify all 33 girls. I will make similar changes to my declaration and send that to you shortly. Also, I notice there is no signature block. Do you want me to sign and file? Or will you do that, Dexter? Thanks. The message is ready to be sent with the following file or link attachments: victim_resp_USArev corrected.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. 628 EFTA00180153 Villafana, Ann Marie C. (USAFLS) From: Villafana, Ann Marie C. (USAFLS) Sent: Wednesday, July 09,2008 9:23 AM To: Lee, Dexter (USAFLS); Acosta, Alex (USAFLS) Cc: Atkinson, Karen (USAFLS); Sloman, Jeff (USAFLS); Jacobus, Wendy (USAFLS) Subject: RE: Emailing: victim_resp_USArev corrected.wpd I was planning to redact all of that information prior to scanning it and attaching Exhibit Stickers. I think we should do so even if this is filed under seal, A. Marie Villafana Assistant U.S. Attorney 561 209-1047 Original Message From: Lee, Dexter (USAFLS) Sent: Wednesday, July 09, 2008 9:22 AM To: Villafana, Ann Marie C. (USAFLS); Acosta, Alex (USAFLS) Cc: Atkinson, Karen (USAFLS); Sloman, Jeff (USAFLS); Jacobus, Wendy (USAFLS) Subject: RE: Emailing: victim_resp_USArev corrected.wpd Marie, I will sign the response. Since this case involves girls who were minors when the crimes were committed, and there is a confidentiality provision in the deferral of prosecution agreement with Epstein, I believe this should be filed under seal. Otherwise, we'll have to go through each letter and excise the names, addresses, and other identifying information on the three girls. Dexter Original Message From: Villafana, Ann Marie C. (USAFLS) Sent: Wednesday, July 09, 2008 9:11 AM To: Lee, Dexter (USAFLS); Acosta, Alex (USAFLS) Cc: Atkinson, Karen (USAFLS); Sloman, Jeff (USAFLS) Subject: Emailing: victim_resp_USArev corrected.wpd Dexter and Alex -- I fixed a couple of typos and entered the correct information about the dates when the letters were sent. I also included the information about all three of Edwards' clients, T.M., C.W., and S.R. At the end, I also corrected the information regarding the notifications of the victims about the change of plea. I called Edwards on Friday, but I'm not sure whether we spoke that day or if he called me over the weekend. And the agents and I didn't start making calls together until Monday after the hearing. So I notified Edwards to inform his three clients, and PBPD tried to notify six 629 EFTA00180154 victims, I think. I didn't want the court to think that we tried to notify all 33 girls. I will make similar changes to my declaration and send that to you shortly. Also, I notice there is no signature block. Do you want me to sign and file? Or will you do that, Dexter? Thanks. The message is ready to be sent with the following file or link attachments: victim_resp_USArev corrected.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: 630 EFTA00180155 Recipient Read Lee, Dexter (USAFLS) Read: 7/9120089:30 AM Acosta, Alex (USAFLS) AUdnson, Karen (USAFLS) Read: 71912008 9:30 AM Slornan, Jett (USAFLS) Road: 7/912008 9:25 AM Jacobus, Wendy (USAFLS) Read: 7/9120089:53 AM 631 EFTA00180156 Villafana, Ann Marie C. (USAFLS) From: Villafana, Ann Marie C. (USAFLS) Sent: Wednesday, July 09, 2008 9:22 AM To: Acosta, Alex (USAFLS); Lee, Dexter (USAFLS) Cc: Atkinson, Karen (USAFLS); Sloman, Jeff (USAFLS) Subject: Emailing: Villafana Declaration-v2 final.wpd Attachments: Villafana Declaration-v2 final.wpd Attached is the revised declaration. Please let me know if any other changes are required. I am off to Court but should be back by 11:30. Thank you. The message is ready to be sent with the following file or link attachments: Villafana Declaration-v2 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. 632 EFTA00180157 Villafana, Ann Marie C. (USAFLS) From: Lee, Dexter (USAFLS) Sent: Wednesday, July 09, 2008 9:22 AM To: Villafana, Ann Marie C. (USAFLS); Acosta, Alex (USAFLS) Cc: Atkinson, Karen (USAFLS); Sloman, Jeff (USAFLS); Jacobus, Wendy (USAFLS) Subject: RE: Emailing: victim_resp_USArev corrected.wpd Marie, I will sign the response. Since this case involves girls who were minors when the crimes were committed, and there is a confidentiality provision in the deferral of prosecution agreement with Epstein, I believe this should be filed under seal. Otherwise, we'll have to go through each letter and excise the names, addresses, and other identifying information on the three girls. Dexter Original Message From: Villafana, Ann Marie C. (USAFLS) Sent: Wednesday, July 09, 2008 9:11 AM To: Lee, Dexter (USAFLS); Acosta, Alex (USAFLS) Cc: Atkinson, Karen (USAFLS); Sloman, Jeff (USAFLS) Subject: Emailing: victim_resp_USArev corrected.wpd Dexter and Alex -- I fixed a couple of typos and entered the correct information about the dates when the letters were sent. I also included the information about all three of Edwards' clients, T.M., C.W., and S.R. At the end, I also corrected the information regarding the notifications of the victims about the change of plea. I called Edwards on Friday, but I'm not sure whether we spoke that day or if he called me over the weekend. And the agents and I didn't start making calls together until Monday after the hearing. So I notified Edwards to inform his three clients, and PBPD tried to notify six victims, I think. I didn't want the court to think that we tried to notify all 33 girls. I will make similar changes to my declaration and send that to you shortly. Also, I notice there is no signature block. Do you want me to sign and file? Or will you do that, Dexter? Thanks. The message is ready to be sent with the following file or link attachments: victim_resp_USArev corrected.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. 633 EFTA00180158