EFTA00190318

Villafana, Ann Marie C. (USAFLS) 
From: 
Villafana, Ann Marie C. (USAFLS) <AVillafana@usa.doj.gov> 
Sent: 
Wednesday, September 17, 2008 1:20 PM 
To: 
Jack Goldberger 
Subject: 
RE: Letter concerning Epstein and the Palm Beach Daily News 
Thank you, Jack. 
A. Marie VilIttIhria 
Assistant U.S. Attorney 
500 S. Australian Ave, Suite 400 
West Palm Beach, FL 33401 
Phone 561 209-1047 
Fax 561 820-8777 
From: Jack Goldberger [mailto:jgoldberger@agwpa.com] 
Sent: Wednesday, September 17, 2008 12:59 PM 
To: Villafana, Ann Marie C. (USAFLS) 
Cc: Jay Lefkowitz; RBlack@RoyBlack.com; Barry Krischer; Sloman, Jeff (USAFLS); Atkinson, Karen (USAFLS); Garcia, 
Rolando (USAFLS) 
Subject: Re: Letter concerning Epstein and the Palm Beach Daily News 
We will deal with the state. To answer your? The addendum has been filed 
Jack Goldberger 
Sent from my 'Phone 
On Sep 17, 2008, at 12:15 PM, "Villafana, Ann Marie C. (USAFLS)" <Ann.Marie.C.Villafana@usdoj.gov>
wrote: 
Gentlemen: Please review the attached letter. Thank you. 
«Lefkowitz 080917.pdf» 
A. Marie Wafaiia 
Assistant.. Attorney 
561 209-1047 
<Lefkowitz 080917.pdf> 
441 
EFTA00190398

G.S. Department of Justice 
United States Attorney 
Southern District of Florida 
500 S. Australian Ave, Ste 400 
West Palm Beach, FL 33401 
(561)820-8711 
Facsimile: (S6!) 820-8777 
September 17, 2008 
DELIVERY BY ELECTRONIC MAIL 
Jay P. Letkowitz, Esq. 
Kirkland & Ellis LLP 
Citigroup Center 
153 East 53rd Street 
New York, New York 10022-4675 
Roy Black, Esq. 
Black Srebnick Komspan & Stumpf P.A. 
201 S. Biscayne Blvd, Suite 1300 
Miami, FL 33131 
Jack A. Goldberger, Esq. 
Atterbury, Goldberger & Weiss, P.A. 
One Clearlake Centre, Suite 1400 
250 Australian Ave S. 
West Palm Beach, FL 33401-5015 
Re: 
Jeffrey Epstein 
Dear Jay, Roy, and Jack: 
On today's date, our Office received an inquiry from State Attorney Barry Krischer 
related to the Non-Prosecution Agreement. In accordance with the terms of that Agreement, 
I am notifying you of this development. State Attorney Krischer has been contacted by 
counsel for the Palm Beach Daily News asking why the Non-Prosecution Agreement is under 
seal in order to determine whether to file suit asking that it be unsealed. I have informed 
State Attorney Krischer that the Agreement contains a confidentiality clause requiring us to 
provide Mr. Epstein's counsel with notice prior to making any disclosure (compulsory or 
otherwise). Since Mr. Epstein is a party to that criminal case, he has standing to contest any 
EFTA00190399

JAY P. LEFKOWITZ, ESQ. 
ROY BLACK, ESQ. 
JACK GOLDBERGER, ESQ. 
SEPTEMBER 17, 2008 
PAGE 2 OF 2 
unsealing, while we do not. Accordingly, I ask that you confer with Mr. Krischer regarding 
how you would like to proceed with the matter. 
I also want to reiterate the concern I raised in my letter of August 15, 2008, that the 
complete Non-Prosecution Agreement, which includes the October Addendum, has not been 
filed with the Court in accordance with the Judge's order. Please advise that this issue has 
been resolved. 
Thank you for your attention to these matters. 
Sincerely, 
R. Alexander Acosta 
United States Attorney 
By: 
A. Marie Villafafia 
Assistant United States Attorney 
cc: 
Barry Krischer, State Attorney 
Karen Atkinson, Chief, Northern Division 
EFTA00190400

• ••••• •••• 
• 
USW 
••• 
IP 
---Original Message--
From: Roy BLACK ImailtoilIBLACKOrovblack.coml
Sent: Wednesday, November 26, 2008 11:56 AM 
To: Villafana, Ann Marie C. (USAFLS) 
Cc: Atkinson, Karen (USAFLS) 
Subject: Re: Jeffrey Epstein 
Marie since receipt of your letter I have looked into the situation and 
the following is what is happening: 
Mr. Epstein has not breached the Non-Prosecution Agreement 
(the "Agreement") by serving a portion of his 18-month 
sentence of imprisonment in the Palm Beach County Work 
Release Program. 
I. He is currently serving his sentence in the Palm 
Beach County Work Release Program, not in the 
State-Regulated Community Control Program. Thus he is not on community 
control. 
o The County Jail sentence he is presently serving is 
being served under the auspices of the Palm Beach 
County Sheriff's Office. 
o The Palm Beach County Sheriff's Office has a policy 
of allowing work release under certain criteria for 
those sentenced to the Palm Beach County Detention 
Center or Stockade. It has already been determined 
that Mr. Epstein qualifies under the Palm Beach County Sheriff's 
Office policy for work release. The Florida statute 
authorizing work release for someone imprisoned in 
county jail is at 951.24 (2Xa). 
o The statute provides that when punishment by 
imprisonment in the county jail is prescribed, the 
sentencing court, in its discretion, may at any time 
during the sentence consider granting the privilege to 
the prisoner to leave the confines of the jail or 
county facility during necessary and reasonable hours, 
subject to the rules and regulations prescribed by the 
570 
EFTA00190401

court, to work at paid employment or to conduct his or 
her own business or profession. Sec Fla. Stat. § 
951.24(2Xa). 
o In Palm Beach County, the Sheriff's Office has 
discretion over work release. The local rules state 
that placement into House Arrest and Work Release "is 
at the discretion of the Sheriff and the presiding 
Judge" and offer no defined scope of the type of 
offenders that are eligible—or that are barred—from 
serving their time in Work Release." See Palm Beach 
County Department of Corrections Inmate Rule G-16. 
2. The Non Prosecution Agreement does not prohibit 
work release. 
o The Agreement does not regulate what programs Mr. Epstein can 
participate in while he is serving the County Jail 
sentence. 
3. The Agreement expressly provides that he is to be 
afforded the same benefits that any other inmate might 
receive. See 1 12 of the Agreement. 
5. Under Florida Law, work release is considered part 
of the confinement. See Rule 33.601.602, Fla. Admin. 
Code. (work release "allows inmates to work at paid 
employment in the community while continuing as inmates 
of the facility where they are confined.").So he is an inmate. 
6. Alex Acosta recognized that Mr. Epstein 
might serve a portion of his sentence through the Work 
Release Program. 
o. On December 6, 2007, after the Agreement had been 
executed, counsel received a draft notification 
letter in which US Attorney Acosta expresses this 
intention. The draft document provides that the 
recipient is "entitled to notification when Mr. Epstein 
is released from imprisonment at the end of his prison 
term and/or if he is allowed to participate in a work 
release program." See December 6, 2007 letter to J. 
Lefkowitz from A. Acosta attaching draft notification 
letter, p. 8. 
7. I am told that on July 3, 2008, you wrote an email 
to the Deputy Sherriff stating that the US Attorney's 
Office had no objection to work release as long as 
Epstein is treated as any similarly situated inmate. If anything 
he is being treated more harshly than any other inmate in 
the program. He can't leave the office. He has a guard 
and is wearing a GPS device. So his terms are not more lenientbut rather 
more restrictive than any other 
inmate in the program. 
Clearly we do not feel this is a violation of the agreement and we have 
no intent to violate it. We will meet with you and anyone in the 
executive office to resolve this matter. Certainly it would be best for 
us to meet and discuss. 
571 
EFTA00190402

>>> "Villafana, Ann Marie C. (USAFLS)" <Ann.Marie.C.Villafana®usdoj.gov> 
11/24/08 12:28 PM >>> 
Dear Roy: 
Please review 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 
572 
EFTA00190403

Villafana, Ann Marie C. (USAFLS) 
From: 
/ay Lefkowitz <JLeficowitz@kirkland.com> 
Sent: 
Wednesday, October 08, 2008 2:40 PM 
To: 
Villafana, Ann Marie C. (USAFLS); Roy Black 
Cc: 
Atkinson, Karen (USAFLS); Lee, Dexter (USAFLS) 
Subject: 
Re: Jane Does I. United States 
Thank you for sending this. 
Jay 
From: "Villafana, Ann Marie C. (USAFLS)" [Ann.Marie.C.Villafana@usdoj.gov] 
Sent: 10/08/2008 02:37 PM AST 
To: <RBIack®RoyBlack.com>; Jay Lefkowitz 
Cc: "Atkinson, Karen (USAFLS)" <Karen.Atkinson®usdoj.gov>; "Lee, Dexter (USAFLS)" <Dexter.Lee®usdoj.gov> 
Subject: Jane Does. United States 
Dear Roy and Jay: 
I am attaching the United States' Response to the Petitioners' Motion to Unseal the Non-Prosecution 
Agreement, which was filed in the victims' rights suit filed against the United States by Attorney Brad Edwards 
on behalf of two of the victims. In his motion to unseal, Attorney Edwards stated that he would provide notice 
of his motion to counsel for Mr. Epstein. I do not know if he actually did so. 
In our response, we oppose the Petitioners' motion, and point out that Mr. Edwards has filed a civil suit against 
Mr. Epstein and that litigation regarding the Non-Prosecution Agreement is more appropriate in that forum 
where the real party in interest (Mr. Epstein) is a party to the suit. 
«DE29_081008_Resp to Motn Unseal.pdf>> 
A. Marie Villajafia 
Assistant U.S. Attorney 
561 209-1047 
Fax 561 820-8777 
The information contained in this communication is 
confidential, may be attorney-client privileged, may 
constitute inside information, and is intended only for 
the use of the addressee. It is the property of 
Kirkland a Ellis LLP or Kirkland s Ellis International LLP. 
Unauthorized use, disclosure or copying of this 
472 
EFTA00190404

communication or any part thereof is strictly prohibited 
and may be unlawful. If you have received this 
communication in error, please notify us immediately by 
return e-mail or by e-mail to postmaster@kirkland.com, and 
destroy this communication and all copies thereof, 
including all attachments. 
473 
EFTA00190405

Villafana, Ann Marie C. (USAFLS) 
From: 
Roy BLACK <RBLACK@royblack.com> 
Sent: 
Thursday, December 04, 2008 1:34 PM 
To: 
Villafana, Ann Marie C. (USAFLS) 
Cc: 
Sloman, Jeff (USAFLS) 
Subject: 
Re: Motion 
Attachments: 
Motion to Correct Sentence.wpd 
Marie here is our motion to correct the sentence. As you can see Judge Pucillo is a retired judge who only handled McSorley's docket 
that day. Since the plea had to be done on that day due to our agreement Judge Pucillo handled it. Epstein's case has always been in 
division W which is McSorley and McSorley's order says all division W cases for work release are in the discretion of the sheriff. Also 
Jack says McSorley entered the new sentencing order without notice to anyone and in fact he didn't know it until this matter came up. 
>>> "Villafana, Ann Marie C. (USAFLS)" <Ann.Marie.C.Villafana@usdoj.gov> 12/4/2008 12:51 PM >>> 
Hi Roy - can you email the motion to Karen and I before it is filed? Thank you. 
628 
EFTA00190406

Villafana, Ann Marie C. (USAFLS) 
From: 
Villafana, Ann Marie C. (USAFLS) <AVillafana@usa.doj.gov> 
Sent: 
Monday, November 24, 2008 12:29 PM 
To: 
Roy BLACK 
Cc: 
Atkinson, Karen (USAFLS) 
Subject: 
Jeffrey Epstein 
Attachments: 
081124 Villafana lir to Black.pdf 
Dear Roy: 
Please review the attached letter. 
Thank you. 
Marie 
«081124 Villafana itr to Black.pdf» 
A. Marie Villafaiia 
Assistant U.S. Attorney 
500 S. Australian Ave, Suite 400 
West Palm Beach, FL 33401 
Phone 561 209-1047 
Fax 561 820-8777 
556 
EFTA00190407

U.S. Department of Justice 
United States Attorney 
Southern District of Florida 
DELIVERY BY ELECTRONIC MAIL 
Roy Black, Esq. 
Black Srebnick Komspan & Stumpf P.A. 
201 S. Biscayne Blvd, Suite 1300 
Miami, FL 33131 
Re: 
Jeffrey Epstein 
Dear Roy: 
500 S. Australian Ave, Ste 400 
West Palm Beach, FL 33401 
(561) 820-8711 
Facsimile: (56!) 820-8777 
November 24, 2008 
On Thursday I learned that Mr. Epstein applied for and was admitted to the Palm 
Beach County Sheriff's Office's work release program and that he has been on work release 
for the past few weeks. For the following reasons, the Office believes that Mr. Epstein's 
application to and participation in the work release program is a material breach of the Non-
Prosecution Agreement. Accordingly, the United States demands that Mr. Epstein withdraw 
his application to participate in the program and complete his eighteen-month term of 
imprisonment in accordance with the Non-Prosecution Agreement. 
The Non-Prosecution Agreement provides that Epstein "shall be sentenced to 
consecutive terms of twelve (12) months and six (6) months in county jail for all charges, 
without any opportunity for withholding adjudication or sentencing, and probation or 
community control in lieu of imprisonment." I have more than a dozen e-mails between 
myself and Jay Lefkowitz discussing the U.S. Attorney's insistence on eighteen months of 
incarceration. You will recall that at one meeting you and Ms. Sanchez raised the idea of Mr. 
Epstein hiring Sheriff's Deputies to guard him as equivalent to imprisonment. Mr. Acosta 
specifically rejected that suggestion. It is our understanding from the Sheriff's Office that 
Mr. Epstein is paying off-duty Sheriff's Deputies to guard him while he "works" at Mr. 
EFTA00190408

Roy BLACK, EsQ. 
NOVEMBER 24, 2008 
PAGE 2 OF 4 
Goldberger's office building each day. 
As you remember, shortly before Mr. Epstein's change of plea, Mr. Goldberger sent 
me a copy of the proposed plea agreement with the state. On June 27, 2008, I sent a letter 
containing the following language to you and Mr. Goldberger: 
The U.S. Attorney's Office hereby provides Notice that the proposed sentencing 
provision does not comply with the terms of the Non-Prosecution Agreement. 
The second sentencing paragraph of the proposed plea agreement reads: 
On 08CF009381AMB, the Defendant is sentenced to 18 months Community Control 
I (one). As a special condition of this Community Control, the Defendant must serve 
the first 6 months in the Palm Beach County Detention Facility . . . 
The Non-Prosecution Agreement specifically provides: 
Epstein shall be sentenced to consecutive terms of twelve (12) months and six (6) 
months in county jail for all charges, . . . without probation or community control in 
lieu of imprisonment. 
Thus, the proposed plea agreement with the State Attorney's Office does not comply 
with the terms of the Non-Prosecution Agreement. To comply with the Agreement, 
Mr. Epstein must make a binding recommendation of eighteen months imprisonment,
which means confinement twenty-four hours a day at the County Jail, and the judge 
must accept that recommendation. Community control must follow that term of 
incarceration. 
(Emphasis in original.) 
As 1 specified in that letter, the Non-Prosecution Agreement calls for "confinement 
twenty-four hours a day." In response to that letter, Mr. Goldberger agreed that he would 
revise the state plea agreement to include the word "imprisonment" to make clear that Mr. 
Epstein would be incarcerated for the full eighteen months and would change the language 
of the state agreement to match the language of the federal agreement. Mr. Goldberger and 
I also discussed the situation and he made clear that Mr. Epstein would not be asking for or 
receiving work release and would remain in jail "around the clock." 
In early August, Karen Atkinson and I raised the same issue with you when we heard 
EFTA00190409

ROY BLACK, ESQ. 
NOVEMBER 24, 2008 
PAGE 3 OF 4 
that Mr. Epstein was considering applying for work release. On August 6, 2008, Ms. 
Atkinson and I had a conference call with you wherein you again stated that Mr. Epstein 
would not apply for or receive work release and would spend his eighteen months 
incarcerated twenty-four hours a day at the Palm Beach County Stockade. 
In preparation for this letter, I obtained a certified copy of Mr. Epstein's state court 
file. On June 30, 2008, on the procurement of minors charge, Judge Pucillo entered the 
following sentence: 
The defendant is hereby committed to the custody of the Sheriff of Palm Beach 
County, Florida for a term of 6 mos. It is further ordered that the Defendant 
shall be allowed a total of I days [sic] as credit for time incarcerated prior to 
imposition of this sentence. It is further ordered that the composite term of all 
sentences imposed for the counts specified in the order shall run consecutive 
to the following: Specific sentences: 2006CF9454AXX. 
. . . the following provisions apply to the sentence imposed: . . . Followed by 
a period of 12 mos on community control 1 under the supervision of the 
Department of Corrections .. . . 
As I learned on Friday when I received the state court file, you neglected to inform 
our Office that, on July 21, 2008, Judge McSorley modified the judgment nunc pro tune to 
an "Order of Community Control I." This same language was the basis for the objection in 
my letter of June 26, 2008 and directly contradicts the language of the Non-Prosecution 
Agreement. I also note that, on the state plea agreement, Mr. Goldberger did not insert the 
word "imprisonment" as agreed prior to the change of plea, instead the words "jail sentence" 
are included. 
The Office's Agreement not to prosecute Mr. Epstein was based upon its 
determination that eighteen months' incarceration (i.e., confinement twenty-four hours a day) 
was sufficient to satisfy the federal interest in Mr. Epstein's crimes. Accordingly, the U.S. 
Attorney's Office hereby gives notice that Mr. Epstein has violated the Non-Prosecution 
Agreement by failing to remain incarcerated twenty-four hours a day for the eighteen-month 
EFTA00190410

Roy BLACK, ESQ. 
NOVEMBER 24, 2008 
PAGE 4 OF 4 
term of imprisonment. The United States will exercise any and all rights it has under the 
Non-Prosecution Agreement unless Mr. Epstein immediately ceases and desists from his 
breach of this Agreement. 
Sincerely, 
R. Alexander Acosta 
United States Attorney 
By: 
A. Marie Villafafta 
Assistant United States Attorney 
cc: 
Karen Atkinson, Chief, Northern Division 
EFTA00190411

JANE DOE I. UNITED STATES 
COURT FILE NO. 08-80736-CV-MARRA 
THIRD SUPPLEMENTAL PRIVILEGE LOG - BOX #5 
Bates Range 
Description 
Privilege(s) Asserted 
P-014924 
5/27/2008 emails between A.M. Villafafia and K. Atkinson regarding 
report of new state plea deal for J. Epstein 
Work Product 
Deliberative Process 
P-014925 
thru 
P-014927 
5/27/2008 emails between A.M. Villafatia, R. Senior, J. Sloman, and K. 
Atkinson regarding potential renewed plea negotiations for J. Epstein 
and plans to review and revise updated indictment package 
Work Product 
Deliberative Process 
Investigative Privilege 
6(e) 
P-014928 
5/23/2008-5/27/2008 emails between A.M. Villafafia„ E.N. Kuyrkendall, 
and J. Richards regarding plans to meet to prepare for indictment 
presentation, service of grand jury subpoenas. interviews of additional 
witnesses, and plea negotiation issue 
Attorney-Client Privilege 
Investigative Privilege 
6(e) 
Privacy Act/TVPA/CVRA 
P-014929 
thru 
P-014933 
5/27/2008-5/28/2008 emails between A.M. Villafafia, E. Nesbitt 
Kuyrkendall, and J. Richards regarding request for legal analysis of 
statute of limitations issues under state and federal law 
Attorney-Client Privilege 
Investigative Privilege 
6(e) 
Privacy Act/TVPA/CVRA 
P-014934 
thru 
P-014935 
5/27/2008-5/28/2008 emails between A.M. Villafafia, J. Sloman, R. 
Senior, K. Atkinson, and R. Garcia regarding report of new state plea 
deal for J. Epstein 
Work Product 
Deliberative Process 
P-014936 
thru 
P-014940 
5/29/2008-5/30/2008 emails between A.M. Villafiuia, J. Sloman, R. 
Senior, K. Atkinson, E. Nesbitt Kuyrkendall, and J. Richards regarding 
planned grand jury presentation, status of investigation, possible grant 
of immunity to victim/witness for grand jury testimony 
Work Product 
Attorney-Client Privilege 
6(e) 
Investigative Privilege 
Deliberative Process 
Privacy Act/TVPA/CVRA 
Pare 1 of 7 
EFTA00190412

Bates Range 
Description 
Privilege(s) Asserted 
P-014941 
thru 
P-014954 
6/2/2008 draft letter to Deputy Attorney General Mark Filip regarding 
reasons to approve continued prosecution of J. Epstein 
(NB: The Court has already determined that final version of this letter 
is protected by Work Product/Deliberative Process/Attorney-Client 
Privileges) 
Work Product 
6(e) 
Deliberative Process 
Investigative Privilege 
PM 14955 
thru 
P-014971 
6/3/2008 draft letter to Deputy Attorney General Mark Filip regarding 
reasons to approve continued prosecution of J. Epstein 
(NB: The Court has already determined that final version of this letter 
is protected by Work Product/Deliberative Process/Attorney-Client 
Privileges) 
Work Product 
6(e) 
Deliberative Process 
Investigative Privilege 
P-014972 
thru 
P-014975 
6/6/2008 emails between A.M. Villafafta and E. Nesbitt Kuyrkendall 
regarding victim/witness subpoenaed to the grand jury and need for 
additional grand jury subpoenas 
Attorney-Client Privilege 
Investigative Privilege 
6(e) 
Privacy Act/TVPA/CVRA 
P-014976 
6/18/2008 emails between A.M. Villafafia, R. Senior, A. Acosta, J. 
Sloman, R. Garcia, and K. Atkinson regarding telephone conference 
with R. Black about allowing J. Epstein to accept state plea to 60 days' 
imprisonment. 
Work Product 
Deliberative Process 
P-014977 
thru 
P-014978 
6/19/2008 email forwarding 6/19/2008 email from B. Edwards to E. 
Nesbitt Kuyrkendall and J. Richards 
(NB: Asserting privilege only for A.M. Villafana email. Attorney 
Edwards presumably has copy of his email to A.M. Villafafla) 
Attorney-Client Privilege 
Investigative Privilege 
P-014979 
thru 
P-014980 
6/23/2008 emails between A.M. Villafaiia, A. Fernandez, and S. Ball 
(USAO staff) regarding scheduling of grand jury time for indictment 
presentation and witness testimony 
(Information regarding unrelated grand jury case redacted) 
Work Product 
Investigative Privilege 
6(e) 
PM14981 
6/23/2008 emails between A.M. Villafatia, E. Nesbitt Kuyrkendall, J. 
Richards, K. Atkinson, and R. Senior regarding grand jury subpoena to 
victim/witness, revisions to indictment, planned grand jury presentation. 
and plans to supersede indictment 
Attorney-Client Privilege 
Work Product 
6(e) 
Investigative Privilege 
Deliberative Process 
Privacy Act/TVPA/CVRA 
Page 2 of 7 
EFTA00190413

Bates Range 
Description 
Privilege(s) Asserted 
P-014982 
thru 
P-014990 
6/25/2008 emails between A.M. Villafafia. J. Sloman, R. Senior, K. 
Atkinson, and A. Acosta regarding draft of notification of victim list for 
J. Epstein counsel with attached drafts 
(NB: Final list, with victim names redacted. has been produced to 
counsel for Petitioners) 
Work Product 
Deliberative Process 
P-014991 
thru 
P-015004 
6/23/2008-6/26/2008 emails between A.M. Villafaria and counsel for 
grand jury witness/victim regarding immunity and travel for grand jury 
appearance 
6(e) 
Investigative privilege 
Privacy Act/TVPAJCVRA 
P-015005 
thru 
P-015006 
6/28/2008 emails between A.M. Villafafia, J. Sloman, A. Acosta, and R. 
Senior regarding correspondence with J. Goldberger and proposed 
change to state plea agreement 
Work Product 
Deliberative Process 
Attorney-Client Privilege 
P-015007 
7/3/2008 emails between A.M. Villafafta, J. Sloman, and A. Acosta 
regarding telephone conf. with B. Edwards and regarding meeting with 
Sheriff's Office about work release program 
Work Product 
Deliberative Process 
P-015008 
thru 
P-015024 
7/8/2008 emails between D. Lee, K. Neal (Attorney Advisory, Victim 
Witness Staff, EOUSA), and A.M. Villafaila regarding filing of 
Petitioners' suit, with attached Draft of Villafafia Declaration and initial 
Petition (DEI) 
(NB: Privilege is not being asserted for second attachment (DE1). 
Attachment was prepared by petitioners and is not being produced 
because it is within their custody and control.) 
Work Product 
Deliberative Process 
P-015025 
thru 
P-015028 
7/8/2008 email from A.M. Villafafia to D. Lee, A. Acosta, and J. 
Sloman regarding victim notification letter provided to counsel for J. 
Epstein on 11/28/2007 with attachment 
(NB: The 11/28/2007 email to J. Lefkowitz with attachment will be 
produced to petitioners' counsel contemporaneously with the filing of 
this log) 
Work Product 
Deliberative Process 
P-015029 
thru 
P-015034 
7/7/2008-7/8/2008 emails between A.M. Villafafia and D. Lee regarding 
background of J. Epstein investigation, negotiations, and victim 
notifications, and forwarding earlier emails related to Lee questions 
Work Product 
Deliberative Process 
Attorney-Client Privilege 
Page 3 of 7 
EFTA00190414

Bates Range 
Description 
Privilege(s) Asserted 
P-015035 
thru 
P415062 
7/8/2008-7/9/2008 emails between A.M. Villafafia, J. Sloman, D. Lee, 
A. Acosta, K. Atkinson. K. Herd, K. Neal, K. Manning, and W. Jacobus 
regarding response to Jane Doe suit, procedure for filing, and internal 
office policies 
Work Product 
Deliberative Process 
P-015063 
thru 
P-015069 
7/11/2008-7/14/2008 emails between D. Lee, A.M. Villafafia, K. Herd, 
K. Neal, A. Acosta, J. Sloman, and W. Jacobus re outcome of hearing in 
Jane Doe I. U.S. suit and contact from counsel for J. Epstein 
Attorney-Client Privilege 
Work Product 
Deliberative Process 
P415070 
thru 
P-015071 
7/14/2008-7/15/2008 emails between A.M. Villafafia, E. Nesbitt 
Kuyrkendall, J. Richards, and T. Smith regarding FBI victim 
notifications and guidance regarding language to use and information to 
provide 
Attorney-Client Privilege 
P-015072 
thru 
P-015074 
7/17/2008 email from J. Sloman to A. Acosta, A.M. Villafafia, K. 
Atkinson. and Dexter Lee with attached draft of letter to M. Tein 
regarding misrepresentations in filings on behalf of J. Epstein in civil 
suits 
Work Product 
Deliberative Process 
P-015075 
thru 
P415081 
7/18/2008-7/21/2008 emails between A.M. Villafafia, J. Sloman, E. 
Nesbitt Kuyrkendall, J. Richards, D. Lee, and K. Atkinson regarding 
preparation of victim notification letters, victim contact list, filing of 
victim notification letter in a civil proceeding, and contact by B. 
Edwards with one victim opining that sentence imposed was insufficient 
Attorney-Client Privilege 
Work Product 
Investigative Privilege 
P-015082 
thni 
P-015084 
7/21/2008 emails between A.M. Villafaria, J. Sloman, R. Senior, D. Lee, 
K. Atkinson, E. Nesbitt Kuyrkendall, and J. Richards regarding ongoing 
victim notification process and Epstein filings in state court litigation 
related to federal grand jury investigation 
Work Product 
Attorney-Client Privilege 
Deliberative Process 
6(e) 
P-015085 
thru 
P-015090 
7/22/2008 emails between A.M. Villafafia, A. Acosta, J. Sloman, R. 
Senior, K. Atkinson, E. Nesbitt Kuyrkendall, and J. Richards regarding 
7/2112008 letter from M. Tein announcing plan to stay the civil suits 
against .1. Epstein and notification that B. Reinhart is counsel of record 
for S. Kellen in civil suits 
(NB: Tein letter is being produced to petitioners' counsel concurrently 
with production of this privilege log) 
Work Product 
Attorney-Client Privilege 
Deliberative Process 
Page 4 of 7 
EFTA00190415

Bates Range 
Description 
Privilege(s) Asserted 
P415091 
thru 
P-015092 
7/22/2008 emails between A.M. Villafafla and E. Nesbitt Kuyrkendall 
regarding ongoing victim notification process 
Attorney-Client Privilege 
6(e) 
Investigative Privilege 
Privacy Act/TVPA/CVRA 
P-015093 
thru 
P-015097 
7/22/2008 emails between A.M. Villafaha, R. Senior. E. Nesbitt 
Kuyrkendall, J. Richards, and K. Atkinson regarding correspondence 
from J. Epstein counsel with attached draft response 
(NB: A final version of the letter has been produced.) 
Attorney-Client Privilege 
Work Product 
6(e) 
Deliberative Process 
P-015098 
7/23/2008 emails between A.M. Villafana and D. Lee regarding 
correspondence with counsel for J. Epstein and notice of breach 
Work Product 
Deliberative Process 
6(e) 
P-015099 
7/25/2008 emails between A.M. Villafafta and K. Atkinson regarding 
extension of grand jury to allow for continued presentation of J. Epstein 
case 
6(e) 
Work Product 
Deliberative Process 
P-015100 
thru 
P-015116 
8/2/2008 email from D. Lee to A. Acosta, J. Sloman W. Jacobus. and 
A.M. Villafana summarizing status of Jane Doe. United States 
litigation and requesting views on making certain disclosures to counsel 
for petitioners with attached pleading filed by petitioners (DE 19) 
(NB: Privilege is not being asserted for attachment. Attachment was 
prepared by petitioners and is not being produced because it is within 
their custody and control.) 
Work Product 
6(e) 
Deliberative Process 
P-015117 
thru 
P-015135 
8/5/2008 email from A.M. Villafafta to A. Acosta, J. Sloman, R. Senior, 
and K. Atkinson regarding analysis of Jeffrey Epstein agreement, with 
attached 6/24/2008 email from A.M. Villafafta to R. Black and J. 
Goldberger and attached Epstein agreement. 
(NB: Privilege is not being asserted for the two attachments. The 
6/24/2008 email will be produced to petitioners' counsel 
contemporaneously with the filing of this log, and the Agreement has 
previously been produced to petitioners pursuant to an earlier Court 
order.) 
Work Product 
Deliberative Process 
Page 5 of 7 
EFTA00190416

Bates Range 
Description 
Privilege(s) Asserted 
P-015136 
thru 
P-015172 
8/13/2008-8/15/2008 emails between A. Acosta, K. Atkinson, R. Senior, 
J. Sloman, D. Lee, and A.M. Villafafia regarding scope of Epstein 
agreement and correspondence and telephone conference with J. 
Lefkowitz 
(NB: Emails to and from J. Lefkowitz and R. Black have been 
produced to Petitioners' counsel) 
Work Product 
Deliberative Process 
Attorney-Client Privilege 
P-015173 
thru 
P-015186 
8/25/2008 emails between A.M. Villafafia, A. Acosta, J. Sloman, R. 
Senior, K. Atkinson, and D. Lee regarding letter received from J. 
Lefkowitz 
(NB: Lefkowitz letter has been produced to Petitioners' counsel) 
Work Product 
Deliberative Process 
Attorney-Client Privilege 
P415187 
thru 
P-015194 
8/20/2008-8/26/2008 emails between A.M. Villafafia, A. Acosta, J. 
Sloman, R. Senior, and K. Atkinson it draft response to .1. Lefkowitz 
and draft amended victim notification letter 
(NB: Final version of letter to Lefkotiz and Black has been produced to 
Petitioners' counsel) 
Work Product 
Deliberative Process 
P-015195 
thru 
P-015198 
9/2/2008 emails between A.M. Villafafia, D. Lee, R. Senior, and J. 
Sloman regarding revised victim notification 
Work Product 
Deliberative Process 
Attorney-Client Privilege 
P-015199 
thru 
P-015206 
9/17/2008 emails between A.M. Villafafia, A. Acosta, J. Sloman, R. 
Senior, D. Lee, K. Atkinson, and R. Garcia regarding efforts by Palm 
Beach Daily News to unseal NonProsecution Agreement that had been 
filed in state court 
(NB: Emails from Counsel for Daily News and from State Attorney's 
Office have been produced to Petitioners' counsel) 
Work Product 
Deliberative Process 
Attorney-Client Privilege 
P-015207 
thru 
P-015213 
9/17/2008 email from A.M. Villafaiiit to A. Acosta, J. Sloman, R. 
Senior, D. Lee, and K. Atkinson regarding attached letters from J. 
Herman alleging that victim notifications violated Bar ethics rules 
(NB: Redacted versions of the letters have been produced to Petitioners' 
counsel) 
Work Product 
Deliberative Process 
Privacy Act/TVPAJCVRA 
P-015214 
thru 
P-015226 
9/29/2008 correspondence to Florida Bar Ethics Counsel regarding 
victim notification letters and allegation of ethics violation for 
distribution of letters with attached proposed victim notification letters 
Work Product 
Relevance 
Florida Bar Privacy Rules 
Page 6 of 7 
EFTA00190417