EFTA00179797

Villafana, Ann Marie C. (USAFLS) 
From: 
Menchel, Matthew (USAFLS) 
Sent: 
Friday, May 11, 2007 2:09 PM 
To: 
Villafana, Ann Marie C. (USAFLS); Lourie, Andrew (USAFLS) 
Subject: 
RE: 
Marie, 
Is the pros memo the same as the earlier version that Andy emailed me? Also you reference Appendix A in your memo 
but it wasn't attached to my first memo. 
Thanks, 
Matt 
From: Villafana, Ann Marie C. (USAFLS) 
Sent: Wednesday, May 09, 2007 5:36 PM 
To: Lourie, Andrew (USAFLS) 
Cc: Menchel, Matthew (USAFLS) 
Subject: RE: 
Hi Andy and Matt Toni and I finalized the forfeiture provisions this afternoon. so here is the indictment with 
the forfeiture language and another copy of the pros memo. Andy — I will sign the indictment and add it to the 
packet. Thanks. 
« File: 070507 Indictment with Forfeiture.wpd » « File: Pros Memo 5-1.07.wpd » 
.4. Marie Villalaiia 
Assistant U.S. Attorney 
500 S. Australian Ave. Suite 400 
West Palm Beach, FL 33401 
Phone 561 209-1047 
Fax 561 820-8777 
From: Lourie, Andrew (USAFLS) 
Sent: Wednesday, May 09, 2007 5:17 PM 
To: Villafana, Ann Marie C. (USAFLS) 
Subject: 
Pls email me pros memo. Thanks. 
182 
EFTA00179817

Villafana, Ann Marie C. (USAFLS) 
From: 
Yera, E.J. (USAFLS) 
Sent: 
Thursday, May 10, 2007 9:53 AM 
To: 
Villafana, Ann Marie C. (USAFLS) 
Subject: 
RE: 
AM - 
This is so wrong - on so many levels - that I don't know where to begin. 
From: Villafana, Ann Marie C. (USAFLS) 
sent: Thursday, May 10, 2007 9:51 AM 
To: Yera, EJ. (USAFLS) 
Subject: FW: 
Your guidance is sorely needed. 
A. Metric. l'ilhOna 
Assistant U.S. Attorney 
500 S. Australian Ave, Suite 400 
West Palm Beach. FL 33401 
Phone 561 209.1047 
Fax 561 820.8777 
From: Lourle, Andrew (USAFLS) 
Sent: Thursday, May 10, 2007 9:49 AM 
To: Villafana, Ann Marie C. (USAFLS) 
Subject: 
marie 
I believe that Epstein's attys are scared of the victims they don't know. Epstein has no doubt told them that there were 
many. Thus I believe the frist indictment should contain only the victims they have nothing on at all. We can add in the 
other ones that have myspace pages and prior testimony in a superseder. I think for the first strike we should make all 
their nightmare's come true. Thoughts? 
183 
EFTA00179818

Villafana, Ann Marie C. (USAFLS) 
From: 
Laurie, Andrew (USAFLS) 
Sent: 
Thursday, May 10, 2007 9:49 AM 
To: 
Villafana, Ann Marie C. (USAFLS) 
marie 
I believe that Epstein's attys are scared of the victims they don't know. Epstein has no doubt told them that there were 
many. Thus I believe the frist indictment should contain only the victims they have nothing on at all. We can add in the 
other ones that have myspace pages and prior testimony in a superseder. I think for the first strike we should make all 
their nightmare's come true. Thoughts? 
184 
EFTA00179819

Villafana, Ann Marie C. (USAFLS) 
From: 
Vi'latrine, Ann Marie C. (USAFLS) 
Sent: 
Monday, May 07. 2007 3:41 PM 
To: 
Lourie, Andrew (USAFLS) 
Cc: 
Barnes, Antonia (USAFLS) 
Subject: 
Revised Indictment 
Hi Andy —I caught a few typos today in the indictment, so here is a revised version (they didn't change any of 
the counts). 
don't think you sent the indictment to Matt Menchel yet, but if you want me to send it to him, please let me 
know. Thank you. 
070507 
IndIctment.wpd 
A. Marie Villafaffa 
Assistant U.S. Attorney 
500 S. Australian Ave, Suite 400 
West Palm Beach, FL 33401 
Phone 561 209-1047 
Fax 561 820-8777 
Tracking: 
185 
EFTA00179820

Recipient 
Loune. Mdrew (USAFLS) 
Barnes. Antonia (USAFLS) 
186 
Read 
Read: 5/8(2007 12:37 PM 
EFTA00179821

Villafana, Ann Marie C. (USAFLS) 
From: 
Villafana, Ann Marie C. (USAFLS) 
Sent: 
Thursday, May 03, 2007 4:29 PM 
To: 
Crespo, Rosita (USAFLS) 
Cc: 
Ball, Shawn (USAFLS) 
Subject: 
FW: Litigative Consultant SOW 
Ili Rosita — Here is the amended Memo. The case is highly sensitive because of the large number of 
identifiable minors, so l have been very succinct. If you have any questions, you can call me at my direct dial 
(shown below). Thank you. 
Ut Consultant 
SOW short.wpd 
A. Marie 
Width 
Assistant U.S. Attorney 
500 S. Australian Ave, Suite 400 
West Palm Beach, FL 33401 
Phone 561 209-1047 
Fax 561 820-8777 
From: Ball, Shawn (USAFLS) 
Sent: Wednesday, May 02, 2007 3:19 PM 
To: Vlllafana, Ann Marie C. (USAFLS) 
Subject: FW: Litigative Consultant SOW 
From: Crespo, Roslta (USAFLS) 
Sent: Wednesday, May 02, 2007 3:16 PM 
To: Ball, Shawn (USAFLS) 
Subject: Litigative Consultant SOW 
Shawn, 
Attach Is the SOW for Litigative Consultant. Add the information needed and return via email. 
You need to add a brief summary of case. 
Thanks. 
Tracking: 
187 
EFTA00179822

Recipient 
Crespo, Rana (USAFLS) 
Ball, Shawn (USAFLS) 
188 
Read 
Read: 5/4/2007 8:08 AM 
EFTA00179823

Villafana, Ann Marie C. (USAFLS) 
From: 
Braden, Myesha 
Sent: 
Thursday, May 03, 2007 12:05 PM 
To: 
Villafana, Ann Marie C. (USAFLS) 
Cc: 
Almanza, Paul 
Subject: 
RE: 2423(c) and 2423(d) 
A. Marie, 
Paul Almanza asked that I respond to your inquiry. 
Without knowing all of your facts, it does not appear to me that you can use the statue in the ways that you describe. 
Regarding the first question, I believe that the language of the statute clearly criminalizes engaging in illicit sexual conduct 
WHILE traveling in foreign commerce. The entire legislative history of the statute shows that it was designed to combat 
international sex tourism. Also the 'travels in .. . and engages" language bears this out. However, it is not necessary to 
use 2423(c) to charge him if you know that his intent was to engage in sex with minors. If that is the case, you should 
charge 2423(b) because it is design to address BOTH interstate and foreign travel for the purpose of illicit sex. 
Regarding the second question, I must respond with two questions. Can you prove that she arranged the travel and 
appointments for her own commercial or financial advantage? It sounds like she just doing what her boss in her legitimate 
job requested of her without additional benefit beyond her standard pay. If that is the case, you will have a great amount 
of difficulty proving the elements of your case. Can you prove that she purposely arranged appointments with underage 
prostitutes? Because 2423(f) defines illicit sexual conduct in two ways, both limiting the focus to sexual activity with 
minors, this is an important issue in deciding whether to charge the assistant. It is also an issue in determining whether 
your target will be able to raise the affirmative defense provided in 2423(g). 
If you'd like to give me a call to talk more about this, please feel free to do so. 
Good luckl 
Myesha 
Myeaha K. Braden 
U.S. Department of Justice 
Criminal Division - CEOS 
(202) 514.6037 
From: Villafana, Ann Marie C. (USAFLS) priallto:Ann.Marle.C.Villafana@usdoj.gov] 
Sent: Thursday, May 03, 2007 10:47 AM 
To: Almanza, Paul 
Subject: 2423(c) and 2423(d) 
Hi Paul — Sorry to bother you. I am charging a case where a man traveled from out of state (and, on one 
occasion, from outside the country) to Palm Beach County to engage in prostitution with minors. 
First question: The man clearly traveled in "foreign commerce" when he traveled from outside the U.S. directly 
to Palm Beach county, and he is a U.S. citizen. Do you think that we could charge 2423(c) even though the 
sexual activity occurred in the U.S.? 
Second question: Do you know of anyone who has charged 2423(d)? The man's personal assistant set up the 
appointments with the prostitutes and also was in charge of organizing his travel, so I think a 2423(d) charge is 
warranted. One question is whether we should charge a separate count for each trip? Or charge only one count 
covering the entire 18-month period of activity? 
189 
EFTA00179824

As always, thank you! 
A. Marie Villafaffa 
Assistant U.S. Attorney 
500 S. Australian Ave, Suite 400 
West Palm Beach, FL 33401 
Phone 561 209-1047 
Fax 561 820-8777 
190 
EFTA00179825

Villafana, Ann Marie C. (USAFLS) 
From: 
Villafana, Ann Marie C. (USAFLS) 
Sent: 
Thursday, May 03, 2007 10:47 AM 
To: 
Almanza, Paul 
Subject: 
2423(c) and 2423(d) 
Iii Paul — Sorry to bother you. 1 am charging a case where a man traveled from out of state (and, on one 
occasion, from outside the country) to Palm Beach County to engage in prostitution with minors. 
First question: The man clearly traveled in "foreign commerce" when he traveled from outside the U.S. directly 
to Palm Beach county, and he is a U.S. citizen. Do you think that we could charge 2423(c) even though the 
sexual activity occurred in the U.S.? 
Second question: Do you know of anyone who has charged 2423(d)? The man's personal assistant set up the 
appointments with the prostitutes and also was in charge of organizing his travel, so I think a 2423(d) charge is 
warranted. One question is whether we should charge a separate count for each trip? Or charge only one count 
covering the entire I8-month period of activity? 
As always, thank you! 
A. Marie Villafalia 
Assistant U.S. Attorney 
500 S. Australian Ave, Suite 400 
West Palm Beach, FL 33401 
Phone 561 209-1047 
Fax 561 820-8777 
191 
EFTA00179826

Villafana, Ann Marie C. (USAFLS) 
From: 
Villafana, Ann Marie C. (USAFLS) 
Sent: 
Wednesday, May 02, 2007 2:40 PM 
To: 
Bail, Shawn (USAFLS) 
Subject: 
Emaiting: Xpert Statement of Work Lit Consult.wpd 
Attachments: 
Xpert Statement of Work Lit Consult.wpd 
Hi Shawn -- I changed it a bit. Thanks. 
The message is ready to be sent with the following file or link attachments: 
Xpert Statement of Work lit Consult.wpd 
Note: To protect against computer viruses, e-mail programs may prevent sending or 
receiving certain types of file attachments. Check your e-mail security settings 
to determine how attachments are handled. 
192 
EFTA00179827

Villafana, Ann Marie C. (USAFLS) 
From: 
Villafana, Ann Marie C. (USAFLS) 
Sent: 
Tuesday, May 01, 2007 5:14 PM 
To: 
Sloman, Jeff (USAFLS) 
Subject: 
Your call 
Hi Jeff -- I got your message. I had already sent some stuff to Barbara, so I think she has what she and Alex 
need. If not, please let me know. 
The big indictment package was turned in today, so hopefully Matt will have it by Thursday. May 15th is our 
target date. 
Thanks. 
A. Mark Villafana 
Assistant U.S. Attorney 
500 S. Australian Ave, Ste 400 
West Palm Beach, FL 33401 
56! 820-8711 
Fax 561 820-8777 
ann.marie.c.villafana®usdoi.gov 
193 
EFTA00179828

Villafana, Ann Marie C. (USAFLS) 
From: 
Villafana, Ann Marie C. (USAFLS) 
Sent: 
Monday, April 23, 2007 7:56 PM 
To: 
Schultz, Anne (USAFLS) 
Cc: 
Yera, E.J. (USAFLS) 
Subject: 
RE: Eleventh Circuit Pattern Jury Instructions 
Hi Annie -- The current version of the jury instruction for violating 18 USC 2422(b) (Offense Instruction 80) is 
currently drafted for the charge of ATTEMPTED enticement of a minor. Because attempt is a specific intent 
crime, an attempt requires that the defendant specifically intend to entice someone under 18, and the current 
pattern instruction includes a willfulness requirement. For the completed offense, however, the defendant only 
needs to knowingly use a computer to entice someone, and then the government has to prove that the person 
actually is under 18. The current pattern jury instruction also does not discuss enticement into prostitution. 
So, the instruction for a completed offense should read: 
First: That the Defendant knowingly used [the mail] [a computer] [describe other interstate facility as alleged in 
indictment] to persuade, induce, entice, or coerce an individual to engage in [prostitution] [sexual activity], as 
charged; 
Second: That the individual whom the defendant enticed was less than eighteen (18) years of age at the time of 
the charged offense; 
And [for cases not involving enticement into prostitution] 
Third: That the Defendant and the individual engaged in sexual activity for which the Defendant could have 
been charged with a criminal offense under the law of [identify the state]. 
EJ and I have gone through all the cases on this for an upcoming indictment, so getting the 11th Circuit's 
attention would be wonderful. If you want the analysis, please let me know. 
Thanks. 
A. Marie Malaita 
Assistant U.S. Attorney 
561 209-1047 
Fax 561 820-8777 
ann.marie.c.villafana®usdqj.gov 
From: 
Schultz, Anne (USAFLS) 
Sent: 
Monday, April 23, 2007 11.29 AM 
To: 
USAFIS-AUSAs District 
Cc 
Curnlck, Janis (USAFLS) 
Subject 
Eleventh Circuit Pattern Jury Instructions 
Judge Mlddlebrooks Informed me on Friday that the Committee that reviews the Eleventh Circuit Pattern Jury 
Instructions will be meeting next week at the Eleventh Circuit Judicial Conference. The Committee will soon begin 
reviewing the current instructions, and Judge Middlebrooks has requested our input. If you have suggestions about the 
instructions as a whole please relay them to me within the next two days so that I can pass our general comments on to 
Judge Mlddlebrooks before the Judicial Conference. If you have any suggestions as to individuals or groups that the 
197 
EFTA00179829

Committee should contact for input regarding the instructions, please give me that information in the next two days as 
well. I would also like your thoughts on instructions that need to be revised or added. While all thoughts are welcome, 
it would really help if you attached instructions that you think should be included in the Pattern Instructions. 
Tracking: 
198 
EFTA00179830

Recipient 
Schanz. Anne (USAFLS) 
Yew. E J (USAFLS) 
199 
Road 
Read: 4/24/2007 9:13 AM 
EFTA00179831

Villafana, Ann Marie C. (USAFLS) 
From: 
Richards, Jason R. (Jason.Richards2©ic.fbi.gov] 
Sent: 
Friday, April 20, 2007 6:21 PM 
To: 
Villafana, Ann Marie C. (USAFLS) 
Cc: 
genekuyrkendall©msn.com 
Attachments: 
Epstein Ssheet.xls 
Hey Marie, 
Here's the draft spreadsheet you requested (Jennifer Siciliano's data still needs 
to be added). Have a good weekend. 
Jason 
200 
EFTA00179832

Villafana, Ann Marie C. (USAFLS) 
From: 
Villafana, Ann Marie C. (USAFLS) 
Sent: 
Friday, April 20, 2007 12:32 PM 
To: 
acsalter@tds.net 
Subject: 
FW: Possible Retainer for a Federal Criminal Investigation/Prosecution 
Eli Anna -- My secretary, Shawn Ball, will be calling to get your Social Security number, etc., so we can get 
funding approved. (I don't want to take up a lot of your time and then get into a fight with my Office.) I'll call 
you on Monday? 
A. Marie Villafafia 
Assistant U.S. Attorney 
561 209-1047 
Fax 561 820-8777 
ann.maric.c.villafanzi(intisdoi.gov 
From: A. Salter [mailto:acsalter@tds.corn] 
Sent: Wednesday, April 18, 2007 8:27 AM 
To: Villafana, Ann Marie C. (USAFLS) 
Subject: RE: Possible Retainer for a Federal Criminal Investigation/Prosecution 
Hi, 
These are all things I could testify about. Can you tell me the time-line? 
I charge $250/hour for everything: reading records, testifying, etc. For traveling I charge from the time I leave the house 
until I arrive at the hotel, and then again the next day from the time I leave the hotel until I return to the hotel or to my 
home. I don't ask for a retainer. 
If that's acceptable, please give me a call at 608-238-8223 at your convenience. Anna Salter 
PS That email address is having trouble. Please send emails to acsalteretds.net.
From: Villafana, Ann Marie C. (USAFLS) [mallto:Ann.Marie.C.Villafana@usdej.gov] 
Sent: Monday, April 16, 2007 10:50 AM 
To: acsalter@annasalter.com 
Subject: Possible Retainer for a Federal Criminal Investigation/Prosecution 
Dear Dr. Salter: 
I am a federal prosecutor in West Palm Beach, Florida, and the District-wide coordinator of child exploitation cases for the 
U.S. Attorney's Office for the Southern District of Florida. I have been reviewing your book, Predators: Pedophiles 
Rapists. & Other Sex Offenders, and have found it immensely informative. 
I am considering undertaking a prosecution, and I am hoping that you would consider serving as an expert consultant and 
possible witness for the case. The types of issues that I am hoping you can address include: 
201 
EFTA00179833

1. Why victims do not report sexual abuse and, when discovered, why it may take several sessions for a victim to 
disclose all of the sexual activity that took place. 
2. Different types of paraphilia -- in particular, describing a predator's interest in post-pubescent children (many people 
are asking why we should prosecute someone who didn't go after really young children). 
3. Traits of psychopathy. 
4. Effects of abuse on victims. 
When you have a chance, would you mind calling or e-mailing me? My direct dial number is shown below. You also can 
contact Special Agent Nesbitt Kuyrkendall, with the FBI, at 561 822-5946. 
Thank you. 
A. Marie Villafaila 
Assistant U.S. Attorney 
561 209-1047 
Fax 561 820-8777 
ann.marie.c.villafana(eausdoi.gov 
202 
EFTA00179834

Villafana, Ann Marie C. (USAFLS) 
From: 
Villafana, Ann Marie C. (USAFLS) 
Sent: 
Friday, April 20, 2007 12:31 PM 
To: 
A. Salter 
Subject: 
RE: Possible Retainer for a Federal Criminal Investigation/Prosecution 
Hi Anna -- My secretary, Shawn Ball, will be calling to get your Social Security number, etc., so we can get 
funding approved. (I don't want to take up a lot of your time and then get into a fight with my Office.) I'll call 
you on Monday? 
A. Marie Villnjaria
Assistant U.S. Attorney 
561 209-1047 
Fax 561 820-8777 
ann.marie.c.villafana@usdoi.gov 
From: A. Salter [mallto:acsalter@tds.com] 
Sent: Wednesday, April 18, 2007 8:27 AM 
To: Villafana, Ann Marie C. (USAFLS) 
Subject: RE: Possible Retainer for a Federal Criminal Investigation/Prosecution 
Hi, 
These are all things I could testify about. Can you tell me the time-line? 
I charge $250/hour for everything: reading records, testifying, etc. For traveling I charge from the time I leave the house 
until I arrive at the hotel, and then again the next day from the time I leave the hotel until I return to the hotel or to my 
home. I don't ask for a retainer. 
If that's acceptable, please give me a call at 608-238-8223 at your convenience. Anna Salter 
PS That email address is having trouble. Please send emails to acsalter6tds.net.
From: Vlllafana, Ann Marie C. (USAFLS) (mailto:Ann.Marle.C.VIllafana@usdoj.gov] 
Sent: Monday, April 16, 2007 10:50 AM 
To: acsalter@annasalter.com 
Subject: Possible Retainer for a Federal Criminal Investigation/Prosecution 
Dear Dr. Salter: 
I am a federal prosecutor in West Palm Beach, Florida, and the District-wide coordinator of child exploitation cases for the 
U.S. Attorney's Office for the Southern District of Florida. I have been reviewing your book  Predators: Pedophiles, 
Rapists. & Other Sex Offenders and have found it immensely informative. 
I am considering undertaking a prosecution, and I am hoping that you would consider serving as an expert consultant and 
possible witness for the case. The types of issues that I am hoping you can address include: 
203 
EFTA00179835

1. Why victims do not report sexual abuse and, when discovered, why it may take several sessions for a victim to 
disclose all of the sexual activity that took place. 
2. Different types of paraphilia -- in particular, describing a predators interest in post-pubescent children (many people 
are asking why we should prosecute someone who didn't go after really young children). 
3. Traits of psychopathy. 
4. Effects of abuse on victims. 
When you have a chance, would you mind calling or e-mailing me? My direct dial number is shown below. You also can 
contact Special Agent Nesbitt Kuyrkendall, with the FBI, at 561 822-5946. 
Thank you. 
A. Mark Vilkfidia 
Assistant U.S. Attorney 
561 209-1047 
Fax 561 820-8777 
ann.marie.c.villatimaAusdoj.gov 
204 
EFTA00179836