EFTA00225102

Villafana, Ann Marie C. (USAFLS) 
From: 
Sent: 
To: 
Cc: 
Subject: 
a 
Sloman, Jeff (USAFLS) <JSloman@usa.doj.gov> 
Tuesday, June 03, 200810:40 AM 
Villafana, Ann Marie C. (USAFLS) 
Campos, Cyndee (USAFLS); Senior, Robert (USAFLS) 
please review 
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se 
EXHIBIT B-128 
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U.S. Department of Justice 
First ..4ssisiani U.S. Attorney 
99 N.E. ith Siren 
Miami. FL 3313.2 
O051 961.9100 
United States Attorney 
Southern District of 
DELIVERY BY FEDERAL EXPRESS 
June 3, 2008 
Honorable Mark Filip 
Office of the Deputy Attorney General 
United States Department of Justice 
950 Pennsylvania Avenue, N.W. 
Washington, 
20530 
Re: 
Jeffrey Epstein 
Dear Judge Filip, 
Jeffrey Epstein was a part-time resident of Palm Beach County, Florida! In 2006, the 
Federal Bureau of Investigation began investigating allegations that, over a two-year period, 
Epstein paid approximately 28 minor females from Royal Palm Beach High School to come to 
his house for sexual favors.2 In July 2006, the matter was presented to AUSA A. Marie Villafalta 
of our West Palm Beach branch office to pursue a formal criminal investigation. That 
investigation resulted in the discovery of approximately one dozen additional minor victims. 
Over the last several months, approximately six more minor victims have been identified. 
Epstein has not resided in Palm Beach since he learned of the instant investigation. 
2 Epstein's sexual conduct with the victims included: instructing them to massage and pinch his 
nipples, masturbating in their presence, digitally penetrating them, using a vibrator on their vaginas, 
engaging in oral sex with them, having the victims perform oral sex on Epstein's adult girlfriend, and 
engaging in sexual intercourse, all in exchange for money, ranging from $200 to $1,000 per session. 
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AUSA Villafana has been ready to present an indictment to a West Palm Beach federal 
grand jury since May 2007. The prosecution memorandum and proposed indictment have been 
extensively reviewed and re-reviewed by Southern District of Florida (SDFL) Deputy Chief of 
the Criminal Division Andrew Lourie, Chief of the Criminal Division Matthew Menchel3, First 
Assistant United States Attorney Jeffrey H. Sloman4, United States Attorney R. Alexander 
Acosta as well as various members of the Child Exploitation and Obscenity Section (CEOS) at 
the Department of Justice including, but not limited to its Chief, Andrew G. Oosterbahn. Many 
of these legal and factual issues have been discussed and approved by Deputy Assistant Attorney 
General for the Criminal Division (DAAG) Sigal Mandelker and the Assistant Attorney 
General for the Criminal Division (AAG) Alice S. Fisher, as well as the Criminal Division's 
Appellate Section and the Office of Enforcement Operations regarding the petit policy. 
By May 2007, AUSA Villafaila began seeking approval from her supervisors to indict 
Epstein. Her immediate supervisor was Andrew Lourie. Mr. Lourie had served as the Chief of the 
Public Integrity Section at DOJ as well as in several supervisory positions in the SDFL. By 
mid-2006, he had returned to his position as the Deputy Chief of the Criminal Division in West 
Palm Beach (head of the West Palm Beach branch office), after serving as the interim Chief of 
the Public Integrity Section at DOJ at the request of AAG Fisher. By October 2007, Mr. Lourie 
would leave the SDFL to become AAG Fisher's Chief of Staff.5 Above Mr. Lourie in the SDFL's 
chain of command were Matthew Menchel, Criminal Division Chief, First Assistant USA 
Sloman and finally, U.S. Attorney Acosta. 
Prior to seeking approval to return an indictment, Epstein's legal team had been actively 
working to convince this Office that such action was not warranted. The legal team has consisted 
of many different local and national lawyers and law firms. It appears as though each lawyer 
and/or firm became actively involved depending upon which person from the SDFL and/or DOJ 
component was involved in the process. For example, at the end of 2006, former SDFL U.S. 
Attorney and EOUSA Executive Director Guy Lewis contacted former colleague AUSA 
Villafafia and, later Deputy Criminal Chief Lourie, when he learned that AUSA Villafalla was 
handling the federal investigation of Epstein. He asked to meet with her but she said that she 
believed such a meeting would be premature. In December, Lilly Ann Sanchez and Gerald 
Lefcourt again contacted AUSA Villafafia to set a meeting. In advance of such a meeting, AUSA 
Villaftula requested documents but that request was refused. Ms. Sanchez then contacted AUSA 
Lourie, who agreed to meet with Ms. Sanchez and Mr. Lefcourt. On February 1, 2007, Ms. 
Sanchez and Mr. Lefcourt met with AUSAs Lourie and Villafafia, as well as a member of the 
FBI, and presented defense counsel's view of the case and promised a willingness to assist in the 
investigation. The SDFL was unpersuaded by their presentation and the investigation continued. 
3Mr. Menchel resigned for private practice on August 3,2007 and was replaced by Robert Senior. 
4Although I, Jeffrey H. Sloman, am writing this letter, I will continue to refer to myself as 
"First Assistant USA Sloman" or "FAUSA Sloman" to help reduce any confusion. 
Rolando Garcia replaced Mr. Lourie as the Deputy Chief of the Criminal Division. 
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By the late Spring and early Summer, the focus of the investigation shifted from 
investigating the facts of the victims' claims to Epstein's background, his asserted defenses, 
co-conspirators, and possible witnesses who could corroborate the victims' statements. The 
investigation also began to look into financial aspects of the case, requiring the issuance of 
several subpoenas. At the time, Mr. Lefcourt began leveling accusations of improprieties with the 
investigation and sought a meeting with Criminal Division Chief Matthew Menchel. By that 
time, the proposed initial indictment package had been reviewed and approved by Mr. Lourie in 
West Palm Beach and by attorneys with CEOS; however, it awaited review by Mr. Menchel and 
FAUSA Sloman. The SDFL deferred presenting the indictment to the grand jury to accommodate 
the Epstein legal team's request for a meeting. We also agreed to wait several weeks for that 
meeting to occur to allow four of Epstein's attorneys to be present and also provided counsel with 
a list of the statutes that were the subject of the investigation. 
On June 26, 2007, Mr. Menchel, Mr. Lourie, AUSA Villafafia, and FAUSA Sloman, and 
two FBI agents met with Alan Dershowitz, Roy Black, Gerald Lefcourt, and Lilly Ann Sanchez. 
During that meeting Professor Dershowitz and other members of the defense team presented 
legal and factual arguments against a federal indictment. Counsel for the defense also requested 
the opportunity to present written arguments, which was granted. The arguments and written 
materials provided by the defense were examined by the SDFL and rejected. 
On July 31, 2007, Mr. Menchel, Mr. Lourie, AUSA Villafafia, and FAUSA Sloman, and 
two FBI agents met with Roy Black, Gerald Lefcourt, and Lilly Ann Sanchez. On that date, the 
SDFL presented a written sheet of terms that would satisfy the SDFL's federal interest in the case 
and discussed the substance of those terms. See Tab A. One of those terms was: 
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 the 
subject matter. Epstein will not contest that the identified victims are persons 
who, while minors, were victims of violations of Title 18, United States Code, §§ 
2422 and/or 2423. 
During that meeting, the focus was on Mr. Epstein's unwillingness to spend time in prison, and 
various suggestions were raised by defense counsel, including the proposal that he could serve a 
sentence of home confinement or probation. This was repeatedly mentioned by counsel for 
Epstein as being equivalent to a term of imprisonment in a state or federal prison. Epstein's 
counsel mentioned their concerns about his safety in prison, and the SDFL offered to explore a 
plea to a federal charge to allow Epstein to serve his time in a federal facility. Counsel were also 
presented with a conservative estimate of the sentence that Epstein would face if he were 
convicted: an advisory guideline range of 188 - 235 months' incarceration with a five-year 
mandatory minimum prison term, to be followed by lifetime supervised release. Counsel was told 
that Epstein had two weeks to accept or reject the proposal. 
It is critical to note that Ms. Sanchez, one of Epstein's local lawyers, seized upon this 
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method of restitution as a condition of deferring federal prosecution. In referring to the 18 U.S.C. 
§ 2255 method of compensation, Ms. Sanchez stated: 
[t)his would allow the victims to be able to promptly put this behind them and go 
forward with their lives. If given the opportunity to opine as to the appropriateness 
of Mr. Epstein's proposal, in my extensive experience in these types of cases, the 
victims prefer a quick resolution with compensation for damages and will always 
support any disposition that eliminates the need for trial. 
See attached Tab B, August 2, 2007 letter from Lilly Ann Sanchez to SDFL Criminal Division 
Chief Menchel, p.2, fn 1. Ironically, it is Epstein's "national" attorneys who are now representing 
to the Deputy Attorney General of the United States in their May 19, 2008 letter that: 
Perhaps most troubling, the USAO in Miami, as a condition of' deferring 
prosecution, required a commingling of substantive federal criminal law with a 
proposed civil remedy engineered in a way that appears intended to profit 
particular lawyers in private practice in South Florida with personal relationships 
to some of the prosecutors involved. 
Not only did Epstein's lawyers like the idea of using 18 U.S.C. § 2255 to compensate the victims 
but, they also sought to make their non-incarcerative state proposal even more attractive by 
offering payments to "a charitable organization benefitting victims of sexual assault," law 
enforcement investigative costs" and "Court and probationary costs." Id. at p. 2. 
Epstein's counsel, still dissatisfied with the Office's review of the case, demanded to meet 
with U.S. Attorney Acosta and to have the opportunity to meet with someone in Washington, 
To accommodate Roy Black, the meeting was put off until September 7, 2007, despite the 
ac that the indictment was ready for presentation to the grand jury. In the interim, AUSA 
Villafafia and the investigators met with CEOS Chief Oosterbahn, to review, yet again, the 
evidence and legal theories of prosecution. Chief Oosterbahn strongly supported the proposed 
indictment and even offered to join the trial team and provide additional support from CEOS. 
On September 7, 2007, U.S. Attorney Acosta met with Kirkland & Ellis partners Jay 
Lefkowitz and former Solicitor General Ken Starr and Ms. Sanchez, along with Chief 
Oosterbahn and AUSAs Villafana, John McMillan, and FAUSA Sloman.6 Messrs. Starr and 
Lefkowitz presented arguments regarding the sufficiency of the federal interest in the case and 
other legal and factual issues. We discussed those legal arguments and the unanimous opinion of 
all of the attorneys present was in favor of prosecution. During that meeting, Mr. Lefkowitz also 
offered a plea resolution. His offer, in essence, was that Epstein be subjected to home 
confinement at his Palm Beach home, using private security officers who would serve as his 
"wardens," if necessary. Mr. Lefkowitz expressed the belief that such a sentence would be 
particularly appropriate because, as a wealthy white man, he may be the subject of violence or 
6Roy Black did not attend. 
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extortion in prison. Finally, Messrs. Starr and Lefkowitz expressed the belief that Epstein's 
extensive philanthropy should be considered in our prosecution decision. U.S. Attorney Acosta 
summarily rejected these proposals, and indicated that the 24-month offer presented previously 
by the SDFL stood. 
The issue of the inclusion of a restitution-type remedy for the victims pursuant to 18 
U.S.C. § 2255 was specifically raised and discussed at the September 7th meeting, and Mr. Starr 
thanked AUSA Villafafia for bringing it to his attention as a novel approach to allowing the 
victims to receive essentially federal restitution while allowing a plea to a state charge. After 
considering everything said and written by Epstein's legal team, and after conferring with Chief 
Oosterbahn, U.S. Attorney Acosta informed Epstein's counsel that the SDFL still intended to 
proceed to indictment. Since counsel indicated a desire to appeal the matter to the Attorney 
General, the Deputy Attorney General, or the Assistant Attorney General for the Criminal 
Division, U.S. Attorney Acosta agreed to delay the presentation of the indictment for two weeks 
to allow them to speak with someone in Washington, IC., if they so chose. 
Instead, Mr. Epstein elected to negotiate the Non-Prosecution Agreement, and on 
September 12, 2007, counsel for the SDFL (AUSAs Lourie, Garcia, and Villafafta) and counsel 
for Epstein (Messrs. Lefcourt, Lefkowitz, and Goldberger) met with Palm Beach County State 
Attorney Barry Krisher and Assistant State Attorney Lanna Belohlavek to discuss a plea to an 
Information in the state court that would satisfy the federal interest in the case. As noted on the 
term sheet of July 31" (Tab A), one of those essential terms was a guilty plea to a charge 
requiring sex offender registration. During that meeting, the issue of sex offender registration 
was raised, and Mr. Goldberger told the' federal prosecutors that there was no problem, Mr. 
Epstein would plead guilty to the charge of procurement of minors for prostitution (Fl. Stat. 
796.03), which was one of the statutes listed on the original term sheet. Although the SDFL had 
wanted Epstein to plead guilty to three different offenses, we agreed to this compromise.' Of 
course, the SDFL later learned that, at the time Mr. Goldberger made that statement, he 
incorrectly believed, based upon a statement from ASA Belohlavek, that Fl. Stat. § 796.03 did 
not require sex offender registration. 
The parties then began working first on a plea agreement to a federal charge and, when it 
was clear that there was no guarantee that Epstein would serve his sentence in a minimum 
security prison camp, the discussion turned to a Non-Prosecution Agreement. Both the federal 
plea agreement and the Non-Prosecution Agreement included references to § 2255 because 
neither the contemplated federal charges nor the proposed state charges encompassed all of the 
identified victims. If Epstein had been prosecuted under the planned indictment, the identified 
victims would have been eligible for restitution and damages under § 2255. As explained 
above, one of our interests, which had to be satisfied by the Non-Prosecution Agreement, was 
providing appropriate compensation to the victims. This provision of the Agreement was heavily 
7 Another significant compromise reached at the meeting was a reduction in the amount of jail 
time - from 24 months down to 18 months, which would be served at the Palm Beach County Jail rather 
than a state prison facility. 
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negotiated. As Mr. Lefkowitz wrote in his November 29th e-mail to FAUSA Sloman, Epstein 
"offered to provide a restitution fund for the alleged victims in this matter; however, that option 
was rejected by [our] Office." That option was rejected for several reasons. First, the SDFL does 
not serve as legal representatives to the victims and has no authority to bind victims, nor could it 
provide a monetary figure that would represent a "loss" amount for restitution purposes. Second, 
there would be no legal basis for federal restitution without a conviction for a federal offense. 
And, third, it was the U.S. Attorney's belief that the SDFL should not be put in the position of 
administering a restitution fluid. Our § 2255 proposal put the victims in the same position that 
they would have been in if we had proceeded to trial and convicted Epstein of his crimes, with 
the exception that the victims were provided with counsel. The appointment of counsel was not 
such a benefit to the victims but, rather, was done, in part, to benefit Epstein by allowing him to 
try to privately negotiate a group resolution of all claims with one attorney. Epstein and his 
lawyers agreed with this alternative. 
The negotiation of the Agreement was lengthy and difficult. Mr. Lefkowitz and AUSA 
Villafafia went through several drafts of both a federal plea agreement and a Non-Prosecution 
Agreement. Throughout these negotiations, when a member of the defense team was dissatisfied 
with the SDFL's position, it was repeatedly appealed throughout the Office. So several members 
of the defense team spoke with the chain of command regarding the terms of the Agreement, 
including the § 2255 provisions. At the eleventh hour, when Epstein's legal team realized that Fl. 
Stat. 796.03 would require him to register as a sex offender, they sought to change the most 
essential term of the agreement - a term that Messrs. Goldberger, Lefkowitz, and Lefcourt had 
specifically agreed to at the September 12th meeting with the State Attorney's Office - asking to 
allow Epstein to plead to a charge that would not require registration. When this was rejected, 
several members of the defense team appealed directly to U.S. Attorney Acosta which also failed. 
When that failed, according to press reports, apparently Mr. Lefcourt "leaked" a letter intended 
for the U.S. Attorney to the press containing the reasons why he/Lefcourt did not believe Epstein 
should have to register. See October 9, 2007 New York Post article attached at Tab C. 
Prior to signing the Non-Prosecution Agreement, Mr. Epstein's defense team included 
Ken Staff, Jay Lefkowitz, Lilly Ann Sanchez, Alan Dershowitz, Gerald Lefcourt, Roy Black, 
Guy Lewis, Martin Weinberg, Jack Goldberger, Stephanie Thacker*, and the associates at 
Kirkland & Ellis who conducted research on discrete issues. This impressive legal team reviewed 
the Agreement and counseled Epstein. Based upon that counsel, Epstein decided that it was in his 
1
best interest to execute the Non-Prosecution Agreement which was signed on September 
, 
2007 by Mr. Lefcourt, Ms. Sanchez and Epstein. A copy of which is attached hereto as Tab . 
The core principles of the Agreement are incarceration, registration as a sex offender and a 
method of compensation.9 Furthermore, and significantly, Epstein agreed that he had the burden 
*Ms. Thacker had recently resigned from CEOS as a Trial Attorney and entered private 
practice. 
9 
• 
Specdically, the Agreement mandates, inter alio, (I) a guilty plea in Palm Beach County Circuit 
Court to solicitation of prostitution (Fl. Stat. § 796.07) and procurement of minors to engage in prostitution 
(FI. Stat. § 796.03) (an offense that requires him to register as a sex offender); (2) a 30-month sentence 
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of ensuring compliance of the Agreement with the Palm Beach County State Attorney's Office 
and the Judge of the 15°' Judicial Circuit and 'that the failure to do so will be a breach of the 
agreement" (emphasis added). To this day, the SDFL has never divulged its evidence to Epstein's 
lawyers. 
Within a week of the execution of the Agreement, the SDFL unilaterally proposed to 
divest its right to select the attorney representative for the victims. Contrary to Messrs. Starr and 
Whitley's recent assertion that this was "engineered in a way that appears intended to profit 
particular lawyers in private practice in South Florida with personal relationships to some of the 
prosecutors involved", it VMS done to avoid even the appearance of favoritism in the selection of the attorney 
representative. As a result, the parties executed an addendum which documented the SDFL's right to 
assign the selection of an attorney representative to an independent third-party. A copy of the 
October 29, 2007 Addendum is attached hereto as Tab 
arties subsequently agreed that 
retired Federal District Court Judge E 
B. 
should be that independent 
third-party/special master. Ultimately, Judge 
selecte 
o ert C. Josefsberg of the law firm 
of Podhurst, Orseck, Josefsberg, et al. I' During this same time frame, Epstein lawyer Jay 
Lefkowitz sought to delay the entry of his guilty plea and sentence. After the SDFL 
accommodated his request (from October 26th to November 20th), Mr. Starr began taking issue 
with the methodology of compensation, notification to the victims, and the issues that had been 
previously considered and rejected during negotiations, ie, that the conduct does not require registration and 
the contemplated state and federal statutes have no applicability to the instant matter. 
In response to Mr. Stares protests, the SDFL offered numerous and various reasonable modifications and 
accommodations which ultimately resulted in U.S. Attorney Acosta's December 19, 2007 letter to Lilly Ann Sanchez. See 
attached Tab F. In that letter, U.S. Attorney Acosta tried to eliminate all concerns which, quite frankly, the SDFL was not 
obligated to address, let alone consider. In consultation with DAAG Mandelker, Mr. Acosta proposed the following language 
regarding the 2255 provision: 
"Any person, who while a minor, was a victim of a violation of an offense enumerated in Title 18, United 
States Code, § 2255, will have the same rights to proceed under § 2255 as she would have had, if Mr. 
Epstein been tried federally and convicted of an enumerated offense. For purposes of implementing this 
paragraph, the United States shall provide Mr. Epstein's attorneys with a list of individuals whom it was 
prepared to name in an Indictment as victims of an enumerated offense by Mr. Epstein. Any judicial 
including 18 months' incarceration in county jail; (3) a methodology to compensate the victims identified 
by the United States utilizing 18 U.S.C. Section 2255 such that they would be placed in the same position 
as if Epstein had been convicted of one of the enumerated offenses set forth in Title 18, United States 
Code, § 2255; (4) entry of the guilty plea and sentence no later than October 26, 2007; and (5) the 
start of the above-mentioned sentence no later than January 4, 2008. 
10 Due to the subsequent objections raised by Epstein's counsel, Mr. Josefsberg was never 
given the opportunity to become the attorney representative. 
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authority interpreting this provision, including any authority determining which evidentiary burdens if any 
a plaintiff must meet, shall consider that it is the intent of the parties to place these identified victims in the 
same position as they would have been had Mr. Epstein been convicted at trial. No more; no less." 
Mr. Starr also objected to the SDFL's intention to notify the victims pursuant to 18 U.S.C. § 3771. In response to Mr. 
Starr's concerns, USA Acosta again consulted with DRAG Mandelker who advised him to make the following proposal: "(w)e 
will defer to the discretion of the State Attorney regarding whether he wishes to provide victims with notice of the state 
proceedings, although we will provide him with the information necessary to do so if he wishes." These proposals were 
immediately rejected by Epstein in Mr. Lefkowitz's December 26, 2007 correspondence to USA Acosta. 
At our December 14, 2007 meeting at the U.S. Attorney's Office in Miami, counsel for 
Epstein articulated that it 
was a "profound injustice" to require 
Epstein to register as a sex offender and reiterated that no federal crime, especially 18 
U.S.C. § 2422(b), had been committed since the statute is only violated if a telephone or means of interstate commerce is used 
to do the persuading or inducing. This particular attack on this statute had been previously raised and thoroughly considered 
and rejected by the SDFL and CEOS prior to the execution of the Agreement. Epstein's lawyers also argued that the facts were 
inapplicable to the contemplated state statutes and that he should not have been allowed to have been induced into the 
Agreement because the facts were not what he understood them to be. To reiterate, the SOIL has never divulged its evidence to 
anyone on the Epstein legal team. Once counsel for Epstein failed to persuade us that federal involvement was inappropriate, 
they mounted an aggressive campaign to defer federal prosecution. When we refused to compromise on anything except the 
length of incarceration, they finally executed the Non-Prosecution Agreement. 
Subsequent to the December 14, 2007 meeting, the SDFL received three letters from Mr. Lefkowitz and/or Mr. Starr 
which expanded on some of the themes announced in the December 14th meeting. Essentially, trying to portray the SOIL as 
trying to coerce a plea to unknown allegations and incoherent theories. In his December 17, 2007 correspondence, Mr. 
Lefkowitz decreed that 
Epstein's conduct did not meet the requirements of one of the state statutes Epstein agreed to plead 
guilty to - procurement of minors to engage in prostitution (Fl. Stat. § 796.03); that 
Epstein's conduct does not require 
registration under Florida law in contravention of the September 24 Agreement; and the State Attorney's Office does not 
believe the conduct is registrable. On December 21. 2007, Mr. Lefkowitz 
rejected the U.S. Attorney's proposed resolution of 
the 2255 provision because they "strongly believe that the provable conduct of Mr. Epstein with respect to these individuals 
fails to satisfy the requisite elements of either 18 U.S.C. Section(s) 2422(b) ... or ... 2423(6)." In his December 26, 2007 
correspondence, he stated that "we have reiterated in previous submissions that Mr. Epstein does not believe he is guilty of the 
federal charges enumerated under section 2255" and requiring "Mr. Epstein to in essence admit guilt, though he believes he 
did not commit the requisite offense." 
The SDFL reiterated time and time again that it had never wanted nor expected Epstein to plead guilty to a charge he 
did not believe he committed and repeatedly offered to dissolve the agreement to allow Epstein to 
contest the charges in the court system. As a result, the SDFL obliged his request for an independent de novo 
review of the investigation and facilitated such a review at the highest levels of the Department 
of Justice. As you know, on May 15, 2008, after months of considering the matter, the Criminal Division considered whether 
there is a legitimate basis for the SDFL to proceed with a federal prosecution of Mr. Epstein. CEOS Section Chief 
Oosterbahn concluded that "federal prosecution would not be improper or inappropriate." See 
attached May 15, 2008 letter from CEOS Section Chief Oosterbahn to Jay Lefkowitz. On May 
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19, 2008, I notified Mr. Lefkowitz that the SDFL would give Epstein a MI two weeks (close of 
business on Monday, June 2, 2008) to comply with the terms and conditions of the 
Non-Prosecution Agreement, as modified by the USA's December 19'" letter to Ms. Sanchez." 
Therefore, despite the fact that the investigation has identified several more victims, the SDFL is 
still offering Epstein the opportunity to comply with the terms and conditions of the 
Non-Prosecution Agreement. 
The SDFL was recently notified that the Office of the Deputy Attorney General has 
agreed to consider additional allegations not considered by CEOS which were recently raised in 
correspondence by two former high-ranking members of the Department of Justice - Ken Starr 
and Joe Whitley. On May 28, 2008, I notified Mr. Lefkowitz by e-mail that the SDFL has 
postponed the June 2, 2008 deadline until the DAG's Office has completed its review of this 
matter. Their correspondence to the DAG alleges that the SDFL's investigation lacks integrity 
because it has leaked "highly confidential aspects" of the investigation and negotiations to the 
New York Times and that I/FAUSA Sloman directed some of the victims to my former law firm. 
They also claim that the "unprecedented extension of federal law" by the SDFL suggests that this 
is politically motivated because Epstein is a prominent figure with "close ties to former President 
Clinton." Messrs. Starr and Whitley go on to claim that FAUSA Sloman unilaterally, arbitrarily 
and unnecessarily imposed a June 2, 2008 deadline in order to prevent Epstein from seeking your 
Office's review and that "the unneroqsary deadline is even more problematic because Mr. 
Epstein's effort to reconcile the state charge and sentence with the terms of the Agreement 
requires an unusual and unprecedented threatened application of federal law." 
1. 
The Alleged "Leak'to the New York Times. 
AUSA David Weinstein became involved in this matter in his capacity as back up for the 
District's Public Information Officer (PIO). While the District's PIO was on annual leave, he 
was the acting PIO during the first week of January 2008. The entirety of his conduct in 
connection with the Epstein matter began on January 2, 2008 and ended on January 7, 2008.12
Specifically, his contact involved five telephone conversation with Landon Thomas, a reporter 
for the New York Times. These conversations occurred on I) the morning of January 2, 2008, 
2) the afternoon of January 2, 2008, 3) the afternoon of January 3, 2008, 4) the afternoon of 
January 4, 2008, and 5) the afternoon of January 7, 2008. 
A. 
The Morning ofJanuary 2, 2008. 
11 Mr. Lefkowitz was placed on notice on February 25, 2008, that in the event that CEOS 
disagreed with Epstein's position, Epstein would have one week to comply with the terms and conditions 
of the Agreement, as modified by the USA's December 19" letter to Ms. Sanchez. 
12AUSA Weinstein has self-reported to the Office of Professional Responsibility. 
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AUSA Weinstein began his conversation with Mr. Thomas by explaining that he was the 
acting PIO for the week and that he had received Mr.Thomas's December 31, 2007 e-mail 
requesting an interview and asking for comments on the following five statements.13 First, "that in 
the summer of 2005 the palm beach police department referred the Epstein case to you." Second, "that the case is being 
overseen by Jeffrey Sloman, and above him, It Alexander Acosta." Third, "that Mr. Acosta has made child pornography a focus 
are [sic] for your office." Fourth, "that this summer your office gave Mr. Epstein an ultimatum: 
plead guilty to a charge that 
would require him to register as a sex offender, or the government would release a 52 page indictment, charging him with 
crimes that could include procuring sex for a third party or engaging in sexual tourism. Both of these charges carry jail sentences 
of as much as 15 years." Fifth, "that your office told Mr. Epstein and his lawyers: we are ready to pull the trigger." Sixth, "I also 
wanted to ask Mr. Sloman about his role in a case involving Jonathan Zirulnikoff and his daughter earlier this year." 
At the outset, Weinstein said that he could not comment on any specific pending matters 
and that he would do his best to answer some of his questions. Thomas said that his questions 
were based, in part, upon conversations that he had already had with members of Mr. Epstein's 
defense team, prior published reports of a pending State case against Mr. Epstein and public 
information available through the State Court system. 
Weinstein refused to answer the first question. As to the second question, Weinstein told 
him that any matter arising out of conduct in Palm Beach County, was prosecuted by our West 
Palm Beach branch office. He also told him that as First Assistant, the FAUSA had supervisory 
authority over all AUSAs throughout the District. In turn, the FAUSA answered directly to the 
U.S. Attorney. 
In response to the third question, Weinstein discussed the difference between child 
exploitation and child pornography. Weinstein said that federal crimes involving child 
exploitation were one of several focus points of our Office. He further explained that in addition 
to traditional federal areas of prosecution the other focus points included health care fraud and 
gang prosecutions. 
Weinstein refused to answer the fourth and fifth topics but did discuss the general nature 
of pre-trial proceedings in federal court. He said that the SDFL does not offer ultimatums, nor 
are we in the business of issuing ultimatums. He explained that in cases where a party wants to 
plead guilty prior to indictment, we will discuss the parameters of guilty pleas and that people 
always have the right to proceed to trial if they choose to do so and that we do not favor one 
resolution over the other. Weinstein told Mr. Thomas that he would not discuss his specific 
question about Mr. Epstein's lawyer's statement that someone from our Office told them that "we 
are ready to pull the trigger." Nor would he discuss anything about who might or might not be 
representing Mr. Epstein. Weinstein told Mr. Thomas that he should not allow himself to be spun 
13After reviewing his e-mail, AUSA Weinstein discussed the matter with U.S. Attorney Acosta. 
Pursuant to USAM 1-7.530 and the Media Relations Guide, Section Ill D2, after consultation with and 
prior approval from the US Attorney, he called Mr. Thomas on the morning ofJanuary 2nd. 
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one way or the other in response to statements Mr. Thomas said he had received from attorneys 
who said that they represented Mr. Epstein. Weinstein ended the conversation by telling Mr. 
Thomas that he would check further into his sixth and final topic and get back to him later in the 
day. 
B. 
Afternoon of January 2, 2008. 
Weinstein informed Mr. Thomas that in regard to his sixth topic, the SDFL had no reason 
to question FAUSA Sloman's judgment or integrity. He also said that this particular subject 
matter was a private matter that FAUSA Sloman did not want to discuss with him.1° Mr. Thomas 
told him that if he had any further questions, he would call back. 
C. 
Afternoon of January 3, 2008. 
This call was in response to a voice mail message that Mr. Thomas had left regarding 
legal issues involving specific state and federal statutes. Specifically, Mr. Thomas had some 
questions about the burden of proof and strict liability in some state and federal statutes that 
governed illegal sexual activity. Again, Weinstein told him that he would not discuss any 
specific cases, but that he would assist him in understanding the statutes about which he had 
some questions. Weinstein explained that some statutes contained defenses that must be proven 
by a defendant, while there were other statutes that did not require a defendant to affirmatively 
prove a defense. The discussion centered around Title 18, United States Code, § 2423(g). Once 
again, Mr. Thomas told Weinstein that if he had any further questions, he would call back. 
I
Afternoon ofJanuary 4, 2008. 
This was another call in response to a voice mail message that Mr. Thomas had left 
regarding some additional questions. Weinstein prefaced the conversation by saying that he 
would not discuss any specific cases. The conversation centered around three specific statutes, 
18 United States Code, § 2422(b), 18 United States Code, § 1591, and 18 United States Code, § 
2423(b) as well as the burden of proof and the applicability of affirmative defenses. They 
discussed the difference between an attempt and a substantive charge pursuant to § 242203) and 
how that affected the government's burden of proof vis-a-vis the age of a child. They also 
14 The case involving "Jonathan Zirulnikoff • involved a March 7, 2007 early morning attempted 
break-in of my/Sloman's house. Zirulnikoff, age 19 at the time, confessed and said that he wanted to "talk" 
to my daughter who was then 16. He also confessed to a prior unrelated break in which Zirulnikoff 
caressed the inner thigh of a 15 year old female. Zirulnikoff who had graduated from my daughter's high 
school in June 2006, dated my daughter's friend and had little if any contact with my daughter for over one 
year. Zirulnikoff negotiated a plea deal, over my objection, with the Miami-Dade State Attorney's Office to 
a misdemeanor trespass. That conviction resulted in a sentence of two years probation and a withhold of 
adjudication upon successful completion of his probationary period. Since this information was completely 
irrelevant to the facts and issues in the instant Epstein matter, I refused to allow Mr. Weinstein to comment 
about this matter to Mr. Thomas. Furthermore, none of this information had been publicized and, upon 
information and belief, only one member of Epstein's legal team knew anything about this matter, my 
former colleague, Lilly Ann Sanchez. 
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discussed the fact that a charge pursuant to § 1591 required the government to prove that the 
defendant had actual knowledge of the age of the victim. Finally, they discussed the fact that if 
the government was charging a defendant with traveling to engage in prostitution, pursuant to § 
2423(3), there was an affirmative defense available to the defendant regarding the reasonable 
belief of the defendant about the age of the victim. 
E. 
Afternoon ofJanuary 7, 2008. 
This final call was made after the U.S. Attorney and FAUSA Sloman had received a call 
from a member of Mr. Epstein's defense team alleging that the SDFL had provided case specific 
information to the media. Weinstein called Mr. Thomas who acknowledged that both before 
and after each of the above-mentioned conversations, he had also called attorneys who were 
representing Mr. Epstein on his pending State charges. Mr. Thomas also acknowledged that all 
of our prior conversations had been about general legal issues and that Weinstein never spoke 
about any specific case. Since the January 7,2008 conversation, Weinstein has not had any 
further contact with Mr. Thomas. 
2. 
Herman S/oman &Mermehrein. 
Seven years ago. I resigned from the SOH. for private practice. less than five months later, I resigned from the law firm 
and returned to the SDFL. Public records reflect the following: on May 8, 2001, articles of amendment were filed with the 
Florida Division of Corporations to reflect that the firm name of "Herman & Mermelstein" was changed to "Herman Sloman & 
Mermelstein" on May 7, 2001. 
I joined the firm at that time and remained a non-equity partner until on or about October 1, 
2001. At that time, I resigned from the firm and returned to the SDFL. Since I never had an equity interest in the firm, I never 
retained an interest in the firm. That was over six and one half years ago. 
Unbeknownst to FAUSA Slornan, on July 2, 2002, articles of amendment were filed with the Florida Division of 
Corporations to reflect that the firm name of "Herman Sloman & Mermelstein" was changed back to "Herman & 
Mermelstein." 
The article of amendment indicates the amendment was adopted on July 1, 2002, without shareholder action. 
Although the filing was not immediate upon my departure from the law firm, it pre-dated for years any dealings with the 
subject case now under consideration by the SOFL. Recently, I learned that there is a reference to the law firm of "Herman 
Annan& Mermelstein" on the Florida Bar website, under a section called "Find A Lawyer." This reference appears when Stuart 
Mermelstein's name and information is accessed. To reiterate, since October 2001. I have had no relationship with that law 
firm, financial or otherwise, and no input or control over the firm's filings with the Florida Division of Corporations and/or the 
Florida Bar. 
On Friday, January 18, 2008, at approximately 1:15 pm, I received a call from Jeffrey Herman of Herman & 
Mermelstein. 
Herman said that he was planning to file a civil lawsuit the next week against Jeffrey Epstein. He said that his 
clients were frustrated with the lack of progress of the state's investigation and wanted to know whether the SDFL could file 
criminal charges even though the state was looking into the matter. I told 
Herman that I would not answer any question 
related to Epstein — hypothetical or otherwise. I asked him how his clients retained him and he said that it was through another 
lawyer. I then specifically asked him whether the referral was the result of anyone in law enforcement contacting him and/or 
the other lawyer. He said "no." At the conclusion of the conversation, I reiterated and confirmed with him that I had refused to 
answer any questions he asked of me. I immediately documented this conversation and informed the U.S. Attorney who 
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informed Senior Litigation Counsel and Ethics Advisor Dexter Lee. AUSA Lee opined that he did not see a conflict. As soon as 
became aware of these allegations, reported myself to the Office of Professional Regulation on or about April 21, 2008. 
3. 
The Alleged Unprecedented Extension of Federal Law and the Allegations of 
Political Motivation for the Prosecution. 
It is my hope that this letter has sufficiently explained how thoroughly this matter has 
been reviewed, how seriously the issues have been considered, and how additional delays may 
adversely affect the case going forward and, more importantly, the victims. I have attached the 
proposed indictment for you to consider the nature and gravity of the crimes. See Tab G. You are 
invited to evaluate whether I, along with U.S. Attorney Acosta, Criminal Division Chiefs 
Menchel and, later Robert Senior, Deputy Criminal Division Chiefs Lourie, followed by Rolando 
Garcia, and AUSA Villafafla have somehow steered this investigation toward "an unprecedented 
extension of federal law"despite being simultaneously and/or subsequently reviewed by CEOS, 
DAAG Mandelker, and AAG Fisher. I also hope that the reputations of the above-mentioned 
professional prosecutors combined with the documented layers of methodical and thorough 
review of all issues raised by Epstein are enough to summarily dismiss the idea that this matter is 
politically motivated. It seems incomprehensible how Messrs. Starr and Whitley could expect 
further review when the due process rights of their client have been considered and reconsidered 
to the point of absurdity. 
With respect to the other allegations of misconduct leveled against investigators and 
prosecutors, similarly false allegations were made against the local police detective who first 
investigated the case. Those false allegations apparently were accepted as true and were not 
investigated or challenged by the State Attorney's Office and, when coupled with the immense 
pressure brought to bear upon the State Attorney by some of these same lawyers who represent 
Epstein today, resulted in a single felony charge related to only two of the more than 20 victims 
identified in the state investigation. Contrary to the claims of Epstein's attorneys, the SDFL is not 
trying to prosecute Epstein more harshly because of his political friends or his financial status; 
rather, the SDFL is attempting to follow Department policy by treating Epstein like all other 
criminal defendants - charging him with the most serious readily provable offenses. The SDFL 
has even continued to allow Epstein the opportunity to perform his obligations under the 
Non-Prosecution Agreement despite his numerous breaches of and attacks on the terms to which 
he already agreed. 
Without attempting to address each and every allegation, I would like to highlight some 
of the misstatements contained in counsels' letter, to provide some sense of counsels' conduct 
throughout this case, particularly after their attempts at legal persuasion failed. Throughout the 
case, counsel have misrepresented the facts of the case to our Office, CEOS, and the press. For 
example, Epstein's counsel reference to this case as "precedent-shattering," suggests that all of 
the victims were at least 16 years old, and that the conduct "was purely local in nature." The 
SDFL has prosecuted several "sex tourism" cases where the "john" communicated via telephone 
with an undercover "pimp" in the SDFL to meet minor females to engage in prostitution. All 
were charged and convicted of violating 18 U.S.C. § 1591. The SDFL has charged and 
convicted a 21-year-old man of violating 18 U.S.C. § 2423 when he traveled to Florida to meet 
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his 14-year-old girlfriend and later digitally penetrated her. The SDFL has prosecuted numerous 
violations of 18 U.S.C. § 2422 where the "facility of interstate commerce" - generally the intemet 
and telephones - are used by a defendant and an undercover pretending to be the parent of a 
minor, to arrange for a meeting that the defendant hopes will result in sexual activity. There is 
nothing extraordinary about Epstein's case except the large number of victims involved. 
Epstein's counsel neglected to inform you that the age range of the victims includes girls 
as young as 14, and glosses over the fact that Epstein did not simply engage in "solo 
self-pleasuring" in front of the victims. Instead, with each visit, he pressured the victims to 
allow him to engage in more and more sexual activity - fondling breasts and vaginas, digital 
penetration, use of a vibrator on their vaginas, performing oral sex on them, having them perform 
oral sex on his adult girlfriend, and engaging in sexual intercourse. Counsel also neglected to 
inform you that many girls did affirmatively tell Epstein their true ages and he told several that he 
"did not care about age." 
Epstein's conduct was not "purely local? He and his assistants called and sent text 
messages to victims in Palm Beach County from other states to arrange "appointments" for his 
upcoming visits to Palm Beach. And, while in Palm Beach, Epstein and his assistants called 
victims in New York to arrange "appointments" for his return to New York. Epstein wired 
money to some victims and sent gifts through the mails. This case falls squarely within federal 
jurisdiction. 
Epstein also falsely claims that certain facts related to the resolution of the case were 
hidden and later discovered by his lawyers. For example, they complain about the proposed use 
of a guardian ad litem, stating that "Mr. Epstein's counsel later established that all but one of 
these individuals were adults, not minors." It was AUSA Villafafia who told Epstein's counsel 
that all of the victims but one had already reached the age of majority, which was one reason why 
the guardian ad litem procedure proposed by Epstein's counsel would not work. Likewise, 
AUSA Villafafla disclosed to Epstein's counsel that one of the five attorney-representatives that 
she recommended for consideration by Epstein's counsel was a "good friend" of a "good friend." 
Despite the disclosure of this relationship, Epstein's counsel selected that person, before the 
SDFL, on its own, decided to use an independent Special Master to make the selection. 
Epstein's counsel states that the "USAO eventually asserted that it could not vouch for the 
veracity of any of the claims that these women might make," but neglects to disclose that the 
SDFL made that statement at Epstein s request to avoid the suggestion that the SDFL was 
involving itself in the outcome of civil litigation. 
Epstein's counsel have repeatedly attacked the SDFL and the FBI for classifying the 
victims as "victims." As you know, all Justice Department employees have the obligation to 
identify victims and to notify them of their rights. "Victims" are defined by law, not by 
self-selection. The girls whom have been identified by the FBI and the SDFL fall within the 
legal definition - they were all minors who engaged in illicit sexual activity with Jeffrey Epstein, 
at his request, in exchange for money. From interviewing them, the FBI Special Agents, the FBI 
Victim-Witness Coordinator, and AUSA Villafafla all feel confident that they suffered harm, in a 
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multitude of ways, by their interaction with Epstein. 
Finally, in contrast to Epstein's counsel allegation that my June 2, 2008 deadline was 
"arbitrary, unfair, and unprecedented," please consider that Mr. Lefkowitz has known since 
February that in the event that CEOS disagreed with his position, Epstein would be given 
one-week to comply with the Non-Prosecution Agreement. Subsequent to the receipt of CEOS 
Section Chief Oosterbahn's May 15, 2008 letter, I notified Mr. Lefkowitz that Epstein would 
have a full two-weeks to comply with the Non-Prosecution Agreement as modified by the 
December 19th letter to Ms. Sanchez. We believe it is finally time to shift the focus from 
Epstein's due process rights to treating him like all other similarly situated criminal defendants 
and perhaps, most importantly, to consider the rights of his victims. Continued delays adversely 
effect the case and the victims in the following ways: 
(1) 
at the time of the offenses, the victims ranged in age 
from 14 to 17 years old. The change 
in physical appearance of many of 
the victims since then has been 
dramatic. Epstein has been claiming 
that he did not know they were 
minors. Obviously, the older they 
look when the case is at issue, the 
harder it will be to overcome that 
defense; 
(2) 
it allows Epstein's lawyers to conduct depositions of the victims in the 
pending state criminal case and allows his private investigators to further 
harass and intimidate the victims; 
(3) 
more victims will seek the services of civil lawyers to file lawsuits thus 
allowing Epstein to make more powerful arguments demeaning the 
credibility of the victims; 
(4) 
the prosecutors and agents may retire, transfer and/or leave the Department 
for other opportunities thus affecting the potential outcome and 
prosecutorial resources. Additionally, 
several of the victims have 
relocated thus increasing the likelihood that crucial witnesses will be lost; 
(5) 
the SDFL has afforded more consideration to Epstein's arguments than any 
other defendant in my years of being the FAUSA and, before that, the 
Chief of the Criminal Division (January 1, 2004 to the present). I believe 
that we have been disproportionally fair to Epstein at the expense of other 
matters; and 
(6) 
prolonged delay may adversely affect the statute of limitations for some of 
the victims. 
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On behalf of the SDFL and the victims in this case, please expedite the review and 
decision of the issues under consideration. 
Sincerely, 
R. Alexander Acosta 
United States Attorney 
By: 
Jeffrey H. Sloman 
First Assistant United States Attorney 
Ends. 
cc: 
Robert Senior, Chief 
Criminal Division 
A. Marie Villafafla 
Assistant U.S. Attorney 
Karen Atkinson 
Assistant U.S. Attorney 
08-80736-g-MARRA 
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Villafana, Ann Marie C. (USAFLS) 
From: 
Villafana, Ann Marie C. (USAFLS) <AVillafana@usa.doj.gov> 
Sent: 
Friday, June 06, 2008 3:04 PM 
To: 
Kuyrkendall, E N. (MM) (FBI) 
Subject: 
RE: Call from M's attorney 
Does she have any criminal history? And can you subpoena her driver's license and autotrack? 
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 
 
Original Message-----
From: Kuyrkendall, E N. (FBI) 
Sent: Friday, June 06, 2008 2:50 PM 
To: Villafana, Ann Marie C. (USAFLS) 
Subject: Re: Call from M's attorney 
I can do a more extensive phone interview with 
and cont to try and locat=ildont know of anyone else that would have 
info o a. 
check on A file on Monday. 
Pre ' 
phone numbers and/or bills from 
04-05. Plus standard lang about gifts, cards and such pertaining to Epstein, 
 
 Original Message ----
From: Villafana, Ann Marie C. (USAFLS)<Ann.Marie.C.Villafana@usdoj.gov> 
To: Kuyrkendall, E N.; Richards, Jason R. 
Sent: Fri Jun 06 14:40:06 2008 
Subject: Call from M's attorney 
attorney called and she would really like full immunity. I said no, so she will have to come and testify in front of the grand 
jury and assert the fifth as to each question. I will start putting together a list of questions for her and send it to you. I also am 
wondering whether we should subpoena any records from her to bring with her to the grand jury. 
1 told him that we will need to see her on a Tuesday in June, he is going to call me back with a date. I also told him that we would pay 
for her plane ticket but not his. 
Can you try to find out if she has an A-file and, if so, get a copy before then? And do you want to try to interview some other New 
York people before she comes to testify? 
Thank you. 
A. Marie Villafana 
Assistant U.S. Attorney 
500 S. Australian Ave, Suite 400 
08-80736-CV-MARRA 
60 
EXHIBIT B-129 
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West Palm Beach, FL 33401 
Phone 561 209-1047 
Fax 561 820-8777 
08-80736-CV-MARRA 
P-014973 
61 
EFTA00225360

Villafana, Ann Marie C. (USAFLS) 
From: 
Kuyrkendall, E N. (FBI) <E.Kuyrkendall@ic.fbi.gov> 
Sent: 
Friday, June 06, 2008 3:39 PM 
To: 
Villafana, Ann Marie C. (USAFLS) 
Subject: 
Re: Call from ■attorney 
I will provide info to u on Monday. 
 
Original Message 
From: Villafana, Ann Marie C. (USAFLS) <Ann.Marie.eillafana@usdoj.gov> 
To: Kuyrkendall, E N. 
Sent: Fri Jun 06 15:04:04 2008 
Subject: RE: Call from It attorney 
Does she have any criminal history? And can you subpoena her driver's license and autotrack? 
Thanks. 
A. Marie Villafafia 
Assistant U.S. Attorney 
500 S. Australian Ave, Suite 400 
West Palm Beach, FL 33401 
Phone 561 209-1047 
Fax 56I 820.8777 
 
Original Message 
From: Kuyrkcndall, E N. (FBI) 
Sent: Friday, June 06, 2008 2:50 PM 
To: Villafana, Ann Marie C. (USAFLS) 
Subject: Re: Call from M's attorney 
I can do a more extensive phone interview with 
and cont to try and locate Leanne. Idont know of anyone else that would have 
info on IM 
other Leslie G. 
c eck on A file on Monday. 
Preliphone numbers and/or bills from 
04-05. Plus standard lang about gifts, cards and such pertaining to Epstein, Leslie, Ciceila and 
---- Original Message 
From: Villafana, Ann Marie C. (USAFLS)<Ann.Marie.C.Villafana@usdoj.gov> 
To: Kuyrkendall, E N.; Richards, Jason R. 
Sent: Fri Jun 06 14:40:06 2008 
Subject: Call from M's attorney 
a
attorney called and she would really like full immunity. I said no, so she will have to come and testify in front of the grand 
assert the fifth as to each question. I will start putting together a list of questions for her and send it to you. I also am 
wondering whether we should subpoena any records from her to bring with her to the grand jury. 
I told him that we will need to see her on a Tuesday in June, he is going to call me back with a date. I also told him that we would pay 
for her plane ticket but not his. 
Can you try to find out if she has an A-file and, if so, get a copy before then? And do you want to try to interview some other New 
York people before she comes to testify? 
Thank you. 
A. Marie Villafafia 
Assistant U.S. Attorney 
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