EFTA00193954

Recipient 
Road 
Jacobus, Wendy (USAFLS) 
Read: 7/7/2008 5:43 PM 
682 
EFTA00194334

500 S. Australian Ave, Suite 400 
West Palm Beach, FL 33401 
Phone 561 209-1047 
Fax 561 820-8777 
Tracking: 
681 
EFTA00194335

Villafana, Ann Marie C. (USAFLS) 
From: 
Villafana, Ann Marie C. (USAFLS) 
Sent: 
Monday, July 07, 2008 5:07 PM 
To: 
Jacobus, Wendy (USAFLS) 
Subject: 
RE: Order requiring response to Jane Doe Complaint 
Thank you, Wendy. Dexter and I have talked about it. I am lucky to have one of your best volunteer to defend 
mc! 
P.S. Hope all is well with you! 
A. Marie Viliafaha 
Assistant U.S. Attorney 
500 S. Australian Ave, Suite 400 
West Palm Beach, FL 33401 
Phone 561 209-1047 
Fax 561 820-8777 
From: Jacobus, Wendy (USAFLS) 
Sent: Monday, July 07, 2008 5:04 PM 
To: Villafana, Ann Marie C. (USAFLS); Lee, Dexter (USAFLS); Sloman, Jeff (USAFLS) 
Cc: Atkinson, Karen (USAFLS) 
Subject: RE: Order requiring response to Jane Doe Complaint 
Ann Marie, 
Dexter has graciously agreed to defend this case and is aware of the filing deadline of this Wednesday at 5:00 pm. 
Thanks for letting us know about this so quicklyl 
Wendy 
From: Villafana, Ann Marie C. (USAFLS) 
Sent: Monday, July 07, 2008 4:17 PM 
To: Lee, Dexter (USAFLS); Jacobus, Wendy (USAFLS); Sloman, Jeff (USAFLS) 
Cc: Atkinson, Karen (USAFLS) 
Subject: Order requiring response to Jane Doe Complaint 
Importance: High 
I spoke too soon. Here is how Judge Marra is reacting to this. Please let me know asap who is assigned or if I 
should draft the response. 
<< File: DE3_080707_Order requiring response.pdf >> 
A. Marie Viliafafla 
Assistant U.S. Attorney 
680 
EFTA00194336

Villafana, Ann Marie C. (USAFLS) 
From: 
Lee, Dexter (USAFLS) 
Sent: 
Monday, July 07, 2008 5:12 PM 
To: 
Villafana, Ann Marie C. (USAFLS) 
Subject: 
CVRA Lawsuit 
Ann Marie, 
Can you look through your files and set aside every piece of correspondence that was sent to either Jane Doe or her 
legal representative? Thanks. 
Dexter 
679 
EFTA00194337

Recipient 
Lee, Dexter (USAF LS) 
Read 
Read: 7/7/2008 5:49 PM 
678 
EFTA00194338

Villafana, Ann Marie C. (USAFLS) 
From: 
Villafana, Ann Marie C. (USAFLS) 
Sent: 
Monday, July 07, 2008 5:14 PM 
To: 
Lee, Dexter (USAFLS) 
Subject: 
RE: CVRA Lawsuit 
Thanks, I am working on that already. 
A. Marie Villafana 
Assistant U.S. Attorney 
500 S. Australian Ave, Suite 400 
West Palm Beach, FL 33401 
Phone 561 209-1047 
Fax 561 820-8777 
From: Lee, Dexter (USAFLS) 
Sent: Monday, July 07, 2008 5:12 PM 
To: Villafana, Ann Marie C. (USAFLS) 
Subject: CVRA Lawsuit 
Ann Marie, 
Can you look through your files and set aside every piece of correspondence that was sent to either Jane Doe or her 
legal representative? Thanks. 
Dexter 
Tracking: 
677 
EFTA00194339

Dexter 
676 
EFTA00194340

Villafana, Ann Marie C. (USAFLS) 
From: 
Villafana, Ann Marie C. (USAFLS) 
Sent: 
Monday, July 07, 2008 5:17 PM 
To: 
Kuyrkendall, E N. (FBI); Richards, Jason R. (FBI) 
Subject: 
FW: CVRA Lawsuit 
Hi guys - Can you get anything that Twiler sent to MI 
to 
Me 
And do you
dates when you provided my original Victim's Rights letter to 
Did we ever give one to 
And do I remember correctly that we gave =her 
letter on the date of the interview? And, do you have that 
date handy? 
Thanks. 
A. Marie Villafana 
Assistant U.S. Attorney 
500 S. Australian Ave, Suite 400 
West Palm Beach, FL 33401 
Phone 561 209-1047 
Fax 561 820-8777 
From: Villafana, Ann Marie C. (USARS) 
Sent: Monday, July 07, 2008 5:14 PM 
To: Lee, Dexter (USAFLS) 
Subject: RE: CVRA Lawsuit 
Thanks, I am working on that already. 
A. Marie Villafaila 
Assistant U.S. Attorney 
500 S. Australian Ave, Suite 400 
West Palm Beach, FL 33401 
Phone 561 209-1047 
Fax 561 820-8777 
From: Lee, Dexter (USAFLS) 
Sent: Monday, July 07, 2008 5:12 PM 
To: Villafana, Ann Made C. (USAFLS) 
Subject CVRA Lawsuit 
Ann Marie, 
Can you look through your files and set aside every piece of correspondence that was sent to either Jane Doe or her 
legal representative? Thanks. 
675 
EFTA00194341

Villafana, Ann Marie C. (USAFLS) 
From: 
Lee, Dexter (USAFLS) 
Sent: 
Monday, July 07, 2008 6:53 PM 
To: 
Villafana, Ann Marie C. (USAFLS) 
Subject: 
CVRA Suit 
Ann Marie, 
The Attorney General Guidelines for Victim and Witness Assistance (May 2005) provides that "responsible officials 
should make reasonable efforts to notify identified victims of, and consider victims' views about, prospective plea 
negotiations." Article IV, Services to Victims and Witnesses, p. 30. 
Has an agreement been signed with Epstein? Did we notify Jane Doe that an agreement was about to be negotiated, 
and the outlines of that proposed agreement? Thanks. 
Dexter 
674 
EFTA00194342

Villafana, Ann Marie C. (USAFLS) 
From: 
Sent: 
To: 
Cc: 
Subject: 
Villafana, Ann Marie C. (USAFLS) 
Monday, July 07, 2008 7:23 PM 
Lee, Dexter (USAFLS) 
Sloman, Jeff (USAFLS) 
Re: CVRA Suit 
Hi dexter. Yes an agreement has been signed and has already been partially 
performed. The agreement is confidential and has been filed under seal in the 
state court proceedings. 
He could be filing his motion on behalf of 3 different jane 
fully identified until after the agreement was signed. T.M. 
notification resulted in claims of prosecutorial misconduct 
I am checking to see if the third, C.W., was notified prior 
agreement. 
 
 Original Message  
From: Lee, Dexter (USAFLS) 
To: Villafana, Ann Marie C. (USAFLS) 
Sent: Mon Jul 07 18:52:42 2008 
Subject: CVRA Suit 
Ann Marie, 
does. S.R. Was not 
was notified and her 
by Epstein's lawyers. 
to the signing of the 
The Attorney General Guidelines for Victim and Witness Assistance (May 2005) 
provides that "responsible officials should make reasonable efforts to notify 
identified victims of, and consider victims' views about, prospective plea 
negotiations." 
Article IV, Services to Victims and Witnesses, p. 30. 
Has an agreement been signed with Epstein? 
Did we notify Jane Doe that an 
agreement was about to be negotiated, and the outlines of that proposed 
agreement? 
Thanks. 
Dexter 
673 
EFTA00194343

To: Villafana, Ann Marie C. (USAFLS) 
Subject: CVRA Lawsuit 
Ann Marie, 
Can you look through your files and set aside every piece of correspondence that was sent to either Jane Doe 
or her legal representative? Thanks. 
Dexter 
672 
EFTA00194344

Villafana, Ann Marie C. (USAFLS) 
From: 
Kuyrkendall, E N. (FBI) 
Sent: 
Monday, July 07, 2008 7:57 PM 
To: 
Villafana, Ann Marie C. (USAFLS) 
Subject: 
RE: CVRA Lawsuit 
Marie, 
Twiler is out all week at a conference In OK. We hopefully will be able to provide you with more details next week. 
TM was interviewed 04/27/2007. We are unsure if a letter was provided at that time. Twiler sent TM's Attorney the FBI 
Victim/Witness letter dated Jan 10, 2008. 
CW also received the FBI Victim/Witness letter from Twiler dated Jan 10, 2008. Jason and I are unable to recall exactly 
how CW was provided the USAO Victim/Witness letter. 
SR was interviewed by the FBI on May 28, 2008. Twiler mailed SR the FBI Victim/Witness letter dated May 30, 2008. 
Nesbitt and Jason 
From: Villafana, Ann Marie C. (USAFLS) [Ann.Marle.C.Villafana@usdoj.gov] 
Sent: Monday, July 07, 2008 5:17 PM 
To: Kuyrkendall, E N.; Richards, Jason R. 
Subject: FW: CVRA Lawsuit 
Ili guys — Can you get anything that Twiler sent toll., 
d/or 
? And do yot
e 
dates when you provided my original Victim's Rights letter to 
? Did we ever give one to 
And do I remember correctly that we gave 
her letter on the date of the interview? And, do you have that 
date handy? 
Thanks. 
A. Marie Villafana 
Assistant U.S. Attorney 
500 S. Australian Ave, Suite 400 
West Palm Beach, FL 33401 
Phone 561 209-1047 
Fax 561 820-8777 
From: Villafana, Ann Marie C. (USAFLS) 
Sent: Monday, July 07, 2008 5:14 PM 
To: Lee, Dexter (USAFLS) 
Subject: RE: CVRA Lawsuit 
Thanks, 1 am working on that already. 
A. Marie Villafana 
Assistant U.S. Attorney 
500 S. Australian Ave, Suite 400 
West Palm Beach, FL, 33401 
Phone 561 209-1047 
Fax 561 820-8777 
From: Lee, Dexter (USAFLS) 
Sent: Monday, July 07, 2008 5:12 PM 
671 
EFTA00194345

Recipient 
Lee, Dexter (LISAFLS) 
Read 
Read: 7/812008 10:21 MA 
670 
EFTA00194346

Villafana, Ann Marie C. (USAFLS) 
From: 
Villafana, Ann Marie C. (USAFLS) 
Sent: 
Tuesday, July 08, 2008 10:17 AM 
To: 
Lee, Dexter (USAFLS) 
Subject: 
Emailing: Villafana Declaration re victim notification.wpd 
Attachments: 
Villafana Declaration re victim notification.wpd 
Hi Dexter -- I am still working on it, but thought this would help with 
background. When I finish, I will send to you, Jeff, and Alex. 
Thanks. 
The message is ready to be sent with the following file or link attachments: 
Villafana Declaration re victim notification.wpd 
Note: To protect against computer viruses, e-mail programs may prevent sending or 
receiving certain types of file attachments. Check your e-mail security settings 
to determine how attachments are handled. 
Tracking: 
669 
EFTA00194347

Recipient 
Read 
Acosta, Alex (USAFLS) 
Read: 718/2008 12:21 PM 
Sloman, Jeff (USAFLS) 
Read: 7/8/2008 10:58 AM 
Lee. Dexter (USAFLS) 
Read: 7/8/2008 10:58 NA 
Atkinson. Karen (USAFLS) 
Read: 7/8/2008 11:22 AM 
668 
EFTA00194348

Villafana, Ann Marie C. (USAFLS) 
From: 
Villafana, Ann Marie C. (USAFLS) 
Sent: 
Tuesday, July 08, 2008 10:54 AM 
To: 
Acosta, Alex (USAFLS); Sloman, Jeff (USAFLS); Lee, Dexter (USAFLS) 
Cc: 
Atkinson, Karen (USAFLS) 
Subject: 
Brad Edwards Letter.pdf 
Everyone — Here is a letter that 1 received from Mr. Edwards yesterday afternoon. It was sent via registered 
mail. 
Thank you. 
Brad Edwards 
Letter.pdf 
A. Marie Villafaila 
Assistant U.S. Attorney 
500 S. Australian Ave, Suite 400 
West Palm Beach, FL 33401 
Phone 561 209-1047 
Fax 561 820-8777 
Tracking: 
667 
EFTA00194349

Recipient 
Acosta, Alex (USAFLS) 
Sloman, Jeff (USAFLS) 
Lee, Dexter (USAFLS) 
Read 
Read: 7/8/2008 12:22 PM 
Read: 7/8/2008 11:01 AM 
666 
EFTA00194350

Villafana, Ann Marie C. (USAFLS) 
From: 
Villafana, Ann Marie C. (USAFLS) 
Sent: 
Tuesday, July 08, 200810:57 AM 
To: 
Acosta, Alex (USAFLS); Sloman, Jeff (USAFLS); Lee, Dexter (USAFLS) 
Subject: 
Victim Notification in Epstein 
Alex and Jeff— Jack Goldberger still has not contacted me regarding the Victim Notification list. Today, I 
would like to provide him with a written notification of failure to perform. Should I inform him of Mr. 
Edwards' complaint? Do we have any duty to notify them of the potential need to disclose the deferred 
prosecution agreement in response to that complaint? 
Thank you. 
A. Marie Villafaila 
Assistant U.S. Attorney 
500 S. Australian Ave, Suite 400 
West Palm Beach, FL 33401 
Phone 561 209-1047 
Fax 561 820-8777 
Tracking: 
665 
EFTA00194351

Villafana, Ann Marie C. (USAFLS) 
From: 
Lee, Dexter (USAFLS) 
Sent: 
Tuesday, July 08, 2008 12:09 PM 
To: 
Villafana, Ann Marie C. (USAFLS) 
Subject: 
Factors in Not Disclosing Plea Agreement Terms 
Marie, 
The Attorney General's Guidelines lists several factors in determining whether to notify a victim of a proposed plea 
agreement: 
(3) Proposed Plea Agreements. Responsible officials should make reasonable efforts to notify identified victims of, and 
consider victims' views about, prospective plea negotiations. In determining what is reasonable, the responsible official 
should consider factors relevant to the wisdom and practicality of giving notice and considering views in the context of 
the particular case, including, but not limited to, the following factors: 
(a) The impact on public safety and risks to personal safety. 
(b) The number of victims. 
(c) Whether time is of the essence in negotiating or entering a proposed plea. 
(d) Whether the proposed plea involves confidential information or conditions. 
(e) Whether there is another need for confidentiality. 
(f) Whether the victim is a possible witness in the case and the effect that relaying any information may have on the 
defendant's right to a fair trial. 
When we spoke this morning, you told me that the initial agreement with Epstein was reached in September 2007. 
An 
addendum was negotiated in October 2007. Finally, an additional portion of the agreement was signed in December 
2007. 
Did we consider these, or any other factors, in deciding not to advise the victims of the plea negotiations, which 
appeared to have commenced in mid-2007? Thanks. 
Dexter 
664 
EFTA00194352

Recipient 
Lee, Dexter (USAFLS) 
Read 
Read: 7/8/2008 12:17 PM 
663 
EFTA00194353