Memorandum

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 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? *********************************************************** The information contained in this communication is confidential, may be attorney-client privileged, may constitute inside information, and is intended only for the use of the addressee. It is the property of Kirkland & Ellis LLP or Kirkland & 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 postmaster@kirkland.com, and destroy this communication and all copies thereof, including all attachments. #4********#4 , ###tt4c#4***********####*********************### #********####4 , 4, **************###*t#ti,*#*#44 , *********4.44.44 2k# The information contained in this communication is confidential, may be attorney-client privileged, may constitute inside information, and is intended only for the use of the addressee. It is the property of Kirkland & Ellis LLP or Kirkland & 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 postmaster@kirkland.com, and destroy this communication and all copies thereof, including all attachments. 2694 EFTA00225417 EXHIBITS TO WRITTEN RESPONSE OF A. MARIE VILLAFANA Exhibit # Date Description I 5/1/2006 Letter from Chief Rcitcr to State Attorney Krischer 2 5/23/2006 File Opening Documents 3 7/3/2007- 7/13/2007 Emails between Criminal Chief Matt Menchel and AUSA Villafaiia regarding plea negotiations. 4 7/31/2007 Tenn Sheet for Epstein Non-Prosecution Agreement 5 Undated File folder entitled 'Meeting Timeline' with contents 6 7/24/2006 Letter from Chief Reiter to victims informing them of FBI investigation 7 7/26/2006 South Florida Sun-Sentinel Article Regarding Chief Reiter's referral of case to FBI 8 8/2/2007 Lilly Ann Sanchez email to Matt Menchel with attached letter containing counter- proposal for plea to two years of 'supenised custody.' 9 8/24/2006- 10/24/2006 Entails betweenJim Eisenberg and Marie Villafana regarding #28 10 10/30/2006- 10/31-2006 Emails between Marie Vitt:liana and Guy Lewis regarding Lewis respresentation of Epstein II 11/8/2006- I/8/2007 Emails between Marie Villatana and Lilly Ann Sanchez regarding Sanchets representation of Epstein 12 8/4/2006 Victim Notification Letters 13 WI1/2006 Victim Notification Letters 14 1/17/07- 2/1/07 Correspondence between Lilly Ann Sanchez, Gerald Lelcourt, Andrew Laurie, A. Marie Villafrina, and John McMillan regarding 2/1/2007 Meeting 15 11/13/06- 1/22/07 Subpoenas to Adrian Mucinska and research re 6001 immunity 16 9/26/2006 Memo regarding Changes to Child Exploitation Statutes in Tide 18 17 2/6/2007 Transcript of Kuyrkendall Testimony 18 2/27/2007 Transcript of Kuyrkendall Testimony 19 3/15/2007 Victim Notification Letter 20 3/20/2007 Transcript of Kuyrkendall Testimony 21 4/24/2007 Transcript of Kiwrkendall Testimony 22 4/24/2007 ' I 't a irseript of #37 Testimony 23 5/8/2007 Presentation Materials 24 5/8/2007 Transcript of Kuyrkendall Testimony 25 5/8/2007 Transcript of Richards Testimony 26 5/14/07- 5/21/07 Emats between Andrew Laurie, Mau MencheLjeff Sloman, mid Marie Villakula 27 5/15/2007 Transcript of Kuyrkendall Testimony 28 5/22/07- 5/24/07 Emails between Andrew Laurie, Gerald Lel-court, Man Mencheljeff Sloman, Marie Villafaiia, Lilly Ann Sanchez, and Karen Atkinson regarding second meeting with counsel for Epstein 29 5/22/2007 Transcript of Kuyrkendall Testimony 30 6/7/2007 Victim Notification Letters 31 6/14/07- 6/21/07 Entails between Marie Villafaiia, Karen Atkinson, Andrew Laurie, Mau Menchel, and Jeff Martian regarding addendum to Pros Memo, grand jury presentation, changes to indictmer it. and meeting with counsel for Epstein. 32 6/25/2007 Letter from Gerald I efcourt tojeffrey Montan and Andrew Laurie regarding 6/26/2007 meeting and emails and notes regarding same. PRIVILEGED and CONFII)ENTIAL Page 1 of 10 CONTAINS 6(c) MATERIAL EFTA00225418 EXHIBITS TO WRITTEN RESPONSE OF A. MARIE VILLAFANA Exhibit 41 Date Description 33 7/6/2007 Letter from Gerald l.efcourt and Alan Dershonia toJeffrey Sloman and Andrei Londe arguing against federal prosecution. 34 7/13/2007 Letter from Roy Black to Marie Villa' la with handwritten attorney Lourie notes 35 7/25/2007 latter from Gerald l.efrourt and Alan Dershowia to Matthew Menchel arguing that no charge can or should be made under 18 U.S.C. S 2422(b). 36 7/26/2007 Email from Marie ViIlafaria to Matt Menchel and Andrew Lourie regarding proposed changes to indictment. 37 7/27/2007 - 8/8/2007 Research regarding 18 U.S.C. S 2255 38 7/81/2007 Email from Marie ViKaiak toJeff Molnar], Man Menchel, and Andrew Lourie summarizing proposed plea terms as per Menchel recommendation 39 7/81/07- 8/3/07 7/31/2007.8/3/2007 Entails between Jeff Montan, Matt Moretti, Andrew Louric, and Marie VilLafaria regarding plea negotiations, including draft response to Nutter counsel regarding proposed agreement 40 8/2/2007 Letter front Lilly Ann Sanchez to Matthew Menchel containing counter-proposal of 2 years' supervised custody with two additional years of probation and internal correspondence regarding same. I I 8/3/2007 Letter from Matthew Menchel to Lilly Ann Sanchez rejecting counterproposal, setting a deadline of 8/17/2007, and advising that LISA Acosta was not inclined to meet with counsel for Epstein, and internal entails regarding same. I.? 8/6/2007 Entails from Marie Villafaila to Cyndee Campos, Frederica Devlin, and Jeff Sloman to determine whether Malt Matchers 8/3/2007 letter went out before he resigned from the U.S. Attorney's Office. 43 8/7/2007 Entails between Drew Oosterbaan, Andrew Laurie, Marie Villafafia, Alex Acosta, Jeff Slontan, and Cyndee Campos regarding request front Epstein's counsel for meeting with CEOS and background of case l 1. 9/4/07- 9/6/07 Entails betweenJeff Molnar', Marie Villafak, Andrew Laurie, Drew Oosterbaan, and Rolando Garcia regarding planned meeting with Epstein defense team and need to confer with victims. I. 9/10/2007 Entails betweenJeff Sloman, Marie Villafafia,John McMillan, and Andrew Larne regarding USA Acosia's inquiry regarding the state grand jury investigation IS 9/10/07- 9/19/07 Entails between Alex Acosta, Jeff Montan, Andrew Laurie, Rolando Garcia, Karen Atkinson, Marie Villafafia, andJohn McMillan regarding plea negotiations 47 9/10/07- 9/11/07 Entails from Marie Viktoria to Gerakl I cfcourt with proposed Non-Prosecution Apvements PI 9/11/07- 9/13/07 Entails between Marie Vilkdafia and Drew Oosterbaan regarding proposed Non- Prosecution Agreement, including research on proposed tnist fund. 19 9/ 1 2/2007- 9/24/2007 Entails between Marie Villafidia and Jay I.elkowitz re plea negotiations 50 9/21/2007 Research re Florida Statutes 51 9/23/2007 Entails between Alex Acosta and Jay Lelkowitz re pica negotiations PRIVILEGED and CONFIDENTIAL. Page 2 of 10 CONTAINS G(e) MATERIAL EFTA00225419 EXHIBITS TO WRITTEN RESPONSE OF A. MARIE VILLAFANA Exhibit (t Date Description 52 9/24/2007 Signed non-prosecution agreement 53 6/18/2007 Letter to Gerald Lefcourt re subpoena to NES, LLC and Jute 26, 2007 meeting 54 5/21/2007 Email regarding guidance on grand jury presentation 55 12/3/2007 Entails from Marie VillafaLfia to Alex Acosta regarding research on proposed trust fund. 56 3/22/2007 Entails between Marie Villafafia and IRS supervisor regarding money laundering research 57 Case regarding nunicy laundering and aiding & abetting 58 2/12/2007 Entails between l'illafafia and Lilly Ann Sanchez regarding employee representation with Lourie and Villafafia handwritten notes 59 5/21/2007 Subpoena to Paul A. Lavery 60 6/18/2007 Subpoena to Witham Riley 61 «18/2007 Subpoena to Riley Kiraly 62 7/18/2007 Email from Villafaita to Matt Menthe! regarding Roy Black objection to subpoenas addressed to William Riley and Riley Kiraly 63 7/19/2007 Entails between A/Malaita, Menthe!, and Loire regarding service of target letters. 64 7/26/2007 Email from Villarafia to Man Menthe) and Andrew Londe regarding reconunended revisions to indictment 65 8/1/2007- 8/2/2007 Entails between Menthe! and Villakdre regarding plea negotiations 66 9/10/2007 Proposed Non-Prosecution Agreement provided to Gerald Leleourt on 9/10/2007 67 9/11/2007 Proposed Non-Prosecution Agreement incorporating Acosta edits provided to Gerald Lefeourt on 9/11/2007 68 6/18/2008- 6/19/2008 Entails between Villafafia, Krischer, Atkinson, Senior, Acosta, Sloman. and Garcia regarding Epstein's case with state court and how it might breach the NPA 69 12/14/2007 Draft letter to Kriseher front Acosta regarding Epstein filing as sex oftender 70 9/16/2008- 9/17/2008 Entails between Villarafia, Krischer, Belohlavek, Garcia, Sloman, and Atkinson regarding Palm Beach Daily News requesting copy of the NPA and discussion 71 «30/2008 Entail front Drew Oosterbaan rc Epstein guilty plea 72 11/14/2007 Entail from Villafafia to Stomata regarding meeting with State Attorney's Office about work release and sex offender registration 73 12/6/2007- 12/7/2007 Entails between Lamm Belohlavek, Marie Villafafia, and Jeff Sloman regarding a factual proffer for state plea 74 12/14/2007 Email from Villafafia to Acosta and Sloman regarding hl. Stat. 796.03 and 2255. 75 12/14/2007 Email front Villafafia to Acosta with three letters requested by Acosta 76 11/15/2007- 11/16/2007 Entails between Richards, Villafafia, Slontan, Garcia, Acosta, and Atkinson regarding work release 77 6/27/2008- «28/2008 Entails between Vilkifafia, Goklberger, and Black regarding issues with state plea agreement 78 «17/2008 Entail from Villafaita to Acosta, Sloman, Senior, Atkinson, and Garcia summarizing meeting with Krischer regarding Epstein's attempt to negotiate a new plea deal PRIVILEGE') and CONFIDENTIAL Page 3 of 10 CONTAINS 6(c) MATERIAL EFTA00225420 EXHIBITS TO WRITTEN RESPONSE OF A. MARIE VILLAFANA &hint # Date Description 79 6/27/2008 Entail from 3rillafaita to Montan summarizing conversation with Goldberger that Epstein would serve sentence in confinement '24-bouts-a-day 80 6/29/2008 Email from Kuyrkendall to Villafana regarding work release 81 7/3/2008 Email from Villafiula to Sloman providing update on meeting with Col Gauger at PBSO regarding work release 82 11/20/2008. 1 iip2 mow Entails between Villafafia, Senior, Acosta, Slontan, Atkinson, and Garcia regarding Epstein work release 83 12/9/2008 Research materials regarding Epstein's work release application 84 12/11/2008 VilLiana letter to Capt. Sleeth, Palm Beach Sheriffs Office, mganling Epstein's work release application 85 6/9/2009 Vadatla Memorandum to Sloman, Senior, Garcia, awl Atkinson seeking permission to declare breach with attachments awl proposal breach letter 86 6/9/2009 Signed indictment package 87 6/12/2009 Villafaiia letter to Goldberger providing notice of breach of NPA 88 6/15/2009 Villafana letter to Lclkowitz, Black, and Goldberger regarding history of Epstein's performance under the NPA 89 6/17(2009 Villafaila letter to Lelkowitz regarding monitoring future performance under the NPA 90 9/1/2009 Black letter to Montan seeking approval for Epstein to transfer community control to the Virgin Islands 91 9/18/2009 Villafaila letter to Black explaining Olfwe's concerns about Epstein's application for transfer to the Virgin Islands A-1 Timeline of Events B-1 Chart addressing Question B.2 11-2 11/19/2007 Plea notification letter datal 11/19/2007 B-3 11/27/2007 Plea notification letter dated 11/27/2007 at 7:11 pm (formatting problem convening from Word Perfect) B-4 11/28/2007 Victim notification letter prepared II/28/2007 at 9:42 pm B-5 12/1/2007 Victim notification letter prepared 12/1/2007 at 7:50 pm 1.6 12/7(2007 Victim notification letter prepared 12/7/2007 at 9:10 pm (formatting problem) 13-7 11/19/2007 Research rc Florida Statute 921.143 B-8 11/28/2007 Email chain between Jay Lelkowitz an dJeff Sloman forwarded to Marie Villaftula B-9 11/29/2007 Letter from Jay Lelkowitz to Alex Acosta re CVRA - victim notifwation letter B-10 II/30/2007 Letter from Alex Acosta to Jay Lefkowia rc Victim Notification letter B-11 12/5/2007 Letter from Ken Starr and Jay I adkowitz to Alex Acosta requesting updated draft victim letters B-12 12/6/2007 Letter from Jeff Mont an to Jay Lefkowitz attaching victim notification letter B-13 12/6/2007- 12/7/2007 Internal entails about need to notify victims of upcoming plea PRIVILEGED and CONFIDENTIAL. Page 4 of 10 CONTAINS 6(c) MKITRIAL EFTA00225421 EXHIBITS TO WRITTEN RESPONSE OF A. MANE VILLAFAHA Exhibit # Dale Description B-14 12/7/2007 Victim notification letters and envelopes that were never sent 13-15 12/7/2007 Letter from Lilly Ann Sanchez with 1/4/2008 plea date 13-16 12/14/2007 Draft Victim Notification Letter prepared I WI4/2007 at 9:57 pm (formatting problem) 13-17 12/14/2007 Email from Marie Villafana to Alex Acostadcff Sloman, Rolando Garcia, and Karen Atkinson with victim letter attached B-18 12/17/2007 Email from Marie Villafana to Jeff Sloman reiterating concerns about failure to notify victims 13.19 12/19/2007 Entails between Alex Acosta,JeffSloman, and Marie Villafafta with draft and final letter to Lilly Ann Sanchez, including promise not to provide victims with notice of state change of plea hearing. 13-20 19/11/2007 Email from Marie Villafana toJeff Sloman and Alex Acosta regarding call with Jim Eisenberg 13.21 12/21/2007 Letter from Jay Lefkowitz to Alex Acosta re wanting to sec victim list B.22 12/26/2007 Letter from Jay Lelkowitz. to Alex Acosta re right to review victim notification letter and belief that it should come from State Attorney's Office 13.23 3/10/2008. 3/12/2008 Entails regarding Epstein attempts to contact victims and finding counsel for victims 13-24 5/15/2008 Letter from Drew Oosterbaan toJay Lelkowitz denying challenge to federal prosecution 13.25 3/14/2008 Revised indictment package B-26 3/18/2008 Grand jury presentation materials and transcript 13-27 3/14/2008 Entails between Marie Villafana, Rolando Garcia, Karen Atkinson, Frederica Devlin, and Shawn Ball rc complete indictment package for Robert Senior review B-28 3/28/2008 Letter from Ken Starr to DAAG SW Mandelker with additional objections B-29 4/29/2008 Summary chart and outline for grand jury presentation B-30 4/29/2008 Draft Indictment 15-31 10/9/2007- 3/25/2008 FBI Interview Reports of— (10/05/2007, 3/20/2008, and 3/25/2008), #2 (10/10/2007), #14 (10/26/2007), #33 (10/02/2007), #20 (10/25/2007), #21 (10/0W2007), - (10/0W2007), — (10/02/2007), #40 (6/12/2007), and #35 (10/02/2007) 13-32 5/19/2008 Letter fromMI.310mm toJay Lefkowitz settingJune 2, 2008 deadline to comply with tenns and conditions of the NPA 1333 5/19/2008- 512712008 Ken Starr/Whitley letters to Deputy Attorney General Mark Filip 13-34 5/27/2008- 6/13/2008 Internal entails after CEOS letter rejecting appeal where Marie Villafana asks to indict andJeff/Alex advise Epstein will be given chance to perform 13-35 5/19/2008 Correspondence between Alex Acosta,Jeff Slomah, and Jay Lelkowitz 1336 5/19/2008 Email from Alex Acosta toJay Lefkowitz responding to Lefkowitz email 1337 5/19/2008 Kirkland & Ellis LIP, Response to letter by FAUSA Sloman dated 5/19/2008 - 10 pages (RFP8) B-38 5/27/2008 Emails between Bob Senior, Jell Montan, Marie Villafana, and Karen Atkinson regarding indictment review and no further plea negotiations B39 5/27/2008 Emails between Marie Villarafia and Karen Atkinson regarding report of new state pica deal PRIVILEGED and CONFIDENTIAL Page 5 of 10 CONTAINS 6(c) MATERIAL EFTA00225422 EXHIBITS TO WRITTEN RESPONSE OF A. MARIE V1LLAFANA &Wait # Date Description B-40 5/29/2008 Email from Jell Sloman to Marie Villafafta, Bob Senior, Karen Atkinson, E. Nesbitt KtnTkendaII, and Jason Richards informing them that l)AG Filip agreed to review matter and that grand jury presentation was canceled 13-41 8/28/2008 Letter front Michael Danchuk to Marie Villafaila regarding victim representation and filing suit against Epstein in state court 13-42 4/9/2008 Mai is Villafana letter to Richard II. Willits (formatting problem) 13-43 6/18/2008 Marie Villalana handwritten notes re calls with Brad Ed wards and Roy Black B-44 6/23/2008 John Roth letter to Kan Starr and Jay Lelkowitt 13-45 6/24/2008 Em.ias between Roy Black, Jack Goldberger, and Marie Villafaiia re wrap up 13-46 6/25/2008 Email from Jcff Montan to Marie Villafafia regarding conversation about 225.5 issue and enui of guilt' plea 1147 6/25/2008 Email from Jeff Sloman to Marie %Adana with attached revised victim notification letter 13-48 6/25/2008 Entails between Marie Villafaila,JcITSIontan, Bob Senior, Karen Atkinson, and Alex Acosta regarding draft of notification of victim list for Jeffrey Epstein counsel with attached drafts 13-49 6/23/2008 Entails betweenJeff Sloman, Bob Senior, and Marie Vitt& instructing Marie Villafana to inform Epstein's attorneys that lie had untiLlune 30 to enter a guilty plea and Villafaita email to Lelkowitz re same. 13-50 6/26/2008 Fax from FBI with final victim list B-51 6/27/2008 Confirmation from police and Epstein's counsel of plea on 6/30/2008 13-52 6/27/2008 Email from Villafaiia to Sloman inquiring about conversation with Chief Reiter. 13-53 6/28/2008 Entails between Villafafm andJeff Montan regarding Chief Reiter providing notifications to victims. B-54 1W7 /2007 Email fmmJeff Montan to Marie Villafana instructing her not to send victim notification letter 13-55 6/30/2008 Notes from calls with attonwys M. Danchuk, R. Willits, J. Herman, B. Edwards. T. Leopokl, and M. Dutko 13,56 6/80/2008 Draft notification of identified victims letters 13-57 7/8/2008 Letter from Marie %Palatal., to Jack Goldberger re victim notification letter 1348 7/8/2008 Letter from Jack Goklberger to Marie Villafaiia that he will respond on 7/9/2008 8.59 7/9/2008 Email from Marie Villafafta to Alex Acosta, Jeff Stoma, and Karen Atkinson re Goldberger letter 11-60 7/9/2008 letter from Marie Villafana to Jack Goldberger regarding notification of identified victims 13.61 7/9/2008 Letter fromJack Goldberger to Marie Villafaita re notification of identified victims B-62 7/10/2008 Letter front Marie Villafana to Jack Goldberger informing him that victim notifications will be provided on a rolling basis 11-63 7/10/2008 letter front Marie Villafana to Goldberger with final notification of identified victims PRIVILEGED and CONFIDENTIAL Page 6 of 10 CONTAINS 6(e) MATERIAL EFTA00225423 EXHIBITS TO WRITTEN RESPONSE OF A. MARIE VILLAFANA Exhibit # Date Description 11-61 7/10/2008 Letter fromJack Goldberger to Marie Villafana requesting list of all victims 11-65 7/10/2008 Email from Jeff Sloman to Marie Villafafta, Alex Acosta, Karen Atkinson, E Nesbitt Kuyrkendall, and Jason Richards regarding proposed response to Jack Goldberger 15-66 7/9/2008 Victim Notification Letters to inditiduals #35 and 43 13-67 7/10/2008 Victim Notification Letters to individuals #3, 8, 17, 25, 26, 37, and I I B-68 7/14/2008- 7/15/2008 Emails between Marie Villafana, E. Nesbitt Kuyrkendall,Jason Richards. and Twiler Smith re FBI victim notifications 15-69 7/18/2008- 7/21/2008 Emails between Marie Villafana, Jeff Montan, E. Nesbitt Kuyrkendall, Jason Richards, Dexter Lee, and Karen Atkinson rc preparation of victim notificatiot I letters and victim contact list and victims that Miler still needs to make contact with 13-70 7/21/2008 Victim Notification Letters to individuals NI, 2, 4, 9, IS, 14, 21, 23, 30, 32, and 38 B-71 8/5/2008 Email from Marie Villafaffa to Alex Acostajeff Montan, Bob Senior, and Karen Atkinson regarding analysis ofJeffrey Epstein agreement, with attached 6/24/2008 email from A. M. Villafafia to R. Black midi. Goldberger and attached Epstein agreement 13-72 8/5/2008 Email from Alex Acosta to Marie Villafatla, Bob Senior, Jeff Simian, Dexter Lee, and Karen Atkinson with attached suggestions to Superseding Non-Prosecution Agreement 13-73 8/7/2008 Email from Roy Black to Marie Villafana responding to 8/7/08 email providing notification of possible compelled disclosure of the Non-Prosecution Agreement B-74 8/6/2008 Email response from Bob Senior to Marie Villafaila regarding Roy Black's response to email B-75 8/12/2008 Email response from Bob Senior to Marie Villafana to request for conference call prior to call with Roy Black B-76 8/13/2008 Email from Bob Senior to Karen Atkinson, Alex Acosta, Jeff Montan, Dexter Lee, and Marie Villalatla regarding Epstein and call with Jay' Lefkowitz B-77 8/13/2008 Email response from Alex Acosta to Karen Atkinson, Bob Senior, Jeff Sloman, Dexter Lee, and Marie \Walt regarding final version of agreement B-78 8/13/2008 Letter front Marie Villafana to Lefkowitz regarding performance of the NPA 13-79 8/13/2008- 8/15/2008 Email chain between Alex Acosta, Karen Atkinson, Bob Senior, Jeff Montan, Dexter Lee, and Marie Villafana regarding scope of Epstein agreement and correspomletwe and telephone conference with Jay Lefkowitz B-80 8/14/2008 Email fromJay Lefkowitz to Marie Villafatia and Karen Atkinson re follow up point regarding victims 15-81 8/15/2008 Etnail from Bob Senior to Alex Acosta, Marie Villalafia,Jeff Sloman, Dexter Lee, and Kamen Atkinson questioning whether offer shoukl be withdrawn as opposed to considering it a nullity B-82 8/15/2008 Email chain between Marie Villafana, Alex Acosta,JeffSbman, Bob Senior, Karen Atkinson, and Dexter Lee re drat response to 8/15/2008 email fromJay Lefkowitz regarding implementation of the NPA PRIVILEGED and CONFIDENTIAL Page 7 of 10 CONTAINS 6(c) MATERIAL EFTA00225424 EXHIBITS TO WRITTEN RESPONSE OF A. MARIE VILLAFANA Exhibit # Date Description B-83 8/15/2008 Letter from Marie Villafaiia to Jay Lelkowitz and Roy Black re terms of NPA 8-84 8/18/2008 Letter fromJay tellowitz to Marie Villafana regarding restitution B-85 8/21/2008 Letter from Marie Villafaila to Jay I elkowilz and Roy Black re Special Master and draft Notification of Identified Victim B-86 8/22/2008 Letter from lay Lelkowitz to Marie Villafana regarding misstatements in 8/21/08 VilliditIR letter B-87 8/26/2008 Letter from Marie Villafaila to Jay Lelkowitz and Roy Black re victim's list 8-88 9/2/2008 Letter from Jay Lclkowitz to Marie Villafana agreeing that Goldberger should be listed as the contact person for civil suits and re victim representativeJosefsberes fees B-89 9/2/2008 Mailed Amended Victim Notification letters to #1 )12, #3 (via Richard H. Willits), #4, #13, #8 friaJeffrey Herman), #9, #10, #11, #14, #16, #I7 (via Theodore Leopold), #20, #21, #23, #24, #25 (viaJelfrey Herman), #26 biaJellity Herman), #30, #31, #32, #33, #37 (via Michael E. Dutko), #38, #44 biaJeffni Herman) 8-90 9/W2008 Victim notification letters to #36, #35 (via Brad Edwards), #42, #43 (via Brad Edwards) B-9I 9/12/2008 Notification of Identified Victim letter #39 B-92 9/15/2008 Mailed victim notification letters for #I8 and #32 15-93 9/17/2008- 11/4/2008 Entails and coorespondence with 'Ilie Florida Bar re victim notifications B-94 11/14/2008 Notification of Identified Victim letters to #20, #40 13-95 12/4/2008 Email from Karen Atkinson to Marie Villafaila in response to draft letter notifying victims of Epstein's work release B-96 12/5/2008 Email from Marie Villafaila to victim's attorneys with attached Work Release Notice 15-97 12/8/2008 Notification of NVotk Release letters to Spencer Kuvin,Jack Scuola, Michael Dutko, #11,1439 and #40 B-98 12/9/2008 Notification of Work Release letters to #4, #10, #16, #I8, #23, #24, #33, #38, #30 (personal note), #42 B-99 12/12/2008- 12/29/2008 Entails with attorneys for victims regarding Epstein work release 11-100 12/12/2008 Notification of Work Release letter to #42 B-101 12/12/2007 Entails between Marie Villafana, Frederica Devlin, and Bob Senior regarding planning indictment review B-102 1/7/2008 Email From Marie Villafaaa to Alex Acosta,Jeff Montan, Bob Senior, Karen Atkinson, and Rolando Gant regarding proposed additional investigative steps in Epstein case 13-103 1/9/2008• 1/14/2008 Entails between Marie Villafaiia, Drew Oosterbaan, Myesha Braden, Nesbitt Kuyrkendall, an dJason Richards regarding assigning a CEOS attorney to the investigation, meeting with the CEOS attorney and victims in Florida, the results of the meetings and planned additional meetings, and revisions to the indictment in light of the meetings II-104 1/10/2008 Email chain between Myesha Braden and Marie Villafaita regarding meeting on 1/11/2008 B-10.5 1/14/2008 Entail chain between Myesha Braden, Marie Villafafia, E. Nesbitt Kuyrkeimlall, and Jason Richards regarding meeting and additional 302s PRIVILEGED and CONFIDENTIAL. Page 8 410 CONTAINS 6(e) MATERIAL EFTA00225425 EXHIBITS TO WRITTEN RESPONSE OF A. MARIE VILLAFANA Exhibit It Date Description B-106 1/I7/2008 Agents compile evidence for Bob Senior indictment review B-107 1/25/2008 Email chain between Myesha Braden and Marie Villafafia regarding victim's names in indictment B-108 1/31/2008 Additional grand jury subpoenas B-109 1/28/2008• 2/1/2008 Entails between Marie Villafana,Jeff Sloman, Alex Acosta, Nesbit Kuyrkendall, Jason Richards, and Alan Santiago regarding results of additional victim-witness interviews and requesting intervention with CEOS to move review process along B-I 10 2/12/2008- 2/22/2008 Entails between Marie Villafana, E. Nesbitt Kuyrkendall, Jason Richards, and Myesha Braden re information for indictment/ongoing investigation B-111 2/20/2008- W21/2008 Entails between Drew Oosterbaan, Marie Villatana, Robert Senior,Jeff Montan, Sigal Mandelker, Karen Atkinson, Alex Acosta, Rolando Garcia and Myesha Braden regarding status of CEOS plans to meet with counsel for Epstein and status of indictment review B-112 245/2008 Email chain between Marie Villafana and Caroline regarding use of Grand Jury B-113 2/25/2008 Email from Marie Villafafia toJeffSlontan, Bob Senior, Rolando Garcia, Karen Atkinson, and Myesha Braden re staying with same grand jury or present to a different gnmd jury 13-114 2/26/2008 Email front Marie Villatana to Myesha Braden re CEOS independent review and concern about victim's mulles being released B-115 2/26/2008 Email response from Marie Villatalia to Jeff Sloman and Bob Senior with concerns regarding allowing Epstein to keep the same deal as before 13-116 2/27/2008 Email chain between Marie Villatana, David Weinstein, and Bob Senior re email to the Civil Rights Chief B-117 2/2W2008 Email chain between Marie Villatanajason Richards, and E. Nesbitt Kuyrkendall regarding further investigation B-118 2/29/2008 Entails betweenJeff Montan, Marie Villatafia, Robert Senior, and David Weinstein regarding continuing investigation and status of CEOS review B-119 3/12/2008 Email from E. Nesbitt Kuyrkendall to Marie Villafafia re affidavit for memory cards B-I20 3/17/2008 Two search warrants for digital camera memory cards 13-121 3/5/2008 Entails between Marie Villafafia and E. Nesbitt Kuyrkendall with attached email to Alex Acosta, Jeff Montan, Drew Oosterbaan, Robert Senior, Myesha Braden, Rolando Garcia, and Karen Atkinson regarding meeting in DC, additional information to prepare for meeting, and new information from ongoing investigation B-122 3/14/2008 Entails between Marie Villafafia, Rolando Garcia, Karen Atkinson, Frederica Devlin, and Shawn Ball regarding complete indictment package for Robert Senior fatal review B-123 6/3/2008 Letter from Jeff Sloman to Deputy Attorney General Mark Filip with auachmems B-124 4/21/2008- 5/9/2008 Emits between Marie Villataila,Jeff Sloman, Karen Atkinson, Bob Senior, E. Nesbitt Kuyrkendall, Jason Richards, and Drew Oosterbaan re status of grand jury presentation. and ongoing investigation, and delay PRIVILEGED and CONFIDENTIAL. Page 9 of 10 CONTAINS 6(c) MATERIAL EFTA00225426 EXHIBITS TO WRITTEN RESPONSE OF A. MARIE VILLAFASA Exhibit N Date Description 5/15/2008- Entails between Marie Villafana, Karen Atkinson. Bob Sentor,JeliSloman. am I 13-125 5/27/2008 agents regarding indictment review and status of investigation 13-126 5/30/2008 FBI-302 of 5/28/08 Interview of Individual #35 6/2/2008 4:25 pm Draft letter from Jeff Sloman to Deputy Attorney General 13-127 6/2/2008 Mark Hip 6/3/2008 10:40 am Draft letter fromJcff Sloman to Deputy Attorney General B-128 6/3/2008 Mark Hip Entails between Villafana and Kuyrkendall re subpoena issued to victimfwitness 13-129 6/6/2008 and need for additional subpoenas 13-130 6/17/2008 Application for 6001 immunity for grand jury witness Letter from Matthew W. Friedrich, Acting Assistant Attorney General. B-131 6/24/2008 authorizing application for a court order granting 6001 int:marl B-B2 6/20/2008 Request to travel to York for witness interviews in June 2008 and subpoena Entails between A. Marie Villafaria, E. Nesbitt Kuyrkendall, J. Richards, K. Atkinson, and R. Senior regarding grand jury time, witness subpoena, and B-133 6/23/2008 indictment 6/23/2008- Entails between Marie Villalirna and attorney for grand jury witness regarding 1 t-I34 6/26/2008 immunity and travel for grand jury appearance Entails between Marie Villafana and attorney for grand jury witness withdrawing 13-135 6/30/2008 subpoena c'- i 1/31/2008 Email from Marie Villafana to Jeff Mon tan and Alex Acosta regarding victims Email chain between Marie Villafana, David Weinstein,Jeff Montan, Bob Senior, Karen Atkinson, and Rolando Garcia with Epstein update from grand jury presentation and grant front theJustice Department to provide legal C-2 3/19/2008 representation to victims 3/19/2008- C-3 3/22/2008 rattails regarding victims being harassed by Epstein's investigators Draft of entail to be sent to Jeff and Matt stating that Villalana disagrees with promising to have a meeting with Lel-court or any of Epstein's other attorneys. 5/22/2007- Believes the prior meeting disclosed prosecution strafe*. and holding another meeting will disclose even more. If meeting is held, Villafalia will ask to have the case reassigned. Attached email correspondence between Andrew Lourie and G. O4 5/23/2007 Lefcourt Email from Matt Menchal to Marie Villatana and Andrew Louric regarding not C-5 .5/14/2007 having approval to proceed with an indictment or complaint 10/3/2007- Entail chain between Marie Villafana, Jeff Montan, and Jay Lefkonitz regarding C-6 10/5/2007 appointing special master 10/16/2007- Entails between Marie Villafana,Jeff Montan, Alex Acosta, and* Lelkowitz C-7 10/28/2007 regarding Special Master PRIVILMED and CONFIDENTIAL. Page 10 of 10 CONTAINS 6(e) MATERIAL EFTA00225427 EPSTEIN INVESTIGATION TIMELINE Date To From Re: Exhibit # 5/1/2006 State Attorney • ga y E B ' Krischer Michael S. Reiter, Chief of Police for Town of Palm Beach Letter urging State Attorney to proceed with probable cause affidavits and cast filing packages or to recuse himself i 5/23/2006 File Opening Documents for Operation Leap Year 2 7/24/2006 Michael S. Reiter, Chief of Police for Town of Palm Beach Letter noting that Palm Beach Police Chief was unhappy with State Attorney's handling of case and was referring matter to the FBI for investigation 6 7/26/2006 South Florida Sun-Sentinel Article Regarding Chief Reiter's referral of case to FBI _ 8/2/2006 Subpoena to Colonial Bank (return date 8/18/06) 8/2/2006 Subpoena to Washington Mutual (return date 8/18/06) 8/2/2006 Subpoena to Capital One (return date 8/18/06) 8/2/2006 Subpoena to Chase (return date 8/18/06) 8/2/2006 Subpoena to Hyperion Air, Inc. (return date 8/18/06) 8/2/2006 Subpoena to JEGE, Inc. (return date 8/18/06) 8/2/2006 Subpoena to David Neville Rodgers (return date 8/18/06) 8/2/2006 Subpoena to DTG Operations d/b/a Dollar Rent-a-car (return date 8/18/06) 8/2/2006 Subpoena to Royal Palm Beach Community High School (return date 8/18/06) 8/2/2006 Subpoena to Custodian of Records 15th Judicial District (return date 8/18/06) 8/4/2006 Victim Notification letters to Individuals #6, #9, #10, #11, #13, #15, #17, #18, #20, #23, #24, #25, #26, #27, #28, #29, #30, #31, #32, #38, #39, #41, #42, and #44 1 :! 8/11/2006 Victim Notification letters to Individuals #4, #5, #6, #9, #12, #13, #15, #19. #26, #28, #29, #31, #32, #34, #38, #39, #43, and #44 8/15/2006 Subpoena to (withdrawn) (return date 8/25/06) Privileged Confidential Page 1 of SI Contains 6(e) Material CVUIDIT A 1 EFTA00225428 EPSTEIN INVESTIGATION TIMELINE Date To From Re: Exhibit # 8/15/2006 Subpoena to Individual #4 (return date 8/25/06) 8/15/2006 Subpoena to Individual #28 (return date 8/25/06) 8/15/2006 Subpoena to Individual #44 (withdrawn) (return date 8/25/06) 8/23/2006 Subpoena to Individual #4 (return date 9/1/06) 8/23/2006 Subpoena to Individual #28 (return date 9/1/06) 8/23/2006 Subpoena to Reimer Employment Agency (return date 9/1/06) 8/23/2006 Subpoena to Evidence Custodian Palm Beach Police Department (return date 9/1/06) 8/24/2006 Villafalia Jim Eisenberg Email re Individual #28 9 8/28/2006 Subpoena to Custodian of Records State Attorney's Office (return date 9/15/06) 8/28/2006 Subpoena to Custodian of Records 15th Judicial District (return date 9/15/06) 9/13/2006 Subpoena to Good Samaritan Hospital (return date 9/22/06) 9/21/2006 Subpoena to The Dalton School (return date 9/29/09) 9/26/2006 Acosta, Mulvihill, Sloman, Noto, Waters, L°urie' Stefin, Atkinson, Garcia, Brown, Boscovich, Martinez Villafaila Memo regarding changes to Child Explotation Statutes in Tide 18 16 10/19/2006 Subpoena to Individual #28 (return date 10/27/06) 10/24/2006 Email chain between Villafaiia and Jim Eisenberg discussing Individual #28 9 10/30/2006 Villafatia Guy Lewis Email re representation of Jeffrey Epstein 10 10/31/2006 Villafatia Guy Lewis Email chain to set up call 10 11/8/2006 Lourie, Villafana ' cc: Menchel Sloman Email re Lilly Ann Sanchez/representation of Jeffrey Epstein Privileged Confidential Page 2 of 51 Contains 6(e) Material EFTA00225429 EPSTEIN INVESTIGATION TIMELINE Date To From Re: Exhibit # 11/13/2006 Subpoena to Bill Hammond (pilot) (return date 12/1/06) 11/13/2006 Subpoena to Larry Visoski (pilot)(return date 12/1/06) 11/13/2006 Subpoena to Janusz Banasiak (property manager)(retum date 12/1/06) 11/13/2006 Subpoena to Adriana Mucinska (former assistant) (return date 12/1/06) 15 I 1/15/2006 A. Marie Villafalia Lilly Ann Sanchez Gerald Lefcourt from New York and Lilly Ann Sanchez will be dealing with the U.S. Attorney's Office in the Jeffrey Epstein matter 1 1 11/16/2006 Lilly Ann Sanchez A. Marie Viilafan_a Request for documents and information necessary to the investigation 11/17/2006 Subpoena to Extra Touch Flowers (return date 2/6/07) 11/21/2006 Lilly Ann Sanchez A. Marie Villafaria Requesting a meeting to discuss 11/16/06 letter 11 11/29/2006 Lilly Ann Sanchez A. Marie Villafafia AUSA Villafatia will be out of district and will not be available for meeting during the proposed dates, but will schedule the meeting when she returns. 1 1 I 2/1/2006 A. Marie Villafalia Lilly Ann Sanchez Will check on the document requests and will schedule the meeting in the new year. 11 12/18/2006 Subpoena to Janusz Banasiak (property manager) (return date 1/12/07) 12/18/2006 Subpoena to (former assistant) (return date 1/12/07) 15 12/18/2006 Subpoena to Anthony Figueroa (return date 1/12/07) 1/5/2007 A. Marie Villafatia Lilly Ann cl. inchez Request for dates and times to schedule meeting 11 1/8/2007 Lilly Ann Sanchez A. Marie Vaifan_a Request for documents prior to setting meeting 1 1/17/200- Lilly Ann Sanchez Andrew Lourie Client wants to cooperate with the investigation, but requests for documents were overly broad. Provided shortened and narrowed list and request for documents to be provided by 1/25/07, so they could be reviewed prior to 2/1/07 meeting. 14 Privileged Confidential Page 3 of 51 Contains 6(e) Material EFTA00225430 EPSTEIN INVESTIGATION TIMELINE Date To From Re: Exhibit # 1/18/2007 A. Marie Villafaiia Lilly Ann Sanchez Because of the Palm Beach Police Department and the State Attorney's . investigation for almost two years, Epstein hired counsel for all employees so contact Ms. Sanchez for contact information for the attorneys. 14 I /22/2007 Andrew Lourie Sanchez Looking forward to the 2/1/07 meeting and expect to send documents previously provided to the Palm Beach County State Attorney's Office by 1/25/07. I I 1/22/2007 Research re NPAs and 6001 immunity I c 1/23/2007 Lilly Ann Sanchez A. Marie Nrillafafia Request for a list of the individuals who have accepted Epstein's offer of payment for representation and the names of their attorneys. 2/1/2007 A. Marie Villafafia Gerald B. Lefcourt Talking points and documents for 2/1/07 meeting 4 2/5/2007 A. Marie Villafatia Gerald B. Lefcourt Production of debit/credit card statement regarding Epstein's birthday and a purchase at Guys and Dolls made by Individual #18. 2/6/2007 Grand Jury Testimony of E. Nesbitt Kuyrkendall I - 2/12/2007 A. Marie Villafana Lilly Ann Sanchez Emails between Villafana and Lilly Ann Sanchez regarding employee representation with Laurie and Villafana handwritten notes 58 2/14/2007 Subpoena to Colonial Bank (return date 3/6/07) 2/14/2007 Subpoena to Palm Beach National Bank (return date 3/6/07) 2/14/2007 Subpoena to Western Union (return date 3/6/07) 2/14/2007 Subpoena to Western Union (return date 3/6/07) 2/14/2007 Subpoena to JP Morgan Chase (return date 3/6/07) 2/20/2007 Meeting (US: Andy Laurie, Marie Villafana, and Junior Ortiz, DEF: Lilly Sanchez and Gerald Lefcourt) 2/23/2007 A. Marie Villafaiia Gerald B. Lefcourt Excerpts of drafts of transcripts from recorded interviews of various witnesses taken during state's investigation. 2/27/2007 Grand Jury Testimony of E. Nesbitt Kuyrkendall 18 3/2/2007 Subpoena to Thomas Rofrano (return date 3/13/07) 3/2/2007 Subpoena to Johanna Sjoberg (return date 3/13/07) 3/2/2007 Subpoena to Christina (return date 3/13/07) 3/2/2007 Subpoena to Palm Beach County Health Dept (return date 3/13/07) 3/2/2007 Subpoena to Perry Bard, DC (return date 3/13/07) Privileged Confidential Page 4 of 51 Contains 6(e) Material EFTA00225431 EPSTEIN INVESTIGATION TIMELINE Date To From Re: Exhibit # 3/15/2007 Victim Notification letter to Individual #4 19 3/16/2007 Subpoena to Individual #29 (return date 3/27/07) 3/20/2007 Grand Jury Testimony of E. Nesbitt Kuyrkendall 20 3/20/2007 Subpoena to Individual #32 (return date 4/3/07) 3/22/2007 Villafatia Stefan Cassella Email re money laundering question 56 4/4/2007 Subpoena to Individual #37 (return date 4/17/07) 4/16/2007 Subpoena to Chase Bank USA, NA Atm: Jeff Sehr (return date 4/24/07) 4/16/2007 Subpoena to Adult Video Warehouse (return date 5/1/07) 4/16/2007 Subpoena to Eve's Garden (return date 5/1/07) 4/17/2007 Subpoena to Individual #28 (return date 5/1/07) 4/20/2007 Subpoena to Adult Video Warehouse (return date 5/1/07) 4/24/2007 Grand Jury Testimony of Special Agent E. Nesbitt Kuyrkendall 21 4/24/2007 Grand Jury Testimony of Individual #37 22 4/24/2007 Subpoena to New York Strategy Group, LLC Custodian of Records (return date 5/8/07) 4/24/2007 Subpoena to Hyperion Air, Inc. Custodian of Records (return date 5/8/07) 4/24/2007 Subpoena to JEGE, Inc. (return date 5/8/07) 5/8/2007 Grand Jury presentation materials 23 5/8/2007 Grand Jury Testimony of E. Nesbitt Kuyrkendall 24 5/8/2007 Grand Jury Testimony of Jason Richards 2