EFTA00190318

Villafana, Ann Marie C. (USAFLS) 
From: 
Sloman, Jeff (USAFLS) <JSloman@usa.doj.gov> 
Sent: 
Monday, July 21, 2008 3:52 PM 
To: 
Villafana, Ann Marie C. (USAFLS) 
Cc: 
Senior, Robert (USAFLS) 
Subject: 
RE: Epstein 
Li 
I don't think it's necessary to point out the NY Post article to those victims and in the next breath say that 
Rubenstein's statement contradicts the agreement. I think our notice to them should give them some comfort 
over a tabloid story. 
From: Villafana, Ann Marie C. (USAFLS) 
Sent: Monday, July 21, 2008 3:47 PM 
To: Sloman, Jeff (USAFLS); Atkinson, Karen (USAFLS); Lee, Dexter (USAFLS) 
Cc: Kuyrkendall, E N. (FBI); Richards, Jason R. (FBI) 
Subject: Epstein 
Well, our friend Jack Goldberger (probably really Mike Tein) is trying to be very smart. 
They have filed a Motion for Return of Property in State Court. The State Attorney will, no doubt, file a 
response saying, "we don't have it, the FBI took it pursuant to a federal grand jury subpoena." Then, Epstein's 
folks will either file that response in federal court to show that the federal criminal action is still pending or they 
will file a motion for return of property in federal court and when we say, "no," then they will claim that the 
federal criminal action is still pending. 
I plan to ignore it for now. 
On another note, I plan to send copies of II more victim notifications to Goldberger today. These girls 
currently arc unrepresented. I have redacted their addresses and intend to state in the cover letter that the 
victims will initiate contact when and if they decide to file a claim. Should I include anything about how Mr. 
Rubenstein's statement to the New York Post directly contradicts Epstein's agreement? 
Epstein's rep, Howard Ruben stein, said, "The lawsuit has absolutely no merit. They're just looking for money. These 
women have lied repeatedly, and in no way shape or form were they victims. They were at his place freely and 
voluntarily. And one of them showed Epstein a fake ID." 
A. Marie Villafillia 
Assistant U.S. Attorney 
500 S. Australian Ave, Suite 400 
West Palm Beach, FL 33401 
Phone 561 209-1047 
Fax 561 820-8777 
251 
EFTA00190578

Villafana, Ann Marie C. (USAFLS) 
From: 
Villafana, Ann Marie C. (USAFLS) <AVillafana@usa.doj.goy> 
Sent: 
Monday, July 21, 2008 3:53 PM 
To: 
Sloman, Jeff (USAFLS) 
Cc: 
Senior, Robert (USAFLS) 
Subject: 
RE: Epstein 
Ili Jeff— Sorry, I wasn't clear. The notice to the victims doesnit say anything about the story. it is just the 
standard notification letter. Goldberger gets a copy of all the letters and I wondered whether, in my cover letter 
to him, I should say something. 
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 
From: Sloman, Jeff (USAFLS) 
Sent: Monday, July 21, 2008 3:52 PM 
To: Villafana, Ann Marie C. (USAFLS) 
Cc: Senior, Robert (USAFLS) 
Subject: RE: Epstein 
I don't think it's necessary to point out the NY Post article to those victims and in the next breath say that 
Rubenstein's statement contradicts the agreement. I think our notice to them should give them some comfort 
over a tabloid story. 
From: Villafana, Ann Marie C. (USAFLS) 
Sent: Monday, July 21, 2008 3:47 PM 
To: Sloman, Jeff (USAFLS); Atkinson, Karen (USAFLS); Lee, Dexter (USAFLS) 
Cc: Kuyrkendall, E N. (FBI); Richards, Jason R. (FBI) 
Subject: Epstein 
Well, our friend Jack Goldberger (probably really Mike Tein) is trying to be very smart. 
They have filed a Motion for Return of Property in State Court. The State Attorney will, no doubt, file a 
response saying, "we don't have it, the FBI took it pursuant to a federal grand jury subpoena." Then, Epstein's 
folks will either file that response in federal court to show that the federal criminal action is still pending or they 
will file a motion for return of property in federal court and when we say, "no," then they will claim that the 
federal criminal action is still pending. 
252 
EFTA00190579

I plan to ignore it for now. 
On another note, 1 plan to send copies of I I more victim notifications to Goldberger today. These girls 
currently are unrepresented. I have redacted their addresses and intend to state in the cover letter that the 
victims will initiate contact when and if they decide to file a claim. Should I include anything about how Mr. 
Rubenstein's statement to the New York Post directly contradicts Epstein's agreement? 
Epstein's rep, Howard Ruben stein, said, 'The lawsuit has absolutely no merit. They're just looking for money. These 
women have lied repeatedly, and in no way shape or form were they victims. They were at his place freely and 
voluntarily. And one of them showed Epstein a fake ID." 
A. Marie Villalafia 
Assistant U.S. Attorney 
500 S. Australian Ave, Suite 400 
West Palm Beach, FL 33401 
Phone 561 209-1047 
Fax 561 820-8777 
253 
EFTA00190580

Villafana, Ann Marie C. (USAFLS) 
•••••••••
•••1 
From: 
Villafana, Ann Marie C. (USAFLS) <AVillafana@usa.doj.gov> 
Sent: 
Tuesday, July 22, 2008 9:30 AM 
(I
°
To: 
Acosta, Alex (USAFLS); Sloman, Jeff (USAFLS); Senior, Robert (USAFLS); Atkinson. Ktirep 
(USAFLS) 
Cc: 
Kuyrkendall, E N. (MM) (FBI); Richards, Jason R. (MM) (FBI) 
Subject: 
Letter from Michael Tein 
Attachments: 
080721 Tein Ltr to Villafana.pdf 
Good morning: 
Mike Tein faxed the following letter to our office at 6:30 last night. It shows that Alex received a copy, but I 
thought I should scan and share with all of you. Tein claims that it is his "ethical duty" to stay the civil 
litigation. What I don't understand is how Epstein can perform his contractual obligations with respect to the 
victim litigation if he intends to stay all litigation until the agreement is fully performed. Indicting him would 
make our lives so much easier. The Jane Doc suit against us would become moot, we now have a guilty plea 
that can be used against Mr. Epstein, and if they try to raise the civil suits to impeach our witnesses, we can 
bring in the fact that he promised to pay them and then reneged. 
Please advise how you would like to proceed. 
«080721 Tein Ltr to Villefana.pdf» 
A. Marie Villafidia 
Assistant U.S. Attorney 
500 S. Australian Ave, Suite 400 
West Palm Beach, FL 33401 
Phone 561 209-1047 
Fax 561 820-8777 
254 
EFTA00190581

From. FAXmaker 
To. 15618208777 
Page: 2/2 
Date: 7/21/2008 6:38:17 PM 
L EW 
is 
 
TOR N EYTA  • L 
PL
July 21, 2008 
Copy via facsimile (561) 820-8777 
Ann Marie C. Villafana, Esq. 
Office of the United States Attorney 
500 S. Australian Avenue 
West Palm Beach, Florida 33401 
RE: 
Jeffrey Epstein 
Dear Ms. Villafana: 
Thank you for your letter of July 17, 2008. In it, you ask whether Mr. Epstein "intends to fully 
abide by the Non-Prosecution Agreement." The answer is yes. 
We confirm as you state in your letter that the Agreement requires that "the federal Grand Jury 
investigation will remain suspended, and all pending federal Grand Jury subpoenas will be held 
in abeyance unless and until [Mr.' Epstein] violates any term of [the Non-Prosecution 
Agreement]." We also confirm that under the Agreement, "prosecution in this District for these 
offenses shall be deferred in favor of prosecution by the State of Florida, provided that Epstein 
abides by the . . . conditions and the requirements of th[e] Agreement." 
As you know, there is no provision in the Agreement referring in any way to Section 3509(k). 
By that statute, Congress imposed a mandatory obligation on federal district courts to stay 
certain civil cases. Its operation is not subject to the control or discretion of any party. Whether 
Title 18, United States Code, Section 3509(k) applies to this civil litigation is a question of law 
for resolution by Judge Marra. Accordingly, we are abiding by our ethical obligation to advise 
the Court of its statutory mandate under Section 3509(k). 
Finally, thank you for notifying me that our motion to quash technically remains outstanding, 
We had previously notified the Court that the parties did not wish to argue the issue. I agree that 
the Agreement requires Its withdrawal and we will file a formal notice withdrawing it this week. 
Please do not hesitate to call me If you wish fkuther clarification of our position or to discuss this 
matter in any way. Until then, I remain, 
Very truly yours, 
• 
Michael R. Tein 
cc: 
Jack Goldberger, Esq. 
Roy Black, Esq. 
Alex Acosta, Esq. 
3055 GRAND AVENUE • 51.JITC 340 • COCONUT OPIOVL, FLORIDA 33133 
TELEPHONE (305) 442-1101 . PACUIMILC (305) 442.6744. 
VNAV.I.CWISTEIN.COM 
Thls fax was sent with OFI FAXmaker tax server. For more intonnetion, visit http://www.gti.corn 
EFTA00190582

From. FAXmaxer 
lo: 1O010,Watt/ 
rags: 114 
watt ti4itzwo 
rm 
Lewis Tein PL 
ATTORNEYS AT LAW 
FACSIMILE TRANSMISSION 
RECIPIENT: Ann Marie C. Villafana, Esq. 
RECIPIENT'S FAX NUMBER: 
(561) 820-8777 
SENDER: 
Michael R. Teln, Esq. 
DATE: 
July 21, 2008 
PAGES (including cover sheet): 2 
COMMENTS: 
IF THE READER OF THIS MESSAGE IS NOT THE INTENDED RECIPIENT. YOU ARE HEREBY NOTIFIED THAT ANY DISSEMINATION. 
DISTRIBUTION OR COPYING OF THIS COMMUNICATION IS STRICTLY PROHIBITED. IF YOU HAVE RECEIVED THIS FACSIMILE IN 
ERROR. PLEASE NOTIFY VS BY TELEPHONE AND RETURN THE ORIGINAL BY MAIL AT THE BELOW ADDRESS. THANK YOU. 
LEWIS TEN, P.L. • 305S GRAND AVENUE • SUIT! 340. COCONUT GROVE, FLORIDA 33133 
TELEPHONE (305) 442-1101 • FACSIMILE (303) 442471 • WWW.LEWISTEN.COM 
This fax was sent with GFI FAXmakor fax server. For more Information, visa. http://www.on.com 
EFTA00190583

Villafana, Ann Marie C. (USAFLS) 
From: 
Acosta, Alex (USAFLS) <AAcosta@usa.doj.gov> 
Sent: 
Tuesday, July 22, 2008 10:29 AM 
To: 
Villafana, Ann Marie C. (USAFLS); Sloman, Jeff (USAFLS); Senior, Robert (USAFLS); 
Atkinson, Karen (USAFLS) 
Cc: 
Kuyrkendall, E N. (MM) (FBI); Richards, Jason R. (MM) (FBI) 
Subject: 
Re: Letter from Michael Tein 
What is your proposal? 
 
Original Message 
From: Villafana, Ann Marie C. (USAFLS) 
To: Acosta, Alex (USAFLS); Sloman, Jeff (USAFLS); Senior, Robert (USAFLS); Atkinson, Karen (USAFLS) 
Cc: Kuyrkendall, E N. (FBI); Richards, Jason R. (FBI) 
Sent: Tue Jul 22 09:29:37 2008 
Subject: Letter from Michael Tcin 
Good morning: 
Mike rein faxed the following letter to our office at 6:30 last night. It shows that Alex received a copy, but I thought I should scan 
and share with all of you. Tein claims that it is his "ethical duty" to stay the civil litigation. What I don't understand is how Epstein 
can perform his contractual obligations with respect to the victim litigation if he intends to stay all litigation until the agreement is 
fully performed. Indicting him would make our lives so much easier. The Jane Doe suit against us would become moot, we now have 
a guilty plea that can be used against Mr. Epstein, and if they try to raise the civil suits to impeach our witnesses, we can bring in the 
fact that he promised to pay them and then reneged. 
Please advise how you would like to proceed. 
<<080721 Tein Itr to Villafana.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 
255 
EFTA00190584

Villafana, Ann Marie C. (USAFLS) 
From: 
Villafana, Ann Marie C. (USAFLS) <AVillafana@usa.doj.gov> 
Sent: 
Tuesday, July 22, 2008 10:35 AM 
To: 
Acosta, Alex (USAFLS); Sloman, Jeff (USAFLS); Senior, Robert (USAFLS); Atkinson, Karen 
(USAFLS) 
Cc: 
Kuyrkendall, E N. (MM) (FBI); Richards, Jason R. (MM) (FBI) 
Subject: 
RE: Letter from Michael Tein 
Right now I am digesting something filed in a new federal civil lawsuit against Epstein. Bruce Reinhart is listed as counsel of record 
for Sarah Kellen, and a deposition transcript attached to the removal petition includes questions from Mike rein to 
G. implying 
that Jeff and I both went to her house and promised her compensation after the end of the criminal case. 
Karen and I put a call in to Dexter about the Bruce issue and we are waiting to hear back. 
I recommend sending a letter telling them that their position makes it impossible for Mr. Epstein to fully perform his contractual 
obligations and that, coupled with Mr. Rubinstein's denial that C.W. was a victim, places them in breach of the agreement and we 
intend to proceed. 
We may want to use that opportunity to put them on notice that Bruce Reinhart cannot represent Ms. Kellen in connection with the 
criminal litigation. 
A. Marie Villafafta 
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: Acosta, Alex (USAFLS) 
Sent: Tuesday, July 22, 2008 10:29 AM 
To: Villafana, Ann Marie C. (USAFLS); Sloman, JetT(USAFLS); Senior, Robert (USAFLS); Atkinson, Karen (USAFLS) 
Cc: Kuyrkendall, E N. (FBI); Richards, Jason R. (FBI) 
Subject: Re: Letter from Michael Tein 
What is your proposal? 
 
Original Message 
From: Villafana, Ann Marie C. (USAFLS) 
To: Acosta, Alex (USAFLS); Sloman, Jeff (USAFLS); Senior, Robert (USAFLS); Atkinson, Karen (USAFLS) 
Cc: Kuyrkendall, E N. (FBI); Richards, Jason R. (FBI) 
Sent: Tue Jul 22 09:29:37 2008 
Subject: Letter from Michael Tein 
Good morning: 
Mike Tein faxed the following letter to our office at 6:30 last night. It shows that Alex received a copy, but I thought I should scan 
and share with all of you. Tein claims that it is his "ethical duty" to stay the civil litigation. What I don't understand is how Epstein 
can perform his contractual obligations with respect to the victim litigation if he intends to stay all litigation until the agreement is 
fully performed. Indicting him would make our lives so much easier. The Jane Doe suit against us would become moot, we now have 
a guilty plea that can be used against Mr. Epstein, and if they try to raise the civil suits to impeach our witnesses, we can bring in the 
fact that he promised to pay them and then reneged. 
Please advise how you would like to proceed. 
256 
EFTA00190585

«080721 Tein Ltr to Villafana.pdf>> 
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 
257 
EFTA00190586

Villafana, Ann Marie C. (USAFLS) 
From: 
Kuyrkendall, E N. (FBI) <E.KuyticendallOicibi.gov> 
Sent: 
Tuesday, July 22, 2008 3:05 PM 
To: 
Villafana, Ann Marie C (USAFLS) 
Subject: 
Re: 
Bogota- ALAT Robert Falero. 
Sydney - ALAT Matthew Witt. 
--- Original Message --
From: Villafana, Ann Marie C. (USAFLS) <Ann.Marie.C.Villafana®usdoj.gov> 
To: Kuyrkendall, E N. 
Sent: Tue Jul 22 15:01:29 2008 
Subject: RE: 
Actually, do you have the names of the LegAtts? 
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 
---Original Message---
From: Kuyrkendall, E N. (FBI) 
Sent: Tuesday, July 22, 2008 2:58 PM 
To: Villafana, Ann Marie C. (USAFLS) 
Subject: Re: 
Leave them unaddressed they will be hand delivered with Twiler's. 
--- Original Message 
From: Villafana, Ann Marie C. (USAFLS) <Ann.Marie.C.Villafana®usdoj.gov> 
To: Kuyrkendall, E N. 
Sent: The Jul 22 14:57:45 2008 
Subject: RE: 
Hey Nesbitt — What addresses should I put on Shasdy's and 
letters? 
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 
From: Kuyrkendall, E N. (FBI) 
711 
265 
EFTA00190587

Sent: 'Tuesday, July 22, 2008 12:28 PM 
To: Villafana, Ann Marie C. (USAFLS) 
Subject: 
Marie, 
Hey take a deep breath!!!! tt I had not read your latest email or Tein's letter. I'm speechless but we must deal with only one issue at a 
lime. We need to, as u say, digest and disect. As I write this, the pain in my gut intensifies. I hope it is only something I ate and not 
an ulcer from Epstein. Anyways, take a deep breathlttl I! 
Our legal has located what we believe to be a good address for Shasdy. I need to come by and get her letter from you so it can be 
included with the lead to Bogata. 
■ 
address is: 13373 Windsong Way, Carrollton, Va 23314 (561)306-9970 
Let me know what lime to come by and also dont hestitate to call if you need something done. Hang in there(THIS IS 
cRAzyptuittninittnnitt
Nesbitt 
266 
EFTA00190588

Villafana, Ann Marie C. (USAFLS) 
From: 
Senior, Robert (USAFLS) <RSenior@usa.doj.gov> 
Sent: 
Tuesday, July 22, 2008 3:47 PM 
To: 
Villafana, Ann Marie C. (USAFLS) 
Subject: 
RE: Emailing: 080722 Tein Ltr.wpd 
Hate to be a pain but I was thinking more along these lines. I don't know the details and would quote from the agreement and 
pleadings, etc. 
Dcar 
I. The agreement called for you to go to jail for x months and to compensate the victims as though you had been convicted of x 
federal law. You agreed to accept a list of the victims that you were to compensate at the time of the change of plea (?). A list was 
provided to you so that you could compensate victims on x date. (I would quote this from the agreement) 
2. Recently, one (more ?) of the designated victims sought relief pursuant to this agreement. In response, Mr. Epstein sought a stay of 
those proceedings based on the fact that an ongoing federal investigation exists. This argument was forwarded despite the 
aforementioned agreement where the USA° has agreed to not prosecute Epstein if he complies with the terms of the agreement. 
3. The portion of the agreement concerning compensation to victims is extremely material to the agreement and is not being honored 
by Epstein. This breech of the agreement is material. (you've done this paragraph already in par. 4 of your letter. 
4. I would end it by quoting from the agreement something along the lines that any material breech of the contract permits us to indict 
(is there something that says that ?) 
Call me. 
Bob 
 
Original Message 
From: Villafana, Ann Marie C. (USAFLS) 
Sent: Tuesday, July 22, 2008 2:41 PM 
To: Senior, Robert (USAFLS) 
Cc: Kuyrkendall, E N. (FBI); Richards, Jason R. (FBI); Atkinson, Karen (USAFLS) 
Subject: Emailing: 080722 Tein Ltr.wpd 
Hi Bob -- Here is my dm0. I thought you should review before it goes to Alex. Thanks. 
The message is ready to be sent with the following file or link attachments: 
080722 Tein Ltr.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. 
267 
EFTA00190589

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) 8204777 
July 22, 2008 
VIA FACSIMILE 
Michael R. Tein, Esq. 
Lewis Tein, P.L. 
3059 Grand Avenue, Suite 340 
Coconut Grove, FL 33133 
Re: 
Jeffrey Epstein 
Dear Mr. Tein: 
In response to your letter of July 21, 2008, the United States hereby provides 
notice that the United States Attorney has determined, based upon reliable evidence, that, 
during the period of the Non-Prosecution Agreement, Jeffrey Epstein has willfully 
violated the conditions of the Agreement. 
In particular, Epstein has repeatedly denied that the victims named by the United 
States are not victims of an enumerated offense contained in Title 18, United States Code, 
Section 2255, and has attempted to stop those victims from pursuing their claims under 
that statute. For example, just yesterday, Epstein's publicist, speaking of behalf of 
Epstein, made the following statement re arding the suit brought against the United 
States by 
R., 
M., and 
W.: 
The lawsuit has absolutely no merit. They're just looking for money. These 
women have lied repeatedly, and in no way shape or form were they 
victims. They were at his place freely and voluntarily. And one of them 
showed Epstein a fake ID. 
(July 21, 2008 New York Post article, entitled "Bid to Burn Epstein Plea," found at 
www.nvpost.com/seven/07212008/gossip/pagesix/bid_to_burri_epstein_plea_ I 20770.htm 
.) 
W. and 
R. are both listed in the United States' July 10, 2008 
"Final Notification of Identified Victims." Mr. Epstein was given more than a week to 
EFTA00190590

M ICI !AEI. R. TIN, ESQ. 
JULY 22, 2008 
PAGE 2 
object to the names on the list and chose not to make any objections. Accordingly, 
pursuant to the terms of the Non-Prosecution A reement as modified, Mr. Epstein and all 
of his representatives are required to treat 
and 
as "victims of an 
enumerated offense." 
Furthermore, Mr. Epstein is frustrating the purpose of the Agreement with respect 
to the victims' ability to obtain damages. Epstein's waiver of liability regarding civil 
suits brought pursuant to 18 U.S.C. § 2255 was a key piece of consideration for the 
United States' willingness to defer its prosecution to the State of Florida. To complete 
his performance of his contractual obligations, Mr. Epstein must submit to suit under 18 
U.S.C. § 2255 and admit that the Identified Victims are victims of an offense enumerated 
in that section. By seeking to stay all civil litigation, during what you assert is the term 
of the Non-Prosecution Agreement, Mr. Epstein is avoiding that essential contractual 
term. 
Accordingly, the United States Attorney's Office hereby provides notice of Mr. 
Epstein's breach of the Non-Prosecution Agreement. 
Sincerely, 
R. Alexander Acosta 
United States Attorney 
By: 
A. Marie VillafaRa 
Assistant United States Attorney 
cc: 
Karen Atkinson, Esq. 
EFTA00190591

Villafana, Ann Marie C. (USAFLS) 
From: 
Villafana, Ann Marie C. (USAFLS) <AVillafana@usa.doj.gov> 
Sent: 
Tuesday, July 22, 2008 3:57 PM 
To: 
Senior, Robert (USAFLS) 
Subject: 
RE: Emailing: 080722 Tein Ltr.wpd 
Part of the problem, Bob, is that Alex took it upon himself to modify that part of the agreement related to compensation, so it no 
longer has any teeth. 1 will give it a go and send it back to you. 
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 
 
Original Message 
From: Senior, Robert (USAFLS) 
Sent: Tuesday, July 22, 2008 3:47 PM 
To: Villafana, Ann Marie C. (USAFLS) 
Subject: RE: Emailing: 080722 Tein Ltr.wpd 
Hate to be a pain but I was thinking more along these lines. I don't know the details and would quote from the agreement and 
pleadings, etc. 
Dear Tein, 
I. The agreement called for you to go to jail for x months and to compensate the victims as though you had been convicted of x 
federal law. You agreed to accept a list of the victims that you were to compensate at the time of the change of plea (?). A list was 
provided to you so that you could compensate victims on x date. (I would quote this from the agreement) 
2. Recently, one (more ?) of the designated victims sought relief pursuant to this agreement. In response, Mr. Epstein sought a stay of 
those proceedings based on the fact that an ongoing federal investigation exists. This argument was forwarded despite the 
aforementioned agreement where the USAO has agreed to not prosecute Epstein if he complies with the terms of the agreement. 
3. The portion of the agreement concerning compensation to victims is extremely material to the agreement and is not being honored 
by Epstein. This breech of the agreement is material. (you've done this paragraph already in par. 4 of your letter. 
4. I would end it by quoting from the agreement something along the lines that any material breech of the contract permits us to indict 
(is there something that says that ?) 
Call me. 
Bob 
 
Original Message 
From: Villafana, Ann Marie C. (USAFLS) 
Sent: Tuesday, July 22, 2008 2:41 PM 
To: Senior, Robert (USAFLS) 
268 
EFTA00190592

Cc: Kuyrkendall, E N. (FBI); Richards, Jason R. (FBI); Atkinson, Karen (USAFLS) 
Subject: Emailing: 080722 Tein Ltr.wpd 
Hi Bob -- Here is my draft. I thought you should review before it goes to Alex. Thanks. 
The message is ready to be sent with the following file or link attachments: 
080722 Tein Ltr.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. 
269 
EFTA00190593

Villafana, Ann Marie C. (USAFLS) 
From: 
Villafana, Ann Marie C. (USAFLS) <AVillafana@usa.doj.gov> 
Sent: 
Wednesday, July 23, 2008 2:32 PM 
To: 
Lee, Dexter (USAFLS) 
Subject: 
RE: Draft Letter to Brad Edwards 
Hi Dexter -- I like it. Just so you know, Bob, Jeff, and I all think that we should give notice of breach to 
Epstein's counsel and indict Epstein. We are waiting for Alex's approval. If that were to happen, it obviously 
would moot the Jane Doe case. I will keep you posted. 
A. Marie Villafana 
Assistant U.S. Attorney 
561 209- I 047 
From: Lee, Dexter (USAFIS) 
Sent: Wednesday, July 23, 2008 1:12 PM 
To: Acosta, Alex (USAFLS); Sloman, Jeff (USAFLS) 
Cc: Villafana, Ann Marie C. (USAFLS); Jacobus, Wendy (USAFLS) 
Subject: Draft Letter to Brad Edwards 
Alex and Jeff, 
Attached please find a draft letter responding to Brad Edwards' July 17, 2008 letter, regarding a stipulation 
regarding agreed facts in our case. Please feel free to make any changes. Thanks. 
Dexter 
270 
EFTA00190594

Villafana, Ann Marie C. (USAFLS) 
From: 
Villafana, Ann Marie C. (USAFLS) <AVillafanatgusa.doj.gov> 
Sent: 
Friday, July 25, 2008 2:11 PM 
To: 
Atkinson, Karen (USAFLS) 
Subject: 
Re: Epstein 
Hi karen. They are 18 use 2422, 2423, 371, 1581 
Good luck. No pink birds but we are having a great lime. 
---- Original Message ----
From: Atkinson, Karen (USAFLS) 
To: Villafana, Ann Marie C. (USAFLS) 
Sent: Fri Jul 25 10:34:12 2008 
Subject Epstein 
33 
We are moving (finally) to extend the grand jury. Can you email the main statutes that are in the proposed indictment with everything 
packed(inctuding my brain) I don't remember. We are filing it today. Did you see the pink birds???? K 
274 
EFTA00190595

Villafana, Ann Marie C. (USAFLS) 
From: 
Villafana, Ann Marie C. (USAFLS) <AVillafana@usa.doj.gov> 
Sent: 
Saturday, August 02, 2008 5:34 PM 
To: 
villafana@hotmail.com 
Subject: 
Fw: Jane Doe Litigation 
Attachments: 
19_pits_resp_g0v_n0tite.pdf 
-- Original Message ---
From: Lee, Dexter (USAFLS) 
To: Acosta, Alex (USAFLS); Sloman, Jeff (USAFLS) 
Cc: Villafana, Ann Marie C. (USAFLS); Jacobus, Wendy (USAFLS) 
Sent: Fri Aug 01 15:53:49 2008 
Subject: Jane Doe Litigation 
Alex and Jeff, 
On Tuesday evening, July 29, I filed with the Court our notice advising that the government did not believe an evidentiary hearing was 
necessary, since there were only two facts which were relevant: (1) no federal charges in S.D.Fla. against Jeffrey Epstein; and (2) 
Epstein plead guilty to state charges on June 30, 2008, was sentenced, and is in jail in Palm Beach County. 
On Wednesday, I received an urgent phone message from Brad Edwards, counsel for the victims. He said he needed to speak with 
me to determine if this matter couldn't be resolved without a hearing or further intervention from the Court. When I called him back, 
Edwards told me he had obtained a copy of the state court plea bargain, and realized Epstein was going to be on probation after his 
incarceration was completed. Edwards understood that, if Epstein violated his probation, that could be a basis for further charges 
against Epstein. The tenor of his conversation was that, since he knew more, he could be convinced that his clients' interests are 
adequately protected by the deferral of prosecution agreement. Edwards requested: (I) a copy of the agreement between the USAO 
and Epstein; and (2) the opportunity to meet with USAO representatives about the agreement and how the provisions would work. 
I 
told him the agreement contained a confidentiality provision, and had been filed under seal in state court, but I would determine if it 
had been publicly filed anywhere. 
On Thursday, I called Edwards to tell him I still had not determine if the agreement had been publicly disclosed anywhere, but that I 
would be glad to meet with him and his clients next week 
Today, I verified with Marie that the agreement had not been filed by Michael Tein in the federal court civil litigation. Tein also 
called me for any information on the Jane Doe case, and I asked him if the agreement had been filed. He told me he had filed sealed 
motions with the court, in which references were made to the provisions of the agreement, but the agreement itself had not been filed. 
Since the agreement is not public, and there is a confidentiality provision in it, I don't believe we can produce it to the victims. We 
can still meet with Edwards and his clients, but it will be without the agreement being produced. This may not satisfy them. 
Edwards just filed a fifteen-page reply/response to our two-page notice to the court. Edwards' response looks more like a summary 
judgment motion, rather than a simple agreement or disagreement with the government's view that no further hearing is necessary. 
Please let me know your views on whether the agreement can be disclosed to Edwards and his clients, and whether it would be 
permissible/advisable to meet with Edwards and his clients. Tha <<19_plts_resp_gov_notice.pdf>> nks. 
Dexter 
<<19_plts_resp_gov_notice.pdf>> 
19 
EFTA00190596

Case 9:08-cv-80736-KAM 
Document 19 
Entered on FLSD Docket 08/01/2008 
Page 1 of 16 
UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
CASE NO.: 08-80736-CIV-MARRA/JOHNSON 
JANE DOE #1 AND JANE DOE #2, 
Petitioners, 
UNITED STATES OF AMERICA, 
Respondent. 
VICTIMS' RESPONSE TO GOVERNMENT'S "NOTICE TO COURT REGARDING 
ABSENCE OF NEED FOR EVIDENTIARY HEARING" AND MOTION FOR 
PRODUCTION OF NON-PROSECUTION AGREEMENT AND OF REPORT OF 
INTERVIEW 
COME NOW the Petitioners, Jane Doe #1 and Jane Doe #2 (the "victims"), by and 
through their undersigned attorneys to file this Response to the Government's document styled as 
"Notice to Court Regarding Absence of Need for Evidentiary Hearing" as follows: 
INTRODUCTION 
At the conclusion of the oral argument on the victims' petition, victims Jane Doe #1 and 
Jane Doe #2 joined the Government in expressing to the Court a desire to work out a set of 
stipulated facts regarding this case. Towards that end, the Government sent a proposed set of 
stipulated facts to the victims' counsel (Exhibit I to this pleading) and, in turn, the victims' sent 
a responsive letter raising concerns about some of the Government's proposed stipulated facts 
and suggesting some additions and modifications (Exhibit 2 to this pleading). The victims also 
requested copies of two relevant documents from the Government: (I) the Non-Prosecution 
1 
EFTA00190597