EFTA00179797

 
 Original Message  
From: Acosta, Alex (USAFLS) 
To: Villafana, Ann Marie C. (USAFLS); Sloman, Jeff (USAFLS); Senior, Robert 
(USAFLS); Lee, Dexter (USAFLS); Atkinson, Karen (USAFLS) 
Sent: Fri Aug 15 11:55:13 2008 
Subject: RE: New proposed response to Day 
How about a slightly different version: 
Thank you for your response. Our communications with Roy Black and later with 
you were solely to determine what Mr. Epstein considered to be the terms of the 
Non-Prosecution Agreement. We appreciate your answering our question with 
finality. You have now made clear that Mr. Epstein did not accept the December 
modification, and accordingly, we will now consider that modification to be a 
nullity. 
Pursuant to our Agreement, I will prepare an Amended Notification that contains 
the name of additional identified victims. In accordance with Paragraph 78, 
please provide me with a proposed written submission to the Special Master by 
Monday afternoon. 
Finally, as you are aware, yhe United States has been ordered to produce the Non-
Prosecution Agreement. In accordance with that Order, we will produce the 
September Agreement with the October Addendum signed by your client. We 
understand that Mr. Goldberg may not have provided the state court with a true 
copy of the complete Agreement, and he should take steps to correct that error. 
From: Villafana, Ann Marie C. (USAFLS) 
Sent: Friday, August 15, 2008 11:42 AM 
To: Acosta, Alex (USAFLS); Sloman, Jeff (USAFLS); Senior, Robert (USAFLS); Lee, 
Dexter (USAFLS); Atkinson, Karen (USAFLS) 
Subject: New proposed response to Jay 
Dear Day: 
Thank you for your response. Our communications with Roy Black and later with 
you were solely to determine what Mr. Epstein considered to be the terms of the 
Non-Prosecution Agreement. You have now made clear that Mr. Epstein did not 
accept the December modification and does not intend to perform the obligations 
set forth therein. The Office is not going to continue negotiating the terms of 
the Agreement. We only sought finality and you have answered our question. 
Accordingly, the December proposed modification is hereby withdrawn. 
The United States has been ordered to produce the Non-Prosecution Agreement and, 
in accordance with that Order, will produce the September Agreement with the 
October Addendum signed by your client. Mr. Goldberger should be advised that we 
181 
EFTA00179977

understand he has not provided the state court with a true copy of the complete 
Agreement, and he should take steps to correct that error. I will prepare an 
Amended Notification that contains the name of additional identified victims and 
will provide that to you promptly. 
In accordance with Paragraph 7B of the Agreement, please provide me with a 
proposed written submission to the Special Master by Monday afternoon. We will 
expect a showing of good faith in the selection of the attorney representative 
and all other terms of the Agreement and excessive delays, like those that have 
occurred in the past, will be considered a breach of that duty of good faith. 
Sincerely, 
A. Marie Villafaha 
Assistant U.S. Attorney 
500 S. Australian Ave, Suite 400 
West Palm Beach, FL 33401 
Phone 561 209-1047 
Fax 561 820-8777 
182 
EFTA00179978

Villafana, Ann Marie C. (USAFLS) 
From: 
Villafana, Ann Marie C. (USAFLS) 
Sent: 
Friday, August 15, 2008 1:54 PM 
To: 
Lee, Dexter (USAFLS) 
Cc: 
Sloman, Jeff (USAFLS) 
Subject: 
FW: New proposed response to Jay 
Importance: 
High 
Dexter -- If we call it "a nullity" instead of "withdrawn" how does that affect 
the issue with the Jane Does? 
A. Marie Villafana 
Assistant U.S. Attorney 
500 S. Australian Ave, Suite 400 
West Palm Beach, FL 33401 
Phone 561 209-1047 
Fax 561 820-8777 
 
Original Message 
From: Sloman, Jeff (USAFLS) 
Sent: Friday, August 15, 2008 1:52 PM 
To: Villafana, Ann Marie C. (USAFLS); Senior, Robert (USAFLS); Acosta, Alex 
(USAFLS); Lee, Dexter (USAFLS); Atkinson, Karen (USAFLS) 
Subject: RE: New proposed response to Jay 
Marie, 
Please substitute the word "withdrawn" in the first sentence with "a nullity" 
Jeff 
 
Original Message 
From: Villafana, Ann Marie C. (USAFLS) 
Sent: Friday, August 15, 2008 1:49 PM 
To: Senior, Robert (USAFLS); Acosta, Alex (USAFLS); Sloman, Jeff (USAFLS); Lee, 
Dexter (USAFLS); Atkinson, Karen (USAFLS) 
Subject: RE: New proposed response to Jay 
Here is my proposal after speaking with Jeff. 
Dear Jay and Roy: 
Thank you for your response to my earlier e-mail. Our communications with 
Mr. Black and later with Mr. Lefkowitz were solely to determine what Mr. Epstein 
considered to be the terms of the Non-Prosecution Agreement. We appreciate your 
answering our question with finality. You have now made clear that Mr. Epstein 
183 
EFTA00179979

did not accept the December modification, and accordingly, the offer to make that 
modification is hereby withdrawn. 
Pursuant to our Agreement, I will prepare an Amended Notification that 
contains the names of additional identified victims. As you know, Judge Davis 
had selected the Podhurst firm to serve as the attorney representative for the 
victims. Assuming that Mr. Josefsberg is still amenable to the appointment, we 
will provide him with the victim list so that he may begin his service. 
Finally, as you are aware, the United States has been ordered to produce the 
Non-Prosecution Agreement. In accordance with that Order, we will produce the 
September Agreement with the October Addendum signed by your client. We 
understand that Mr. Goldberger did not provide the state court with a true copy 
of the complete Agreement, and he should take steps to correct that error. 
A. Marie Villafaha 
Assistant U.S. Attorney 
500 S. Australian Ave, Suite 400 
West Palm Beach, FL 33401 
Phone 561 209-1047 
Fax 561 820-8777 
 
Original Message 
From: Senior, Robert (USAFLS) 
Sent: Friday, August 15, 2008 1:34 PM 
To: Acosta, Alex (USAFLS); Villafana, Ann Marie C. (USAFLS); Sloman, Jeff 
(USAFLS); Lee, Dexter (USAFLS); Atkinson, Karen (USAFLS) 
Subject: Re: New proposed response to Jay 
Shouldn't we formally withdraw the offer as opposed to considering it a nullity ? 
 
 Original Message  
From: Acosta, Alex (USAFLS) 
To: Villafana, Ann Marie C. (USAFLS); Sloman, Jeff (USAFLS); Senior, Robert 
(USAFLS); Lee, Dexter (USAFLS); Atkinson, Karen (USAFLS) 
Sent: Fri Aug 15 11:55:13 2008 
Subject: RE: New proposed response to Jay 
How about a slightly different version: 
Thank you for your response. Our communications with Roy Black and later with 
you were solely to determine what Mr. Epstein considered to be the terms of the 
Non-Prosecution Agreement. We appreciate your answering our question with 
finality. You have now made clear that Mr. Epstein did not accept the December 
modification, and accordingly, we will now consider that modification to be a 
nullity. 
Pursuant to our Agreement, I will prepare an Amended Notification that contains 
the name of additional identified victims. In accordance with Paragraph 76, 
lel 
EFTA00179980

please provide me with a proposed written submission to the Special Master by 
Monday afternoon. 
Finally, as you are aware, yhe United States has been ordered to produce the Non-
Prosecution Agreement. In accordance with that Order, we will produce the 
September Agreement with the October Addendum signed by your client. We 
understand that Mr. Goldberg may not have provided the state court with a true 
copy of the complete Agreement, and he should take steps to correct that error. 
From: Villafana, Ann Marie C. (USAFLS) 
Sent: Friday, August 15, 2008 11:42 AM 
To: Acosta, Alex (USAFLS); Sloman, Jeff (USAFLS); Senior, Robert (USAFLS); Lee, 
Dexter (USAFLS); Atkinson, Karen (USAFLS) 
Subject: New proposed response to Jay 
Dear Jay: 
Thank you for your response. Our communications with Roy Black and later with 
you were solely to determine what Mr. Epstein considered to be the terms of the 
Non-Prosecution Agreement. You have now made clear that Mr. Epstein did not 
accept the December modification and does not intend to perform the obligations 
set forth therein. The Office is not going to continue negotiating the terms of 
the Agreement. We only sought finality and you have answered our question. 
Accordingly, the December proposed modification is hereby withdrawn. 
The United States has been ordered to produce the Non-Prosecution Agreement and, 
in accordance with that Order, will produce the September Agreement with the 
October Addendum signed by your client. Mr. Goldberger should be advised that we 
understand he has not provided the state court with a true copy of the complete 
Agreement, and he should take steps to correct that error. I will prepare an 
Amended Notification that contains the name of additional identified victims and 
will provide that to you promptly. 
In accordance with Paragraph 7B of the Agreement, please provide me with a 
proposed written submission to the Special Master by Monday afternoon. We will 
expect a showing of good faith in the selection of the attorney representative 
and all other terms of the Agreement and excessive delays, like those that have 
occurred in the past, will be considered a breach of that duty of good faith. 
Sincerely, 
A. Marie Villafaha 
Assistant U.S. Attorney 
500 5. Australian Ave, Suite 400 
West Palm Beach, FL 33401 
Phone 561 209-1047 
185 
EFTA00179981

Fax 561 820-8777 
Tracking: 
186 
EFTA00179982

Recipient 
Read 
Lee, Oozier (USAFLS) 
Read: 811 5/2008 1:55 PM 
Stamen, Jeff (USAFLS) 
Read: 8/15/2008 1:57 PM 
187 
EFTA00179983

Villafana, Ann Marie C. (USAFLS) 
From: 
Sloman, Jeff (USAFLS) 
Sent: 
Friday, August 15, 2008 1:52 PM 
To: 
Villafana, Ann Marie C. (USAFLS); Senior, Robert (USAFLS); Acosta, Alex (USAFLS); Lee, 
Dexter (USAFLS); Atkinson, Karen (USAFLS) 
Subject: 
RE: New proposed response to Jay 
Marie, 
Please substitute the word "withdrawn" in the first sentence with "a nullity" 
Jeff 
 
Original Message 
From: Villafana, Ann Marie C. (USAFLS) 
Sent: Friday, August 15, 2008 1:49 PM 
To: Senior, Robert (USAFLS); Acosta, Alex (USAFLS); Sloman, Jeff (USAFLS); Lee, 
Dexter (USAFLS); Atkinson, Karen (USAFLS) 
Subject: RE: New proposed response to Jay 
Here is my proposal after speaking with Jeff. 
Dear Jay and Roy: 
Thank you for your response to my earlier e-mail. Our communications with 
Mr. Black and later with Mr. Lefkowitz were solely to determine what Mr. Epstein 
considered to be the terms of the Non-Prosecution Agreement. We appreciate your 
answering our question with finality. You have now made clear that Mr. Epstein 
did not accept the December modification, and accordingly, the offer to make that 
modification is hereby withdrawn. 
Pursuant to our Agreement, I will prepare an Amended Notification that 
contains the names of additional identified victims. As you know, Judge Davis 
had selected the Podhurst firm to serve as the attorney representative for the 
victims. Assuming that Mr. Josefsberg is still amenable to the appointment, we 
will provide him with the victim list so that he may begin his service. 
Finally, as you are aware, the United States has been ordered to produce the 
Non-Prosecution Agreement. In accordance with that Order, we will produce the 
September Agreement with the October Addendum signed by your client. We 
understand that Mr. Goldberger did not provide the state court with a true copy 
of the complete Agreement, and he should take steps to correct that error. 
A. Marie Villafana 
Assistant U.S. Attorney 
500 S. Australian Ave, Suite 400 
West Palm Beach, FL 33401 
Phone 561 209-1047 
Fax 561 820-8777 
188 
EFTA00179984

 
Original Message 
From: Senior, Robert (USAFLS) 
Sent: Friday, August 15, 2008 1:34 PM 
To: Acosta, Alex (USAFLS); Villafana, Ann Marie C. (USAFLS); Sloman, Jeff 
(USAFLS); Lee, Dexter (USAFLS); Atkinson, Karen (USAFLS) 
Subject: Re: New proposed response to Jay 
Shouldn't we formally withdraw the offer as opposed to considering it a nullity ? 
 
 Original Message  
From: Acosta, Alex (USAFLS) 
To: Villafana, Ann Marie C. (USAFLS); Sloman, Jeff (USAFLS); Senior, Robert 
(USAFLS); Lee, Dexter (USAFLS); Atkinson, Karen (USAFLS) 
Sent: Fri Aug 15 11:55:13 2008 
Subject: RE: New proposed response to Jay 
How about a slightly different version: 
Thank you for your response. Our communications with Roy Black and later with 
you were solely to determine what Mr. Epstein considered to be the terms of the 
Non-Prosecution Agreement. We appreciate your answering our question with 
finality. You have now made clear that Mr. Epstein did not accept the December 
modification, and accordingly, we will now consider that modification to be a 
nullity. 
Pursuant to our Agreement, I will prepare an Amended Notification that contains 
the name of additional identified victims. In accordance with Paragraph 76, 
please provide me with a proposed written submission to the Special Master by 
Monday afternoon. 
Finally, as you are aware, yhe United States has been ordered to produce the Non-
Prosecution Agreement. In accordance with that Order, we will produce the 
September Agreement with the October Addendum signed by your client. We 
understand that Mr. Goldberg may not have provided the state court with a true 
copy of the complete Agreement, and he should take steps to correct that error. 
From: Villafana, Ann Marie C. (USAFLS) 
Sent: Friday, August 15, 2008 11:42 AM 
To: Acosta, Alex (USAFLS); Sloman, Jeff (USAFLS); Senior, Robert (USAFLS); Lee, 
Dexter (USAFLS); Atkinson, Karen (USAFLS) 
Subject: New proposed response to Jay 
Dear Jay: 
189 
EFTA00179985

Thank you for your response. Our communications with Roy Black and later with 
you were solely to determine what Mr. Epstein considered to be the terms of the 
Non-Prosecution Agreement. You have now made clear that Mr. Epstein did not 
accept the December modification and does not intend to perform the obligations 
set forth therein. The Office is not going to continue negotiating the terms of 
the Agreement. We only sought finality and you have answered our question. 
Accordingly, the December proposed modification is hereby withdrawn. 
The United States has been ordered to produce the Non-Prosecution Agreement and, 
in accordance with that Order, will produce the September Agreement with the 
October Addendum signed by your client. Mr. Goldberger should be advised that we 
understand he has not provided the state court with a true copy of the complete 
Agreement, and he should take steps to correct that error. I will prepare an 
Amended Notification that contains the name of additional identified victims and 
will provide that to you promptly. 
In accordance with Paragraph 7B of the Agreement, please provide me with a 
proposed written submission to the Special Master by Monday afternoon. We will 
expect a showing of good faith in the selection of the attorney representative 
and all other terms of the Agreement and excessive delays, like those that have 
occurred in the past, will be considered a breach of that duty of good faith. 
Sincerely, 
A. Marie Villafana 
Assistant U.S. Attorney 
500 S. Australian Ave, Suite 400 
West Palm Beach, FL 33401 
Phone 561 209-1047 
Fax 561 820-8777 
190 
EFTA00179986

Villafana, Ann Marie C. (USAFLS) 
From: 
Villafana, Ann Marie C. (USAFLS) 
Sent: 
Friday, August 15, 2008 1:49 PM 
To: 
Senior, Robert (USAFLS); Acosta, Alex (USAFLS); Sloman, Jeff (USAFLS); Lee, Dexter 
(USAFLS); Atkinson, Karen (USAFLS) 
Subject: 
RE: New proposed response to Jay 
Here is my proposal after speaking with Jeff. 
Dear Jay and Roy: 
Thank you for your response to my earlier e-mail. Our communications with 
Mr. Black and later with Mr. Lefkowitz were solely to determine what Mr. Epstein 
considered to be the terms of the Non-Prosecution Agreement. We appreciate your 
answering our question with finality. You have now made clear that Mr. Epstein 
did not accept the December modification, and accordingly, the offer to make that 
modification is hereby withdrawn. 
Pursuant to our Agreement, I will prepare an Amended Notification that 
contains the names of additional identified victims. As you know, Judge Davis 
had selected the Podhurst firm to serve as the attorney representative for the 
victims. Assuming that Mr. Josefsberg is still amenable to the appointment, we 
will provide him with the victim list so that he may begin his service. 
Finally, as you are aware, the United States has been ordered to produce the 
Non-Prosecution Agreement. In accordance with that Order, we will produce the 
September Agreement with the October Addendum signed by your client. We 
understand that Mr. Goldberger did not provide the state court with a true copy 
of the complete Agreement, and he should take steps to correct that error. 
A. Marie Villafaha 
Assistant U.S. Attorney 
500 S. Australian Ave Suite 400 
West Palm Beach, FL 33401 
Phone 561 209-1047 
Fax 561 820-8777 
 
Original Message 
From: Senior, Robert (USAFLS) 
Sent: Friday, August 15, 2008 1:34 PM 
To: Acosta, Alex (USAFLS); Villafana, Ann Marie C. (USAFLS); Sloman, Jeff 
(USAFLS); Lee, Dexter (USAFLS); Atkinson, Karen (USAFLS) 
Subject: Re: New proposed response to Jay 
Shouldn't we formally withdraw the offer as opposed to considering it a nullity ? 
 
 Original Message  
From: Acosta, Alex (USAFLS) 
191 
EFTA00179987

To: Villafana, Ann Marie C. (USAFLS); Sloman, Jeff (USAFLS); Senior, Robert 
(USAFLS); Lee, Dexter (USAFLS); Atkinson, Karen (USAFLS) 
Sent: Fri Aug 15 11:55:13 2008 
Subject: RE: New proposed response to Jay 
How about a slightly different version: 
Thank you for your response. Our communications with Roy Black and later with 
you were solely to determine what Mr. Epstein considered to be the terms of the 
Non-Prosecution Agreement. We appreciate your answering our question with 
finality. You have now made clear that Mr. Epstein did not accept the December 
modification, and accordingly, we will now consider that modification to be a 
nullity. 
Pursuant to our Agreement, I will prepare an Amended Notification that contains 
the name of additional identified victims. In accordance with Paragraph 76, 
please provide me with a proposed written submission to the Special Master by 
Monday afternoon. 
Finally, as you are aware, yhe United States has been ordered to produce the Non-
Prosecution Agreement. In accordance with that Order, we will produce the 
September Agreement with the October Addendum signed by your client. We 
understand that Mr. Goldberg may not have provided the state court with a true 
copy of the complete Agreement, and he should take steps to correct that error. 
From: Villafana, Ann Marie C. (USAFLS) 
Sent: Friday, August 15, 2008 11:42 AM 
To: Acosta, Alex (USAFLS); Sloman, Jeff (USAFLS); Senior, Robert (USAFLS); Lee, 
Dexter (USAFLS); Atkinson, Karen (USAFLS) 
Subject: New proposed response to Jay 
Dear Jay: 
Thank you for your response. Our communications with Roy Black and later with 
you were solely to determine what Mr. Epstein considered to be the terms of the 
Non-Prosecution Agreement. You have now made clear that Mr. Epstein did not 
accept the December modification and does not intend to perform the obligations 
set forth therein. The Office is not going to continue negotiating the terms of 
the Agreement. We only sought finality and you have answered our question. 
Accordingly, the December proposed modification is hereby withdrawn. 
The United States has been ordered to produce the Non-Prosecution Agreement and, 
in accordance with that Order, will produce the September Agreement with the 
October Addendum signed by your client. Mr. Goldberger should be advised that we 
understand he has not provided the state court with a true copy of the complete 
Agreement, and he should take steps to correct that error. I will prepare an 
192 
EFTA00179988

Amended Notification that contains the name of additional identified victims and 
will provide that to you promptly. 
In accordance with Paragraph 7B of the Agreement, please provide me with a 
proposed written submission to the Special Master by Monday afternoon. We will 
expect a showing of good faith in the selection of the attorney representative 
and all other terms of the Agreement and excessive delays, like those that have 
occurred in the past, will be considered a breach of that duty of good faith. 
Sincerely, 
A. Marie Villafaha 
Assistant U.S. Attorney 
500 S. Australian Ave, Suite 400 
West Palm Beach, FL 33401 
Phone 561 209-1047 
Fax 561 820-8777 
Tracking: 
193 
EFTA00179989

Recipient 
Read 
Senior, Robed (USAFLS) 
Read: 8/16/2008 1:55 PM 
Acosta, A/ex (USAFLS) 
Read: 8/15/20081:51 PM 
Sloman, Jeff (USAFLS) 
Read: 8/15/2008 1:49 PM 
Lee, Dexter (USAFLS) 
Read: 8/15/2008 1:54 PM 
Atkinson. Karen (USAFLS) 
194 
EFTA00179990