RE: Epstein update

Hi Myesha – Our server was down for a few hours this morning, so I am very behind on my revisions. I wanted to talk about which girls we should drop.
[REDACTED] and [REDACTED], are the girls who have filed lawsuits. I have excluded them.
With respect to the other girls brought by [REDACTED], here are my thoughts. We can drop [REDACTED] and [REDACTED] S. very easily. Both only gave 1 or 2 massages and did not disclose their ages. [REDACTED] S. is a good witness because she shows that, if you aren’t willing to do more sexual activity, Epstein stops the massage and doesn’t want to see you anymore. She seems like someone whom we could get in as 404(b) because the probative nature outweighs its prejudice.

I think we should drop [REDACTED], because I don’t believe she will ever be completely truthful about the amount of sexual activity that occurred. (She is the girl that one of the witnesses described as “a virgin on graduation day.”)

That only leaves [REDACTED], the soccer player who cried for the entire interview. I think that she may be worth keeping. We have such good documentary evidence related to her – message pads, car rental records, 156 calls with [REDACTED], and 2 calls with [REDACTED] (we have very few phone calls with [REDACTED], so this is key).
What do you think?
Assistant U.S. Attorney

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FYI – Tell me what you think. Also, can you pull the messages from [REDACTED] [REDACTED] and see if you can tell what the dates are and who took the messages? [REDACTED].
And am I correct that we have only two phone calls with [REDACTED]? 4/23/04 and 5/2/04

[REDACTED]orney
561

Hey Marie,

There was no indictment attached to your email. Can you send it again.

In addition to the two calls from [redacted] to [redacted] on her cell phone 4/23/04 at 1:35 pm and 5/2/04 at 10:32 am,
we have two telephone calls from [redacted] to Shawn Haught's ([redacted] boyfriend) telephone on 03/04/2004 at
9:46 am and 2:30 pm.

Message pads reflect 10 messages from beginning 03/11/2003 ending 03/01/2006. Individuals identified as taking the messages are , and Alfredo Rodriguez.

Hi [Redacted] – I didn’t send the indictment yet. I was just asking for input on who to include and who to exclude.

How old was [Redacted] when she went with [Redacted]?

[Redacted]
Attorney

Hi guys – sorry to bother you. On some of the new girls I don’t have dobs.

Martell
Dicenso (the 302 says her dob is 8/5/2007)

e (and do we have phone number?)

Have you guys ever talked to or ? Should I include them?

Assistant U.S. Attorney

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Here are the names of people I am intending to keep in the indictment:

This image is not a chart. It contains a list of names that are intended to be kept in an indictment. However, most of the names are redacted (blacked out). The visible information indicates:

• One entry is "(redacted) eyewitness info only)".
• Another entry states "- initials only, not listed Jane Doe".

Not all will be in substantive counts, but they will be mentioned in the overt acts.

Assistant U.S. Attorney

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EFTA00223750

Here are the names of people I am intending to keep in the indictment:

(eyewitness info only)

• initials only. not' listed Jane Doe

Not all will be in substantive counts, but they will be mentioned in the overt acts.
Assistant U.S. Attorney

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EFTA00223748

The image contains contact information, likely for an organization. The address is 500 S. Australian Ave, Suite 400, West Palm Beach, FL 33401. A phone number is also partially visible, starting with "Phone 5". The text "Thanks" is also present.

Original Message
From: Kuyrkendall, N.
Sent: Friday February 22 2008 2:08 PM
To: (USAFLS)
Subject: Re: Phone call info

Ill fax it in 5 min(what fax )

Original Message
From: (USAFLS) <
To: Kuyrkendall, N.
Sent: Fri Feb 22 14:07:06 2008
Subject: Phone call info

Hi - Can you email or fume the dates of the calls? I can add them to the indictment today. I think is going to try to finish her review over the weekend.

Thanks.

Marie Villafaña

Assistant U.S. Attorney

500 S. Australian Ave, Suite 400

West Palm Beach, FL 33401

Phone 561 209-1047

Fax

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Hi — I have received two conflicting points of view regarding this question, so I thought I should ask the ..Here exp is my situation:

1 have been involved in' long-term investigation of I ild exploitation case. Throughout the investigation, I have prese ed evidence and testimony to Grand Jury I Some of that evidence and testimony related to six victims (ofI total of 19 victims), including the live testimony of one of those victims. I also began presenting evidence related to what I called '"draft proposed indictment." For various reasons, the indictment has been delayed about 9 months. And,r r other strategic reasons, we have decided to drop the six victims referenced above, and replaced them with different six victims.

The question is now raised as to whether I should continue presenting to Grand Jury', with' 404(b)-type instruction related to the evidence of the six dropped victims and some sort of instruction regarding the initial "draft proposed indictment", or whether I should present i Grand Jury B, excluding any testimony regarding those six victims. One other consideration — Grand Jury is due to expire in August, and I anticipate that the investigation will continue for quite some time after indi ant. It is possible that the 6 dropped victims will be re-added in 'superseding indictment.

Thank you.

I. Marie Villafaña
Assistant U.S. Attorney
500 S. Australian Ave, Suite 400
West Palm Beach, FL 33401
Phone :
Fax

Tracking:

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Marie:

I see no need to change grand juries. Indeed, changing grand juries might suggest that something untoward occurred, which is not the case.

Nor do I see requirement to give 404(b) type instruction. Let's not forget that the role of the grand is to investigate, and it is wholly appropriate that grand jury in good faith pursued line of investigation that does not lead to indictment. That is very different matter from presenting information pursuant to 404(b), to prove motive, lack of accident, etc.

I share your instinct that just dropping six victims, and the draft proposed indictment, might call for some explanation, or at least acknowledgement, to the grand jury. It's always dicey, and not really desirable, to explain and share legal strategies with the grand jury. Perhaps you can simply tell them that the old draft proposed indictment is being withdrawn, and II ifferent set of facts is being pursued, and ask them if they can set aside what they heard previously, and base determination of probable cause solely on the new evidence. If any of them indicat inability to do so, perha they should li excused from consideration of this case; if that leaves you without I quorum, then you have I basis to go to I new grand jury.

I hope this helps; I'm available by phone as well.

Caroline

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FYI

From: Sloman, Jeff (USAFLS)
Sent: Monday, February 25, 2008 7:43 PM
To: JLefkowit2@kirkland.com
Cc: Oosterbaan, Andrew
Subject: Epstein

Jay,

The Section Chief of DOJ's Child Exploitation Obscenity Section (CEOS) notified me today that he will review the matter involving your client Jeffrey Epstein. The Section Chief has indicated that he is ready to proceed immediately, and I understand you are in the process of providing him this week with a summary of issues to be reviewed, and expect to meet with him next week.

The Section Chief also indicated that you would be calling this Office regarding the upcoming March 3, 2008 court date in the Fifteenth Judicial Circuit, in and for Palm Beach County. As you know, the Agreement entered into by your client originally provided that the United States

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Attorney's Office for the Southern District of Florida (this Office) would defer prosecution if your client pled guilty to enumerated state charges by October 26, 2007. Since then, that date has been postponed for' number of reasons. At this juncture, it would not be reasonable to keep the current March 3ldate as I deadline for compliance with the Agreement. That said, this Office is very concerned about additional delays. Despite this concern, I want to assure you that if counsel for Mr. Epstein meets with CEOS next week (the week of March 3$, this Office will extend the time for compliance with the Agreement to provide CEOS time to engage in' thorough review.

It goes without saying that in the event that CEOS decides that' federal prosecution should not be undertaken against Mr. Epstein, this Office will close its investigation. However, should CEOS disagree with Mr. Epstein's position, Mr. Epstein shall have one week to abide by the terms and conditions of the September 24, 2007 Agreement as amended by letter from United States Attorney Acosta to Jay Lefkowitz.

Jeffrey,. Sloman
First Assistant U.S. Attorney
Southern District of Florida

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Bob, Jeff, Alex and I discussed this yesterday. Jeff made some edits to your proposed letter and wants to send it out under Bob's signature.
Bob have you had a chance to review Jeff's email?

----- Original Message -----
From: (USAFLS)
To: Weinstein, David (USAFLS)
Cc: Senior, Robert (USAFLS)
Sent: Wed Feb 27 16:16:36 2008
Subject: RE: To the Civil Rights Chief

Hi David -- Have you had chance to talk to Bob about this? I think my window is close to "opening" and don't want the bad guys to come up with another II reason for delay.

Thank you.

l

lMarie Villafaha
ssistant U.S. Attorney
500 S. Australian Ave, Suite 400
West Palm Beach, FL 33401
Phone 561 209-1047
Fax

-----Original Message-----
From: Weinstein, David (USAFLS)
Sent: Thursday, February 21, 2008 5:03 PM
To: [REDACTED] (USAFLS)
Cc: Senior, Robert (USAFLS); [REDACTED] (USAFLS); Garcia, Rolando (USAFLS)
Subject: Re: To the Civil Rights Chief

Timing is everything. Right now I am at the NAC attending the Criminal Civil Rights Seminar.

Your letter seems to cover everything, but I want to chat with Bob about it before we send it out. It should probably be addressed to Stephan Curran, who is the Deputy assigned to cover our District.

Bob an talk Monday when I get back and w can send out the letter.
Since shop is involved and has been for while, they will hopefully agree
with our/your conclusion.
DSW

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we made contact I ny girl. Ny agent to set up interview for next week. Sorry haven't made it over there yet, I'm hoping to finish up on the GJSs soon.

Original Message
From (USAFLS)< j.gov>
To: N.; Richards, Jason R.
Sent: Thu Feb 28 16:07:12 2008
Subject: fun task

Hi guys - I am still wading through these FedEx records. There are I lot of shipments from "The Art of Women" n Haleiwa, Hawaii. I was able to access their MySpace page and he claims to be photographer for "aspiring models." He invites aspiring models to visit s website, www.artofwomen.com li http://www.artofwomen.com , but I cannot access it because DOJ blocks me. Can you try?

Also, someone from ]E's office sent llpackage to Chiko Hoge, U.S. Secret Service, in Honolulu. It looks like t was around the me that JE took Clinton to Africa.

Dave Rogers also sent package to "Inspector Lewis, U.S. Customs Service, 1210 Corbin Street, Elizabe , NJ 07201" IL

There were 'lot of packages to Karin Models/MC-squared.

Helen Kim's name appears as the person sendi e packages 'lot, do we know if she still works for JE? What about Cecilia ?

Any word from FBI New York?

Thanks.

Marie

Assistant U.S. Attorney

500 S. Australian Ave, Suite 400

West Palm Beach, FL 33401

Phone 561 209-1047

Fax

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Hi Marie,

What? CEOS conducting its own independent review? Independent of what? Do they not
understand who they are and what their job is? Why are they letting themselves be
manipulated like that? And how can defense lawyers "demand" a meeting main Justice? I [x]
am so sorry for you. At least they should wall off few people to help you later with motions.
It's good for me to see my future, I guess,

We know about the John Melk lawsuit and have 'fair amount of info on it. It is odd that JE fed ex'd him something — I wonder if JE was part of the straw man action. I wonder if DC used fed ex — not that we know but it's worth checking.

We're moving ahead w/our investigation at this time. We are pretty sure we can charge DC
and his assistants with 'conspiracy of 1201 (kidnapping), citing the new-ish part of 1201 which
prohibits the use of interstate facilities in furtherance of the crime. Here we see international
travel brought about by inveigle or decoy, use of emails and phones to trick her to travel, and
her arrival at the isolated island with no way off and no passport (DC took hers the first night
and held it until they were on the plane out), holding her for ransom, reward or other (here for
sexual activity & whether it's "consensual" or not sho1I be decisive).
We think it works, our local FBI ASAC is on board and emailed with David Karp in DC -- [x]
opines that the statute fits this crime. Have you had any contact with Karp on your case? [x]
thinking he's I good guy.

We had' conf call with OIA and the FBI guy in Bahamas today. We really need to search DC's place to find out about security and surveillance systems, phone si ems, locks on the doors, etc - We're still going through the seized computers, including bunch of Macs, and iphones. The Bureau doesn't have many Mac examiners but I never knew that before. It's taking forever.

Bruce Lyon called again to ask questions about DC . He again talked about JE rot. When I asked him if he was' lawyer in the JE case, he said he was one of JE's attorneys. Pretty weird for 'lawyer for' witness. I haven't mentioned that I know about it or know you. Let's keep in touch. Susie

From: (USAFLS)
Sent: Thursday, February 28, 2008 1:22 PM
To:Roe, Susan (USAWAW)
Subject: DC and JE

Hi Susan — What is the word with you? My word is growing ever more bizarre. JE's lawyers have demanded' meeting with the head of CEOS with the understanding that CEOS will do an "independent review" of the case and then will play no role in the litigation thereafter (so when I am swamped with silly motions I will not be able to reach out to them for help). This meeting is supposed to happen next week. In the meantime, we keep finding more and more girls.

On the DC/JE front. I have found 'somewhat shady business connection. I am reviewing JE's Federal Express records from the past 5 years (I treasure trove of info) and found 'package sent by JE to "John Melk/Musha Cay." I googled those two names and came up with this article.

http://www.foxnews.com/story/0,2933.304900,00.html

I like the obscure reference to "rumors" about Copperfield's personal life. Maybe Melk is someone to talk to?

I hope all is well.

[Redacted]
Assistant U.S. Attorney
500 S. Australian Ave., Suite 400
West Palm Beach, FL 33401
Phone [Redacted]
Fax [Redacted]

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Hi guys other New York girl has been identif d and will be interviewed next week. so have FedEx records corroborating girl who saw Epstein (and receive gift from him) when she was 15.

I have mailed CEOS about additional information in preparation for their meeting but have received no response. I don't know whether I should send them info about the additional girls (to show how this case continues to grow, and has become multi-state) or not send the info to avoid an unintentional leak to Epstein's lawyers.

I also wasn't sure whether you guys heard that parents have voluntarily dismissed their case against Epstein. According to the papers here no money changed hands, but it seems unlikely. I will be issuing subpoena for her deposition transcript.

Can someone give me an update? Thank you.

Marie Villafaña
Assistant U.S. Attorney
500 S. Australian Ave, Suite 400
West Palm Beach, FL 33401
Phone 561 209-1047
Fax 561 820-8777

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I don't think we have an issue with staleness because the memory cards are fixed (they haven't changed since the original search warrant).

Marie Villafaña
Assistant U.S. Attorney
500 S. Australian Ave, Suite 400
West Palm Beach, FL 33401
Phone 561 209-1047
Fax

-----Original Message-----
From: Kuyrkendall, N.
Sent: Wednesday March 05 2008 5:55 PM
To: (USAFLS)
Subject: Re: Epstein update

I like your style! Unsure what communication btw Jeff and )ay is about?? Also do we have staleness issues with SW?

----- Original Message -----
From: [REDACTED] [REDACTED] (USAFLS) <[REDACTED]>
To: Acosta, Alex (USA); Sloman, Jeff (USA); Oosterbaan, Andrew (CRM); Senior,
Robert (USA)
Cc: [REDACTED] (USA); [REDACTED] (USA)
Sent: Wed Mar 05 16:54:35 2008
Subject: Epstein update

Hi all - I wanted to update you on couple of ew developments in the Epstein case. First, ff Herman is supposed to give rpress conference today a ouncing the filing of third lawsuit against Epstein. That case also involves victim whom we are no onger referring to in the indictment [Drew - tell that to the defense.] Herman seems to have latched onto the group which, as discussed in my third addendum to the pros memo, we ave a rea y decided to forego for the most part.

Since I am not certain of the scope of your meeting, I do not know how cal it is for you to see the new facts developed in the supplemental pros memos (you reviewed the initial pros memo from May of last year). If you would like the supplements, please let me know. The legal theories have remained the same.

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I also wanted to call to everyone's attention the three-year statute of limitations in Florida for the state solicitation offenses. The st ute will run for all e victims this summer. Once it runs we cannot insist on state court plea to new charge. It also means that the state cannot charge t e crimes il related o the victims discovered after the initial investigation. We have asked Ir the Palm Beach Police Department to forego presenting thdse charges for state prosecution in deference to our prosecution. If we do not intend to go forward, it is imperative that we communicate that to the Police Department as soon as possible so they can present those victims for state prosecution.

I have reserved time with the grand jury on the 18th. I had hoped to present the indictment at that time, but in light of Jeff's communication with Jay, I will push it off until the 25th. I would still like to start the presentation on the 18th so we aren't accused of rushing the grand jury. So; I hope that the final indictment packet will be approved by that date.

Thank you.

Marie Villafaña

Assistant U.S. Attorney

500 S. Australian Ave, Suite 400

West Palm Beach, FL 33401

Phone 561 209-1047

Fax

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Thanks, Marie I don't think money is ever an issue.

From: (USAFLS) [mailto:
Sent: Thursday, March 06, 2008 11:18 AM

To: Oosterbaan, Andrew

Subject: RE: Epstein update

Hi Drew - Here you go. Please let me know if you need anything else. Thanks.

[ ]

As Alex and Jeff can tell you, the defense can always come up with another reason to have another
meeting. surprised that Mr. Epstein hasn't started complaining about legal fees. [x]

.1 Marie Vithiafia
Assistant U.S. Attorney
500 S. Australian Ave. Suite 400
West Palm Beach. Fl. 33401
Phone 561 209-1047
Fax

From: Oosterbaan, Andrew
Sent: Thursday, March 06, 2008 8:46 AM
To: (USAFLS)
Subject: RE: Epstein update

That's not' bad idea. I don I need the names or any identifying information. Thanks, Marie.

From: (USAFLS) [mailto:Ann

Sent: Thursday, March 06, 2008 8:19 AM

To: Oosterbaan, Andrew

Subject: RE: Epstein update

Hi Drew – I am running off to court but should be back by 10:30. Do you want me to redact the names or anything to prevent any unintentional leaks to the defense? They are very good at extracting information. they even gut me by around the eh meeting.

A. Marie Villafana
Assistant U.S. Attorney
500 S. Australian Ave. Suite 400
West Palm Beach, FL 33401
Phone [redacted]
Fax [redacted]

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