EFTA00225378

Memorandum 
Subject 
Memorandum seeking Travel Authorization 
Operation Leap Year 
Dote 
June 20, 2008 
TO 
Rolando Garcia, Deputy Chief 
Criminal Division 
Karen Atkinson, Chic 
Northern Division 
From 
A. Marie Villaf 
Assistant U.S. A 
I. 
INTRODUCTION 
This memorandum seeks travel authorization to travel to New York from June 19 to June 20, 
2008, in connection with Operation Leap Year. 
II. 
THE PROPOSED TRAVEL AND ITS PURPOSE 
As you know, we plan to present a final indictment to the grand jury in approximately two 
weeks. Since our original planned indictment, we have learned about a series of victims in New 
York and the 
ssible involvement of Epstein's two New York-based assistants, 
and 
The inclusion of New York victims would be a great benefit to the indictment, and 
we would like to interview some key people in New York in order to include that evidence in the 
indictment. 
Accordingly, I propose to travel to New York on the afternoon of Thursday, June 19 to 
conduct interviews on Friday, June 20, 2008.' FBI Special Agents Nesbitt Kuyrkendall and Jason 
Richards also will be traveling, although they may stay longer. 
First, we would like to interview 
She has been identified by two victims 
as someone who recruited numerous others to Epstein's New York residence. We know that Lacerda 
was going to Epstein's home when she was 14, and it is possible that she was going there as early 
as 13. This trip is contingent upon approval from the Justice Department of our immunity request 
for Lacerda. Yesterday I spoke with someone at the Witness Immunity Unit who stated that we 
'I may decide to stay in New York on Friday night in order to see a college friend. If I do, 
I will pay for the hotel room on Friday night and any difference in the airfares. 
EXHIBIT B-132 
Case No. 08-80736-CV-MARRA 
P-008379 
EFTA00225378

should have the approval by early next week.' 
In addition, a witness here in the Palm Beach area came forward recently to inform the FBI 
about a link between Epstein and the MC Modeling Agency. The witness stated that Epstein and 
the head of MC2, Jean Luc Brunel, worked together to obtain fraudulent visas to bring potential 
models to the United States. The witness stated that Epstein selected some of the underage girls to 
come to the United States even though Brunel never intended to use them as models so that Epstein 
could engage in sexual activity with them. Brunel's name appears on several of the message pads 
recovered during the search of Epstein's home. Some of the messages describe young girls that he 
would like Epstein to meet (including a I6-year-old who would "teach Russian" to Epstein). The 
FBI previously tried to interview Brunel, but he refused to speak with them. The Palm Beach 
witness has told the FBI that a former MC2 employee is willing to speak with the FBI about the 
fraud. 
Yesterday, the FBI in New York arrested two Bear Steams employees for securities fraud 
related to Bear Steams hedge funds involved in the subprime loan crisis. Epstein has been reported 
as one of the creators of those hedge funds in financial news sources. The agents here are contacting 
the New York agents to determine if Epstein is a target/subject of the New York investigation and 
also to find out whether the two employees are cooperating and would be willing to speak with us. 
For the foregoing reasons, I recommend that the Office approve the costs of a hotel room and 
a flight for my travel to New York. 
'-Travel plans will not be made until the immunity is confirmed. 
-2-
Case No. 08-80736-CV-MARRA 
P-008380 
EFTA00225379

‘A0/10 (Ho 04/07)Suboxra Co Testify Before Grand Any 
UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
TO: 
SUBPOENA TO TESTIFY 
BEFORE GRAND JURY 
01.1031MPB1-Tues. No. OLY-05/2 
SUBPOENA FOR: 
e PERSON 
I DOCUMENT(S) OR OBJECTS) 
YOU ARE HEREBY COMMANDED to appear and terrify before the Grand Jury of the United States District 
Court at the place, date, and lime specified below, 
PLACE 
United States District Court 
701 Clematis Street 
West Palm Beach. Florida 33401 
COURTROOM 
Grand Jury Room 
DATE AND TIME 
71112008 10:30 am 
YOU ARE ALSO COMMANDED to bring with you the following document(s) or object(s):* 
ALL DOCUMENTS AND INFORMATION REFERENCED IN THE ATTACHMENT TO THIS SUBPOENA. 
U Please see additional information on rei • 
This subpoena shall remain in elf 
behalf of the court. 
This subpoena is issued on application 
or the 
of A 
• Ilea applicable. eat 'none" 
In by the cowl or by an officer acting on 
NAME ADDRESS AND PHONE NUMBER OF ASSISTANT U S ATTORNEY
AnnMarie C. Villaf aria , Assistant U.S. Attorney 
500 South Australian Avenue, Suite 400 
West Palm Beach, Florida 33401-6235 
Tel (561) 820.8711, ext 3047 
Case No. 08-80736-CV-MARRA 
P-008381 
EFTA00225380

ATTACHMENT TO GRAND JURY SLBPOENA OLY-85/I 
ADDRESSED TO 
PLEASE BRINGTHE. FOLLOWING DOCUM ENTS, FILMS, AND INFORMATION WITH YOU 
TO YOUR GRAND JURY APPEARANCE: 
1. 
Any and all notes, letters, cards, ifts, a ments, hoto ra hs, or other items that 
u 
"'
received from Jeffrey Epstein, 
Lesley Groff, Ghislaine Maxwell. and/or any other employee or associate o Je rey Epstein. 
2. 
An and all hot 
a hs, whether printed or di ital, ofJeffrey Epstein, 
. Cecilia Steen,
 Ghislaine Maxwell, and/or any 
other employee or associate o Jeffrey Epstein. 
3. 
Any and all e-mails, instant messages, chats, text messages, voiccmails or tele hone 
10111
t
received from Jeffrey Epstein. 
. 
Lesley Groff, Ghislaine Maxwe a 
or any of r 
employee or associate o Je rey Epstein. 
4. 
A list of all telephone numbers (cellular and "land line"), c-mail addresses, screen 
names, addresses, and any other contact information that you have for the following persons during 
the period of January I, 2003 to the present: 
a. 
yourself; 
b. 
Jeffrey Epstein; 
c. 
d. 
e. 
f. 
g. 
h. 
Ghislaine Maxwell; 
i. 
any person(s) who introduced you to Jeffrey Epstein and/or Ghislaine 
Maxwell; 
any person(s) whom you introduced to Jeffrey Epstein and/or Ghislaine 
Maxwell; 
k. 
any person(s) who communicated with you to arrange appointments to meet 
with Jeffrey Epstein and/or Ghislaine Maxwell. 
5. 
Any billing statements for telephone service (cellular and "land line") for any 
telephone you used during the period of January I, 2003 to the present. 
Case No. 08-80736-CV-MARRA 
P-008382 
EFTA00225381

Villafana, Ann Marie C. (USAFLS) 
From: 
Fernandez, Aida I. (USAFLS) <afernandez@usa.doj.gov> 
Sent: 
Monday, June 23, 2008 9:23 AM 
To: 
Villafana, Ann Marie C. (USAFLS) 
Subject: 
RE: Grand Jury on 6/26 and 7/1 
Ok - got it - thx 
From: Villafana, Ann Marie C. (USAFLS) 
Sent: Monday, June 23, 2008 9:19 AM 
To: Fernandez, Aida I. (USAFLS) 
Subject: RE: Grand Jury on 6/26 and 7/1 
Hi Aida. Thank you for asking. We will be presenting the witness testimony after the indictment. (I would like 
to do the indictment in the morning and the witness in the afternoon, if possible.) 
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: Fernandez, Alda I. (USAFLS) 
Sent: Monday, June 23, 2008 9:18 AM 
To: Villafana, Ann Marie C. (USAFLS) 
Cc: Ball, Shawn (USAFLS) 
Subject: RE: Grand Jury on 6/26 and 7/1 
I assume you will be presenting your witness testimony first? Pls advise so that I know the order in which to 
present them next week. 
Pls advise. 
Thx. 
From: Villafana, Ann Marie C. (USAFLS) 
Sent: Monday, June 23, 2008 9:09 AM 
To: Fernandez, Aida I. (USAFLS) 
Cc: Ball, Shawn (USAFLS) 
Subject: Grand Jury on 6/26 and 7/1 
EXHIBIT B-133 
08-80736-CV-MARRA 
P-014979 
6 
EFTA00225382

Hi Aida — I think you already have this, but, if not: 
Can you put me down for a half-hour on Thursday, 6/26, in the morning, for an indictmen-
And, on 7/1 can I have 2 hours in the morning for an indictment on Operation Leap Year. Witness will be 
Nesbitt Kuyrkendall, FBI. It will be sealed. 
Also on 7/1, I will need 2 hours for witness testimony on Operation Leap Year. Witness will be 
Thank you! 
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 
08-80736-CV-MARRA 
P-014980 
7 
EFTA00225383

Villafana, Ann Marie C. (USAFLS) 
From: 
Senior, Robert (USAFLS) 
Sent: 
Monday, June 23, 2008 1. 11 
To: 
Villafana, Ann Marie C. (USAFLS); Kuyrkendall, E N. (MM) (FBI); Richards, Jason R. (MM) 
(FBI) 
Cc: 
Atkinson, Karen (USAFLS) 
Subject: 
RE: Trip to New York, etc. 
Ok. Marie, hoping to hear from DAG's office today giving the green light. Let's talk when that decision is 
made. 
From: Villafana, Ann Marie C. (USAFLS) 
Sent: Monday, June 23, 2008 9:15 AM 
To: Kuyrkendall, E N. (FBI); Richards, Jason R. (FBI) 
Cc: Atkinson, Karen (USAFLS); Senior, Robert (USAFLS) 
Subject: Trip to New York, etc. 
We will not be interviewing 
in New York. Her attorney gave a copy of the grand jury subpoena to 
Epstein's lawyers. They, in turn, promptly sent it on to Washington complaining, yet again, about me. So, I do 
not want to do an interview with him present, and we will have to put her in the grand jury. 
Given that, let's take the New York section out of the indictment so we can present the indictment Tuesday 
morning. Then we can do 
interview in the afternoon with plans to supersede. It probably makes sense 
to wait on the rest of the interviews until we hear whadMI has to say, so let's plan to do the New York trip 
in a few weeks. 
Bob — I will revise everything accordingly and send it down to you. We have another girl from Florida, so I 
will replace our New York Jane Doe with her. 
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 
08-80736-CV-MARRA 
P-014981 
78 
EFTA00225384

Villafana, Ann Marie C. (USAFLS) 
From: 
Brendan White <brendan@whiwhi.com> 
Sent: 
Thursday, June 26, 2008 10:38 AM 
To: 
Villafana, Ann Marie C. (USAFLS) 
Subject: 
Re: Grand Jury Appearance 
Dear Ms. Villafana: 
I understand that there has been a recent development with respect to Mr. Epstein in that he intends to plead guilty in 
Florida state court on Monday pursuant to a deferred prosecution agreement with your office that has already been 
executed. Since this would seem to obviate any need for Ms. Lacerda to testify, please let me know what is going on with 
respect to this Tuesday. Do we still need to come down there and, if so, will she receive court-ordered 
immunity? Thanks. 
Brendan White 
--- Original Message --
From: Vilfacana. Ahn Marie C. (USAFLS) 
To: Brendan White 
Sent: Monday, June 23, 2008 2:09 PM 
Subject: RE: Grand Jury Appearance 
Dear Mr. White: 
Please feel free to make your own travel arrangements, but if you would like Ms. Lacerda's travel costs to be 
reimbursed, they must be made through the government's approved agency on the approved carriers. 
Regarding the immunity, at this point, without a written proffer from you regarding the substance of her 
anticipated testimony, I believe that the more prudent course will be to question Ms. Lacerda to determine the 
limits of her Fifth Amendment exposure and, if necessary, to apply to the Court at that time. If you provide me 
with a written proffer that summarizes her anticipated testimony and explains how she will be exposed to 
criminal liability, then I can make the motion ahead of time. Your written statement would be treated as an 
attorney statement made in the course of confidential plea discussions and related negotiations, and would be 
governed by Fed. R. Crim. P. 11(0 and Fed. R. Evid. 410. 
A. Marie Wolin 
Assistant U.S. Attorney 
500 S. Australian Ave, Suite 400 
West Palm Beach, FL 3340] 
Phone 561 209-1047 
Fax 561 820-8777 
From: Brendan White [mailto:brendan@whiwhl.com] 
Sent: Monday, June 23, 2008 1:45 PM 
To: Villafana, Ann Marie C. (USAFLS) 
Cc Ball, Shawn (USAFLS) 
Subject: Re: Grand Jury Appearance 
We will be there, and I will make the travel arrangements. I am assuming that this will be done in connection with an 
order of immunity. Please let me know if that is correct so I can advise Ms. Lacerda. Thanks. 
Brendan White 
08-80736-CV-MARRA 
99 
P-014991 
EXHIBIT B-I34 
EFTA00225385

— Original Message ---
From: Villafana. Arm Marie C. (USAFLS1 
To: Brendan White 
Cc: Ball Shawn (USARSI 
Sent: Monday, June 23, 2008 11:27 AM 
Subject: Grand Jury Appearance 
Dear Mr. White: 
Ms. Lacerda will need to appear before the grand jury on July 1m to give testimony. Please contact my 
assistant, Shawn Ball, at 561 820-8711, ext. 3037, to make travel arrangements. I expect that Ms. Lacerda's 
testimony will begin either in the late morning or early afternoon, but she should be available for the whole 
day. 
Thank you. 
A. Marie Villafaiia 
Assistant U.S. Attorney 
500 S. Australian Ave, Suite 400 
West Palm Beach, FL 33401 
Phone 561 209-1047 
Fax 561 820-8777 
08-80736-CV-MARRA 
P-014992 
l's 
EFTA00225386

Villafana, Ann Marie C. (USAFLS) 
From: 
Villafana, Ann Marie C. (USAFLS) <Avillafana@usa.doj.gov> 
Sent: 
Thursday, June 26, 2008 10:55 AM 
To: 
Brendan White 
Subject: 
RE: Grand Jury Appearance 
Dear Mr. White: 
If Mr. Epstein enters a guilty plea in accordance with that agreement on Monday, then the subpoena will be 
withdrawn. At this point, I have not received confirmation that the change of plea is going to occur, nor have I 
received information confirming that the plea will be in conformance with our agreement. As such, at this time, 
1 still intend to present Ms. Lacerda's testimony to the grand jury on Tuesday. With respect to the immunity 
question, I refer you to my e-mail of June 2314, which is shown below. 
If the situation changes, I will contact you. 
Thank you. 
A. Marie Villafaiia 
Assistant U.S. Attorney 
500 S. Australian Ave, Suite 400 
West Palm Beach, FL 33401 
Phone 561 209-1047 
Fax 561 820-8777 
From: Brendan White [mailto:brendan@whiwhl.com] 
Sent: Thursday, June 26, 2008 10:38 AM 
To: Villafana, Ann Marie C. (USAFLS) 
Subject: Re: Grand Jury Appearance 
Dear Ms. Villafana: 
I understand that there has been a recent development with respect to Mr. Epstein in that he intends to plead guilty in 
Florida state court on Monday pursuant to a deferred prosecution agreement with your office that has already been 
executed. Since this would seem to obviate any need for Ms. Lacerda to testify, please let me know what is going on with 
respect to this Tuesday. Do we still need to come down there and, if so, will she receive court-ordered 
immunity? Thanks. 
Brendan White 
--- Original Message ---
From: Villafana. AM Marie C. (USAFLS). 
To: Brendan White 
Sent: Monday, June 23, 2008 2:09 PM 
Subject: RE: Grand Jury Appearance 
Dear Mr. White: 
Please feel free to make your own travel arrangements, but if you would like Ms. Lacerda's travel costs to be 
reimbursed, they must be made through the government's approved agency on the approved carriers. 
08-80736-CV-MARRA 
101 
P-014993 
EFTA00225387

Regarding the immunity, at this point, without a written proffer from you regarding the substance of her 
anticipated testimony, I believe that the more prudent course will be to question Ms. Lacerda to determine the 
limits of her Fifth Amendment exposure and, if necessary, to apply to the Court at that time. If you provide me 
with a written proffer that summarizes her anticipated testimony and explains how she will be exposed to 
criminal liability, then f can make the motion ahead of time. Your written statement would be treated as an 
attorney statement made in the course of confidential plea discussions and related negotiations, and would be 
governed by Fed. R. Crim. P. 11(0 and Fed. R. Evid. 410. 
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 
From: Brendan White [rnailto:brendan@whiwhl.com] 
Sent: Monday, June 23, 2008 1:45 PM 
To: Villafana, Ann Made C. (USAFIS) 
Cc: Ball, Shawn (USAFLS) 
Subject: Re: Grand Jury Appearance 
We will be there, and I will make the travel arrangements. I am assuming that this will be done in connection with an 
order of immunity. Please let me know if that is correct so I can advise Ms. Lacerda. Thanks. 
Brendan White 
 
 Original Message --
From: Villifena. Ann Mane C. (USAFLS) 
To: Brendan White 
Cc: Ball, Shawn (USAFLS) 
Sent: Monday, June 23, 2008 11:27 AM 
Subject: Grand Jury Appearance 
Dear Mr. White: 
N 
t 
Ms. Lacerda will need to appear before the grand jury on July In to give testimony. Please contact my 
assistant, Shawn Ball, at 561 820-8711, ext. 3037, to make travel arrangements. I expect that Ms. Lacerda's 
testimony will begin either in the late morning or early afternoon, but she should be available for the whole 
day. 
Thank you. 
A. Marie Villafafia 
Assistant U.S. Attorney 
500 S. Australian Ave, Suite 400 
West Palm Beach, FL 33401 
Phone 561 209-1047 
08-80736-CV-MARRA 
P-014994 
102 
EFTA00225388

I I Fax 561 820-8777 
08-80736-CV-MARRA 
P-014995 
103 
EFTA00225389

Villafana, Ann Marie C. (USAFLS) 
From: 
Brendan White <brendan@whiwhi.com> 
Sent: 
Thursday, June 26, 2008 11:26 AM 
To: 
Villafana, Ann Marie C. (USAFLS) 
Subject: 
Re: Grand Jury Appearance 
Thanks. 
---- Original Message ---
From: Villafana. Anny.Matie C. (USAFLS) 
To: Brendan White 
Sent: Thursday, June 26, 2008 10:55 AM 
Subject: RE: Grand Jury Appearance 
Dear Mr. White: 
• 
If Mr. Epstein enters a guilty plea in accordance with that agreement on Monday, then the subpoena will be 
withdrawn. At this point, 1 have not received confirmation that the change of plea is going to occur, nor have I 
received information confirming that the plea will be in conformance with our agreement. As such, at this 
time, I still intend to present Ms. Lacerda's testimony to the grand jury on Tuesday. With respect to the 
immunity question, I refer you to my e-mail of June 23rd, which is shown below. 
If the situation changes, I will contact you. 
Thank you. 
A. Marie Villafana 
Assistant U.S. Attorney 
500 S. Australian Ave, Suite 400 
West Palm Beach, FL 33401 
Phone 561 209-1047 
Fax 561 820-8777 
From: Brendan White [mailto:brendan@whiwhi.com] 
Sent: Thursday, June 26, 2008 10:38 AM 
To: Villafana, Ann Marie C. (USAFLS) 
Subject: Re: Grand Jury Appearance 
Dear Ms. Villafana: 
I understand that there has been a recent development with respect to Mr. Epstein in that he intends to plead guilty in 
Florida state court on Monday pursuant to a deferred prosecution agreement with your office that has already been 
executed. Since this would seem to obviate any need for Ms. Lacerda to testify, please let me know what is going on 
with respect to this Tuesday. Do we still need to come down there and, if so, will she receive court-ordered 
immunity? Thanks. 
Brendan White 
-- Original Message --
From: Villafana, Ann Marie C. (USAFLS1 
To: Brendan White 
Sent: Monday, June 23, 2008 2:09 PM 
Subject: RE: Grand Jury Appearance 
08-80736-CV-MARRA 
P-014996 
104 
EFTA00225390

Dear Mr. White: 
Please feel free to make your own travel arrangements, but if you would like Ms. Lacerda's travel costs to be 
reimbursed, they must be made through the government's approved agency on the approved carriers. 
Regarding the immunity, at this point, without a written proffer from you regarding the substance of her 
anticipated testimony, I believe that the more prudent course will be to question Ms. Lacerda to determine the 
limits of her Fifth Amendment exposure and, if necessary, to apply to the Court at that time. If you provide 
me with a written proffer that summarizes her anticipated testimony and explains how she will be exposed to 
criminal liability, then I can make the motion ahead of time. Your written statement would be treated as an 
attorney statement made in the course of confidential plea discussions and related negotiations, and would be 
governed by Fed. R. Crim. P. 11(1) and Fed. R. Evid. 410. 
A. Marie Villafana 
Assistant U.S. Attorney 
500 S. Australian Ave, Suite 400 
West Palm Beach, FL 33401 
Phone 561 209-1047 
Fax 561 820-8777 
From: Brendan White [mallto:brendan@whiwhi.com) 
Sent: Monday, June 23, 2008 1:45 PM 
To: VIllafana, Ann Marie C. (USAFLS) 
Cc: Ball, Shawn (USAFLS) 
Subject: Re: Grand Jury Appearance 
We will be there, and I will make the travel arrangements. I am assuming that this will be done in connection with an 
order of immunity. Please let me know if that is correct so I can advise Ms. Lacerda. Thanks. 
Brendan White 
— Original Message ---
Villarana, Ann Marie C. (USAFLS) 
To: Brendan White 
Cc: Ball. Shawn (USAFLS) 
Sent: Monday, June 23, 2008 11:27 AM 
Subject: Grand Jury Appearance 
Dear Mr. White: 
A*. 
Ms. Lacerda will need to appear before the grand jury on July 1St to give testimony. Please contact my 
assistant, Shawn Ball, at 561 820-8711, ext. 3037, to make travel arrangements. I expect that Ms. Lacerda's 
testimony will begin either in the late morning or early afternoon, but she should be available for the whole 
day. 
Thank you. 
A. Marie Villafafla 
Assistant U.S. Attorney 
08-80736-CV-MARRA 
P-014997 
10$ 
EFTA00225391

500 S. Australian Ave, Suite 400 
West Palm Beach, FL 33401 
Phone 561 209-1047 
Fax 561 820-8777 
08-80736-CV-MARRA 
P-014998 
106 
EFTA00225392

Villafana, Ann Marie C. (USAFLS) 
From: 
Brendan White <brendan@whiwhi.com> 
Sent: 
Thursday, June 26, 2008 3:00 PM 
To: 
Villafana, Ann Marie C. (USAFLS) 
Subject: 
Re: Grand Jury Appearance 
I've learned from Mr. Epstein's attorney that the plea is scheduled to take place on Monday morning. In understand, of 
course, that you need confirmation of this before withdrawing the subpoena, but it might make logistical sense to consider 
putting the contingent appearance off for another week at this point, to avoid our having to make an unnecessary trip to 
Florida. Although I am confident that things will proceed as scheduled, should there be a problem, we would then be able 
to appear at a later date. 
Brendan White 
Original Message ---
FrcimiVillafand: ArineMorie,C. tUSAR.S1.4. . 
To: Brendan White 
Sent: Thursday, June 26, 2008 10:55 AM 
Subject: RE: Grand Jury Appearance 
Dear Mr. White: 
If Mr. Epstein enters a guilty plea in accordance with that agreement on Monday, then the subpoena will be 
withdrawn. At this point, I have not received confirmation that the change of plea is going to occur, nor have I 
received information confirming that the plea will be in conformance with our agreement. As such, at this 
time, 1 still intend to present Ms. Lacerda's testimony to the grand jury on Tuesday. With respect to the 
immunity question, I refer you to my e-mail of June 23Id, which is shown below. 
If the situation changes, I will contact you. 
Thank 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 
From: Brendan White (mallto:brendan@whiwhi.com) 
Sent: Thursday, June 26, 2008 10:38 AM 
To: Villafana, Ann Marie C. (USAFLS) 
Subject: Re: Grand Jury Appearance 
Dear Ms. Villafana: 
I understand that there has been a recent development with respect to Mr. Epstein in that he intends to plead guilty in 
Florida state court on Monday pursuant to a deferred prosecution agreement with your office that has already been 
executed. Since this would seem to obviate any need for Ms. Lacerda to testify, please let me know what is going on 
with respect to this Tuesday. Do we still need to come down there and, if so, will she receive court-ordered 
immunity? Thanks. 
08-80736-CV-MARRA 
109 
P-014999 
EFTA00225393

Brendan White 
-- Original Message --
;From: Villafana, Ann Marie.C. fUSAFLSI 
To: prendan White 
Sent: Monday, June 23, 2008 2:09 PM 
Subject: RE: Grand Jury Appearance 
Dear Mr. White: 
Please feel free to make your own travel arrangements, but if you would like Ms. Lacerda's travel costs to be 
reimbursed, they must be made through the government's approved agency on the approved carriers. 
Regarding the immunity, at this point, without a written proffer from you regarding the substance of her 
anticipated testimony, I believe that the more prudent course will be to question Ms. Lacerda to determine the 
limits of her Fifth Amendment exposure and, if necessary, to apply to the Court at that time. If you provide 
me with a written proffer that summarizes her anticipated testimony and explains how she will be exposed to 
criminal liability, then 1 can make the motion ahead of time. Your written statement would be treated as an 
attorney statement made in the course of confidential plea discussions and related negotiations, and would be 
governed by Fed. R. Crim. P. 11(0 and Fed. R. Evid. 410. 
A. Marie Villafana 
Assistant U.S. Attorney 
500 S. Australian Ave, Suite 400 
West Palm Beach, FL 33401 
Phone 561 209-1047 
Fax 561 820-8777 
From: Brendan White imallto:brendanOwhlwhl.com] 
Sent: Monday, June 23, 2008 1:45 PM 
To: Villafana, Ann Marie C. (USAFLS) 
Cc: Ball, Shawn (USAFLS) 
Subject: Re: Grand Jury Appearance 
We will be there, and I will make the travel arrangements. I am assuming that this will be done in connection with an 
order of immunity. Please let me knoie if that is correct so I can advise Ms. Lacerda. Thanks. 
Brendan White 
-- Original Message - 
From: Villeanie. Ann Mile C. (USAFISI 
To: Brendan White 
Cc: Ball. Shawn fUSAFLS) 
Sent: Monday, June 23, 2008 11:27 AM 
Subject: Grand Jury Appearance 
Dear Mr. White: 
k t • 
Ms. Lacerda will need to appear before the grand jury on July 1st to give testimony. Please contact my 
assistant, Shawn Ball, at 561 820-8711, ext. 3037, to make travel arrangements. I expect that Ms. Lacerda's 
testimony will begin either in the late morning or early afternoon, but she should be available for the whole 
day. 
Thank you. 
08-80736-CV-MARRA 
P-015000 
110 
EFTA00225394

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 
4+, 
08-80736-CV-MARRA 
P-015001 
111 
EFTA00225395

Villafana, Ann Marie C. (USAFLS) 
From: 
Villafana, Ann Marie C. (USAFLS) <AVillafana@usa.doj.gov> 
Sent: 
Thursday, June 26, 2008 6:41 PM 
To: 
Brendan White 
Subject: 
RE: Grand Jury Appearance 
Dear Mr. White: 
I have not received any such confirmation. At this time, we are still on for July 1m. I recommend that you make 
your travel plans for Monday afternoon or evening and if things change, I will call you right away. 
Thank you. 
A. Marie Villafana 
Assistant U.S. Attorney 
500 S. Australian Ave, Suite 400 
West Palm Beach, FL 33401 
Phone 561 209-1047 
Fax 561 820-8777 
From: Brendan White [mailto:brendan@whiwhi.com] 
Sent: Thursday, June 26, 2008 3:00 PM 
To: Villafana, Ann Marie C. (USAFLS) 
Subject: Re: Grand Jury Appearance 
I've learned from Mr. Epstein's attorney that the plea is scheduled to take place on Monday morning. In understand, of 
course, that you need confirmation of this before withdrawing the subpoena, but it might make logistical sense to consider 
pulling the contingent appearance off for another week at this point, to avoid our having to make an unnecessary trip to 
Florida. Although I am confident that things will proceed as scheduled, should there be a problem, we would then be able 
to appear at a later date. 
Brendan White 
---- Original Message ----
FrormtVillefina, Aim Marie C. (USAE.LSr:.: 
To: Brendan White 
Sent: Thursday, June 26, 200810:55 AM 
Subject: RE: Grand Jury Appearance 
Dear Mr. White: 
If Mr. Epstein enters a guilty plea in accordance with that agreement on Monday, then the subpoena will be 
withdrawn. At this point, I have not received confirmation that the change of plea is going to occur, nor have I 
received information confirming that the plea will be in conformance with our agreement. As such, at this 
time, I still intend to present Ms. Lacerda's testimony to the grand jury on Tuesday. With respect to the 
immunity question, I refer you to my e-mail of June 23id, which is shown below. 
If the situation changes, I will contact you. 
Thank you. 
08-80736-CV-MARRA 
P-015002 
112 
EFTA00225396

A. Marie Villain& 
Assistant U.S. Attorney 
500 S. Australian Ave, Suite 400 
West Palm Beach, FL 33401 
Phone 561 209-1047 
Fax 561 820-8777 
From: Brendan White [malito:brendan@whlwhl.com] 
Sent: Thursday, June 26, 2008 10:38 AM 
To: Vlllafana, Ann Marie C. (USAFLS) 
Subject: Re: Grand Jury Appearance 
Dear Ms. Villafana: 
I understand that there has been a recent development with respect to Mr. Epstein in that he intends to plead guilty in 
Florida state court on Monday pursuant to a deferred prosecution agreement with your office that has already been 
executed. Since this would seem to obviate any need for Ms. Lacerda to testify, please let me know what is going on 
with respect to this Tuesday. Do we still need to come down there and, if so, will she receive court-ordered 
immunity? Thanks. 
Brendan White 
Original Message --
Freim: Vil 
Ana &Wert (USAFLS) 
To: Brendan White 
Sent: Monday, June 23, 2008 2:09 PM 
Subject: RE: Grand Jury Appearance 
Dear Mr. White: 
Please feel free to make your own travel arrangements, but if you would like Ms. Lacerda's travel costs to be 
reimbursed, they must be made through the government's approved agency on the approved carriers. 
Regarding the immunity, at this point, without a written proffer from you regarding the substance of her 
anticipated testimony, I believe that the more prudent course will be to question Ms. Lacerda to determine the 
limits of her Fifth Amendment exposure and, if necessary, to apply to the Court at that time. If you provide 
me with a written proffer that summarizes her anticipated testimony and explains how she will be exposed to 
criminal liability, then I can make tte motion ahead of time. Your written statement would be treated as an 
attorney statement made in the course of confidential plea discussions and related negotiations, and would be 
governed by Fed. R. Crim. P. 11(0 and Fed. R. Evid. 410. 
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: Brendan White (mailto:brendan@whiwhi.com] 
Sent: Monday, June 23, 2008 1:45 PM 
To: Villafana, Ann Marie C. (USAFLS) 
Cc: Ball, Shawn (USAFLS) 
Subject: Re: Grand Jury Appearance 
08-80736-CV-MARRA 
P-015003 
113 
EFTA00225397