EFTA00225378

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: Villafana, Ann Marie C. (USAFLS) 
To: Brendan White 
Cc: Ball, Shawn (USAFLS) 
Sent: Monday, June 23, 200811:27 AM 
Subject: Grand Jury Appearance 
Dear Mr. White: 
Ms. Lacerda will need to appear before the grand jury on July l g to give testimony. Please contact my 
assistant, Shawn Ball, at 561 820-8711, ext. 3037, to make travel arrangements. 1 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 Villajaiia 
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-015004 
114 
EFTA00225398

Villafana, Ann Marie C. (USAFLS) 
From: 
Brendan White [brendan@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 Lacerda is withdrawn.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. Mark Villafana 
Assistant U.S. Attorney 
500 S. Australian Ave, Suite 400 
West Palm Beach, FL 33401 
Phone 561 209-1047 
Fax 561 820-8777 
EXHIBIT B-135 
753 
EFTA00225399

Villafana, Ann Marie C. (USAFLS) 
From: 
Villafana, Ann Marie C. (USAFLS) 
Sent: 
Thursday, January 31, 2008 7:33 PM 
To: 
Sloman, Jeff (USAFLS); Acosta, Alex (USAFLS) 
Subject: 
Epstein 
Hi Jeff and Alex — We just finished interviewing three of the girls. I wish you could have been there to see how 
much this has affected them. 
One girl broke down sobbing so that we had to stop the interview twice within a 20 minute span. She regained 
her composure enough to continue a short time, but she said that she was having nightmares about Epstein 
coming after her and she started to break down again, so we stopped the interview. 
The second girl, who has a baby girl of her own, told us that she was very upset about the 18 month deal she 
had read about in the paper. She said that 18 months was nothing and that she had heard that the girls could get 
restitution, but she would rather not get any money and have Epstein spend a significant time in jail. 
The FBI's victim-witness coordinator attended and she has arranged for counseling for several of the girls. 
Please reach out to Alice to make her decision. These girls deserve so much better than they have received so 
far, and I hate feeling that there is nothing I can do to help them. 
We have four more girls coming in tomorrow. Can I persuade you to attend? 
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: 
EXHIBIT 
1779 
08-80736-CV-MARRA 
P-014573 
EFTA00225400

Villafana, Ann Marie C. (USAFLS) 
From: 
Villafana, Ann Marie C. (USAFLS) 
Sent: 
Wednesday, March 19. 2008 2:30 PM 
To: 
Weinstein, David (USAFLS) 
Subject: 
RE: Epstein update 
Why is this allowed to continue? Al least put us out of our misery quickly if that is what is going to happen! 
A. Marie lillaleala 
Assistant 11.5. Attorney 
500 S. Australian Ave. Suite 400 
West Palm Beach. FL 33401 
Phone 56 I 209-I 047 
Fax 561 820-8777 
From: Weinstein, David (USAFLS) 
Sent: Wednesday, March 19, 2008 2:29 PM 
To: Villafana, Ann Marie C. (USAFLS) 
Subject: RE: Epstein update 
Thank you for silently keeping me in the loop. 
Outrageous. 
From: Villafana, Ann Marie C. (USAFLS) 
Sent: Wednesday, March 19, 2008 2:16 PM 
To: Sloman, Jeff (USAFLS); Senior, Robert (USAFLS) 
Cc: Atkinson, Karen (USAFLS); Garcia, Rolando (USAFLS) 
Subject: Epstein update 
Hi Jeff and Bob — I am hoping that you have an update from Drew. I wanted to fill you in on recent events. 
Yesterday we did the first half of the grand jury presentation on the indictment. Many of the grand jurors 
expressed thanks for our return. After a break as 1 walked into the room, I overheard one juror telling another 
that he had been concerned that we were going to "whitewash" this case and not charge it. 
Epstein's lawyers arc using the civil lawsuits as an excuse to harass a number of the victims. One girl, who is a 
scholarship student at a local university, was hauled into the Dean of Students office to be served with a 
subpoena for a deposition. It is scheduled for Monday. 
A national crime victims service organization has received a grant from the Justice Department to provide legal 
representation to victims. They have agreed to provide counsel for our victims. The only problem is that the 
lawyers are located in Maryland. But they will try to find pro bono lawyers here to help out. 
I also told Bob that one of our victims tried to commit suicide last week. The FBI's victim-witness coordinator 
is doing her best to get counseling for all of our needy victims, but I just can't stress enough how important it is 
1315 
08-80736-CV-MARRA 
EX1 II BIT C-2 
P-014781 
EFTA00225401

for these girls to have a resolution in this case. The "please be patient" answer is really wearing thin, especially 
when Epstein's group is still on the attack while we are forced to wait on the sidelines. 
Your guidance is needed. 
Thank you. 
A. Marie Yillafalia 
Assistant U.S. Attorney 
500 S. Australian Ave, Suite 400 
West Palm Beach, FL. 33401 
Phone 561 209-1047 
Fax 561 820-8777 
1316 
08-80736-CV-MARRA 
P-014782 
EFTA00225402

Villafana, Ann Marie C. (USAFLS) 
From: 
Villafana, Ann Marie C. (USAFLS) 
Sent: 
Wednesday, March 19, 2008 4:34 PM 
To: 
Sloman, Jeff (USAFLS); Senior, Robert (USAFLS); Atkinson, Karen (USAFLS); Garcia, 
Rolando (USAFLS) 
Cc: 
Kuyrkendall, E N. 
Subject: 
Victim Subpoena 
Ili everyone — I just spoke with the subpoenaed victim. The subpoena was issued in connection with the state 
criminal case, which, as you know, doesn't involve most of the victims in our case (including the girl who was 
subpoenaed). The state attorney's office told us from the beginning that their case has been resolved. He is 
going to plead to the solicitation of adults for prostitution charge, so this seems to be a clear effort to find out 
about our case through the state case. 
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 
Tracking: 
1313 
EXHIBIT C-3 
08-80736-CV-MARRA 
P-014783 
EFTA00225403

Villafana, Ann Marie C. (USAFLS) 
From: 
Villafana, Ann Marie C. (USAFLS) 
Sent: 
Saturday, March 22, 2008 8:51 PM 
To: 
Sloman, Jeff (USAFLS); Senior, Robert (USAFLS) 
Cc: 
Atkinson, Karen (USAFLS); Garcia, Rolando (USAFLS) 
Subject: 
Epstein 
Hi all - So sorry to bother you on a Saturday, but I am hoping that I can persuade you to reach out to Drew 
about Epstein's investigators harassing the girls. Nesbitt received a frantic call today about Epstein's 
investigators bothering the parents of one of the victims. According to the victim, he demanded to see the 
victim and when he saw her, he told the victim that they had video of the girl and were planning to put it on the 
internet. We don't believe that Epstein actually has video of any of the girls, and Nesbitt has calmed the girl 
down, but this activity seems to be getting more aggressive. Remember also that Epstein is using the state 
criminal case to subpoena depositions of victims in the federal case (who are not part of the state indictment) to 
get information about our investigation. These actions do not seem consistent with what Epstein's attorneys are 
supposed to be trying to work out with Drew in DC. Any chance Drew will ask Epstein's people to call off 
their dogs until he makes his decision? 
4. Marie Villafana 
Assistant U.S. Attorney 
561 209-1047 
Fax 561 820-8777 
Tracking: 
1256 
08-80736-CV-MARRA 
P-014790 
EFTA00225404

Villafana, Ann Marie C. (USAFLS) 
From: 
Villafana, Ann Marie C. (USAFLS) 
Sent: 
Saturday, March 22, 2008 9:43 PM 
To: 
Kuyrkendall, E N. 
Subject: 
Message from Jeff 
Hi Nesbitt — I contacted Jeff and Bob about the harassment issue and Jeff also recommended calling the police. 
When Twiler calls on Monday can she provide the non-emergency police numbers for the local police 
departments where the girls are located and ask them to call the police directly if they are getting harassed? I 
think we should be documenting this stuff with someone other than you. 
Thank you. 
A. Marie Mal-aft 
Assistant U.S. Attorney 
561 209-1047 
Fax 561 820-8777 
1248 
08-80736-CV-MARRA 
P-014795 
EFTA00225405

Villafana, Ann Marie C. (USAFLS) 
From: 
Atkinson, Karen (USAFLS) 
Sent: 
Wednesday, May 23, 2007 4:20 PM 
To: 
Villafana, Ann Marie C. (USAFLS) 
Subject: 
RE: Jeffrey Epstein 
Let's talk before this is sent, please. 
From: Villafana, Ann Marie C. (USAFLS) 
Sent: Wednesday, May 23, 2007 3:45 PM 
To: Atkinson, Karen (USAFLS) 
Subject: FW: Jeffrey Epstein 
Karen — What do you think? 
Hi Jeff and Mau — I just want to again voice my disagreement with promising to have a meeting or having a 
meeting with Lefcourt or any other of Epstein's attorneys. As I mentioned, this is not a case where we will be 
sitting down to negotiate whether a defendant will serve one year versus two years of probation. This is a case 
where the defendant is facing the possibility of dozens of years of prison time. Just as the defense will defend a 
case like that differently than they would handle a probation-type case, we need to handle this case 
differently. Part of our prosecution strategy was already disclosed at the last meeting, and I am concerned that 
more will be disclosed at a future meeting. 
My co-chair, John McMillan, who has prosecuted more of these cases than the rest of us combined and who 
actually worked on the drafting of some of the child exploitation statutes, also opposes a meeting. We have 
been accused of not being "strategic thinkers" because of our opposition to these meetings, but we are simply 
looking at this case as a violent crime prosecution involving stiff penalties rather than as a white collar or public 
corruption case where the parties can amicably work out a light sentence. 
With respect to the "policy reasons" that Lefcourt wants to discuss, those were already raised in his letter 
(which is part of the indictment package) and during his meeting with Andy and myself. Those reasons are: (1) 
he wants the Petit policy to trump our ability to prosecute Epstein, (2) this shouldn't be a federal offense, and 
(3) the victims were willing participants so the crime shouldn't be prosecuted at all. Unless the Office thinks 
that any of those arguments will be persuasive, a meeting will not be beneficial to the prosecution, it will only 
benefit the defense. With respect to Lefcourt's promised legal analysis, that also has already been 
provided. The only way to get additional analysis is to expose to the defense the other charges that we are 
considering. In my opinion this would seriously undermine the prosecution. 
The defense is anxious to have a meeting in order to delay the investigation/prosecution, to find out more about 
our investigation, and to use political pressure to stop the investigation. 
I have no control over the Office's decisions regarding whether to meet with the defense or to whom the facts 
and analysis of the case will be disclosed. However, if you all do decide to go forward with these meetings in a 
way that is detrimental to the investigation, then I will have to ask to have the case reassigned to an AUSA who 
is in agreement with the handling of the case. 
A. Marie Villafaila 
Assistant U.S. Attorney 
EXHIBIT C-4 
110 
EFTA00225406

500 S. Australian Ave, Suite 400 
West Palm Beach, FL 33401 
Phone 561 209-1047 
Fax 561 820-8777 
From: Lourie, Andrew (USAFLS) 
Sent: Tuesday, May 22, 2007 6:33 PM 
To: Villafana, Ann Marie C. (USAFLS) 
Subject: FW: Jeffrey Epstein 
fyi 
From: Lourie, Andrew (USAFLS) 
Sent: Tuesday, May 22, 2007 6:32 PM 
To: 'Gerald Lefcourt' 
Subject: RE: Jeffrey Epstein 
I have your letter. I think we are on the same page, but to be sure I do want to clarify that we spoke the other week and 
I did say that if you want to meet with me again, I am ready to do so. The wording of your letter, however, suggests 
implicitly that I agreed to contact you before a decision is made to seek an indictment of Mr. Epstein. If that was your 
understanding, then please allow me to clarify. Our investigation is ongoing and if we decide to seek an indictment, we 
don't intend to call Mr. Epstein's representatives to let him know that. Of course, in the interim, if you would like to 
make a presentation to us, we are willing to listen. 
Along those lines, given the fact that we have already met once, with schedules being what they are, it makes sense for 
our criminal chief, Matt Menchel, to be included when you make another presentation, rather than working up the 
chain incrementally. I realize you were being respectful in not attempting to leapfrog over me, which I appreciate. I 
will pass on your request to meet with the U.S. Attorney as well, but can't commit for him one way or another. When 
you have some dates in mind, let me know and I will try to set up a meeting in Miami. 
From: Gerald Lefcourt [mailto:GBL@lefcourtlaw.com] 
Sent: Tuesday, May 22, 2007 2:05 PM 
To: Lourle, Andrew (USAFLS) 
Cc: Villafana, Ann Marie C. (USAFLS); Lilly Ann Sanchez 
Subject: Jeffrey Epstein 
Andy, attached is a letter seeking meetings, as discussed with you, but with others if it is not resolved. Thanks for your 
attention. Could you email back so that I know you have received this letter? 
Gerald B. Lefcourt 
Gerald B. Lefcourt, P.C. 
148 E. 78th Street 
New York, New York 10021 
.0400 
Fax
obkalercourtlaw.com 
111 
EFTA00225407

Villafana, Ann Marie C. (USAFLS) 
From: 
Menchel, Matthew (USAFLS) 
Sent: 
Monday, May 14, 2007 10:52 AM 
To: 
Villafana, Ann Marie C. (USAFLS); Lourie, Andrew (USAFLS) 
Subject: 
Re: Operation Leap Year 
Marie, 
You will not have approval to go forward tomorrow with an indictment or to poceed by complaint. Alex has your memo 
and lefcourt's letter but he is out of the district at the US Attorney's conference for the next several days. 
I'm having trouble understanding - given how long this case has been pending - what the rush is. This is obviously a very 
significant case and alex wants to take his time making sure he is comfortable before proceeding. 
Sent from my BlackBerry Wireless Handheld 
 
Original Message 
From: Villafana, Ann Marie C. (USAFLS) <AVillafana@usa.doj.gov> 
To: Lourie, Andrew (USAFLS) <Alourie@usa.doj.gov>; Menchel, Matthew (USAFLS) <MMenchel@usa.doj.gov> 
Sent: Mon May 14 10:38:15 2007 
Subject: Operation Leap Year 
Good morning: I just received a call that Epstein's plane is flying from the Virgin Islands to Newark now, so it looks like 
Epstein is going to show up for his court appearance tomorrow. Can you let me know if the indictment is going 
tomorrow or, if not, whether we are authorized to proceed by Complaint? 
Thank you. 
A. Marie Villafaha 
Assistant U.S. Attorney 
500 S. Australian Ave, Suite 400 
West Palm Beach, FL 33401 
Phone 561 209-1047 
Fax 561 820-8777 
EXHIBIT C-5 
EFTA00225408

Villafana, Ann Marie C. (USAFLS) 
From: 
VIHelena. Ann Marie C. (USAFLS) 
Sent: 
Friday, October 05, 2007 4:48 PM 
To: 
Sloman, Jeff (USAFLS) 
Subject: 
FW: Proposed Letter to Special Master 
Attachments: 
PROPOSED Letter to Special Master.pdf; Special Master Proposal.pdf; Ltr from Lefkowitz to 
Villafana (Oct. 5, 2007)212135690_4)1)OC 
lii Jeff Can I please just indict him? Can you give me a call on my cell phone? 561 601-2301. Since they 
object to using a Special Master. we have two options — we can just choose the lawyer ourselves or as part of 
our selection process. we can deal with the Special Master ourselves and, upon receiving the Special Master's 
choice. provide that name to the defense, understanding that they may then reject the selection. 
The other issues, regarding paying the attorney, clearly violate the terms of the agreement, which specifically 
state "if any of the individuals elects to file suit." 
A. Mark Villafafta 
Assistant U.S. Attorney 
561 209-1047 
Fax 561 820-8777 
From: Jay Lefkowitz [mailto:Reficowit@kirkland.com] 
Sent: Fri 10/5/2007 11:03 AM 
To: Villafana, Ann Marie C. (USAFLS) 
Cc: Lourie, Andrew; owlmgw@worldnet.att.net; glewis@lewistein.com 
Subject: RE: Proposed Letter to Special Master 
Marie. 
Attached is a letter responding to your latest proposals. For your convenience, I've also attached your prior e-mails and 
attachments regarding this matter so that you can easily see what I am responding to (see the chain below). If you are 
available, I'm free to talk at 5:30 this evening. We can use my usual call-in number at (866) 462-0164. The code is 
'4464970'. 
Thanks, 
Jay 
"Villatana, Ann Marie C. (USAFLSr 
cAnn.Marie.C.Vifialaniausdoi.00v>
10/05/2007 07 48 AM 
To -Jay Letkormts" clletkomMakirkland corny 
cc 
Subject RE. Proposed Letter to Special Master 
EXHIBIT C-6 
2767 
EFTA00225409

Good morning, Jay. We need to resolve the attorney issue today. It has been weeks since 
execution of the contract, and there is no need for further delay. 
As far as the five attorney names that we will be providing, I propose Bert Ocariz, 
Katherine Ezell at Podhurst Orseck, Stuart Grossman, Ed Rogers, and Walter Cobath. 
If you would like to use the same Special Master to resolve fees disputes as well as to 
handle the selection of the attorney, I 
recommend that w 
tired 11th Circuit 
Judge Joseph Hatchett instead of Judge 
because of Judge 
illie 
health problems. 
:No one has contacted Judge Hatchett yet, but one of the District udges in Miami 
mentioned him as a good choice.) 
I am available for a conference call between 9:00 and 10:00, and between 3:15 and 6:00. 
Please call me on my cell (561 601-2301) and let me know which of those times works best 
for you. 
Thank you. 
From: Jay Lefkowitz (mailto:JLefkowitz@kirkland.com) 
Sent: Wed 10/3/2007 4:26 PM 
To: Villafana, Ann Marie C. (USAFLS) 
Subject: Re: Proposed Letter tc Special Master 
Marie - I, too, am interested in speed. But I really need to go over this and then 
discuss with Jeffrey. So please do not send this to any Special Master before we discuss 
the next steps. 
Thanks -- Jay 
"Villafana, Ann Marie C. (USAFLS)" <Ann.Marie.C.Viliatana@usdoj.gov>
10/03/2007 04:24 PM 
To 
"Jay Lefkowitz" <JLefkowitz@kirkland.com>
cc 
Subject 
Proposed Letter to Special Master 
Hi Jay - To move things along, I also have enclosed the proposed text of a letter to the 
Special Master. 
<<PROPOSED Letter to Special Master.pdf» 
A. Marie Villafafla 
Assistant "J.S. Attorney 
2768 
EFTA00225410

561 209-1047 
Fax 561 920-877'7
"ViIlafana, Ann Mario C. (USAFLS)-
cAnn.Marie.S.Villalanageusdoiciov>
10/03/2007 04 24 PM 
To "Jay lentowaz ciLefltovnizattkirkiand corn,
cc 
Subject Proposed Letter to Special Master 
Hi Jay — To move things along. I also have enclosed the proposed text of a letter to the Special Master. 
«PROPOSED Letter to Special Master pdf» 
A. Mark Villafaik 
Assistant U.S. Attorney 
561 209-1047 
Fax 561 820-8777 
"Vilialana, Ann Marie C. (USAFLS)" 
4Ann,Mario.C.Villaranalausdoickur>
10/03/2007 03 18 PM 
To "Jay Lefkowitz" <JLetkomtzrekirsiand corn> 
cc 
&beset Memo in POF lomat 
Hi Jay — In case you can't open the other version, here it is in pdf. 
<<Special Master Proposetpdf» 
A. Mark Vilkfafia 
Assistant U.S. Attorney 
561 209-1047 
Fax 561 820-8777 
2769 
EFTA00225411

Villafana, Ann Marie C. (USAFLS) 
From: 
Villafana. Ann Marie C. (USAFLS) 
Sent: 
Tuesday, October 23, 2007 5:58 PM 
To: 
Sloman, Jeff (USAFLS) 
Subject: 
RE: Letter from Jay Lefkowitz 
Welcome to my world. I love the way that they want to interpret this agreement. First, during the negotiations, I 
repeatedly told Jay that we could not bind the girls to Epstein's desired out-of-court settlement strategy and. therefore. the 
agreement could not try to bind them in that way. 
The 550,000/S150,000 thing is a complete red herring, and Jay keeps calling it a "limit," when it is actually a floor, not a 
ceiling. 
It also looks like they are planning to ask for and receive a sentence far lower than the one we agreed to. Has 
anyone talked to Barry about this? Maybe this is the real reason for the delay in entering the guilty plea? We 
also have to contact the victims to tell me about the outcome of the case and to advise them that an attorney will 
be contacting them regarding possible claims against Mr. Epstein. If we don't do that, it may be a violation of 
the Florida Bar Rules for the selected attorney to "cold call" the girls. 
Their complaint about the 24-year-old concerns me only because their continued dragging out of this matter is 
ly going to foreclose other girls. The language of the agreement with Epstein and the letter to Judge 
i iissib 
both refer to persons we have identified as victims as defined in 2255, it says nothing about whether the 
gir s claims are necessarily valid. I have no idea whether the girl who currently is 24 either wants to sue 
Epstein or has any viable state or other federal claims -- that is why we are TRYING to get them a lawyer. And 
they have always known that most of the girls are now over the age of 18 -- goodness -- the time period of the 
violations was from 2001 to 2005 and it is now the end of 2007! 
Why don't we agree to mutual recission and indict him? 
From: Sloman, Jeff (USAFLS) 
Sent: Tue 10/23/2007 5:13 PM 
To: Villafana, Ann Marie C. (USAFLS) 
Subject: FW: Letter from Jay Lefkowitz 
Wait to you see this one. 
From: Jay Lefkowitz (mailto:JLefkowitz@kirkland.com] 
Sent: Tuesday, October 23, 2007 4:57 PM 
To: Acosta, Alex (USAFLS) 
Cc: Sloman, Jeff (USAFLS) 
Subject: Letter from Jay Lefkowitz 
Dear Alex and Jeff, 
Here is my response to Jeffs email from late yesterday. 
Please let me know if you want to speak later this evening. I am also available any time tomorrow. 
2687 
EXHIBIT C-7 
EFTA00225412

Thanks -- Jay 
The information contained in this communication is 
confidential, may be attorney-client privileged, may 
constitute inside information, and is intended only tor 
the use of the addressee. It is the property of 
Kirkland & Ellis LLP or Kirkland 6 Ellis International LLP. 
Unauthorized use, disclosure or copying of this 
communication or any part thereof is strictly prohibited 
and may be unlawful. If you have received this 
communication in error, please notify us immediately by 
return e-mail or by e-mail to postmastetikirkland.com, and 
destroy this communication and all copies thereof, 
including all attachments. 
2688 
EFTA00225413

Villafana, Ann Marie C. (USAFLS) 
From: 
Sloman. Jeff (USAFLS) 
Sent: 
Monday, October 22, 2007 5:26 PM 
To: 
Villafana, Ann Marie C. (USAFLS); Acosta, Alex (USAFLS) 
Subject: 
Fw: Epstein 
Fyi 
Sent from my BlackBerry Wireless Handheld 
 
 Original Message  
From: Sloman, Jeff (USAFLS) 
To: 'flefkowitz@kirkland.com. <JLefkowitz@kirkland.com> 
Sent: Mon Oct 22 17:23:30 2007 
Subject: Re: Epstein 
I
l
I have not spoken to him b 
' was our intention to assign the decision to 
select a lawyer to Judge 
not for him to represent the girls. We do not 
want to select the lawyer w o 
l represents the girls. I don't know who said he'd do 
it but it wasn't us. 
Sent from my BlackBerry Wireless Handheld 
 
 Original Message  
From: Jay Lefkowitz <JLefkowitz@kirkland.com> 
To: Sloman, Jeff (USAFLS) 
Cc: Acosta, Alex (USAFLS); Villafana, Ann Marie C. (USAFLS) 
Sent: Mon Oct 22 17:10:00 2007 
Subject: Re: Epstein 
Jeff -- I will review these materials this evening and be in touch with you 
tomorrow with the expectation of wrapping this up by 
nd of the day. One 
question I have, however, is why you say that Judge 
is a non-starter. I 
understood that he was ready, willing and able to serve as the attorney 
representative. If you have had conversations with him and that is not the case, 
please let me know. 
I will go over the other issues you raise in your email and will look forward to 
speaking tomorrow. 
Thanks -- Jay 
"Sloman, Jeff (USAFLS)" <]eff.Sloman@usdoj.gov> 
2691 
EFTA00225414

10/22/2007 04:40 PM 
To 
"Jay Lefkowitz" <JLefkowitz@kirkland.com> cc 
"Acosta, Alex (USAFLS)" cAlex.Acosta@usdoj.gov>, "Villafana, Ann Marie C. 
(USAFLS)" <Ann.Marie.C.Villafana@usdoj.gov> Subject 
Epstein 
Jay, 
The Judge 
issue is a non-starter. We've beaten that horse to death. 
Regarding your contention that "the attorney representative be told clearly that 
Mr. Epstein has agreed to pay the lawyer's hourly rate only for the time he or 
she spends working to effectuate settlements for the identified women," Alex and 
I agree that paragraph 7C is sufficient, Regarding the other points, we have 
made the following concessions: 
1. 
Regarding the language concerning a lawyer whose firm is 
sizeable enough to litigate multiple trials simultaneously, I have removed 
paragraph 4 on page 3 of the letter. 
2. 
Regarding the 150k statutory limit language, I have included a 
footnote which should satisfy your concern. 
3. 
Regarding language there may be discovery to test the claims 
of alleged "victims", please see new paragraph 4 on page 3 which now states as 
criteria that the firm should have "Experience litigating against large law firms 
and high profile attorneys who may test the veracity of the victims' claims." 
I have attached the Addendum and the revised letter to Judge 
Jay, this 
needs to be concluded. Alex and I believe that this is as far 
w can go. 
Therefore, please advise me whether we have a deal no later than COB tomorrow, 
Tuesday, October 23, 2007. Thanks, 
Jeff 
 
Original Message 
From: Jay Lefkowitz [mailto:]Lefkowitz@kirkland.com] 
Sent: Friday, October 19, 2007 4:05 PM 
To: Sloman, Jeff (USAFLS) 
Subject: Re: 
Jeff - 
2692 
EFTA00225415

I have reviewed your proposed language and wanted to raise a few areas of 
concern. 
First, I am not sure why we are not just asking Judge 
to represent these 
women. If he is available, that would save us a whole a itional layer of 
process. 
I had thought that was initially the idea. I am not sure why you seem 
to be moving in another direction. 
I also cannot understand why the draft affirmatively requests that J 
select 
a lawyer whose firm is sizeable enough to litigate multiple trials 
simultaneously. That seems to be directly at odds with the purpose of the 
agreement, which is to facilitate out of court settlements. 
Indeed, to the 
extent any woman were to elect to bring an action against Mr. Epstein, she would 
not only be free to select any lawyer of her choice, but would be restricted from 
using the lawyer representative in this capacity due to the conflicts of 
interests that would cause. 
This part of your proposed language is of 
signficiant concern to me. 
Your letter also indicates the 150k statutory limit without reference to the 
pre-existing 50G limit. To be sure, any of the women are free to seek whatever 
settlement they want, but given the question that exists about the statutory 
amount, the letter should not state definitely that it will be 150k. 
In addition 
have omitted a few important items from your proposal. Given 
that Judge 
or any other potential attorney representative should understand 
the scope o 
e work, the language should make clear that there may be discovery 
to test the claims of alleged "victims." 
Finally, I think it is important that the attorney representative be told clearly 
that Mr. Epstein has agreed to pay the lawyer's hourly rate only for the time he 
or she spends working to effectuate settlements for the identified women. 
Jay 
 
 Original Message  
From: "Sloman, Jeff (USAFLS)" [Jeff.Sloman@usdoj.gov] 
Sent: 10/17/2007 01:58 PM AST 
To: Jay Lefkowitz 
Subject: RE: 
<<071015 Special Master Letter2.wpd» Jay, 
Here's our proposed letter to the special master. 
Jeff 
 
Original Message 
From: Jay Lefkowitz [mailto:JLefkowitz@kirkland.com] 
2693 
EFTA00225416

Sent: Tuesday, October 16, 2007 9:26 AM 
To: Sloman, Jeff (USAFLS) 
Subject: 
Jeff - is there a time today we can speak? 
How about 430 pm? 
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