EFTA00193954

Villafana, Ann Marie C. (USAFLS) 
From: 
Senior, Robert (USAFLS) <RSenior@usa.doj.gov> 
Sent: 
Tuesday, May 27, 2008 5:09 PM 
To: 
Villafana, Ann Marie C. (USAFLS) 
Subject: 
RE: Epstein 
Perfect. Enjoy your trip. We're in good shape (so far). 
----Original Message----
From: Villafana, Ann Marie C. (USAFLS) 
Sent: Tuesday, May 27, 2008 3:56 PM 
To: Senior, Robert (USAFLS) 
Subject: Re: Epstein 
Hi bob. I get back on saturday. I will spend sunday with nesbitt and monday with you. I will be there by 10:00 unless you need me 
there earlier. 
Original Message ----
From: Senior, Robert (USAFLS) 
To: Villafana, Ann Marie C. (USAFLS); Sloman, Jeff (USAFLS) 
Cc: Atkinson, Karen (USAFLS) 
Sent: Tue May 27 15:24:50 2008 
Subject: RE: Epstein 
Marie, are you back 7 We need to spend some time together on the indictment. I was planning on Monday because I thought you 
were back that day but if you're already back let me know. By the way, Jeff and Alex have been very clear that we are not negotiating 
with this guy any more in any way. 
Thx. Bob 
----Original Message--
From: Villafana, Ann Marie C. (USAFLS) 
Sent: Tuesday, May 27, 2008 2:54 PM 
To: Sloman, Jeff (USAFLS); Senior, Robert (USAFLS) 
Cc: Atkinson, Karen (USAFLS) 
Subject: Epstein 
Hi Jeff. Karen sent me an email about epstein wanting to do less time. I hope that his request will be denied. The original deal was 
supposed to be 2 years so he has already gotten a big break. Plus we have identified more victims since we agreed to the 18 months. 
Please keep me posted. Thanks. 
2 
EFTA00194254

Villafana, Ann Marie C. (USAFLS) 
From: 
Villafana, Ann Marie C. (USAFLS) 
Sent: 
Monday, December 03, 2007 3:45 PM 
To: 
Acosta, Alex (USAFLS) 
Cc: 
Sloman, Jeff (USAFLS) 
Subject: 
Relevant Drafts of the Agreement 
Importance: 
High 
Hi Alex — Here are the first set of agreements that we proposed. They were drafted on September e. The plea 
agreement (where he pleads to a federal charge) contains nothing about section 2255. The Non-Prosecution 
Agreement contains the following: 
4. 
Epstein agrees that, if any of the victims identified in the federal investigation file suit 
pursuant to 18 U.S.C. § 2255, Epstein will not contest the jurisdiction of the U.S. District 
Court for the Southern District of Florida over his person and/or the subject matter, and 
Epstein will not contest that the identified victims are persons who, while minors, were 
victims of violations of Title IS. United States Code, Sections(s) 2422 and/or 2423. 
5. 
The United States shall provide Epstein's attorneys with a list of the identified victims, 
which will not exceed forty, after Epstein has signed this agreement and entered his 
guilty plea. The United States shall make a motion with the United States District Court 
for the Southern District of Florida for the appointment of a guardian ad litem for the 
identified victims and Epstein's counsel may contact the identified victims through that 
counsel. 
At the beginning, Epstein was most interested in pleading to a federal charge, so we spent a lot of time on the 
federal plea agreement. This identical language was incorporated into the proposed federal plea agreement. I 
have I I drafts of the plea agreement on my computer, they all have the identical language on this point. 
Around mid-September. we went back to the Non-Prosecution Agreement. 
On September le, Jay proposed the following language: 
Epstein agrees to fund a Trust set up in concert with the Government and under the supervision of the 
le Judicial Circuit in and for Palm Beach County, Epstein agrees that a Trustee will be appointed by 
the Circuit Court and that funds from the Trust will be available to be disbursed at the Trustee's 
discretion to an agreed list of persons who seek reimbursement and make a good faith showing to the 
Trustee that they suffered injury as a result of the conduct of Epstein. Epstein waives his right to contest 
liability or damages up to an amount agreed to by the parties for any settlements entered into by the 
Trustee. Epstein's waiver is not to be construed as an admission of civil or criminal liability in regards 
to any of those who seek compensation from the Trust. 
I sent an e-mail to Jay on September I e. with the following response: 
Re your paragraph 8: As t mentioned over the telephone, I cannot bind the girls to the Trust 
Agreement, and I don't think it Is appropriate that a state court would administer a trust that seeks to 
pay for federal civil claims. We both want to avoid unscrupulous attorneys and/or litigants from 
coming forward, and I know that your client wants to keep these matters outside of public court filings, 
bull just don't have the power to do what you ask. Here is my'recommendation. During the period 
between Mr. Epstein's plea and sentencing, I make a motion for appointment of the Guardian Ad 
2487 
08-80736-CV-MARRA 
P-014355 
EFTA00194255

Lltem. The three of us sit down and discuss things, and I will facilitate as much as I can getting the 
girls approval of this procedure because, as I mentioned, I think it Is probably in their best Interests 
In terms of plea agreement language. let me suggest the following: 
The United States agrees to make a motion seeking the appointment of a Guardian ad Lltem to 
represent the identified victims. Following the appointment of such Guardian. the parties agree to 
work together in good faith to develop a Trust Agreement, subject to the Court's approval, that would 
provide for any damages owed to the identified Victims pursuant to 18 U.S.C. Section 2255. Then 
include the last two sentences of your paragraph B. 
NOTICE that I offered to try to put together a Trust Agreement. 
On September I e, Jay sent a proposed agreement that made no mention at all of payments to the victims. 
Jay sent the following redline on September 2111: 
Non Prosecution 
Igreement Star.. 
On September 2.3rd, he sent me a "redline" of my most recent version, with the following changes: 
20070923_8pmR 
II ne_of~1V Ag 
On September 23rd, at around 8:00 p.m., the language was: 
6. 
The United States shall provide Epstein's attorneys with a list of individuals whom 
it has identified as victims, as defined in 18 U.S.C, § 2255, after Epstein has 
signed this agreement and been sentenced. Upon the execution of this agreement, 
the United States will file a motion with the United States District Court for the 
Southern District of Florida for the appointment ofla guardian ad litem for these 
persons. Epstein's counsel may contact the identified individuals through that 
guardian. 
7. 
If any of the individuals referred to in paragraph (6), supra, elects to file suit 
pursuant to 18 U.S.C. § 2255, Epstein will not contest the jurisdiction of the 
United States District Court for the Southern District of Florida over his person 
and/or the subject matter, and Epstein waives his right to contest liability and also 
waives his right to contest damages up to an amount as agreed to between the 
identified victim and Epstein, so long as the identified victim elects to proceed 
exclusively under 18 U.S.C. § 2255, and agrees to waive any other claim for 
damages, whether pursuant to state, federal, or common law. Notwithstanding this 
waiver, as to those individuals whose names appear on the list provided by the 
United States, Epstein's signature on this agreement is not to be construed as an 
admission of any criminal or oivil liability other than that contained in 18 U.S.C. § 
2255. 
2488 
08-80736-CV-MARRA 
P-014356 
EFTA00194256

8. 
Epstein's signature on this agreement also is not to be construed as an admission 
of civil or criminal liability or a waiver of any jurisdictional or other defense as to 
any person whose name does not appear on the list provided by the United States. 
At the end of the day on September 241h, at Jay's request, there were several significant changes. Here 
is the new language: 
7. 
The United States shall provide Epstein's attorneys with a list of individuals whom 
it has identified as victims, as defined in 18 U.S.C. § 2255, alter Epstein has 
signed this agreement and been sentenced. Upon the execution of this agreement, 
the United States, in consultation with and subject to the good faith approval of 
Epstein's counsel, shall select an attorney representative for these persons, who 
shall be paid for by Epstein. Epstein's counsel may contact the identified 
individuals through that representative. 
8. 
If any of the individuals referred to in paragraph (7), supra, elects to file suit 
pursuant to 18 U.S.C. § 2255, Epstein will not contest the jurisdiction of the 
United States District Court for the Southern District of Florida over his person 
and/or the subject matter, and Epstein waives his right to contest liability and also 
waives his right to contest damages up to an amount as agreed to between the 
identified individual and Epstein, so long as the identified individual elects to 
proceed exclusively under 18 U.S.C. § 2255, and agrees to waive any other claim 
for damages, whether pursuant to state, federal, or common law. Notwithstanding 
this waiver, as to those individuals whose names appear on the list provided by the 
United States, Epstein's signature on this agreement, his waivers and failures to 
contest liability and such damages in any suit are not to be construed as an 
admission of any criminal or civil liability. 
9. 
Epstein's signature on this agreement also is not to be construed as an admission 
of civil or criminal liability or a waiver of any jurisdictional or other defense as to 
any person whose name does not appear on the list provided by the United States. 
10. 
Except as to those individuals who elect to proceed exclusively under 18 U.S.C. § 
2255, as set forth in paragraph (8), supra, neither Epstein's signature on this agreement, nor its 
terms, nor any resulting waivers or settlements by Epstein are to be construed as admissions or 
evidence of civil or criminal liability or a waiver of any jurisdictional or other defense as to any 
person, whether or not her name appears on the list provided by the United States. 
This was the final language. 
Please let me know if you need other information. "Thank you. 
A. Marie Villaaa 
Assistant U.S. Attorney 
500 S. Australian Ave, Suite 400 
2489 
08-80736-CV-MARRA 
PM 14357 
EFTA00194257

Villafana, Ann Marie C. (USAFLS) 
From: 
Villafana, Ann Marie C. (USAFLS) 
Sent: 
Sunday, June 29, 2008 12:15 PM 
To: 
Kuyrkendall, E N. (FBI) 
Subject: 
RE: Notice of Non-Compliance CONFIDENTIAL 
Hi Nesbitt -- I sent you an e-mail earlier today letting you know that Goldberger 
agreed to my change, so it looks like Monday is going to happen. I have spoken 
with the Chief and he also spoke to the Sheriff about serving the time out at the 
jail. The Chief also is going to call some victims to inform them that he 
received a call from the State Attorney's Office about a plea hearing on Monday. 
I am very surprised that there has been no press coverage. 
Yes, can we meet on Monday morning. I want to have the victim list ready to go 
before we head to the hearing in case we can get him to sign it right then and 
there. 
A. Marie Villafaha 
Assistant U.S. Attorney 
561 209-1047 
Fax 561 820-8777 
 
Original Message 
From: Kuyrkendall, E N. (FBI) 
Sent: Sunday, June 29, 2008 11:54 AM 
To: Villafana, Ann Marie C. (USAFLS) 
Subject: RE: Notice of Non-Compliance 
Marie, 
Just wanted to let you know Jason and I are working on the remaining 5 girls and 
getting everything ready for GJ. Did you ever hear back from Jack Goldberger? I 
spoke with Joe yesterday and he agreed with Dave, that the PBC Detention Center 
is the jail. He also mentioned any sentenced under a year is served at the jail. 
If over that, Epstein will be serving at the Dept of Correction which is the 
Stockade. Joe also mentioned that the Sheriff determines how the sentence is 
carried out. We have already met with the Colonel at the jail some months ago. 
If all goes well tomorrow, we should ALL meet with the Colonel again just to 
reiterate our position. We have not heard from AMOC but will let you know when 
we do. Give us a shout later today and let us know if you would like to meet us 
tomorrow morning prior to going to the courthouse. 
Nesbitt 
From: Villafana, Ann Marie C. (USAFLS) [Ann.Marie.C.Villafana@usdoj.gov] 
Sent: Saturday, June 28, 2008 11:20 AM 
To: jgoldberger@agwpa.com 
Cc: Atkinson, Karen (USAFLS); RBlack@RoyBlack.com 
758 
EFTA00194258

Villafana, Ann Marie C. (USAFLS) 
From: 
Villafana, Ann Marie C. (USAFLS) 
Sent: 
Sunday, June 29, 2008 5:20 PM 
To: 
Sloman, Jeff (USAFLS); Atkinson, Karen (USAFLS) 
Subject: 
JE 
Just got word from FAA that JE's plane is flying from NY to West Palm with a stop 
in Georgia (probably to pick up Goldberger from his vacation). So maybe tomorrow 
really will happen. 
The agents and I are meeting early tomorrow to finalize victim list in the hopes 
that he will sign the notification in the courtroom. Does that sound alright with 
you? 
Please let me know. 
757 
EFTA00194259

Villafana, Ann Marie C. (USAFLS) 
From: 
Sloman, Jeff (USAFLS) 
Sent: 
Sunday, June 29, 2008 5:22 PM 
To: 
Villafana, Ann Marie C. (USAFLS); Atkinson, Karen (USAFLS) 
Cc: 
Acosta, Alex (USAFLS) 
Subject: 
Re: JE 
Yes - go get him! Good luck. 
 
 Original Message  
From: Villafana, Ann Marie C. (USAFLS) 
To: Sloman, Jeff (USAFLS); Atkinson, Karen (USAFLS) 
Sent: Sun Jun 29 17:19:41 2008 
Subject: JE 
Just got word from FAA that JE's plane is flying from NY to West Palm with a stop 
in Georgia (probably to pick up Goldberger from his vacation). So maybe tomorrow 
really will happen. 
The agents and I are meeting early tomorrow to finalize victim list in the hopes 
that he will sign the notification in the courtroom. Does that sound alright with 
you? 
Please let me know. 
756 
EFTA00194260

Villafana, Ann Marie C. (USAFLS) 
From: 
Villafana, Ann Marie C. (USAFLS) 
Sent: 
Monday, June 30, 2008 10:11 AM 
To: 
Sloman, Jeff (USAFLS); Atkinson, Karen (USAFLS); Senior, Robert (USAFLS); Ball, Shawn 
(USAFLS); Acosta, Alex (USAFLS) 
Subject: 
Je 
It is done, we think 
755 
EFTA00194261

Villafana, Ann Marie C. (USAFLS) 
From: 
Villafana, Ann Marie C. (USAFLS) 
Sent: 
Monday, June 30, 2008 10:59 AM 
To: 
Brendan White 
Cc: 
Ball, Shawn (USAFLS) 
Subject: 
Cancellation of Grand Jury Appearance 
Dear Mr. White: At this time, the subpoena of Ms. Lacerda is withdrawn. If that should change, I will contact 
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 
754 
EFTA00194262

Villafana, Ann Marie C. (USAFLS) 
From: 
Brendan White Ibrendan@whiwhi.com] 
Sent: 
Monday, June 30, 2008 11:20 AM 
To: 
Villafana, Ann Marie C. (USAFLS) 
Subject: 
Re: Cancellation of Grand Jury Appearance 
Thank you for letting me know. I will inform Ms. Lacerda. 
Brendan 
-- Original Message ----
From: Villafana. Ann Marie C. (USAFLS) 
To: Brendan White 
Cc: Ball, Shawn (USAFLS) 
Sent: Monday, June 30, 2008 10:59 AM 
Subject: Cancellation of Grand Jury Appearance 
Dear Mr. White: At this time, the subpoena of Ms. Lacerda is withdrawn. If that should change, I will contact 
you. 
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 
753 
EFTA00194263

Recipient 
Read 
Campos. Cyndee (USAFLS) 
Read: 61301200811:31 AM 
Sloman, Jeff (USAFLS) 
Read: 6/30/2008 11:31 AM 
752 
EFTA00194264

Villafana, Ann Marie C. (USAFLS) 
From: 
Villafana, Ann Marie C. (USAFLS) 
Sent: 
Monday, June 30, 2008 11:30 AM 
To: 
Campos, Cyndee (USAFLS); Sloman, Jeff (USAFLS) 
Subject: 
Can I get a copy of the signed letter between Alex and Lilly? 
Importance: 
High 
Hi Cyndee or Jeff— Do we have a signed copy of the letter between Alex and Lilly where he modifies the 
agreement? I only have an c-mail containing the language. 
Thanks. 
A. Marie Villafana 
Assistant U.S. Attorney 
500 S. Australian Ave, Suite 400 
West Palm Beach, FL 33401 
Phone 561 209-1047 
Fax 561 820-8777 
Tracking: 
751 
EFTA00194265

Recipient 
Road 
Campos, Cyndee (USAFLS) 
Read: 6130/2008 11:32 AM 
750 
EFTA00194266

Villafana, Ann Marie C. (USAFLS) 
From: 
Villafana, Ann Marie C. (USAFLS) 
Sent: 
Monday, June 30, 200811:32 AM 
To: 
Campos, Cyndee (USAFLS) 
Subject: 
RE: Can I get a copy of the signed letter between Alex and Lilly? 
5618208711 
Thanks. 
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 
From: Campos, Cyndee (USAFLS) 
Sent: Monday, June 30, 2008 11:31 AM 
To: Villafana, Ann Marie C. (USAFLS) 
Subject: RE: Can I get a copy of the signed letter between Alex and Lilly? 
What is your fax number 
From: Villafana, Ann Mane C. (USAFLS) 
Sent: Monday, June 30, 2008 11:30 AM 
To: Campos, Cyndee (USAFLS); Sloman, Jeff (USAFLS) 
Subject: Can I get a copy of the signed letter between Alex and Lilly? 
Importance: High 
Hi Cyndee or Jeff— Do we have a signed copy of the letter between Alex and Lilly where he modifies the 
agreement? I only have an e-mail containing the language. 
Thanks. 
A. Marie Villafaila 
Assistant U.S. Attorney 
500 S. Australian Ave, Suite 400 
West Palm Beach, FL 33401 
Phone 561 209-1047 
Fax 561 820-8777 
Tracking: 
749 
EFTA00194267

Recipient 
Read 
Campos, Cyodee (USAFLS) 
Read: 6130/2008 11:33 AM 
748 
EFTA00194268

Villafana, Ann Marie C. (USAFLS) 
From: 
Villafana, Ann Marie C. (USAFLS) 
Sent: 
Monday, June 30, 200811:32 AM 
To: 
Campos, Cyndee (USAFLS) 
Subject: 
RE: Can I get a copy of the signed letter between Alex and Lilly? 
Sorry it is 561-820-8777 
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 
From: Campos, Cyndee (USAFLS) 
Sent: Monday, June 30, 2008 11:32 AM 
To: Villafana, Ann Marie C. (USAFLS) 
Subject: RE: Can I get a copy of the signed letter between Alex and Lilly? 
Sorry saw it 
From: Villafana, Ann Marie C. (USAFLS) 
Sent: Monday, June 30, 2008 11:30 AM 
To: Campos, Cyndee (USAFLS); Sloman, Jeff (USAFLS) 
Subject: Can I get a copy of the signed letter between Alex and Ully? 
Importance: High 
Hi Cyndee or Jeff— Do we have a signed copy of the letter between Alex and Lilly where he modifies the 
agreement? I only have an e-mail containing the language. 
Thanks. 
A. Marie Villafacia 
Assistant U.S. Attorney 
500 S. Australian Ave, Suite 400 
West Palm Beach, FL 33401 
Phone 561 209-1047 
Fax 561 820-8777 
Tracking: 
747 
EFTA00194269

Villafana, Ann Marie C. (USAFLS) 
From: 
Sent: 
To: 
Subject: 
Villafana, Ann Marie C. (USAFLS) 
Monday, June 30, 2008 12:13 PM 
Sloman, Jeff (USAFLS); Senior, Robert (USAFLS) 
PB Post Article.pdf 
Here is the latest. Jeff — Can you call me asap? I am meeting with Goldberger at 12:15. 
PB Post 
Article.pdf 
746 
EFTA00194270

Recipient 
'Jack Goldberger' 
Atkinson, Karen (USAFLS) 
Sloman, Jeff (USAFLS) 
Senior, Robert (USAFLS) 
Read 
Read: 8/30/2008 2:08 PM 
Read: 8130/20081:14 PM 
Read: 6/30/20081:04 PM 
745 
EFTA00194271

Villafana, Ann Marie C. (USAFLS) 
From: 
Villafana, Ann Marie C. (USAFLS) 
Sent: 
Monday, June 30, 2008 12:57 PM 
To: 
'Jack Goldberger 
Cc: 
Atkinson, Karen (USAFLS) 
Subject: 
Revised page one of Notification 
Dear Jack: Attached please find the first page of the Notification, revised to reflect the changed plea agreement 
term. 
Thanku. 
Victim 
itlficatIon and Nc 
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 
Tracking: 
744 
EFTA00194272

Villafana, Ann Marie C. (USAFLS) 
From: 
Oosterbaan, Andrew (CRM) 
Sent: 
Monday, June 30, 2008 2:19 PM 
l
To: 
Villafana, Ann Marie C. (USAFLS) 
[ 
Cc: 
Sloman, Jeff (USAFLS); Senior. Robert (USAFLS)
Subject: 
FW: Epstein pleads guilty in state court 
Attachments: 
Epstein pleads guilty in state court 
Congratulations, Marie — at long last! Your work on this matter was truly exceptional, and you obtained a very significant 
result that will serve the victims well. Please pass on my congratulations to the rest of your team. 
Drew 
743 
EFTA00194273