EFTA00190318

Villafana, Ann Marie C. (USAFLS) 
From: 
Villafana, Ann Marie C. (USAFLS) <AVillafana@usa.doj.gov> 
Sent: 
Friday, August 15, 20081:49 PM 
To: 
Senior, Robert (USAFLS); Acosta, Alex (USAFLS); Sloman, Jeff (USAFLS); Lee, Dexter 
(USAFLS); Atkinson, Karen (USAFLS) 
Subject: 
RE: New proposed response to Jay 
Here is my proposal after speaking with Jeff. 
Dear Jay and Roy: 
Thank you for your response to my earlier e-mail. Our communications with Mr. Black and later with Mr. Lefkowitz were 
solely to determine what Mr. Epstein considered to be the terms of the Non-Prosecution Agreement. We appreciate your answering 
our question with finality. You have now made clear that Mr. Epstein did not accept the December modification, and accordingly, the 
offer to make that modification is hereby withdrawn. 
Pursuant to our Agreement, I will prepare an Amended Notification that contains the names of additional identified victims. As 
you know, Judge 
had selected the Podhurst firm to serve as the attorney representative for the victims. Assuming that Mr. 
Josefsberg is still amenable to the appointment, we will provide him with the victim list so that he may begin his service. 
Finally, as you are aware, the United States has been ordered to produce the Non-Prosecution Agreement. In accordance with 
that Order, we will produce the September Agreement with the October Addendum signed by your client. We understand that Mr. 
Goldberger did not provide the state court with a true copy of the complete Agreement, and he should take steps to correct that error. 
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: Senior, Robert (USAFLS) 
Sent: Friday, August 15, 2008 1:34 PM 
To: Acosta, Alex (USAFLS); Villafana, Ann Marie C. (USAFLS); Sloman, Jeff (USAFLS); Lee, Dexter (USAFLS); Atkinson, Karen 
(USAFLS) 
Subject: Re: New proposed response to Jay 
Shouldn't we formally withdraw the offer as opposed to considering it a nullity ? 
— Original Message — 
From: Acosta, Alex (USAFLS) 
To: Villafana, Ann Marie C. (USAFLS); Sloman, Jeff (USAFLS); Senior, Robert (USAFLS); Lee, Dexter (USAFLS); Atkinson, 
Karen (USAFLS) 
Sent: Fri Aug 15 11:55:13 2008 
Subject: RE: New proposed response to Jay 
How about a slightly different version: 
357 
EFTA00190658

Thank you for your response. Our communications with Roy Black and later with you were solely to determine what Mr. Epstein 
considered to be the terms of the Non-Prosecution Agreement. We appreciate your answering our question with finality. You have 
now made clear that Mr. Epstein did not accept the December modification, and accordingly, we will now consider that modification 
to be a nullity. 
Pursuant to our Agreement, I will prepare an Amended Notification that contains the name of additional identified victims. In 
accordance with Paragraph 7B, please provide me with a proposed written submission to the Special Master by Monday afternoon. 
Finally, as you are aware, yhe United States has been ordered to produce the Non-Prosecution Agreement. In accordance with that 
Order, we will produce the September Agreement with the October Addendum signed by your client. We understand that Mr. 
Goldberg may not have provided the state court with a true copy of the complete Agreement, and he should take steps to correct that 
error. 
From: Villafana, Ann Marie C. (USAFLS) 
Sent: Friday, August 15, 2008 11:42 AM 
To: Acosta, Alex (USAFLS); Sloman, Jeff (USAFLS); Senior, Robert (USAFLS); Lee, Dexter (USAFLS); Atkinson, Karen 
(USAFLS) 
Subject: New proposed response to Jay 
Dear Jay: 
Thank you for your response. Our communications with Roy Black and later with you were solely to determine what Mr. Epstein 
considered to be the terms of the Non-Prosecution Agreement. You have now made clear that Mr. Epstein did not accept the 
December modification and does not intend to perform the obligations set forth therein. The Office is not going to continue ' 
negotiating the terms of the Agreement. We only sought finality and you have answered our question. Accordingly, the December 
proposed modification is hereby withdrawn. 
The United States has been ordered to produce the Non-Prosecution Agreement and, in accordance with that Order, will produce the 
September Agreement with the October Addendum signed by your client. Mr. Goldberger should be advised that we understand he 
has not provided the state court with a true copy of the complete Agreement, and he should take steps to correct that error. I will 
prepare an Amended Notification that contains the name of additional identified victims and will provide that to you promptly. 
In accordance with Paragraph 7B of the Agreement, please provide me with a proposed written submission to the Special Master by 
Monday afternoon. We will expect a showing of good faith in the selection of the attorney representative and all other terms of the 
Agreement and excessive delays, like those that have occurred in the past, will be considered a breach of that duty of good faith. 
Sincerely, 
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 
358 
EFTA00190659

Villafana, Ann Marie C. (USAFLS) 
From: 
Sloman, Jeff (USAFLS) <JSloman@usa.doj.gov> 
Sent: 
Friday, August 15, 2008 1:52 PM 
To: 
Villafana, Ann Marie C. (USAFLS); Senior, Robert (USAFLS); Acosta, Alex (USAFLS); Lee, 
Dexter (USAFLS); Atkinson, Karen (USAFLS) 
Subject: 
RE: New proposed response to Jay 
Marie, 
Please substitute the word "withdrawn" in the first sentence with "a nullity" 
Jeff 
 
Original Message-----
From: Villafana, Ann Marie C. (USAFLS) 
Sent: Friday, August IS, 2008 1:49 PM 
To: Senior, Robert (USAFLS); Acosta, Alex (USAFLS); Sloman, Jeff (USA ELS); Lcc, Dexter (USA EIS); Atkinson, Karen 
(USAFLS) 
Subject: RE: New proposed response to Jay 
Here is my proposal after speaking with Jeff. 
Dear Jay and Roy: 
Thank you for your response to my earlier e-mail. Our communications with Mr. Black and later with Mr. Lefkowitz were 
solely to determine what Mr. Epstein considered to be the terms of the Non-Prosecution Agreement. We appreciate your answering 
our question with finality. You have now made clear that Mr. Epstein did not accept the December modification, and accordingly, the 
offer to make that modification is hereby withdrawn. 
Pursuant to our Agreement, I will prepare an Amended Notification that contains the names of additional identified victims. As 
you know, Judge= had selected the Podhurst firm to serve as the attorney representative for the victims. Assuming that Mr. 
Josefsberg is still amenable to the appointment, we will provide him with the victim list so that he may begin his service. 
Finally, as you are aware, the United States has been ordered to produce the Non-Prosecution Agreement. In accordance with 
that Order, we will produce the September Agreement with the October Addendum signed by your client. We understand that Mr. 
Goldberger did not provide the state court with a true copy of the complete Agreement, and he should lake steps to correct that error. 
A. Marie Villafalia 
Assistant U.S. Attorney 
500 S. Australian Ave, Suite 400 
West Palm Beach, FL 33401 
Phone 561 209-1047 
Fax 561 820.8777 
 
Original Message 
From: Senior, Robert (USAFLS) 
Sent: Friday, August I5, 2008 1:34 PM 
To: Acosta, Alex (USAFLS); Villafana, Ann Marie C. (USAFLS); Similar), Jeff (USAFLS); Lee, Dexter (USAFLS); Atkinson, Karen 
(USAFLS) 
359 
EFTA00190660

Subject: Re: New proposed response to Jay 
Shouldn't we formally withdraw the offer as opposed to considering it a nullity? 
— Original Message ----
From: Acosta, Alex (USAFLS) 
To: Villafana, Ann Marie C. (USAFLS); Sloman, Jeff (USAFLS); Senior, Robert (USAFLS); Lee, Dexter (USAFLS); Atkinson, 
Karen (USAFLS) 
Sent: Fri Aug 15 11:55:13 2008 
Subject: RE: New proposed response to Jay 
How about a slightly different version: 
Thank you for your response. Our communications with Roy Black and later with you were solely to determine what Mr. Epstein 
considered to be the terms of the Non-Prosecution Agreement. We appreciate your answering our question with finality. You have 
now made clear that Mr. Epstein did not accept the December modification, and accordingly, we will now consider that modification 
to be a nullity. 
Pursuant to our Agreement, I will prepare an Amended Notification that contains the name of additional identified victims. In 
accordance with Paragraph 7B, please provide me with a proposed written submission to the Special Master by Monday afternoon. 
Finally, as you arc aware, yhe United States has been ordered to produce the Non-Prosecution Agreement. In accordance with that 
Order, we will produce the September Agreement with the October Addendum signed by your client. We understand that Mr. 
Goldberg may not have provided the state court with a true copy of the complete Agreement, and he should take steps to correct that 
error. 
From: Villafana, Ann Marie C. (USAFLS) 
Sent: Friday, August 15, 2008 II:42 AM 
To: Acosta, Alex (USAFLS); Sloman, Jeff(USAFLS); Senior, Robert (USAFLS); Lee, Dexter (USAFLS); Atkinson, Karen 
(USAFLS) 
Subject: New proposed response to Jay 
Dear Jay: 
Thank you for your response. Our communications with Roy Black and later with you were solely to determine what Mr. Epstein 
considered to be the terms of the Non-Prosecution Agreement. You have now made clear that Mr. Epstein did not accept the 
December modification and does not intend to perform the obligations set forth therein. The Office is not going to continue 
negotiating the terms of the Agreement. We only sought finality and you have answered our question. Accordingly, the December 
proposed modification is hereby withdrawn. 
The United Slates has been ordered to produce the Non-Prosecution Agreement and, in accordance with that Order, will produce the 
September Agreement with the October Addendum signed by your client. Mr. Goldberger should be advised that we understand he 
has not provided the state court with a true copy of the complete Agreement, and he should take steps to correct that error. I will 
prepare an Amended Notification that contains the name of additional identified victims and will provide that to you promptly. 
In accordance with Paragraph 7B of the Agreement, please provide me with a proposed written submission to the Special Master by 
Monday afternoon. We will expect a showing of good faith in the selection of the attorney representative and all other terms of the 
Agreement and excessive delays, like those that have occurred in the past, will be considered a breach of that duty of good faith. 
Sincerely, 
360 
EFTA00190661

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 
361 
EFTA00190662

Villafana, Ann Marie C. (USAFLS) 
From: 
Villafana, Ann Marie C. (USAFLS) <AVillafana@usa.doj.gov> 
Sent: 
Friday, August 15, 2008 1:54 PM 
To: 
Lee, Dexter (USAFLS) 
Cc: 
Sloman, Jeff (USAFLS) 
Subject: 
FW: New proposed response to Jay 
Importance: 
High 
Dexter -- If we call it "a nullity" instead of "withdrawn" how does that affect the issue with the Jane Does? 
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: Simian, Jeff (USAFLS) 
Sent: Friday, August IS, 2008 1:52 PM 
To: Villafana, Ann Marie C. (USAFLS); Senior, Robert (USAFLS); Acosta, Alex (USAFLS); Lee, Dexter (USAFLS); Atkinson, 
Karen (USAFLS) 
Subject: RE: New proposed response to Jay 
Marie, 
Please substitute the word "withdrawn" in the first sentence with "a nullity" 
Jeff 
 
Original Message 
From: Villafana, Ann Marie C. (USAFLS) 
Sent: Friday, August I5, 2008 1:49 PM 
To: Senior, Robert (USAFLS); Acosta, Alex (USAFLS); Sloman, Jeff (USAFLS); Lee, Dexter (USAFLS); Atkinson, Karen 
(USAFLS) 
Subject: RE: New proposed response to Jay 
Here is my proposal after speaking with Jeff. 
Dear Jay and Roy: 
Thank you for your response to my earlier e-mail. Our communications with Mr. Black and later with Mr. Lefkowitz were 
solely to determine what Mr. Epstein considered to be the terms of the Non-Prosecution Agreement. We appreciate your answering 
our question with finality. You have now made clear that Mr. Epstein did not accept the December modification, and accordingly, the 
offer to make that modification is hereby withdrawn. 
362 
EFTA00190663

Pursuant to our Agreement, I will prepare an Amended Notification that contains the names of additional identified victims. As 
you know, Judge IM had selected the Podhurst firm to serve as the attorney representative for the victims. Assuming that Mr. 
Josefsberg is still amenable to the appointment, we will provide him with the victim list so that he may begin his service. 
Finally, as you are aware, the United States has been ordered to produce the Non-Prosecution Agreement. In accordance with 
that Order, we will produce the September Agreement with the October Addendum signed by your client. We understand that Mr. 
Goldberger did not provide the state court with a true copy of the complete Agreement, and he should take steps to correct that error. 
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: Senior, Robert (USAFLS) 
Sent: Friday, August 15, 2008 1:34 PM 
To: Acosta, Alex (USAFLS); Villafana, Ann Marie C. (USAFLS); Sloman, Jeff (USAFLS); Lee, Dexter (USAFLS); Atkinson, Karen 
(USAFLS) 
Subject: Re: New proposed response to Jay 
Shouldn't we formally withdraw the offer as opposed to considering it a nullity ? 
Original Message ----
From: Acosta, Alex (USAFLS) 
To: Villafana, Ann Marie C. (USAFLS); Sloman, Jeff (USAFLS); Senior, Robert (USAFLS)• Lee, Dexter (USAFLS); Atkinson, 
Karen (USAFLS) 
Sent: Fri Aug 15 11:55:13 2008 
Subject: RE: New proposed response to Jay 
How about a slightly different version: 
Thank you for your response. Our communications with Roy Black and later with you were solely to determine what Mr. Epstein 
considered to be the terms of the Non-Prosecution Agreement. We appreciate your answering our question with finality. You have 
now made clear that Mr. Epstein did not accept the December modification, and accordingly, we will now consider that modification 
to be a nullity. 
Pursuant to our Agreement, I will prepare an Amended Notification that contains the name of additional identified victims. In 
accordance with Paragraph 7B, please provide me with a proposed written submission to the Special Master by Monday afternoon. 
Finally, as you are aware, yhe United States has been ordered to produce the Non-Prosecution Agreement. In accordance with that 
Order, we will produce the September Agreement with the October Addendum signed by your client. We understand that Mr. 
Goldberg may not have provided the state court with a true copy of the complete Agreement, and he should take steps to correct that 
error. 
From: Villafana, Ann Marie C. (USAFLS) 
Sent: Friday, August IS, 2008 11:42 AM 
To: Acosta, Alex (USAFLS); Sloman, Jeff (USAFLS); Senior, Robert (USAFLS); Lee, Dexter (USAFLS); Atkinson, Karen 
(USAFLS) 
363 
EFTA00190664

Subject: New proposed response to Jay 
Dear Jay: 
Thank you for your response. Our communications with Roy Black and later with you were solely to determine what Mr. Epstein 
considered to be the terms of the Non-Prosecution Agreement. You have now made clear that Mr. Epstein did not accept the 
December modification and does not intend to perform the obligations set forth therein. The Office is not going to continue 
negotiating the terms of the Agreement. We only sought finality and you have answered our question. Accordingly, the December 
proposed modification is hereby withdrawn. 
The United States has been ordered to produce the Non-Prosecution Agreement and, in accordance with that Order, will produce the 
September Agreement with the October Addendum signed by your client. Mr. Goldberger should be advised that we understand he 
has not provided the state court with a true copy of the complete Agreement, and he should take steps to correct that error. 1 will 
prepare an Amended Notification that contains the name of additional identified victims and will provide that to you promptly. 
In accordance with Paragraph 7B of the Agreement, please provide me with a proposed written submission to the Special Master by 
Monday afternoon. We will expect a showing of good faith in the selection of the attorney representative and all other tenns of the 
Agreement and excessive delays, like those that have occurred in the past, will be considered a breach of that duty of good faith. 
Sincerely, 
A. Marie Villafaha 
Assistant U.S. Attorney 
500 S. Australian Ave, Suite 400 
West Palm Beach, FL 33401 
Phone 561 209-1047 
Fax 561 820-8777 
364 
EFTA00190665

Villafana, Ann Marie C. (USAFLS) 
From: 
Lee, Dexter (USAFLS) <DLee@usa.doj.gov> 
Sent: 
Friday, August 15, 2008 2:05 PM 
To: 
Villafana, Ann Marie C. (USAFLS) 
Cc: 
Sloman, Jeff (USAFLS) 
Subject: 
RE: New proposed response to Jay 
Something which is a nullity lacks any legal import. If it has been withdrawn, then the item had import at one time, but it no longer 
does. If the December 2007 letter is viewed as an offer, there was no acceptance, or it has been rejected. Consequently, the offer no 
longer has an legal import. 
We are obligated to provide a copy of the non-prosecution agreement to petitioners, whatever that agreement is. If the December 
2007 letter never became a part of the agreement, and the government and Epstein are in agreement as to that issue, then we can 
produce the September 2007 agreement and the addendum. Are we at that point? 
Dexter 
 
Original Message 
From: Villafana, Ann Marie C. (USAFLS) 
Sent: Friday, August IS, 2008 1:54 PM 
To: Lee, Dexter (USAFLS) 
Cc: Sloman, Jeff (USAFLS) 
Subject: FW: New proposed response to Jay 
Importance: High 
Dexter -- If we call it "a nullity" instead of "withdrawn" how does that affect the issue with the Jane Does? 
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: Sloman, Jeff (USAFLS) 
Sent: Friday, August 15, 2008 1:52 PM 
To: Villafana, Ann Marie C. (USAFLS); Senior, Robert (USAFLS); Acosta, Alex (USAFLS); Lee, Dexter (USAFLS); Atkinson, 
Karen (USAFLS) 
Subject: RE: New proposed response to Jay 
Marie, 
Please substitute the word "withdrawn" in the first sentence with "a nullity" 
Jeff 
 
Original Message 
Front: Villafana, Ann Marie C. (USAFLS) 
Sent: Friday, August 15, 2008 1:49 PM 
365 
EFTA00190666

To: Senior, Robert (USAFLS); Acosta, Alex (USAFLS); Sloman, Jeff (USAFLS); Lee, Dexter (USAFLS); Atkinson, Karen 
(USAFLS) 
Subject: RE: New proposed response to Jay 
Here is my proposal after speaking with Jeff. 
Dear Jay and Roy: 
Thank you for your response to my earlier e-mail. Our communications with Mr. Black and later with Mr. Lefkowitz were 
solely to determine what Mr. Epstein considered to be the terms of the Non-Prosecution Agreement. We appreciate your answering 
our question with finality. You have now made clear that Mr. Epstein did not accept the December modification, and accordingly, the 
offer to make that modification is hereby withdrawn. 
Pursuant to our Agreement, I will prepare an Amended Notification that contains the names of additional identified victims. As 
you know, Judge 
had selected the Podhurst firm to serve as the attorney representative for the victims. Assuming that Mr. 
Josefsberg is still amenable to the appointment, we will provide him with the victim list so that he may begin his service. 
Finally, as you are aware, the United States has been ordered to produce the Non-Prosecution Agreement. In accordance with 
that Order, we will produce the September Agreement with the October Addendum signed by your client. We understand that Mr. 
Goldberger did not provide the state court with a true copy of the complete Agreement, and he should take steps to correct that error. 
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: Senior, Robert (USAFLS) 
Sent: Friday, August IS, 2008 1:34 PM 
To: Acosta, Alex (USAFLS); Villafana, Ann Marie C. (USAFLS); Sloman, Jeff (USAFLS); Lee, Dexter (USAFLS); Atkinson, Karen 
(USAFLS) 
Subject: Re: New proposed response to Jay 
Shouldn't we formally withdraw the offer as opposed to considering it a nullity? 
Original Message ----
From: Acosta, Alex (USAFLS) 
To: Villafana, Ann Marie C. (USAFLS); Sloman, Jeff (USAFLS); Senior, Robert (USAFLS); Lee, Dexter (USAFLS); Atkinson, 
Karen (USAFLS) 
Sent: Fri Aug 15 11:55:13 2008 
Subject: RE: New proposed response to Jay 
Flow about a slightly different version: 
Thank you for your response. Our communications with Roy Black and later with you were solely to determine what Mr. Epstein 
considered to be the terms of the Non-Prosecution Agreement. We appreciate your answering our question with finality. You have 
now made clear that Mr. Epstein did not accept the December modification, and accordingly, we will now consider that modification 
to be a nullity. 
366 
EFTA00190667

Pursuant to our Agreement, I will prepare an Amended Notification that contains the name of additional identified victims. In 
accordance with Paragraph 7B, please provide me with a proposed written submission to the Special Master by Monday afternoon. 
Finally, as you are aware, yhe United States has been ordered to produce the Non-Prosecution Agreement. In accordance with that 
Order, we will produce the September Agreement with the October Addendum signed by your client. We understand that Mr. 
Goldberg may not have provided the state court with a true copy of the complete Agreement, and he should take steps to correct that 
error. 
From: Villafana, Ann Marie C. (USAFLS) 
Sent: Friday, August 15, 2008 11:42 AM 
To: Acosta, Alex (USAFLS); Slomen, Jeff (USAFLS); Senior, Robert (USAFLS); Lee, Dexter (USAFLS); Atkinson, Karen 
(USAFLS) 
Subject: New proposed response to Jay 
Dear Jay: 
Thank you for your response. Our communications with Roy Black and later with you were solely to determine what Mr. Epstein 
considered to be the terns of the Non-Prosecution Agreement. You have now made clear that Mr. Epstein did not accept the 
December modification and does not intend to perform the obligations set forth therein. The Office is not going to continue 
negotiating the terms of the Agreement. We only sought finality and you have answered our question. Accordingly, the December 
proposed modification is hereby withdrawn. 
The United States has been ordered to produce the Non-Prosecution Agreement and, in accordance with that Order, will produce the 
September Agreement with the October Addendum signed by your client. Mr. Goldberger should be advised that we understand he 
has not provided the state court with a true copy of the complete Agreement, and he should take steps to correct that error. I will 
prepare an Amended Notification that contains the name of additional identified victims and will provide that to you promptly. 
In accordance with Paragraph 7B of the Agreement, please provide me with a proposed written submission to the Special Master by 
Monday afternoon. We will expect a showing of good faith in the selection of the attorney representative and all other terms of the 
Agreement and excessive delays, like those that have occurred in the past, will be considered a breach of that duty of good faith. 
Sincerely, 
A. Marie Villatafla 
Assistant U.S. Attorney 
500 S. Australian Ave, Suite 400 
West Palm Beach, FL 33401 
Phone 561 209-1047 
Fax 561 820-8777 
367 
EFTA00190668

Villafana, Ann Marie C. (USAFLS) 
From: 
Villafana, Ann Marie C. (USAFLS) <AVillafana@usa.doj.gov> 
Sent: 
Monday, August 25, 2008 9:48 AM 
To: 
Acosta, Alex (USAFLS); Sloman, Jeff (USAFLS); Senior, Robert (USAFLS); Atkinson, Karen 
93 
(USAFLS); Lee, Dexter (USAFLS) 
Subject: 
Letter re Epstein and Protective Order 
Attachments: 
080822 Lefkowitz Itr to Villafana.pdf 
Good morning, everyone. 
I have attached a letter from Jay Lefkowitz that came in by fax on Friday night. The good news is that they 
seem to be in agreement regarding Mr. Josefsberg. Most of the letter doesn't really require a comment, but I 
wanted to get Dexter's feedback regarding the notification to the victims of their right to see the 
agreement. Here is the language from my proposed victim notification letter: 
"In addition, a judge has ordered that the United States make available to any designated victim 
(and/or her attorney) a copy of the actual agreement between Mr. Epstein and the United States, so 
long as the victim (and/or her attorne 
reviews, signs, and agrees to be bound by a Protective 
Order entered by the Court. If Ms. 
would like to review the Agreement, please let me 
know, and I will forward a copy of the Protective Order for her signature." 
Lefkowitz objects, but I am wondering whether Dexter agrees that the spirit of our discussions with 
Judge Marra requires such a notification. If we make the entire agreement available to Mr. 
Josefsberg and he conveys that information to all of his clients, the concern becomes moot, I 
suppose. 
Lastly, from my discussion with Bob, it appears that the Office does not want to add to the list the names of 
victims identified after the date of signing the September agreement unless our investigation had provided 
enough information that we were pre ared to include them in the indictment — i.e., the New York girls — and 
that you do not want me to re-add 
to the list, even though we have extensive corroboration of her 
involvement with Epstein. Can someone please confirm? 
Thank you all. 
«080822 Lefkowitz ftr to Villafana.pdf» 
A. Marie Vitiate& 
Assistant U.S. Attorney 
500 S. Australian Ave, Suite 400 
West Palm Beach, FL 33401 
Phone 561 209-1047 
Fax 561 820-8777 
385 
EFTA00190669

Villafana, Ann Marie C. (USAFLS) 
From: 
Lee, Dexter (USAFLS) <DLee@usa.doj.gov> 
Sent: 
Monday, August 25, 2008 10:25 AM 
To: 
Villafana, Ann Marie C. (USAFLS); Acosta, Alex (USAFLS); Sloman, Jeff (USAFLS); Senior, 
Robert (USAFLS); Atkinson, Karen (USAFLS) 
Subject: 
RE: Letter re Epstein and Protective Order 
Marie, 
During our telephonic hearing, I received the clear impression that Judge Marra wanted the other victims 
(non-parties to the Jane Doe litigation), would be given the opportunity to see the Agreement, subject to each 
one agreeing to be bound by the protective order. I believe it would be contrary to Judge Marra's intent for 
us to go through the trouble of creating a mechanism for the other non-party victims to have access to the 
Agreement, and then not tell them there is an Agreement. 
Also, does CVRA impose any obligation on us, independent of what Judge Marra ordered, to advise the victims 
of the Agreement? 
Dexter 
From: Villafana, Ann Marie C. (USAFLS) 
Sent: Monday, August 25, 2008 9:48 AM 
To: Acosta, Alex (USAFLS); Sloman, Jeff (USAFLS); Senior, Robert (USAFLS); Atkinson, Karen (USAFLS); Lee, Dexter 
(USAFLS) 
Subject: Letter re Epstein and Protective Order 
Good morning, everyone. 
I have attached a letter from Jay Lefkowitz that came in by fax on Friday night. The good news is that they 
seem to be in agreement regarding Mr. Josefsberg. Most of the letter doesn't really require a comment, but I 
wanted to get Dexter's feedback regarding the notification to the victims of their right to see the 
agreement. Here is the language from my proposed victim notification letter: 
"In addition, a judge has ordered that the United States make available to any designated victim 
(and/or her attorney) a copy of the actual agreement between Mr. Epstein and the United States, so 
long as the victim (and/or her attorne 
reviews, signs, and agrees to be bound by a Protective 
Order entered by the Court. If Ms. 
would like to review the Agreement, please let me 
know, and I will forward a copy of the Protective Order for her signature." 
Lefkowitz objects, but I am wondering whether Dexter agrees that the spirit of our discussions with 
Judge Marra requires such a notification. If we make the entire agreement available to Mr. 
Josefsberg and he conveys that information to all of his clients, the concern becomes moot, I 
suppose. 
Lastly, from my discussion with Bob, it appears that the Office does not want to add to the list the names of 
victims identified after the date of signing the September agreement unless our investigation had provided 
386 
EFTA00190670

enough information that we were pad to include them in the indictment — i.e., the New York girls — and 
that you do not want me to re-add 
to the list, even though we have extensive corroboration of her 
involvement with Epstein. Can someone please confirm? 
Thank you all. 
•c< File: 080822 Lefkowitz Itr to Villafana.pdf >> 
A. Marie Walla 
Assistant U.S. Attorney 
500 S. Australian Ave, Suite 400 
West Palm Beach, FL 33401 
Phone 561 209-1047 
Fax 561 820-8777 
387 
EFTA00190671

KIRKLAND & ELLIS LLP 
N4) Al numb PARTNICESIPM 
Cillornup Cooler 
153 E0:4 S3ru Street 
New York. Nov York 100274511 
Jay P I OlkowitZ. P C 
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A. Marie Villafana 
inked States Attorney's Office 
.Southern District of Florida 
a 
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West Palm Beach. Florida 33401 
Re: 
Jegiey Epstein 
Dear Marie: 
F a r. nu e 
446.490 
write this letter to correct certain misstatements made in your Idler date) August 21. 
2008. and the accompanying draft notification. 
First, you state that "Mr. Josefsberg expended time. effort and funds in preparing to serve 
as attorney representative in October of 2007.- Neither I. nor any other attorney on Mr. 
Epstein's defense team. was notified of this work by Mr. Josefsberg. 
Second. in the victim notification letter, no judge "has ordered that the United States" 
make available a copy of the Non-Prosecution. Agreement. Section (d} of the Order to Compel 
Production and Protective Order provides that if any of the alleged - victims- and/or their 
attorneys "request the apponunity to review the Agreement.- the USA() shall comply with the 
request so long as those individuals agree not to disclose the Non-Prosecution Agreement. There 
is no court order requiring the government to provide the alleged "victims- with notice that the 
Non-Prosecution Agreement is available to them upon request and doing so is in conflict with 
the confidentiality provisions of the Agreement. Given that the individuals on the list will have 
an attorney representative who is fully aware of the terms of the Non-Prosecution Agreement. 
this conflicting paragraph of your notice is unnecessary in any event and should he excisVd. 
Third. misstatements in your prior notification were not made "with the approval of 
Mr. Hpstein's counsel.-
Fourth, we are concerned with your open-ended description of Mr. fipswin's 
responsibilities regarding civil restitution. The resolution of liability pursuant to I$ U.S.C. 
•
 
EFTA00190672

KIRKLAND & ELLIS LLP 
A. Marie Vi 
August 11 200:t 
Page 2 
.2253 is as stated in paragraphs 7 and 8 of the Agreement and the Addendum to the Agreement. 
no more. no less. 
Fifth. while 'you state, in your letter. that the USAO does not intend to delete any of the 
names on the list provided to Mr. Epstein's counsel, you do not confirm that the prior list is final 
and complete. There can he no expansion of the list of individuals that you informed us had 
been memorialized tIS of September 24. 2007 and disclosed to Mr. Epstein un June 30. 2008 (the 
date of sentence pursuant to the Agreement's disclosure requirement:O. Please confirm the exact 
name and number of individuals the government plans on notifying as provided fur under the 
Agreement. 
Sixth. hased on express language in prior communications front your Ollice. we are in 
agreement that paragraphs 7 and 8 of the Agreement are in need of clarification and 
implementation. We will work with the attorney representative in attempting to reach a fair 
resolution of the outstanding civil matters in a manner that is in accordance with the Agreement. 
Seventh, we have previously communicated our objections In the propriety of the 
attorney representative engaging in contested litigation. We again dispute the assertion that 
Mr. Josef berg's duties include thing contested litigation. In any ease, that issue is not ripe thr 
resolution at this point. but again, given his agreement to be the attorney representative. we will 
address these matters directly with Mr. Joscfsberg. 
Sin,eyrely. 
el
. „ 
• 
06. Lakowitz 
cc: 
Karen Atkinson. Chief. Monk= Division 
EFTA00190673

KIRKLAND & ELLIS LLP 
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A. Marie Villafana 
United States Attorneys Office 
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Karen Atkinson 
United States Attorney's Office 
561-820-8777 
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From: 
• 
Date: 
Pages weaver 
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Jay P. Lelkowity. 
August 22. 2008 
message: 
EFTA00190674

Villafana, Ann Marie C. (USAFLS) 
From: 
VII'Mane, Ann Marie C. (USAFLS) <AVillatana@usa.doj.gov> 
Sent: 
Monday, August 25, 2008 1:54 PM 
To: 
Lee, Dexter (USAFLS) 
Subject: 
RE: Letter re Epstein and Protective Order 
Ili Dexter — Thank you for your response. Did you ever send the agreement to Brad? Do you want me to do 
that? 
A. Marie Villrfaha
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, August 25, 2008 10:25 AM 
To: Villafana, Ann Marie C. (USAFLS); Acosta, Alex (USAFLS); Sloman, Jeff (USAFLS); Senior, Robert (USAFLS); Atkinson, 
Karen (USAFLS) 
Subject: RE: Letter re Epstein and Protective Order 
Marie, 
During our telephonic hearing, I received the clear impression that Judge Marra wanted the other victims 
(non-parties to the Jane Doe litigation), would be given the opportunity to see the Agreement, subject to each 
one agreeing to be bound by the protective order. I believe it would be contrary to Judge Marra's intent for 
us to go through the trouble of creating a mechanism for the other non-party victims to have access to the 
Agreement, and then not tell them there is an Agreement. 
Also, does CVRA impose any obligation on us, independent of what Judge Marra ordered, to advise the victims 
of the Agreement? 
Dexter 
From: Villafana, Ann Marie C. (USAFLS) 
Sent: Monday, August 25, 2008 9:48 AM 
To: Acosta, Alex (USAFLS); Sloman, Jeff (USAFLS); Senior, Robert (USAFLS); Atkinson, Karen (USAFLS); Lee, Dexter 
(USAFLS) 
Subject: Letter re Epstein and Protective Order 
Good morning, everyone. 
388 
EFTA00190675

I have attached a letter from Jay Lefkowitz that came in by fax on Friday night. The good news is that they 
seem to be in agreement regarding Mr. Josefsberg. Most of the letter doesn't really require a comment, but I 
wanted to get Dexter's feedback regarding the notification to the victims of their right to see the 
agreement. Here is the language from my proposed victim notification letter: 
"In addition, a judge has ordered that the United States make available to any designated victim 
(and/or her attorney) a copy of the actual agreement between Mr. Epstein and the United States, so 
long as the victim (and/or her attorne 
reviews, signs, and agrees to be bound by a Protective 
Order entered by the Court. If Ms. 
would like to review the Agreement, please let me 
know, and I will forward a copy of the Protective Order for her signature." 
Lefkowitz objects, but I am wondering whether Dexter agrees that the spirit of our discussions with 
Judge Mara requires such a notification. If we make the entire agreement available to Mr. 
Josefsberg and he conveys that information to all of his clients, the concern becomes moot, I 
suppose. 
Lastly, from my discussion with Bob, it appears that the Office does not want to add to the list the names of 
victims identified after the date of signing the September agreement unless our investigation had provided 
enough information that we were re ared to include them in the indictment — i.e., the New York girls — and 
that you do not want me to re-add 
to the list, even though we have extensive corroboration of her 
involvement with Epstein. Can someone please confirm? 
Thank you all. 
<< File: 080822 Lefkowitz kr to Villafana.pdf >> 
A. Marie Villafalla 
Assistant U.S. Attorney 
500 S. Australian Ave, Suite 400 
West Palm Beach, FL 33401 
Phone 561 209-1047 
Fax 561 820-8777 
389 
EFTA00190676

Villafana, Ann Marie C. (USAFLS) 
From: 
Lee, Dexter (USAFLS) <DLee@usa.doj.gov> 
Sent: 
Monday, August 25, 2008 2:18 PM 
To: 
Villafana, Ann Marie C. (USAFLS) 
Subject: 
RE: Letter re Epstein and Protective Order 
Marie, 
I have not sent Brad the Agreement, and would appreciate it if you could take care of that. Are we sending 
out parts I and II, and leaving out the December 2007 letter? Thanks. 
Dexter 
From: Villafana, Ann Marie C. (USAFLS) 
Sent: Monday, August 25, 2008 1:54 PM 
To: Lee, Dexter (USAFLS) 
Subject: RE: Letter re Epstein and Protective Order 
Hi Dexter — Thank you for your response. Did you ever send the agreement to Brad? Do you want me to do 
that? 
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 
From: Lee, Dexter (USAFLS) 
Sent: Monday, August 25, 2008 10:25 AM 
To: Villafana, Ann Marie C. (USAFLS); Acosta, Alex (USAFLS); Sloman, Jeff (USAFLS); Senior, Robert (USAFLS); Atkinson, 
Karen (USAFLS) 
Subject: RE: Letter re Epstein and Protective Order 
Marie, 
During our telephonic hearing, I received the clear impression that Judge Marra wanted the other victims 
(non-parties to the Jane Doe litigation), would be given the opportunity to see the Agreement, subject to each 
one agreeing to be bound by the protective order. I believe it would be contrary to Judge Marra's intent for 
us to go through the trouble of creating a mechanism for the other non-party victims to have access to the 
Agreement, and then not tell them there is an Agreement. 
390 
EFTA00190677