This is an FBI investigation document from the Epstein Files collection (FBI VOL00009). Text has been machine-extracted from the original PDF file. Search more documents →
FBI VOL00009
EFTA00190318
446 pages
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UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 08-80736-Civ-MarratIVIatthewman JANE DOE #1 AND JANE DOE #2, Petitioners, UNITED STATES OF AMERICA, Respondent. UNITED STATES' NOTICE OF FILING THIRD SUPPLEMENTAL PRIVILEGE LOG Pursuant to the Court's June 18, 2013 Omnibus Order (DE 190), the Respondent, United States of America, by and through the undersigned Assistant United States Attorney, hereby gives notice of its filing of its Third Supplemental Privilege Log. The index has been marked with Bates Numbers P-014924 thru P-015267. The documents referenced in the Third Supplemental Privilege Log will be delivered tomorrow to the Chambers of U.S. District Judge Kenneth A. Marra for ex parte in camera review, pursuant to the Court's Omnibus Order. Respectfully submitted, WIFREDO A. FERRER UNITED STATES ATTORNEY By: s/A. Marie Villafafia A. MARIE VILLAFAFIA Assistant United States Attorney Florida Bar No. 0018255 500 South Australian Ave, Suite 400 West Palm Beach, FL 33401 Telephone: 561-820-8711 Facsimile: 561-820-8777 ann.marie.c.villafana@usdoj.gov EFTA00190318
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CERTIFICATE OF SERVICE I HEREBY CERTIFY that on August 3, 2015, I electronically filed the foregoing document with the Clerk of the Court using CM/ECF. According to the Court's website, counsel for all parties are able to receive notice via the CM/ECF system. s/A. Marie Viilafafia A. MARIE VILLAFAA Assistant United States Attorney SERVICE LIST Jane Does I and 21. United States, Case No. 08-80736-CIV-MARRA/MATTHEWMAN United States District Court, Southern District of Florida Brad Edwards, Esq., Farmer Jaffe Weissing Edwards Fistos Lehrman 425 N Andrews Ave Ste 2 Fort Lauderdale, FL 33301-3268 brad®pathtojustice.com 954-524-2820 Fax: 954-524-2822 Paul G. Cassell S.J. Quinney College of Law at the University of Utah 332 S. 1400 E. Salt Lake City, Utah 84112 (80 I ) 585-5202 Fax: (801) 585-6833 E-mail: casselp®law.utah.edu Attorneys for Jane Doe # I and Jane Doe # 2 2 EFTA00190319
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Fax 561 820-8777 From: Villafana, Ann Marie C. (USAF! RI Sent: Tuesday, June 24, 2008 4:05 PM To: 'Roy BLACK'; 'Jack Goldberger' Cc: Atkinson, Karen (USAFLS) Subject: Jeffrey Epstein Agreement Dear Roy and Jack: ReAAA ea A I am just writing to re-state that it is cd, binding agreement and that there is no need for further mod Nr4j. Please keep us informed of the date Thank you. 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 EFTA00190320
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Villafana, Ann Marie C. (USAFLS) From: Villafana, Ann Marie C. (USAFLS) <AVillafana@usa.doj.gov> Sent: Wednesday, July 09, 2008 12:35 PM To: Acosta, Alex (USAFLS); Sloman, Jeff (USAFLS); Atkinson, Karen (USAFLS) Cc: Kuyrkendall, E N. (MM) (FBI); Richards, Jason R. (MM) (FBI); Lee, Dexter (USAFLS) Subject: FW: Jeffrey Epstein -- Response from Jack Goldberger Attachments: Letter to A. Marie Villafana dated 070908.pdf Attached please find Jack Goldberger's response to my letter. A. Marie Villafafla Assistant U.S. Attorney 561 209-1047 Original Message From: Nira Alanis [mailto:nalanist anwoa.comi Sent: Wednesday, July 09, 2008 12:28 PM To: Villafana, Ann Marie C. (USAFLS) Subject: Jeffrey Epstein This attachment has been sent to you on behalf of Jack A. Goldberger, Esquire. Regards, Nayanira Alanis, Legal Assistant Atterbury, Goldberger & Weiss, P.A. 250 Australian Avenue South Suite 1400 West Palm Beach, FL 33401 T#561.659-8300 F#561.835-8691 25 EFTA00190321
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ctW'ti corny'% July 9, 2008 A. Marie C. Villafana, Esq. Assistant United States Attorney United States Attorney's Office 500 South Australian Avenue 4th Floor, Suite 400 West Palm Beach, Florida 33401 SENT VIA E-MAIL ct FACSIMILE (561) 820-8777 Re: Jeffrey E. Epstein Dear Ms. Villafana: JOSEPH R.ATTERBURY • t JACK A. GOLDBERGER JASON &WEISS Board Certified Criminal Trial Attorney f Member of New Jersey & Florida Bars Thank you for your letter to me dated July 8, 2008 and the draft document dated, e-mailed and faxed to me at my office on June 30, 2008, styled "Notification of Identified Victims." I would like to address a few related issues. First, please note that we have several requests concerning any such notification. Specifically, we request that: (a) My notification be sent to any individual by mail (or served upon their attorney, to the extent known), and we respectfully object to any service by hand, a method of service which carries the concomitant risk of conversations regarding the notification that potentially would place the federal authorities in a position of being advocates for civil litigation; (b) Any notification be effectuated by a separate mailing to each individual without the inclusion of any language that appeared on the second page of your June 30, 2008 memorandum; i.e. rather than including in each notification a large section listing "identified individuals" with redactions other than the name of the recipient (which we contend would be a clear and impermissible signal to any individual that the notification is a broad notification to numerous other alleged victims). Rather, a simple one page notification directed only to the recipient, and limited to the information currently on the first page of your draft memorandum would suffice. One Clearlake Centre. Suite 1400 250 Australian Avenue South West Palm Beach, FL 33401 p 561.659.8300 f 561.835.8691 wwwagwpa.com EFTA00190322
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(c) You eliminate from any notification any language that is currently contained in the "acknowledgment" section of the June 30, 2008 memorandum; and (d) You supplement the notification with the Government's previously made representation that it is not vouching for the veracity of any claim by any identified individual. See Letter from J. Sloman to E. (10/25/07). Second, please note also that we do not understand your request that Mr. Epstein and his attorneys execute the rider / acknowledgment contained within your June 30 hand-delivered draft. Specifically, we do not believe that the Non-Prosecution Agreement requires Mr. Epstein's execution of any such additional stipulation. Because we want to ensure that Mr. Epstein continues to strictly comply with the letter of the parties' agreement, we respectfully ask that you explain why you believe that the Non-Prosecution Agreement requires execution of your stipulation. Our understanding of the Non-Prosecution Agreement is that it does not require Mr. Epstein to "acknowledge" anything not already contained within the four corners of the written agreement. The agreement certainly contains no written term obligating that he "waive any evidentiary challenge to the introduction of a copy" of any "Notification of Identified Victims" in "any judicial proceeding between any identified individual" and Mr. Epstein, as your memorandum currently requests. Further, please note that your June 30 stipulation, as drafted, is not limited to Section 2255 proceedings. Rather, your June 30 draft requires Mr. Epstein to waive evidentiary challenges in "any judicial proceeding" - - which clearly exceeds the bounds of the parties' written agreement. Third, I would respectfully request that you provide me with the names of the "pro bono lawyers" who, you indicated to me at our June 30 meeting at my office, were intending to represent certain persons identified on your June 30 draft notification, as well as any knowledge that the Government has as to how they were selected, and what communications the Government has had with them to date. Finally, please know that it is Mr. Epstein's firm intent to fulfill strictly each term and condition of his Non-Prosecution Agreement with the Government. Nothing in this letter should be construed, however, as waiving any defense that may be available to Mr. Epstein under the parties' written agreement. I look forward to your response. Until then, I remain, V trul A. Goldberger cc: Jeffrey Epstein EFTA00190323
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From: viiiatana, Ann Marie C. (USAFLS) Sent: Wednesday, November 28, 2007 4:47 PM To: Jay Lefkowitz Cc: Sloman, Jeff (USAFLS); Acosta, Alex (USAFLS) Subject: Epstein: Victim Notification Letter Dear Jay: Jeff asked that I forward the victim notification letter to you. It is attached. Thank you. «Victim Notification Ltr.pdf» A. Marie Villafafia Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 Phone 561 209-1047 Fax 561 820-8777 39 EFTA00190324
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U.S. Department of Justice United States Attorney Southern District of Florida 500 South Australian Ave., Suite 400 West Palm Beach, FL 33401 (561) 8204711 Facsimile: (561) 820-8777 November 29, 2007 DELIVERY BY HAND Miss Re: Crime Victims' Riahts — Notification of Resolution of Epstein Investigation Dear Miss Several months ago, I provided you with a letter notifying you of your rights as a victim pursuant to the Justice for All Act of 2004 and other federal legislation, including: (I) The right to be reasonably protected from the accused. (2) The right to reasonable, accurate, and timely notice of any public court proceeding involving the crime or of any release or escape of the accused. (3) The right not to be excluded from any public court proceeding, unless the court determines that your testimony may be materially altered if you are present for other portions of a proceeding. (4) The right to be reasonably heard at any public proceeding in the district court involving release, plea, or sentencing. (5) The reasonable right to confer with the attorney for the United States in the case. (6) The right to full and timely restitution as provided in law. (7) The right to proceedings free from unreasonable delay. (8) The right to be treated with fairness and with respect for the victim's dignity and privacy. I am writing to inform you that the federal investigation of Jeffrey Epstein has been completed, and Mr. Epstein and the U.S. Attorney's Office have reached an agreement containing the following terms. First, Mr. Epstein agrees that he will plead guilty to two state offenses, including the offense of soliciting minors to engage in prostitution, which will require him to register as a sexual predator for the remainder of his life. EFTA00190325
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MISS
NOVEMBER 29, 2007
PAGE 2
Second, Mr. Epstein has agreed to make a binding recommendation of 18 months'
imprisonment to the state court judge who sentences him. Mr. Epstein will serve that sentence of
imprisonment at the Palm Beach County Jail.
Third, Mr. Epstein has agreed that he will not contest jurisdiction or liability if you elect to
seek damages from him because the United States has identified you as a minor victim of certain
federal offenses, including travel in interstate commerce to engage in prostitution with minors and
the use of facilities of interstate commerce to induce minors to engage in prostitution. To assist you
in making such a claim, the U.S. Attorney's Office has asked an independent Special Master to
select attorneys to represent you. Those attorneys are Aaron Podhurst and Robert ("Bob")
Josefsberg with the law firm of Podhurst Orseck, P.A. They can be reached at (305) 358-2800. 1
anticipate that someone from their law firm will be contacting you shortly. I must also advise you
that you are not obligated to use these attorneys. In fact you have the absolute right to select your
own attorney. so you can decide not to speak with Mssrs. Podhurst/ Josefsberg at all. or you can
speak with them and decide at any time to use a different attorney. Ifyou do decide to seek damages
from Mr. Epstein and you decide to use Messrs. Podhurst / Josefsberg as your attorneys, Mr. Epstein
will be responsible for paying attorney's fees incurred during the time spent trying to negotiate a
settlement. If you are unable to reach a settlement with Mr. Epstein, you and Mr. Josefsberg can
discuss how best to proceed.
As I mentioned above, as part of the resolution of the federal investigation, Mr. Epstein has
agreed to plead guilty to state charges. Mr. Epstein's change of plea and sentencing will occur on
December 14, 2007, at
a.m., before Judge Sandra K. McSorley, in Courtroom 11F at the Palm
Beach County Courthouse, 205 North Dixie Highway, West Palm Beach, Florida. Pursuant to
Florida Statutes Sections 960.001(1)(k) and 921.143(1), you are entitled to be present and to make
a statement under oath. If you choose, you can submit a written statement under oath, which will
be filed by the State Attorney's Office on your behalf. If you elect to prepare a written statement,
it should address the following:
the facts of the case and the extent of any harm, including social, psychological, or
physical harm, financial losses, loss of earnings directly or indirectly resulting from
the crime for which the defendant is being sentenced, and any matter relevant to an
appropriate disposition and sentence. Fl. Stat. 921.143(2).
You also are 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. To receive
such notification, please provide the State Attorney's Office with the following information:
1.
Your name
2.
Your address
3.
Your home, work, and/or cell phone numbers
EFTA00190326
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MISS NOVEMBER 29, 2007 PAGE 3 4. Your e-mail address 5. A notation of whether you would like to participate in the "VINE system," which provides automated notification calls any time an inmate is moved. (To use this system, your calls must go to you directly, not through a switchboard.) Thank you for all of your help during the course of the investigation. If you have any questions or concerns, please do not hesitate to contact me or Special Agent Nesbitt Kuyrkendall at (561) 822-5946. Sincerely, R. Alexander Acosta United States Attorney By: A. Marie Villafana Assistant United States Attorney cc: Special Agent Nesbitt Kuyrkendall, F.B.I. Ms. Clearetha Wright, Victim-Witness Coordinator, U.S. Attorney's Office EFTA00190327
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Villafana, Ann Marie C. (USAFLS) From: Villafana, Ann Marie C. (USAFLS) <AVillafana@usa.doj.gov> Sent: Tuesday, June 24, 2008 2:02 PM To: Jack Goldberger Cc: Atkinson, Karen (USAFLS) Subject: RE: Jeffrey Epstein Jack, Karen and I will call you at 3:30. Should we call 659-8300? And what number should we use for Roy? Thank you. A. Marie Villafalia Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Reach, FL 33401 Phone 561 209-1047 Fax 561 820-8777 From: Jack Goldberger [mailto:jgoldberger@agwpa.com] Sent: Tuesday, June 24, 2008 1:32 PM To: Villafana, Ann Marie C. (USAFLS) Subject: RE: Jeffrey Epstein I'm ok with 3;30 please conference me into the call Jack From: Villafana, Ann Marie C. (USAFLS) [malito:Ann.Marie.C.Villafana@usdoj.govj Sent: Tuesday, June 24, 2008 12:23 PM To: RBlack@RoyBlack.com Cc: Atkinson, Karen (USAFLS) Subject: FW: Jeffrey Epstein Dear Roy: Jeff Sloman contacted me and asked me to return your call regarding the Epstein matter. I am forwarding to you an e-mail that I sent to Jay Lefkowitz last night. Karen and I can call you at 3:30 to speak about your list of issues. If that time does not work, please let me know what times you are available. Thank you. A. Marie I/alfalfa Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 76 EFTA00190328
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West Palm Beach, FL 33401 Phone 561 209-1047 Fax 561 820-8777 From: Villafana, Ann Marie C. (USAFLS) Sent: Monday, June 23, 2008 5:55 PM To: lefkowitz@kirkland.com; Jay Lefkowitz Cc: Atkinson, Karen (USAFLS) Subject: Jeffrey Epstein Dear Mr. Lefkowitz: 1 understand that the Deputy Attorney General has completed his review of the Epstein matter and has determined that federal prosecution of Mr. Epstein's case is appropriate. Accordingly, Mr. Epstein has until the close of business on Monday, June 30, 2008, to comply with the terms and conditions of the agreement between the United States and Mr. Epstein (as modified by the U.S. Attorney's December 19th letter to Ms. Sanchez), including entry of a guilty plea, sentencing, and surrendering to begin his sentence of imprisonment. If you have any questions, please feel free to contact me at the number shown below. A. Marie Villafafla Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 Phone 561 209-1047 Fax 561 820-8777 77 EFTA00190329
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Villafana, Ann Marie C. (USAFLS) From: Villafana, Ann Marie C. (USAFLS) <AVillafanagusa.dolgov> Sent: Tuesday, June 24, 2008 12:23 PM To: REtlack@Royelack.com Cc: Atkinson, Karen (USAFLS) Subject FW: Jeffrey Epstein Dear Roy: Jeff Sloman contacted me and asked me to return your call regarding the Epstein matter. I am forwarding to you an e-mail that I sent to Jay Lefkowitz last night. Karen and I can call you at 3:30 to speak about your list of issues. If that time does not work, please let me know what times you are available. Thank you. 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, June 23, 2008 5:55 PM To: lefkowitz@kirkland.com; Jay Lefkowitz Cc: Atkinson, Karen (USAFLS) Subject: Jeffrey Epstein Dear Mr. Lefkowitz: I understand that the Deputy Attorney General has completed his review of the Epstein matter and has determined that federal prosecution of Mr. Epstein's case is appropriate. Accordingly, Mr. Epstein has until the close of business on Monday, June 30, 2008, to comply with the terms and conditions of the agreement between the United States and Mr. Epstein (as modified by the U.S. Attorney's December 19'h letter to Ms. Sanchez), including entry of a guilty plea, sentencing, and surrendering to begin his sentence of imprisonment. If you have any questions, please feel free to contact me at the number shown below. A. Marie Villafana 81 EFTA00190330
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Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 Phone 561 209-1047 Fax 561 820-8777 82 EFTA00190331
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Villafana, Ann Marie C. (USAFLS) From: Jack Goldberger <jgoldberger@agwpa.com> Sent: Tuesday, June 24, 2008 1:32 PM To: Villafana, Ann Marie C. (USAFLS) Subject: RE: Jeffrey Epstein I'm ok with 3;30 please conference me into the call Jack From: Villafana, Ann Marie C. (USAFLS) (mailto:Ann.Marle.C.Villafana@usdoj.gov] Sent: Tuesday, June 24, 2008 12:23 PM To: RBlack@RoyBlack.com Cc: Atkinson, Karen (USAFLS) Subject: FW: Jeffrey Epstein Dear Roy: Jeff Sloman contacted me and asked me to return your call regarding the Epstein matter. I am forwarding to you an e-mail that I sent to Jay Lefkowitz last night. Karen and I can call you at 3:30 to speak about your list of issues. If that time does not work, please let me know what times you are available. Thank you. 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, June 23, 2008 5:55 PM To: lefkowitz@kirkland.com; Jay Lefkowitz Cc: Atkinson, Karen (USAFLS) Subject: Jeffrey Epstein Dear Mr. Lefkowitz: I understand that the Deputy Attorney General has completed his review of the Epstein matter and has determined that federal prosecution of Mr. Epstein's case is appropriate. 83 EFTA00190332
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Accordingly, Mr. Epstein has until the close of business on Monday, June 30, 2008, to comply with the terms and conditions of the agreement between the United States and Mr. Epstein (as modified by the U.S. Attorney's December 10 letter to Ms. Sanchez), including entry of a guilty plea, sentencing, and surrendering to begin his sentence of imprisonment. If you have any questions, please feel free to contact me at the number shown below. 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 84 EFTA00190333
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Villafana, Ann Marie C. (USAFLS) From: Roy BLACK <RBLACK@royblack.com> Sent: Tuesday, June 24, 2008 3:02 PM To: Villafana, Ann Marie C. (USAFLS) Cc: jack goldberger Subject: Re: FW: Jeffrey Epstein Marie that is a good time. I also want to conference Jack Goldberger into the call. This will be a wrap up call. Roy >>> "Villafana, Ann Marie C. (USAFLS)" <Ann.Marie.C.Villafana@usdoj.gov> 6/24/2008 12:23 PM >>> Dear Roy: Jeff Sloman contacted me and asked me to return your call regarding the Epstein matter. I am forwarding to you an e-mail that I sent to Jay Lefkowitz last night. Karen and I can call you at 3:30 to speak about your list of issues. If that time does not work, please let me know what times you are available. 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 From: Villafana, Ann Marie C. (USAFLS) Sent: Monday, June 23, 2008 5:55 PM To: letkowitz@kirkland.com; Jay Lefkowitz Cc: Atkinson, Karen (USAFLS) Subject: Jeffrey Epstein Dear Mr. Lefkowitz: I understand that the Deputy Attorney General has completed his review of the Epstein matter and has dctcnnincd that federal prosecution of Mr. Epstein's case is appropriate. Accordingly, Mr. Epstein has until the close of business on Monday, June 30, 2008, to comply with the terms and conditions of the agreement between the United States and Mr. Epstein (as modified by the U.S. Attorney's December 19th letter to Ms. Sanchez), including entry of a guilty plea, sentencing, and surrendering to begin his sentence of imprisonment. If you have any questions, please feel free to contact me at the number shown below. 85 EFTA00190334
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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 86 EFTA00190335
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Villafana, Ann Marie C. (USAFLS) From: Villafana, Ann Marie C. (USAFLS) <AVillafana@usa.doj.gov> Sent: Tuesday, June 24, 2008 3:08 PM To: Roy BLACK Subject: RE: FW: Jeffrey Epstein Iii Roy -- Is this the best number to call? (305) 371-6421 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: Roy BLACK [mailto:RBLACKerovblack.comi Sent: Tuesday, June 24, 2008 3:02 PM To: Villafana, Ann Marie C. (USAFLS) Cc: jack goldberger Subject: Re: FW: Jeffrey Epstein Marie that is a good time. I also want to conference Jack Goldberger into the call. This will be a wrap up call. Roy >>> "Villafana, Ann Marie C. (USAFLS)" <Ann.Maric.C.Villafana@usdoj.gov> 6/24/2008 12:23 PM >>> Dear Roy: Jeff Sloman contacted me and asked me to return your call regarding the Epstein matter. I am forwarding to you an e-mail that I sent to Jay Lcfkowitz last night. Karen and I can call you at 3:30 to speak about your list of issues. If that time does not work, please let me know what times you are available. Thank you. 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, June 23,2008 5:55 PM To: letkowitz@kirk land.com; Jay Lefkowitz Cc: Atkinson, Karen (USAFLS) Subject: Jeffrey Epstein 87 EFTA00190336
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Dear Mr. Leflcowitz: I understand that the Deputy Attorney General has completed his review of the Epstein matter and has determined that federal prosecution of Mr. Epstein's case is appropriate. Accordingly, Mr. Epstein has until the close of business on Monday, June 30, 2008, to comply with the terms and conditions of the agreement between the United States and Mr. Epstein (as modified by the U.S. Attorney's December 19th letter to Ms. Sanchez), including entry of a guilty plea, sentencing, and surrendering to begin his sentence of imprisonment. If you have any questions, please feel free to contact me at the number shown below. A. Marie Villafatha Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 Phone 561 209-1047 Fax 561 820-8777 88 EFTA00190337
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