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From: IIIIIIIIIIIIIIIIIIIIIINI. Sent: i r 2:05 PM To: MERCEDES C. ESTRADA Subject: Civil Cases Involving Jeffrey Epstein Hi all — I just received Bert's voicemail message. 1 do not know all of the case numbers of cases involving Jeffrey Epstein. If you go to the District Court's PACER site, and search for the party name of Jeffrey Epstein, they will all come up. The press also has reported that some cases were recently filed in Palm Beach County state court. You can do a similar search on the Clerk of Court's website to find all of the state court cases. Thank you. Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 Phone Fax 561 820-8777 22 EFTA00227071 From: Jay Lefkowitz Sent: Wednesda October 08, 2008 2:40 PM To: (USAFLS); Roy Black Cc: Subject: Re: Jane Does United States Thank you for sending this. Jay From: Sent: 10/08/2008 02:37 PM AST To: Jay Letkowitz Cc: Subject: Jane Does v. United States Dear Roy and Jay: v> I am attaching the United States' Response to the Petitioners' Motion to Unseal the Non-Prosecution Agreement, which was filed in the victims' rights suit filed against the United States by Attorney Brad Edwards on behalf of two of the victims. In his motion to unseal, Attorney Edwards stated that he would provide notice of his motion to counsel for Mr. Epstein. I do not know if he actually did so. In our response, we oppose the Petitioners' motion, and point out that Mr. Edwards has filed a civil suit against Mr. Epstein and that litigation regarding the Non-Prosecution Agreement is more appropriate in that forum where the real party in interest (Mr. Epstein) is a party to the suit. «DE29_081008_Resp to Moth Unseal.pdf>> Assistant U.S. Attorney Fax 561 820-8777 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 6 EFTA00227072 communication in error, please notify us immediately by return e-mail or by e-mail to postmastergkirkland.com, and destroy this communication and all copies thereof, including all attachments. EFTA00227073 From: Sent: Wednesday, October 08, 2008 2:38 PM To: Lefkowttz Cc: Subject: Jane Does v. United States Dear Roy and Jay: I am attaching the United States' Response to the Petitioners' Motion to Unseal the Non-Prosecution Agreement, which was filed in the victims' rights suit filed against the United States by Attorney Brad Edwards on behalf of two of the victims. In his motion to unseal, Attorney Edwards stated that he would provide notice of his motion to counsel for Mr. Epstein. I do not know if he actually did so. In our response, we oppose the Petitioners' motion, and point out that Mr. Edwards has filed a civil suit against Mr. Epstein and that litigation regarding the Non-Prosecution Agreement is more appropriate in that forum where the real party in interest (Mr. Epstein) is a party to the suit. DE29 _081008_Ft p to Morn Unsea ssistant U.S. Attorney Fax 561 820-8777 Tracking: EFTA00227074 From: Lilly Ann Sanchez Sent: Friday, December To: (USAFLS) Subject: Marie- I hope that the two weeks you will be out of the district is for a well-deserved vacation. I have been so busy lately that I am also looking forward to taking some time off closer to the end of the year. I am planning to be out of the office the weeks of Dec. 18 and Dec. 25 to spend much quality time with my son who is now 8 years old and growing up too fast. Since it looks like we will miss each other before the New Year, I will be in touch at that time and hopefully we will be able to meet shortly thereafter. In the interim, I will check on the document requests you made and get back to you. Regards. Lilly Ann Sanchez, Esq. FOWLER WHITE BURNETT P.A. Espirito Santo Plaza, 14th Floor 1395 Brickell Avenue Miami, Florida 33131-3302 Telephone: Direct Dial Facsimile: > > > 11/17/2006 9:22 AM >>> Hi Lilly -- This is the correct e-mail address. I hope that you received the letter that I faxed yesterday. I will be out of the office today, but I will be back on Monday. Thank you. Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Phone 243 EFTA00227075 From: Sent: To: Subject: fyi Lourie, Andrew (USAFLS) Tuesday. May 22. 2007 6.33 PM FW: Jeffrey Epstein From: Lourie, Andrew (USAFLS) Sent: Tuesday, May 22, 2007 6:32 PM To: 'Gerald Lefcourt' Subject: RE: Jeffrey Epstein have your letter. I think we are on the same page, but to be sure No 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 Lercourt Sent: Tuesday, May 22, 2007 2:05 PM To: Lourie, Andrew USAFLS Cc: 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 Tel. Fax [email protected] 152 EFTA00227076 From: Sent: Monday. February 12, 2007 3:43 PM To: Lilly Ann Sanchez Subject: RE Epstein Matter Thank you, Lilly. Assistant U.S. Attorney 500 S. Australian Ave, Ste 400 FL 33401 Fax 561 820-8777 From: Lilly Ann Sanchez Sent: Monday, Februa 12, 2007 1:45 PM To: Subject: Re: Epstein Matter merle- i received your email. I will speak to gerry and get back to you shortly on both items. hope you are well. regards Lilly Ann Sanchez, Esq. FOWLER WHITE BURNETT' P.A. Espirito Santo Plaza, 14th Floor 1395 Brick Miami, Flo ' Telephone: Direct Dial: Facsimile: >>> SAFLS) 12/2007 12:24 PM >>> Hi Lilly — Please let Gerry know that I took his comments to heart and I am re-reviewing all of the tapes. I noticed that he had transcripts of at least some of the tapes. Any chance you would be willing to share those with me? It would make the review oh so much quicker. And, could you send me the list of the lawyers who represent current or former employees? Before you ask, Rule 6(e) requires that I keep mattcrs before the grand jury secret, so I cannot tell you who or what I am subpoenaing. If the subpoenaed party (or his/her attorney) decides to disclose that information to you, that is his/her prerogative, but 1 can't do it. Thank you very much. Assistant U.S. Attorney 500 S. Australian Ave, Ste 400 227 EFTA00227077 West Palm Beach, F1.33401 Fax 561 820-8777 **TAX MATTERS- IRS Circular 230 Disclosure: To ensure compliance with requirements imposed by the IRS, we inform you that any tax advice contained in this communication (including attachments) was not intended or written to be used, and cannot be used, for the purpose of (i) avoiding penalties under the Internal Revenue Code or promoting, marketing or recommending to another party any transaction or matter addressed herein. If you would like such advice, please contact us.*** ***Attention: The information contained in this E-mail message is attorney privileged and confidential information intended only for the use of the individual(s) named above. If the reader of this message is not the intended recipient, you are hereby notified that any dissemination, distribution or copy of this communication is strictly prohibited. If you have received this communication in error, please contact the sender by reply E-mail and destroy all copies of the original message. Thank you. EFTA00227078 From: Lilly Ann Sanchez • Sent: Monda , Februa 12, 2007 1:45 PM To: Subject: e: psein a er merle- I received your email. I will speak to gerry and get back to you shortly on both items. hope you are well. regards Ully Ann Sanchez, Esq. FOWLER WHITE BURNETT P.A. Espirito Santo Plaza, 14th Floor 1395 Brlckell Avenue Miami, Florida 33131-3302 Telephone: Direct Dial: Facsimile: >>> 2/12/2007 12:24 PM >» Hi Lilly -- Please let Gerry know that I took his comments to heart and 1 am re-reviewing all of the tapes. I noticed that he had transcripts of at least some of the tapes. Any chance you would be willing to share those with me? ►t would make the review oh so much quicker. And, could you send me the list of the lawyers who represent current or former employees? Before you ask, Rule 6(e)requires that I keep matters before the grand jury secret, so I cannot tell you who or what I am subpoenaing. If the subpoenaed party (or his/her attorney) decides to disclose that information to you, that is his/her prerogative, but I can't do it. Thank you very much. Assistant U.S. Attorney 500 S. Australian Ave, Ste 400 West Palm Beach, FL 33401 Fax 561 820-8777 **TAX MATTERS- IRS Circular 230 Disclosure: To ensure compliance with requirements imposed by the IRS, we inform you that any tax advice contained in this communication (including attachments) was not intended or written to be used, and cannot be used, for the purpose of (i) avoiding penalties under the Internal Revenue Code or (ii) promoting, marketing or recommending to another party any transaction or matter addressed herein. If you would like such advice, please contact us.*** ***Attention: The information contained in this E-mail message is attorney privileged and confidential information intended only for the use of the individual(s) named above. If the reader of this 229 EFTA00227079 message is not the intended recipient, you are hereby notified that any dissemination, distribution or copy of this communication is strictly prohibited. If you have received this communication in error, please contact the sender by reply E-mail and destroy all copies of the original message. Thank you. 230 EFTA00227080 From: Sent: To: Subject: Contacts: Monday, February 12 2007 12:25 PM Sanchez, Lilly Ann Epstein Matter Lilly Ann Sanchez Hi Lilly -- Please let Gerry know that I took his comments to heart and I am re-reviewing all of the tapes. I noticed that he had transcripts of at least some of the tapes. Any chance you would be willing to share those with me? It would make the review oh so much quicker. And, could you send me the list of the lawyers who represent current or former employees? Before you ask, Rule 6(e) requires that I keep matters before the grand jury secret, so I cannot tell you who or what lam subpoenaing. If the subpoenaed party (or his/her attorney) decides to disclose that information to you, that is his/her prerogative, but I can't do it. Thank you very much. Assistant U.S. Attorney 500 S. Australian Ave, Ste 400 FL 33401 Fax 561 820-8777 231 EFTA00227081 From: Sent: To: Subject: Hi Jim -- I just received your letter. It, of course, contains a number of topics, but I will address only the first. I have conferred with our victim-witness coordinator, who tells me that we can reimburse Ms. Miller for childcare expenses. I need an estimate to prepare the request and then, after the testimony, if Ms. Miller provides me with the amount of money that she actually paid, we can reimburse that amount. As for the remainder of the letter, I am a big believer in actions speaking louder than words, so the only way to prove that I am exercising independent judgment is to do so. I intend to do a thorough independent investigation so that I can make a reasoned decision about the matter. I cannot do that if witnesses who are not targets refuse to speak to me, even with assurances that their statements will not be used against them. As soon as I know the grand jury's schedule, I will call you with the time. Thank you. Assistant . Attorney 500 S. Australian Ave, Ste 400 West Palm Beach, Ft. 33401 Fax 561 820-8777 From Se AM Mial l= To: Subject: Re: I just wrote you a letter confirming that Ms. Miller will be at the grand jury room with me. Please keep me informed as to the time. I must warn you, my letter is critical of your office, although not at all critical of you. If you change your mind about forcing Ms Miller to appear, please e-mail or call at once so she does not have to make arrangements for child care to be in court. Thanks, Jim Eisenberg 232 EFTA00227082 From: Sent: Friday, February 02, 2007 9:36 AM To: Vill e C. (USAFLS) Subject: Re: I just wrote you a letter confirming that Ms. Miller will be at the grand jury room with me. Please keep me informed as to the time. I must warn you, my letter is critical of your office, although not at all critical of you. If you change your mind about forcing Ms Miller to appear, please e-mail or call at once so she does not have to make arrangements for child care to be in court. Thanks, Jim Eisenberg 233 EFTA00227083 From: Sent: Friday, February 02, To: enberg Subject: Contacts: James L. Eisenberg Eli Jim -- Will Ms. Miller appear at the grand jury on Tuesday? I believe that we will start at 1:00, but I won't know for certain until later today or Monday. Thank you. Assistant U.S. Attorney 500 S. Australian Ave, Ste 400 West Palm Beach, FL 33401 Fax 561 820-8777 234 EFTA00227084 From: Sent: To: Cc: Subject: n bancnez Friday, January 05, 2007 4:05 PM Gerald Lefcourt Jeffrey Epstein Marie- hope you had a great holiday season. Gerald Lefcourt and I would like to speak with you early next week on the Epstein matter. if you provide me with some convenient dates and times for us to call you, i will coordinate with Gerry and confirm same. regards Lilly Ann Sanchez, Esq. FOWLER WHITE BURNETT P.A. Espirito Santo Plaza, 14th Floor 1395 Brickell Avenue Miami, Flo Telephon Direct Dial Facsimile: **TAX MATTERS- IRS Circular 23C Disclosure: To ensure compliance with requirements imposed by the IRS, we inform you that any tax advice contained in this communication (including attachments) was not intended or written to be used, and cannot be used, for the purpose of (i) avoiding penalties under the Internal Revenue Code or (ii) promoting, marketing or recommending to another party any transaction or matter addressed herein. If you would like such advice, please contact us.*** ***Attention: The information contained in this E-mail message is attorney privileged and confidential information intended only for the use of the individual(s) named above. If the reader of this message is not the intended recipient, you are hereby notified that any dissemination, distribution or copy of this communication is strictly prohibited. If you have received this communication in error, please contact the sender by reply E-mail and destroy all copies of the original message. Thank you. 240 EFTA00227085 From: Sent: urs ay, ebruary 15, 2007 3:51 To: Lilly Ann Sanchez Subject: RE: JE Great. We will see you then. Assistant U.S. Attorney 500 S. Australian Ave, Ste 400 West Palm Beach, FL 33401 777 From: Lilly Ann Sanchez Sent: Thursda Februa 15 2007 3:41 PM To: Subject: RE: JE absolutely not in that case, gerry and i may come In jeans. Ully Ann Sanchez, Esq. FOWLER WHITE BURNETT P.A. Espirito Santo Plaza, 14th Floor 1395 Brickell Avenue Miami, Florida 33131-3302 Telephone: (305) 789-9200 Direct Dial: (305) 789-9279 Facsimile: (305) 789-9201 Isanchezefowler-white.com >>> ' > 2/15/2007 3:20 PM >>> HI Lilly -- is is a si y question ut I some peop e om an earlier generation get upset. The agents and I had set aside next week to go through all the tapes, so we are setting up a warroom and I was planning to just wear jeans. Do you think Gerry would be offended? Assistant U.S. Attorney 500 S. Australian Ave, Ste 400 FL 33401 Fax 561 820-8777 219 EFTA00227086 From: Lilly Ann Sanchez [mailto Sent: Thursday, February 15, 2007 3:18 PM To Subject: JE confirmed meeting on Tuesday at loam with gerry lefcourt. see you then. safe trip. Ully Ann Sanchez, Esq. FOWLER WHITE BURNETT P.A. Espirito Santo Plaza, 14th Floor 1395 Brickell Avenue Miami, Flo Telephone Direct Dial Facsimile: lsanchez(afowler-white.com **TAX MATTERS- IRS Circular 230 Disclosure: To ensure compliance with requirements imposed by the IRS, we inform you that any tax advice contained in this communication (including attachments) was not intended or written to be used, and cannot be used, for the purpose of (i) avoiding penalties under the Internal Revenue Code or (ii) promoting, marketing or recommending to another party any transaction or matter addressed herein. If you would like such advice, please contact us.*** ***Attention: The information contained in this E-mail message is attorney privileged and confidential information intended only for the use of the individual(s) named above. If the reader of this message is not the intended recipient, you are hereby notified that any dissemination, distribution or copy of this communication is strictly prohibited. If you have received this communication in error, please contact the sender by reply E-mail and destroy all copies of the original message. Thank you. **TAX MATTERS- IRS Circular 230 Disclosure: To ensure compliance with requirements imposed by the IRS, we inform you that any tax advice contained in this communication (including attachments) was not intended or written to be used, and cannot be used, for the purpose of (i) avoiding penalties under the Internal Revenue Code or (ii) promoting, marketing or recommending to another party any transaction or matter addressed herein. If you would like such advice, please contact us.*** ***Attention: The information contained in this E-mail message is attorney privileged and confidential information intended only for the use of the individual(s) named above. If the reader of this message is not the intended recipient, you are hereby notified that any dissemination, distribution or copy of this communication is strictly prohibited. If you have received this communication in error, please contact the sender by reply E-mail and destroy all copies of the original message. Thank you. 220 EFTA00227087 From: Sent: February 15. 1 To: Lilly Ann Sanchez Subject: RE: JE Hi Ully -- This is a silly question but I know some people from an earlier generation get upset. The agents and I had set aside next week to go through all the tapes, so we are setting up a warroom and I was planning to just wear jeans. Do you think Gerry would be offended? Assistant U.S. Attorney 500 S. Australian Ave, Ste 400 West Palm Beach, FL 33401 From: Lilly Ann Sanchez Sent: . TIlursda 3:18 PM To: Subject: JE confirmed meeting on Tuesday at loam with gerry lefcourt. see you then. safe trip. Lilly Ann Sanchez, Esq. FOWLER WHITE BURNETT P.A. Espirito Santo Plaza, 14th Floor 1395 Brickell Avenue Miami, Flo Telephone: Direct Dial: Facsimile: Isancheeafowler-white.Conl **TAX MATTERS- IRS Circular 230 Disclosure: To ensure compliance with requirements imposed by the IRS, we inform you that any tax advice contained in this communication (including attachments) was not intended or written to be used, and cannot be used, for the purpose of (i) avoiding penalties under the Internal Revenue Code or (ii) promoting, marketing or recommending to another party any transaction or matter addressed herein. If you would like such advice, please contact us.*•• •••Attention: The information contained in this E-mail message is attorney privileged and confidential information intended only for the use of the individual(s) named above. If the reader of this message is not the intended recipient, you are hereby notified that any dissemination, distribution or copy of this communication is strictly prohibited. If you have received this communication in error, please 221 EFTA00227088 contact the sender by reply E-mail and destroy all copies of the original message. Thank you. 222 EFTA00227089 Villafana, Ann Marie C. (USAFLS) From: Sent: To: Subject: Lilly Ann Sanchez JE confirmed meeting on Tuesday at 10am with gerry lefcourt. See you then. safe trip. Lilly Ann Sanchez, Esq. FOWLER WHITE BURNETT P.A. Espirito Santo Plaza, 14th Floor 1395 Brickell Avenue Miami, Florida 33131.3302 Telephone: Direct Dial: Facsimile: Isanchezefowler-w ite.com **TAX MATTERS- IRS Circular 230 Disclosure: To ensure compliance with requirements imposed by the IRS, we inform you that any tax advice contained in this communication (including attachments) was not intended or written to be used, and cannot be used, for the purpose of (i) avoiding penalties under the Internal Revenue Code or (ii) promoting, marketing or recommending to another party any transaction or matter addressed herein. If you would like such advice, please contact us.*** ***Attention: The information contained in this E-mail message is attorney privileged and confidential information intended only for the use of the individual(s) named above. If the reader of this message is not the intended recipient, you are hereby notified that any dissemination, distribution or copy of this communication is strictly prohibited. If you have received this communication in error, please contact the sender by reply E-mail and destroy all copies of the original message.. Thank you. 223 EFTA00227090 From: INISMIEMMOISUSAFLS) Sent: Tuesday. Februa 13, 2007 4:41 PM To: Bruce M. Lyons Subject: Adrianna Ross Contacts: Bruce M. Lyons Hi Bruce -- I was hoping I could get that factual proffer from you so I can see what the Office wants to do regarding immunity. On a totally unrelated note, are you related to Dennis Lyons from the Chicago area? Thank you. Assistant U.S. Attorney Fax 561 820-8777 ann.marie.c.villafanaritusdoi.gov 224 EFTA00227091 (USAFLS) From: Sent: Tuesday, February 1 To: James L. Eisenberg Subject: Wntter Proffer Contacts: James L. Eisenberg Hi Jim -- I haven't received your written proffers likely testimony. Have you sent it already? Thank you. Assistant U.S. Attorney Fax 561 820-8777 226 EFTA00227092 SAFLS) From: Sent: Friday, February 23 20071:3 To: Sanchez, Lilly Ann Subject: Transcripts Hi Lilly -- I talked to Nesbitt, and we would like to get the transcripts and cifalli , if possible. Thank you very much for interceding on our behalf. Have a very good weekend. IIMMOMMIN Assistant U.S. Attorney I LI11.20-8777 218 EFTA00227093 USAFLS From: Sent: Wednesday, April 25, 2007 5:39 PM To: Subject: _ps ern orpora ions Attachments: Hyperion Subpoena001.pdf; JEGE Subpoena001.pdf Hi Bruce -- I tried faxing these a couple of times but your fax machine wasn't picking up, so I just scanned them in. These are the JEGE and Hyperion Subpoenas. I will wait to hear from you about the other items. Thank you. Assistant U.S. Attorney Fax 561 820-8777 From: Sent: ay, n .2 : To: Subject: Re: Epstein Corporations I will get you the information on his NY counsel and find out the other info you request. See what's free at AOL com. 194 EFTA00227094 From: Sent: Wednesday. Ap To: Bruce M Lyons Subject: Epstein Corporations Contacts: Bruce M. Lyons Hi Bruce -- Sorry to bother you. I couldn't remember whether you represented JEGE and Hyperion or if you only represented the pilots. Could you let me know? I need a few more business records. And, do you represent any other corporate entities owned/operated by Mr. Epstein? If not, do you know who his general corporate counsel is? Thank you! Assistant U.S. Attorney Fax 561 820-8777 [email protected] 195 EFTA00227095 From: Sent: To: Subject: Dear Sir or Madam: Service on a Delaware Corporation I have a federal grand jury subpoena that needs to be served on a Delaware corporation for which CT Corporation is listed as the registered agent. Do you accept service via facsilime and/or via e-mail? Thank you for your kind assistance. Assistant U.S. Attorney Fax 561 820-8777 196 EFTA00227096 S) From: Sent: To: Sanchez, Lilly Ann Subject: Jeffrey Epstein Contacts: Lilly Ann Sanchez ); Gerald Lefcourt Esq. ( Hi Lilly and Gerry -- I have been out sick and have a 2255 due by the end of the week. I will give you a call next week. Thank you. Assistant U.S. Attorney 500 S. Australian Ave, Ste 400 West Palm Bcach, FL 33401 11111.11.111S Fax 561 820-8777 206 EFTA00227097 From: Sent: a nes ay, e ru ry . : AM To: Subject: MIMI= Hi Jim -- Your favorite AUSA contacting you about your favorite client. I hope all is well. I reviewed the proffer and I will make the request to Washington. I will be out of town next week, but hopefully will have an answer by the time I return. Thank you. Assistant U.S. Attorney 561 209- I 047 Fax 561 820-8777 217 EFTA00227098 From: Sent: To: Cc: Subject: Attachments: Gerald Lefcourt Lilly Ann Sanchez; Roy BLACK RE: Jeffrey Epstein 2007-07-18 Villafana re NES subpoena.pdf Marie please consider this letter in response to the subpoena to NES. Gerald B. Lefcourt Gerald B. Lefcourt, P.C. 148 E. 78th Street New York, New York 10021 Tell Fax Original Message From: Sent: Wednesday, July 04, 2007 4:07 PM To: Lilly Ann Sanchez Cc: Gerald Lefcourt Subject: RE: Jeffrey Epstein Dear Lilly and Gerry: Thank you for your e-mail and your message. This e-mail was supposed to have gone out yesterday while I was in trial. I have no objection to the two-week extension with respect to NES, New York Strategy Group, and Epstein Virgin Islands Foundation. With respect to the subpoena to the investigator, I would like to get the computer equipment as soon as possible. If you prefer to simply turn over the equipment without anyone appearing before the grand jury that is fine. If we proceed that way, we can defer litigating the issue of the applicability of the attorney-client and/or work product privilege to information related to how and why the equipment was removed. I will be in trial this week, so please contact Jason Richards at the FBI directly at 561 833-7517. I look forward to your July 11th submission. If you would like to discuss the possibility of a federal resolution of Mr. Epstein's case that could run concurrently with any state resolution, please leave a message on my voicemail at the office (561 209-1047) and I will get back to you after trial has ended for the day. Thank you. Assistant U.S. Attorney 51 EFTA00227099 Original Message From: Lilly Ann Sanchez [mailt Sent: Frida June 29 2007 4:05 PM To: Cc: Gerald Lefcourt Subject: Jeffrey Epstein Marie- As i stated in my earlier voicemail today, we were calling to request a two-week extension on the return date of the following outstanding subpoenas: 1. NES 2. NY Strategy 3. Investigator Riley 4. Certification for St. Thomas entity We will be providing an additional submission to the Office by July 11 and hope to be able to reach a state-based resolution shortly thereafter. as your voicemail to me indicted, you would not oppose a one to two-week extension. accordingly, we would like to extend the return date two weeks-- to July 24. regards Lilly Ann Sanchez, Esq. FOWLER WHITE BURNETT P.A. Espirito Santo Plaza, 14th Floor 1395 Brickell Avenue Miami, Flor' Telephone: Direct Dial Facsimile: lsanchezQfowler-white.com 52 EFTA00227100 From: Sent: To: Subject: rrway, JUIY UU, 'Sanchez, Lilly Ann Extension of Time re Computer Subpoena Hi Lilly and Gerry — I hope you are enjoying your time off. Your request to extend the time to respond to the Riley and Riley-Kiraly subpoenas is fine. I will schedule time with the grand jury on July 17th, so if you intend to move to quash the subpoenas, please file your papers not later than July 16 FYI--United States District Judge Middlebrooks is assigned to handle matters related to the relevant grand jury. As I am sure you know, pursuant to Fed. R. Crim. P. 6(eX6), any such motion must be filed under seal. Thank you. Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Pilia. 33401 Phone Fax 561 820-8777 as EFTA00227101 From: Sent: Wednesday. July 04, 2007 4:07 PM To: 'Lilly Ann Sanchez Cc: Gerald Lefcourt Subject: RE: Jeffrey Epstein Dear Lilly and Gerry: Thank you for your e-mail and your message. This e-mail was supposed to have gone out yesterday while I was in trial. I have no objection to the two-week extension with respect to NES, New York Strategy Group, and Epstein Virgin Islands Foundation. With respect to the subpoena to the investigator, I would like to get the computer equipment as soon as possible. If you prefer to simply turn over the equipment without anyone appearing before the grand jury that is fine. If we proceed that way, we can defer litigating the issue of the applicability of the attorney-client and/or work product privilege to information related to how and why the equipment was removed. I will be in trial this week, so please contact Jason Richards at the FBI directly at 561 833-7517. I look forward to your July 11th submission. If you would like to discuss the possibility of a federal resolution of Mr. Epstein's case that could run concurrently with any state resolution, please leave a message on my voicemail at the offices and I will get back to you after trial has ended for the day. Thank you. Assistant U.S. Attorney Original Message From: Lilly Ann Sanchez [mailtc Sent: Frida June 29 2007 4:05 PM To: Cc: Gerald Lefcourt Subject: Jeffrey Epstein Marie- As i stated in my earlier voicemail today, we were calling to request a two-week extension on the return date of the following outstanding subpoenas: 1. NES 2. NY Strategy 3. Investigator Riley 4. Certification for St. Thomas entity We will be providing an additional submission to the Office by July 11 and hope to be able to reach a state-based resolution shortly thereafter. 99 EFTA00227102 as your voicemail to me indicted, you would not oppose a one to two-week extension. accordingly, we would like to extend the return date two weeks-- to July 24. regards Lilly Ann Sanchez, Esq. FOWLER WHITE BURNETT P.A. Espirito Santo Plaza, 14th Floor 1395 Brickell Avenue Miami, Flor Telephone: Direct Dial Facsimile: lsanchez0fowler-white.com Tracking: 100 EFTA00227103 From: Lilly Ann Sanchez Sent: To: Cc: Gerald Letcourt Subject: Jeffrey Epstein Marie- As i stated in my earlier voicemail today, we were calling to request a two-week extension on the return date of the following outstanding subpoenas: 1. NES 2. NY Strategy 3. Investigator Riley 4. Certification for St. Thomas entity We will be providing an additional submission to the Office by July 11 and hope to be able to reach a state-based resolution shortly thereafter. as your voicemail to me indicted, you would not oppose a one to two-week extension. accordingly, we would like to extend the return date two weeks-- to July 24. regards Lilly Ann Sanchez, Esq. FOWLER WHITE BURNETT P.A. Espirito Santo Plaza, 14th Floor 1395 Brickell Avenue Miami, Flor Telephone: Direct Dial Facsimile: lsanchezefowler-white.com 110 EFTA00227104 From: Sent: Monday. June 25, 2007 4:54 PM To: Sanchez, Lilly Anri Subject: Your letter Hi Lilly — I did get a copy of your letter, thanks. I will see you tomorrow morning. Regards, Marie 113 EFTA00227105 From: Sent: To: Subject: Wednesday, June 13, 2007 5:48 PM Another Corporation Dear Gerry and Lilly: Sorry to trouble you yet again, but are you authorized to accept service of a subpoena for NES, LLC? Thank you again. se ttorney 135 EFTA00227106 From: Sent: To: Cc: Subject: Attachments: Dear Ms. Faith A Friedman Tuesday, June 12, 2007 5.45 PM era a court Subpoenas dated May 31, 2007, to J. Epstein Virgin Islands Foundation. Inca, J. Epstein & Co., Inc.; Epstein Interests: and Financial Trust Company. Inc 2007-06-12 to Villafana w subpoena material.pdf At Mr. Lefcourt's request, I hereby provide you with responses to the subpoenas served on the above entities all of which were dated May 31, 200 7. I note that the original, along with the documents referenced therein, was sent to your office this afternoon by Federal Express. If you do not receive these items or have any questions please do not hesitate to contact Mr. Lefcourt. Very truly yours, Faith A. Friedman, Esq. Law Offices of Gerald B. Lefcourt, P.C. 148 East 78th Street York 10021 x327 email. ffri i: Stfogifilzys2m 136 EFTA00227107 From: Sent: Thursday, May 31, 2007 8:26 PM To: Gerald Lefcourt Cc: Ball, Shawn (USAFLS) Subject: RE: Representation of Financial Trust Company, Inc.. J. Epstein & Company. Inc., and other corporate entities Hi Gerry — Sorry. I was out and then I had to start trial. You will receive them tomorrow. Thank you again. Assistant U.S. Attorney 561 209-1047 From: Gerald Lefcourt [mailto Sent: Thursday, May 31, 2007 11:56 AM To: Villafana, Ann Marie C. (USAFLS) Cc: Lilly Ann Sanchez Subject: RE: Representation of Financial Trust Company, Inc., J. Epstein & Company, Inc., and other corporate entities Marie, when we spoke last Thursday I agreed to accept service of a subpoena (without promising I would represent Financial Trust depending on what was being requested) that I think you said you would fax. This is just to let you know that I never received any fax to that end --just in case it was sent somewhere else in error. Gerald B. Lefcourt Gerald B. Letcourt, P.C. 148 E. 78th Street New York. York 10021 Tel. Fax obl(&leicourtlaw com From: S) [mailto Sent: Tuesday, May 22, 2007 7:14 PM To: Gerald Lefcourt Subject: Representation of Financial Trust Company, Inc., J. Epstein & Company, Inc., and other corporate entities Dear Gerry: I noticed that, at least as of July 2005, you have served as counsel to Financial Trust Company, Inc. in connection with litigation. Can you let me know if you still represent Financial Trust Company, Inc., and if you represent J. Epstein & Company, Inc.. J. Epstein Virgin Islands Foundation, Inc., and/or Epstein Interests? If you represent any or all of those entities, are you willing to accept service of subpoenas via fax? Thank you for your assistance. Marie 137 EFTA00227108 Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 Phone Fax 561 820-8777 138 EFTA00227109 From: Gerald lefcourtmapiiiim Sent: Thursda Ma To: Cc: Lilly Ann Sanchez Subject: RE: Representation of Financial Trust Company, Inc.. J. Epstein & Company, Inc., and other corporate entities hen we spoke last Thursday I agreed to accept service of a subpoena (without promising I would represent Financial Trust depending on what was being requested) that I think you said you would fax. This is just to let you know that I never received any fax to that end -- just in case it was sent somewhere else in error. Gerald B. Lefcourt Gerald B. Lefcourt, P.C. 148 E. 78th Street New York New York 10021 Tel. Fax Rbialercoudlaw.com From: Sent: u ay, ay , To: Gerald Lefcourt Subject: Representation of Financial Trust Company, Inc., J. Epstein & Company, Inc., and other corporate entities Dear Gerry: I noticed that, at least as of July 2005, you have served as counsel to Financial Trust Company, Inc. in connection with litigation. Can you let me know if you still represent Financial Trust Company, Inc., and if you represent J. Epstein & Company, Inc., .1. Epstein Virgin Islands Foundation, Inc., and/or Epstein Interests? If you represent any or all of those entities, are you willing to accept service of subpoenas via fax? Thank you for your assistance. Marie Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 Rhona... Fax 561 820-8777 139 EFTA00227110 From: Sent: To: Subject: Please put in your file. thx Lourie, Andrew (USAFLS) FW: Jeffrey Epstein From: Gerald Lefcourt Sent: Wednesday, May 23, 2007 5:00 PM To: Lourie, Andrew (USAFLS) Subject: RE: Jeffrey Epstein Thanks for the email. I will get back to you aS to timing of the meeting. Gerald B. Lefcourt Gerald B. Lefcourt, P.C. 148 E. 78th Street New York New York 10021 Tel. Fax oblOletcourtlaw.com 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 Sent: Tuesday, May 22, 2007 2:05 PM To: Lourie Andrew Cc: Subject: Jeffrey Epstein 141 EFTA00227111 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 Tel. Fax 142 EFTA00227112 From: Villafana, Ann Marie C. (USAFLS) Sent: Tuesday, May 22, 2007 7:14 PM To: [email protected] Subject: Representation of Financial Trust Company, Inc., J. Epstein & Company. Inc., and other corporate entities Dear Gerry: I noticed that, at least as of July 2005, you have served as counsel to Financial Trust Company, Inc. in connection with litigation. Can you let me know if you still represent Financial Trust Company, Inc., and if you represent J. Epstein & Company, Inc., J. Epstein Virgin Islands Foundation, Inc., and/or Epstein Interests? If you represent any or all of those entities, are you willing to accept service of subpoenas via fax? Thank you for your assistance. Marie Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West POO.3401 Phone Fax 561 820-8777 146 EFTA00227113 From: ) Sent: Millliiill. To: [email protected] Subject: Representation of Financial Trust Company, Inc., J. Epstein & Company. Inc., and other corporate entities Dear Gerry: I noticed that, at least as of July 2005, you have served as counsel to Financial Trust Company, Inc. in connection with litigation. Can you let me know if you still represent Financial Trust Company, Inc., and if you represent J. Epstein & Company, Inc., J. Epstein Virgin Islands Foundation, Inc., and/or Epstein Interests? If you represent any or all of those entities, are you willing to accept service of subpoenas via fax? Thank you for your assistance. Marie Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 Westiiiii.340 I Phon Fax 561 820-8777 Tracking: 147 EFTA00227114 From: Sent: Thursda , Au ust 02, 2007 12:56 PM To: Subject: : e er Attachments: MenschelFinalLetter.pdf FYI Original Message From: Lilly Ann Sanchez [mailto:[email protected]] Sent: Thursday, August 02, 2007 12:38 PM To: Menchel, Matthew (USAFLS) Cc: Jacqueline Borrero Subject: JE -- letter matt- please see attached and confirm receipt. i am also having letter hand-delivered to you and alex. regards Lilly Ann Sanchez, Esq. FOWLER WHITE BURNETT P.A. Espirito Santo Plaza, 14th Floor 1395 Brickell Avenue Miami, Florida 33131-3302 Telephone: (305) 789-9200 Direct Dial: (305) 789-9279 Facsimile: (305) 789-9201 lsanchez0fowler-white.com **TAX MATTERS- IRS Circular 230 Disclosure: To ensure compliance with requirements imposed by the IRS, we inform you that any tax advice contained in this communication (including attachments) was not intended or written to be used, and cannot be used, for the purpose of (i) avoiding penalties under the Internal Revenue Code or (ii) promoting, marketing or recommending to another party any transaction or matter addressed herein. If you would like such advice, please contact us.*** ***Attention: The information contained in this E-mail message is attorney privileged and confidential information intended only for the use of the individual(s) named above. If the reader of this message is not the intended recipient, you are hereby notified that any dissemination, distribution or copy of this communication is strictly prohibited. If you have received this communication in error, please contact the sender by reply E-mail and destroy all copies of the original message. Thank you. 41 EFTA00227115 From: Sent: To: Subject: Roy BLACK ([email protected]] Au ust 2008 1:49 PM Re: Follow-up on last week's call Ok. Will do. Original Message From: To: Roy BLACK <[email protected]> Cc: Karen (USAFLS) Atkinson <[email protected]> Sent: 8/6/2008 1:38:23 PM Subject: RE: Follow-up on last week's call Hi Roy -- Hope your trip is going well. Are you available today at 4:30 Eastern (1:30 Pacific)? If so, please call my office at the number below, and Karen and I can both be reached there. Thank you. PRIPPRIM sssar rney 500 S. Australian Ave, Suite 400 West Palm Beach. FL 33401 Fax 561 820-8777 Original Message From: Roy BLACK [mailto:[email protected]] Sent: Tuesday, August 05, 2008 11:40 PM To: Cc: Atkinson, Karen (USAFLS) Subject: Re: Follow-up on last week's call III I just got back to my computer. Sorry it took awhile to respond. I am able tomorrow to call you. Let me know what time to call. Remember I am 3 hours behind you so email me the time in the am and I will call. Thanks Roy 08/05/08 1:01 PM >>> Hi Roy - Are you available late this afternoon to do a follow-up on last week's call? If today does not work, can you let us know about your availability tomorrow, as well? Thank you. 308 EFTA00227116 Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 Phone Fax 561 820-8777 309 EFTA00227117 USAFLS) From: Sent: Wednesday, August 06, 2008 1 38 PM To: Roy BLACK Cc: Subject: RE: Follow-up on last week's call Hi Roy -- Hope your trip is going well. Are you available today at 4:30 Eastern (1:30 Pacific)? If so, please call my office at the number below, and Karen and I can both be reached there. Thank you. Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 Phone Fax 561 820-8777 Original Message From: Roy BLACK Cmailto:[email protected]] Sent: Tuesda Au ust 05 2008 11:40 PM To: Cc: Atkinson, Karen (USAFLS) Subject: Re: Follow-up on last week's call I just got back to my computer. Sorry it took awhile to respond. I am ble tomorrow to call you. Let me know what time to call. Remember I am 3 hours behind you so email me the time in the am and I will call. Thanks Roy >>> . (USAFLS)" 08/05/08 1:01 PM >>> Hi Roy - Are you available late this afternoon to do a follow-up on last week's call? If today does not work, can you let us know about your availability tomorrow, as well? Thank you. Assistant . . attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 Pho Fax 561 820-8777 310 EFTA00227118 Tracking: 311 EFTA00227119 (USAFLS) From: Sent: To: Cc: Subject: Dear Jay and Roy: Response to your e-mail Friday. AUGUst 15. 2008 2:12 PM 'Roy BLACK' Please see the attached. Thank you. PLR 380815 tillufunum Ltr to Lefkow... Assistant U.S. Attorney 500 S. Australian Aye, Suite 400 West Palm Beach, FL 33401 Phont Fax 561 820-8777 Tracking: 177 EFTA00227120 (USAFLS) From: Lourie, Andrew (USAFLS) Sent: Thursday, August 23, 2007 11:27 AM To: IMPRIIIIIRIMIIIIII IIII. Subject: FW: fyi From: Lourie, Andrew (USAFLS) Sent: Thursda Au ust 23 2007 11:27 AM To: Subject: Dear Lilly, Following up on our conversation yesterday, given that Roy Black will be on vacation through Labor Day, we are agreeable to jointly requesting that Judge Marra set the hearing regarding the subpoena during the week of September 11. You may make this representation to the Court on our behalf. With respect to the September 4 return date for the agents who served the subpoena were left with the impression, based upon her statements, that she already had an attorney. If this is the case, that attorney should contact o discuss any issues he/she has with the return date. If M does not have an attorney and you intend to procure her one, then please let Marie know. If you are unable to find one quickly and need an extra week, Marie has informed me that she is agreeable to extending the subpoena return date to September 111h as well. However, if she is not already represented, please attempt to procure the attorney as soon as possible so that he or she has time to get up to speed in advance of the 11th. We would like to avoid the need for further extensions. We will wait to hear from you regarding but otherwise the above should resolve all the issues raised by telephone yesterday. Regards, Andy EFTA00227121 USAFLS) From: Sent: !may, ugust To: '[email protected]' Sublect: Epstein Computer Litigation Hi Roy —1 have conferred with the appropriate people, and we are not willing to agree to a stay on your Motion to Quash. Regards, Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 Phone Fax 561 820-8777 2 EFTA00227122 (USA FLS) From: Sent: Monday, August 06, 2007 12:53 PM To: 'Matthew I. Menchel' Subject: RE: Did the letter go out on Friday? Thank you! I hope the first day is going well. Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 Phon Fax Original Message From: Matthew I. Menchel [mailto: Sent: Monda Au ust 06 2007 12:36 PM To: Subject: Re: Did the letter go out on Friday? Yes, I emailed it and then sent hard copies to everyone including you. And thanks for your congrats. I wish you all the best with the case. Matthew Menchel Kobre & Kim LLP and Affiliates 800 Third Avenue New York, New York 10022 Tel Fax www.kobrekim.com Original Message From: To: Matthew I. Menchel Sent: Mon Aug 06 11:23:35 2007 Subject: Did the letter go out on Friday? Hi Matt - Sorry to bother you now that you are gone. (Congratulations!) Did the letter to Lilly go out on Friday? Thank you, and best of luck with your new venture. Assistant U.S. Attorney 22 EFTA00227123 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 Phone Fax 561 820-8777 This e-mail message is from Kobre & Kim LLP, a law firm, and may contain legally privileged and/or confidential information. If the reader of this message is not the intended recipient(s), or the employee or agent responsible for delivering the message to the intended recipient(s), you are hereby notified that any dissemination, distribution or copying of this e-mail message is strictly prohibited. If you have received this message in error, please notify the sender immediately and delete this e-mail message and any attachments from your computer without retaining a copy. IRS Circular 230 disclosure: Any tax advice contained in this communication (including any attachments or enclosures) was not intended or written to be used, and cannot be used, for the purpose of (i) avoiding penalties under the Internal Revenue Code or (ii) promoting, marketing or recommending to another party any transaction or matter addressed in this communication. (The foregoing disclaimer has been affixed pursuant to U.S. Treasury regulations governing tax practitioners.) 23 EFTA00227124 SAF LS) From: Sent: To: Matthew Menchel Subject: Did the letter go 0 Hi Matt — Sony to bother you now that you are gone. (Congratulations!) Did the letter to Lilly go out on Friday? Thank you, and best of luck with your new venture. 500 S. Australian Ave, Suite 400 West Palm Reach, FL 33401 Phone Fax 561 820-8777 24 EFTA00227125 (USAFLS) From: MOSEMSIMMIlla Sent: Monday, August 06, 200711:21 AM To: Menchel, Matthew (USAFLS) Subject: Did the letter go out on Friday? Hi Matt — Sony to bother you now that you arc gone. (Congratulations!) Did the letter to Lilly go out on Friday? Thank you, and best of luck with your new venture. Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach FL 33401 Phone Fax 561 820-8777 25 EFTA00227126 (USAFLS) From: Sent: To: Subject: S) Monda Se tember 08. 2008 9 46 AM Dear Jeff and Adam: I apologize, but the attached letters were sent to your offices on September 2id, but were just returned for insufficient postage. I will send the originals out by FedEx today. I received a call, I believe from Mr. Mennelstein, asking why I had sent a letter to a represented party. The enclosed letters are for those victims whom 1 know to be represented by you. If you undertake representation of any other victims, please let me know so that I may keep that in my records. 1 expect that you will share these letters with your clients so that they may decide how they wish to proceed. Regards, Marie 080902 F nal XS to Herman Cl. Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 Phone 561 209-1047 Fax 561 820-8777 72 EFTA00227127 (USAFLS) From: Sent: To: Cc: Subject: Dear Jay and Roy: Tuesday, September 02, 200B 1:16 PM Thank you for your fax have received your fax. I will start sending out the victim notifications today. In accordance with your request, I have changed the language regarding the victims' right to receive a copy of the Agreement. Mr. Goldberger will be receiving copies as the letters go out. Thank you. Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 Phone 561 209-1047 Fax 561 820-8777 Tracking: SS EFTA00227128 (USAFLS) From: Sent: WS ay, ugus . To: Brad Edwards Cc: Subject: RE: Epstein Attachments: Epstein NonProsecution Agrmt w Addendum.pdf Hi Brad — I received your fax with the signed Protective Order, so I have attached the Non-Prosecution Agreement. Please give me a call when you receive. And please send or fax over copies of the signed Protective Order as you receive them from your clients and co-counsel. Thank you. Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 Phone 561 209-1047 Fax 561 820-8777 From: Brad Edwards Sen • To: Subject: RE: Epstein It has already been faxed to you. Please let me know if you do not receive it. Also, I would appreciate it if you could fax it to me as well as mail it, as I would really like to see it today if at all possible. Thanks Brad Edwards, Esquire Law Office of Brad Edwards & Associates 2028 Harrison Street Suite 202 Hollywood, Florida 33020 Telephone: 954-414-8033 (Broward) 305-935-2011 (Miami-Dade) Facsimile: 954-924-1530(Broward) 305/9354227 (Miami-Dade) e-mail: be©bradedwardslaw.com PRIVILEGED AND CONFIDENTIAL: The information contained in this e-mail message is intended for the use of the individual or entity to which it is addressed and may contain information that is proprietary, privileged, confidential, and exempt from disclosure under applicable laws. If the reader of this message is not the intended recipient, or the employee or agent responsible for delivery to the intended recipient, you are hereby notified that any use, printing, reproduction, disclosure or dissemination of this communication may be subject to legal restriction or sanction. 103 EFTA00227129 From: (USAFLS) Hailtosigir— Sent: Wednesday, August 27, 2008 6:47 PM To: Brad Edwards Subject: Epstein Hi Brad — I haven't received a signed protective order from you yet, so I haven't sent over the agreement. Can you fax it to me and then I will get the agreement out to you? I will be out of the office in the morning but back in the afternoon. Thanks. Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 Phone Fax 561 820-8777 Tracking: 104 EFTA00227130 USAFLS) From: Sent: Thursday, August 28. 2008 9 33 AM To: Subject: pstem It has already been faxed to you. Please let me know if you do not receive it. Also, I would appreciate it if you could fax it to me as well as mail it, as I would really like to see it today if at all possible. Thanks Brad Edwards, Esquire Law Office of Brad Edwards & Associates 2028 Harrison Street Suite 202 Hollywood, Florida 33020 Telephone: 954-414-8033 (Broward) 305-935-2011 (Miami-Dade) Facsimile: 954-924-I 530(Broward) 305/935-4227 (Miami-Dade) e-mail: [email protected] PRIVILEGED AND CONFIDENTIAL: The information contained in this e-mail message is intended for the use of the individual or entity to which it is addressed and may contain information that is proprietary, privileged, confidential, and exempt from disclosure under applicable laws. If the reader of this message is not the intended recipient, or the employee or agent responsible for delivery to the intended recipient, you are hereby notified that any use, printing, reproduction, disclosure or dissemination of this communication may be subject to legal restriction or sanction. From: Sent Wednesday, August 27, 2008 6:47 PM To: Brad Edwards Subject Epstein Hi Brad — I haven't received a signed protective order from you yet, so I haven't sent over the agreement. Can you fax it to me and then I will get the agreement out to you? I will be out of the office in the morning but back in the afternoon. Thanks. Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 Phone 106 EFTA00227131 Fax 561 820-8777 107 EFTA00227132 (USAFLS) From: Sent: To: Subject: Hi Brad Edwards Wednesda i .Au RE Epstein I did not know you needed that from me first. The last email I received from Mr. Lee indicated that you do not need the acknowledgement from us prior to disclosure of the agreement, or at least that is how I understood it. So I have just been waiting to receive it. We must have gotten our wires crossed. Either way, no big deal. I have signed it, and I just sent an email to my secretary to fax it to you first thing tomorrow. If you get an opportunity to call me tomorrow afternoon, I would appreciate it. Thanks Sincerely, Brad Edwards, Esquire Law Office of Brad Edwards & Associates 2028 Harrison Street Suite 202 Hollywood, Florida 33020 Telephone: 954-414-8033 (Broward) 305-935-2011 (Miami-Dade) Facsimile: 954-924-1530(Broward) 305/935-4227 (Miami-Dade) e-mail: beta bradedwa rdslaw.com PRIVILEGED AND CONFIDENTIAL: The information contained in this e-mail message is intended for the use of the individual or entity to which it is addressed and may contain information that is proprietary, privileged, confidential, and exempt from disclosure under applicable laws. If the reader of this message is not the intended recipient, or the employee or agent responsible for delivery to the intended recipient, you are hereby notified that any use, printing, reproduction, disclosure or dissemination of this communication may be subject to legal restriction or sanction. From Sent: Wednesday, August 27, 2008 5:47 PM To: Brad Edwards Subject: Epstein Ili Brad — I haven't received a signed protective order from you yet. so I haven't sent over the agreement. Can you fax it to me and then I will get the agreement out to you? I will be out of the office in the morning but back in the afternoon. Thanks. 108 EFTA00227133 Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 a Fax 561 820-8777 109 EFTA00227134 (USAFLS) From: Sent: To: Subject: Wednesday, August 27, 2008 6:47 PM ps ein Hi Brad — I haven't received a signed protective order from you yet, so I haven't sent over the agreement. Can you fax it to me and then I will get the agreement out to you? I will be out of the office in the morning but back in the afternoon. Thanks. Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 Phone Fax 561 820-8777 110 EFTA00227135 (USAFLS) From: al Sent: Wednesday, August 27, 2008 6:36 PM To: [email protected] Subject: Epstein Hi Brad — I haven't received a signed protective order from you yet, so I haven't sent over the agreement. Can you fax it to me and then I will get the agreement out to you? I will be out of the office in the morning but back in the afternoon. Thanks. 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 RIMINIMEM Fax 561 820-8777 111 EFTA00227136 (USAFLS) From: Sent: Tuesday, August 26, 2008 1:26 PM To: e; Roy BLACK Cc: Subject: Jeffrey Epstein Lelkowi z 08082600 .pdf Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 P1w 33401 Pho Fax 561 820-8777 Tracking: 112 EFTA00227137 (USAFLS) From: Sent: Thursday, August 21, 2008 5:32 PM To: Cc: Atkinson, Karen (USAFLS) Subject: Jeffrey Epstein Dear Jay and Roy —I have attached a letter in response to Jay's letter of August 18, 2008, and an Order we received today in the Jane Doe v. United States litigation. )80821 Villafana Itr to Lefkow... DE26 080821 P Dtective Order.p. Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 Phone Fax 561 820-8777 Tracking: 136 EFTA00227138 (USAFLS) From: EMOIMMINIIIMIPM Sent: Wednesday, August 20, 2008 3:19 PM To: [email protected] Subject: Epstein Civil Cases Hi Bert — Here is a chart with all of the information. Please let Mr. Josefsberg know that Mr. Epstein has to answer all of the Complaints in the Jeffrey Herman cases by September 4th. Thank you. ro EPSTEIN CIVIL LIGATION CASES M IRMPP it . . ttorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 Phone Fax 561 820-8777 151 EFTA00227139 (USAFLS) From: Jay Lefkowtz Sent: WednesclaMMO8 9:35 AM To: Cc: Subject: e: our ax Thanks Marie. We arc working on something and will share it with you. Good luck with the weather. From: Sent: 08/20/2008 09:28 AM AST To: Jay Lcflcowitz Cc: "Atkinson, Karen (USAFLS)1 Subject: RE: Your fax P.S. In the meanwhile, if you would like to propose language for our joint submission, I am happy to look that over. Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 Pho Fax 561 820-8777 Fro AM To: Jay Lefkowitz Cc Su Jed: Your Good morning, Jay. Our office has been closed since Monday afternoon due to the Tropical Storm, so I just received your fax. I have to be in Court this morning, but I will turn my attention to your response upon my return and will get back to you later today or tomorrow morning. 156 EFTA00227140 Thank you. Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 Phon Fax 561 820-8777 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 postmasterfakirkland.com, and destroy this communication and all copies thereof, including all attachments. 157 EFTA00227141 . (USAFLS) From: I NIONMiMiliNniiiiiil Sent: Wednesday, August 20, 2008 9:28 AM To: 'Jay Lefkowitz' Cc: Atkinson, Karen (USAFLS) Subject: RE: Your fax P.S. In the meanwhile, if you would like to propose language for our joint submission, I am happy to look that over. Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 Pho Fax 561 820-8777 From: Sent: VilinIMAIIIIMAM To: Jay Lefkowitz Cc: alSisimMillIMIMIO Subject: Your fax Good morning, Jay. Our office has been closed since Monday afternoon due to the Tropical Storm, so I just received your fax. I have to be in Court this morning, but I will turn my attention to your response upon my return and will get back to you later today or tomorrow morning. Thank you. Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 Phor Fax 561 820-8777 158 EFTA00227142 SAFLS) From: Sent: Wednesday, August 20, 2008 9 26 AM To: Jay Lefkowitz Cc: Subject: Your fax Good morning, Jay. Our office has been closed since Monday afternoon due to the Tropical Storm, so 1 just received your fax. I have to be in Court this morning, but I will turn my attention to your response upon my return and will get back to you later today or tomorrow morning. Thank you. Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West PaiiiikL 33401 Phone Fax 561 820-8777 159 EFTA00227143 (USAFLS) From: Brad Edwards Sent: Fridav August 1 To: Cc: Subject: 49 P RE Draft Protective Order - slight tweak It looks ok. Go ahead and submit it. While we would disagree with your statement that our proposed order goes well beyond what is at issue, since it actually covers very thoroughly the ruling by Judge Marra yesterday, at this point we feel that time is of the essence and we will agree with you submitting your proposed order as is. I think we all heard Judge Marra and are thus all clear as to the terms of the protective order and what is required. I would prefer that there is some language that the protective order is entered without prejudice to petitioners (seems like it would go in paragraph b), but if you are unable to incorporate it in your order, then I am sure there is a record from yesterday that could be used to help us get relief from the protective order at a later hearing. Anyway, thanks for preparing the order. We will look out for the "agreement". Thanks From: Sent: Friday, August 15, 2008 1:24 PM To: Paul Cassell• Brad Edwards Cc: Subject: RE: Draft Protective Order - slight tweak Judge Cassell and Brad, I have incorporated the change suggested by Judge Cassell to paragraph (c). I also added language in paragraph (e), referring to other victims, which also provides for petitioners' counsel to promptly provide a copy of the acknowledgment to the U.S. Attorney's Office. The government has no doubts that counsel for petitioners will ensure the authorized recipients are aware of the protective order and agree to abide by it, prior to disclosure. We do not require the acknowledgment in writing prior to the non-prosecution agreement being disclosed to an authorized recipient. We believe the petitioners' proposed protective order goes well beyond what is at issue, the government's disclosure of the non-prosecution agreement, conditioned on limited dissemination of the document upon receipt by petitioners. Consequently, we believe the attached proposed order, incorporating your revisions, is appropriate for the task at hand. Thanks. Dexter From: Paul Cassell Sent: Friday, August 15 2008 12:21 PM To Cc Subject: RE: Draft Protective Order - slight tweak Hello First, I don't know if we've been formally introduced. Nice to meet you ... electronically at least. 171 EFTA00227144 Second, on the language -- As Brad mentioned, we need to see this document quite quickly in view of the Government's representations yesterday that Epstein is trying to ignore the agreement. As a result - - and in view of the difficulty of making immediate contact with our clients -- I propose one change. Instead of this: Prior to producing the documents to Petitioners' counsel, a copy of this Order must be provided to counsel and their clients, who must review and acknowledge their receipt of and agreement to abide by the terms of this Order, and who must provide a copy of that acknowledgment to the USAO. How about this: Before counsel for Petitioner's show the agreement to their clients or discuss the specific terms with them, they must provide a copy of this Order to Petitioners, who must review and acknowledge their receipt of and agreement to abide by the terms of this Order. Counsel for Petitioner's must promptly provide a copy of that acknowledgment to the USAO. I assume that the USAO is not concerned about us as attorneys somehow ignoring the Court's protective order, so this change would focus in on the non-law trained clients. Paul G. Cassell Ronald M. Boyce Presidential Professor of Law S. J. Quinney College of Law University of Utah 332 South 1400 East, Room 101 Salt Lake City, UT 84112 172 EFTA00227145 From: Sent: To: Cc: Subject: Attachments: PM FLS) RE: Draft Protective Order - slight tweak Protective Order_v2 doc Judge Cassell and Brad, I have incorporated the change suggested by Judge Cassell to paragraph (c). I also added language in paragraph (e), referring to other victims, which also provides for petitioners' counsel to promptly provide a copy of the acknowledgment to the U.S. Attorney's Office. The government has no doubts that counsel for petitioners will ensure the authorized recipients are aware of the protective order and agree to abide by it, prior to disclosure. We do not require the acknowledgment in writing prior to the non-prosecution agreement being disclosed to an authorized recipient. We believe the petitioners' proposed protective order goes well beyond what is at issue, the government's disclosure of the non-prosecution agreement, conditioned on limited dissemination of the document upon receipt by petitioners. Consequently, we believe the attached proposed order, incorporating your revisions, is appropriate for the task at hand. Thanks. From: Paul Cassell Sen To: Cc; Subject: RE: Draft Protective Order - slight tweak Hell First, I don't know if we've been formally introduced. Nice to meet you ... electronically at least. Second, on the language -- As Brad mentioned, we need to see this document quite quickly in view of the Government's representations yesterday that Epstein is trying to ignore the agreement. As a result - - and in view of the difficulty of making immediate contact with our clients -- I propose one change. Instead of this: Prior to producing the documents to Petitioners' counsel, a copy of this Order must be provided to counsel and their clients, who must review and acknowledge their receipt of and agreement to abide by the terms of this Order, and who must provide a copy of that acknowledgment to the USAO. Flow about this: Before counsel for Petitioner's show the agreement to their clients or discuss the specific terms with them, they must provide a copy of this Order to Petitioners, who must review and acknowledge their 173 EFTA00227146 receipt of and agreement to abide by the terms of this Order. Counsel for Petitioner% must promptly provide a copy of that acknowledgment to the USAO. I assume that the USAO is not concerned about us as attorneys somehow ignoring the Court's protective order, so this change would focus in on the non-law trained clients. Paul a Cassell Ronald M. Boyce Presidential Professor of Law S. J. Quinney College of Law University of Utah 332 South 1400 East, Room 101 Salt Lake City. UT 84112 174 EFTA00227147 USAFLS) From: Sent: IIIIIIIIIIIIIIIIIIIIII , To: letkowitz kirklanu.com; Roy BLACK Cc: SAFLS) Subject: Response to your e-mail Dear Jay and Roy: Please see the attached. Thank you. )80815 Villafana Ltr to Lefkow... MINIMIney 500 S. Australian Ave, Suite 400 West Palm Beach FL 33401 Phone Fax 561 820-8777 Tracking: 175 EFTA00227148 (USAFLS) From: Paul Cassell (cassellp©LAW.UTAH.EDU) Sent: Friday, August 15, 2008 12:21 PM To: Brad Edwards; Lee, Dexter (USAFLS) Cc: Villafana, Ann Marie C. (USAFLS) Subject: RE: Draft Protective Order - slight tweak Hello First, I don't know if we've been formally introduced. Nice to meet you ... electronically at least. Second, on the language — As Brad mentioned, we need to see this document quite quickly in view of the Government's representations yesterday that Epstein is trying to ignore the agreement. As a result - - and in view of the difficulty of making immediate contact with our clients -- I propose one change. Instead of this: Prior to producing the documents to Petitioners' counsel, a copy of this Order must be provided to counsel and their clients, who must review and acknowledge their receipt of and agreement to abide by the terms of this Order, and who must provide a copy of that acknowledgment to the USAO. How about this: Before counsel for Petitioner's show the agreement to their clients or discuss the specific terms with them, they must provide a copy of this Order to Petitioners, who must review and acknowledge their receipt of and agreement to abide by the terms of this Order. Counsel for Petitioner's must promptly provide a copy of that acknowledgment to the USAO. I assume that the USAO is not concerned about us as attorneys somehow ignoring the Court's protective order, so this change would focus in on the non-law trained clients. Paul G. Cassell Ronald M. Boyce Presidential Professor of Law S. J. Quinney College of Law University of Utah 332 South 1400 East, Room 101 Salt Lake City, UT 84112 Ca$sellpelaw utah edu 198 EFTA00227149 (USAFLS) From: Lee, Dexter (USAFLS) Sent: Friday, August 15. 2008 11:41 AM To: be BradEdwardsLawcom Cc: Subject: Draft Protective Order Brad, Attached please find a draft protective order regarding the disclosure of the non-prosecution agreement to you and Jane Does 1 and 2. Please let us know if there are any changes you wish to make. Thanks. Protective Order.doc 207 EFTA00227150 USAFLS) From: Sent: Wednesday, September 17, 2008 1:20 PM To: Jack Goldberger Subject: RE: Letter concerning Epstein and the Palm Beach Daily News Thank you, Jack. ssis 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 Phone Fax 561 820-8777 From: Jack Goldberger Sent: Wednesday, September 17, 2008 12:59 PM To: Villafana, Ann Marie C. (USAFLS) Cc: Jay Lefkowitz; [email protected]; Barry Krischer; Sloman, Jeff Subject: Re: Letter concerning Epstein and the Palm Beach Daily News We will deal with the state. To answer your? The addendum has been filed Jack Goldberger Sent from my iPhone On Sep 17, 2008, at 12:15 PM, wrote: Gentlemen: Please review the attached letter. Thank you. «Lefkowitz 080917.pdf» Assistant VS. Attorney <Lefkowitz 080917.pdfl 49 EFTA00227151 From: Sent: To: Cc: Subject: USAFLS) Jack Goldberger gimplumpimegm. Wednesday, September 17, 2008 12:59 PM Villafana, Ann Marie C. (USAFLS) Sloman, Re: Letter concerning Epstein and the Palm Beach Daily News We will deal with the state. To answer your? The addendum has been filed Jack Goldberger Sent from my iPhone On Sep 17, 2008, at 12:15 PM, wrote: Gentlemen: Please review the attached letter. Thank you. «Lefkowitz 080917 pdf» • Assistant V.S. Attorney <Lefkowitz 080917.pdf> EFTA00227152 (ILSAFLS) From: Sent: Wednesday, September 17, 2008 12:04 PM To: Jay Lefkowitz; Jack Alan Goldberger (jgoldberger@agwpa com), [email protected] Cc: Barry Krischer: Sloman. Jeff (USAFLS), Atkinson, Karen (USAFLS); Garcia, Rolando (USAFLS) Subject: Letter concerning Epstein and the Palm Beach Daily News Gentlemen: Please review the attached letter. Thank you. Leflsowi z 08091/.pdf Assistant . Attorney 561209-1047 51 EFTA00227153 (USAFLS) From: Sent: Wednesday, September 17. 2008 12:00 PM To: Barry Krischer Cc: Lanna Belohlavek (lbelohla@sa15 state fl us), Subject: Your inquiry regarding the Epstein case Hi Barry — The Non-Prosecution Agreement contains a confidentiality provision that requires us to inform Mr. Epstein's counsel before making any disclosure — even a compulsory disclosure. I am cc'ing you on a letter to Jay Leflcowitz, Roy Black, and Jack Goldberger informing them of the request and asking them, as parties to the criminal case, to contact you regarding a possible suit by the Shiny Sheet. On another note, I also will be informing them that I believe that they still have not filed the complete agreement with the Court, as required by the Judge at the hearing. Thank you very much for reaching out to us when you received this request, and if you need any help from us, please let us know. Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 Phone 561 209-1047 Fax 561 820-8777 52 EFTA00227154 (USAFLS) From: Sent: _Thursday, May 22, 2008 3:38 AM To: Subject: Fw confidential communication Original Message From: Sloman, Jeff (USAFLS) To: Villafana, Ann Marie C. (USAFLS) Sent: Mon May 19 15:37:30 2008 Subject: RE: confidential communication Original Message From: Villafana, Ann Marie C. (USAFLS) Sent: Monday, May 19, 2008 3:37 PM To: Acosta, Alex (USAFLS); Garcia, Rolando (USAFLS); Sloman, Jeff (USAFLS) Subject: Re: confidential communication Original Message From: Acosta, Alex (USAFLS) To: Sloman, Jeff (USAFLS); Campos, Cyndee (USAFLS); (USAFLS) Sent: Mon May 19 12:40:32 2008 Subject: FW: confidential communication For your records. From: Jay Lefkowitz [mailto: Sent: Monday, May 19, 2008 10:54 AM To: Acosta, Alex (USAFLS) Subject: confidential communication Dear Alex: I am writing to you because I have just received the attached letter from Drew Oosterbaan. In light of that letter, and given the critical new evidence discussed below, I would like to request a meeting with you, mindful of our July 1026 EFTA00227155 8 deadline, at your earliest opportunity. Given your personal involvement in this matter to date, and the fact that at this juncture it is clear that CEOS has referred the matter back to you, I respectfully request that you not shunt me off to one of your staff. You and I have both spent a great deal of time on this matter, and I know that we both would like to resolve this matter in a way that bestows integrity both on the Department and the process. In our prior discussions, you expressed that you were "not unsympathetic" to our various federalism concerns, but stated that because you serve within the "unitary Executive," you believed your hands were tied by Main Justice. You were also extremely gracious in stating that you did not want the United States to be "unfair". Although CEOS limited its assessment to the federal statutes your Office had brought forth and to the application of those laws to the facts as presented, it is abundantly clear from Drew's letter that Main Justice is not directing this prosecution. In fact, CEOS plainly acknowledged that a federal prosecution of Mr. Epstein would involve a "novel application" of federal statutes and that our arguments against federal involvement are "compelling." Moreover, the language used by Drew in his concluding paragraph, that he cannot conclude that a prosecution by you in this case "would be an abuse of discretion" is hardly an endorsement that you move forward. Moreover, as you know, Drew made clear that the scope of his review did not extend to the other significant issues we have raised with you, such as the undo interest by some members of your staff with the financial and civil aspects of this matter, or with the inappropriate discussion one member of your Office had with alSenior reporter at the New York Times. (In fact, I have met with that reporter and have reviewed copious notes of his conversation with Mr. Weinstein). At this stage, we have no alternative but to raise our serious concerns regarding the issues Drew refused to address with the Deputy or, if necessary, the Attorney General, because we believe those issues have significantly impacted the investigation and any recommendation by your staff to proceed with an indictment. That being said, it would obviously be much more constructive and efficient if we could resolve this matter directly with you in the advance of further proceedings in Washington. Because it is clear that national policy, as determined by Main Justice, is not driving this case, the resolution of this matter is squarely, and solely, your responsibility. I know you want to do the right thing, and it is because you have made clear to me on several occasions that you will always look at all of the relevant and material facts that I call the following to your attention. New information that has come to light strongly suggests that the facts of this case cannot possibly implicate a federal prosecutorial priority. Due to established state procedures and following the initiation of multiple civil lawsuits, Mr. Epstein's counsel was able to take limited discovery of certain women in this matter. The sworn statements provided by these women all confirm that federal prosecution is not appropriate in this case. The consistent repr ' witnesses such as and and the civil complainants and their attorneys, confirm t e o owing key points: First, there was no telephonic 1027 EFTA00227156 communication that met the requirements of § 2422(b). For example, as many other witnesses have stated, Ms. Beale testified in no unclear terms that there was never any discussion over the phone about her coming over to Mr. Epstein's home to engage in sexual activity• "The only thing that ever occurred on any of these phone calls [with r another assistant] was, 'Are you willing to come over,' or, 'Wou you I' e to come over and give a massage.'" Beale Tr. A at 15. Second, the underage women who visited Mr. Epstein have testified that they lied about their age in order to gain admittance into his home and women who brought their underage friends to Mr. Epstein counseled them to lie about their ages as well. Ms. stated the following: "I would tell my girlfriends just like approached me. Make sure you tell him you're 18. Well, these girls that I brought, I know that they were 18 or 19 or 20. And the girls that I didn't know and I don't know if they were lying or not, I would say make sure that you tell him you're 18." Tr. at 22. Third, there was no routine or habit suggesting an intent to transform a massage into an illegal sexual act. For instance, Ms. stated that Mr. Epstein "never touched [her] physically" and that all she did was "massage[ ] his back, his chest and his thighs and that was it." Laduke Tr. at 12-13. Finally, as you are well aware, there was no force, coercion, fraud, violence, drugs, or even alcohol present in connection with Mr. Epstein's encounters with these women. The civil suits confirm that the plaintiffs did not discuss engaging in sexually- related activities with anyone prior to arriving at Mr. Epstein's residence. This reinforces the fact that no telephonic or Internet persuasion, inducement, enticement or coercion of any kind occurred. Furthermore, Mr. Herman, the attorney for most of the civil complainants, was quoted in the Palm Beach Post as saying that "it doesn't matter" that his clients lied about their ages and told Mr. Epstein that they were 18 or 19. In short, the new evidence establishing that the women deliberately lied about their age because they knew Mr. Epstein did not want anyone under 18 in his house directly undercuts the claim that Mr. Epstein willfully blinded himself as to their ages. Willful blindness is not a substitute for evidence of knowledge nor is it a negligence standard. It requires proof beyond reasonable doubt of deliberate intent and specific action to hide one's knowledge. There is absolutely no such evidence of that here, so it is not even a jury issue. Furthermore, willful ignorance cannot constitute the required mens rea for a crime of conspiracy or aiding and abetting. Through the recent witness statements, we have also discovered another serious issue that implicates the integrity of the federal investigation. We have learned that FBI Special Agent attempted to convince these adult women, now in their twenties, t re in fact "victims" even though the women themselves strongly disagreed with this characterization. This conduct, once again, goes to the heart of the integrity of the investigation. In a sworn statement, Ms. Beale was highly critical of the overreaching by federal law enforcement officers in this case. She testified—in no uncertain terms—that she does not, and never did, feel like a "victim," despite the fact that the FBI repeatedly tried to convince her otherwise. I am mindful of the fact that we have a state court date of July 8 on which either to enter a plea or to commence trial. As I review the trial options with 1028 EFTA00227157 Mr. Epstein, I certainly want to make sure I do everything within my power to obviate a need for trial through a reasonable alternative resolution. Although it is clear that CEOS is not directing a prosecution here, and has stated only that you have the authority to commence such a prosecution, I am well aware that the decision whether to proceed, subject to any further process in Washington, is now within your discretion. I think the new facts should greatly influence your decision and accordingly, I hope you will agree to meet with me, both to discuss the new evidence and to discuss a resolution to this matter once and for all. I am available to meet with you at your earliest convenience subject to our mutual availability. Respectfully, Jay **************###44#*##*######################*#*44******** 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 [email protected], and destroy this communication and all copies thereof, including all attachments. ******44####*##*###*####*********************************** 1029 EFTA00227158 From: Sent: To: Cc: Subject: Dear Jay and Roy: Thursday, August 14, 2008 4:21 PM Roy BLACK' We just finished our hearing with Judge Marra. He has ordered us to make the Agreement available to the plaintiffs in this case pursuant to a protective order limiting the disclosure to the victims and their counsel only. He further has ordered that we have to make the agreement available to any other identified victim and her attorney, so long as they also agree to be bound by the protective order. Judge Marra stated that the plaintiffs can litigate the issue of further disclosure directly with Mr. Epstein in the context of their civil suits. When I receive the Court's order and a signed protective order, I will provide them to you. Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Bcach, FL 33401 Phone Fax 561 820-8777 Tracking: 234 EFTA00227159 From: Sent: To: Cc: ;'Roy BLACK' Subject: RE: Follow-up point Dear Jay: The modification contained in the December letter is clear and simple, that is why we were not surprised by Mr. Epstein's and his attorneys' actions affirming acceptance of the modification. Mr. Epstein's acceptance of the modification by pleading guilty was equally clear and simple -- it followed written communications from Mr. Sloman and myself that read: "Mr. Epstein has until the close of business on Monday, June 30, 2008, to comply with the terms and conditions of the agreement between the United States and Mr. Epstein (as modified by the U.S. Attorney's December 19'h letter to Ms. Sanchez), including entry of a guilty plea, sentencing, and surrendering to begin his sentence of imprisonment." As clearly stated in the December letter, only those "individuals whom [the United States] was prepared to name in an Indictment as victims of an enumerated offense" are the beneficiaries of the agreement. That is the list of names that I provided to Messrs. Goldberger and Tein following the change of plea. Under the September/October agreement, all "individuals whom [the United States] has identified as victims" are the beneficiaries, so I would prepare a supplement to the earlier list to include identified victims whom we were not yet prepared to name in an indictment. Again, as stated in the letter, the modification replaces paragraphs 7 and 8 of the Agreement, including paragraphs 7A through 7C that are included in the October Addendum. This means that Mr. Epstein's waiver of "his right to contest damages up to an amount as agreed to between the identified individual and Epstein" will no longer exist, nor will Mr. Epstein's obligation to pay for the victims' counsel. Paragraphs 9 and 10 are still in effect. This includes the statement that there is no admission of civil or criminal liability, and that, "[e]xcept as to those individuals who elect to proceed EXCLUSIVELY under 18 USC § 2255, ... Epstein's signature [cannot] be construed as admissions or evidence of civil or criminal liability." This addresses your question regarding exclusivity. I don't think that Mr. Epstein has to make any constructive admissions of conviction. He only needs to admit that the 32 girls whose names I have provided to Mr. Goldberger are "victims" of an offense listed in 18 U.S.C. 2255. Please let me know if you have any additional questions. Thank you. Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach FL 33401 Phone Fax 561 820-8777 From: Sent: Thursday, August 14, 2008 2:39 PM To: Villafana, Ann Marie C. (USAFLS) 236 EFTA00227160 Cc: Atkinson, Karen (USAFLS); Subject: Re: Follow-up point Marie - In reviewing your December proposal, there are a couple of things I don't understand. What limits are placed upon individuals who proceed under 2255 as if "Mr. Epstein had been tried federally and convicted of an enumerated offense." In other words, what individuals would have this right? And would these individual only have this right if they proceeded exclusively under 2255? Also, to what enumerated offenses do you think would Mr. Epstein have to make constructive admissions of conviction? and how many such offenses? And against whom? Remember that while you may have investigated various offenses, he only plead guilty to certain state crimes. Finally, would paragraphs 8-10 of the September Agreement still be operative? I am trying hard to understand what you have intended by the December letter. Alex has says he thinks it benefits Jeffrey, and I am open to understanding it that way. But I would like some clarity on these issues. Thanks — Jay 08/142008 12'44 PM To Subject Follow-up pont Hi Jay — I forgot to mention that I can no longer argue that the Court shouldn't force us to produce the agreement because we have already provided the victims with the relevant portion when I now understand from you that I have NOT provided them with the relevant portion. Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 Phone Fax 561 820-8777 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 postmasterekirkland.com, and 237 EFTA00227161 destroy this communication and all copies thereof, including all attachments. Tracking: 238 EFTA00227162 SA FLS) From: Jay Lefkowitz Sent: Th rsda Au ust 14 2 2. PM To: Cc: Subject: Re: Follow-up point In reviewing your December proposal, there are a couple of things I don't understand. What limits are placed upon individuals who proceed under 2255 as if "Mr. Epstein had been tried federally and convicted of an enumerated offense." In other words, what individuals would have this right? And would these individual only have this right if they proceeded exclusively under 2255? Also, to what enumerated offenses do you think would Mr. Epstein have to make constructive admissions of conviction? and how many such offenses? And against whom? Remember that while you may have investigated various offenses, he only plead guilty to certain state crimes. Finally, would paragraphs 8-10 of the September Agreement still be operative? I am trying hard to understand what you have intended by the December letter. Alex has says he thinks it benefits Jeffrey, and I am open to understanding it that way. But I would like some clarity on these issues. Thanks -- Jay TCEMIIMIIM 08/14/2008 12.44 PM Subject Fe:on-up pcci Hi Jay — I forgot to mention that I can no longer argue that the Court shouldn't force us to produce the agreement because we have already provided the victims with the relevant portion when I now understand from you that I have NOT provided them with the relevant portion. Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FI, 33401 Phon Fax 561 820-8777 The information contained in this communication is confidential, may be attorney-client privileged, may 246 EFTA00227163 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 [email protected], and destroy this communication and all copies thereof, including all attachments. 247 EFTA00227164 (USAFLS) From: Sent: To: Cc: Subject: Thursday, August 14, 2008 12.43 PM Follow-up point Ili Jay — I forgot to mention that I can no longer argue that the Court shouldn't force us to produce the agreement because we have already provided the victims with the relevant portion when I now understand from you that I have NOT provided them with the relevant portion. Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 Phone SIMS Fax 561 820-8777 250 EFTA00227165 USAFLS) From: Sent: liursday, ugL IM .•11R2 12•M To: Jay Lefkowitz Subject: RE: Telephone Call Fine. Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 Phone 561 209-1047 Fax 561 820-8777 From: Jay Lefkowltz Sent: Thursday, August 14, 2008 12:26 PM To Cc Subject: Re: Telephone Call How about 10 minutes? From: "Villafana, Ann Marie C. (USAFLS)" [Ann.Marie.C.Villafana@usdojjgosl Sent: 08/14/2008 12:19 PM AST To: Jay Letkowitz Cc: "Atkinson, Karen (USAFLS)" <Karen.Atkinson@usdolgov> Subject: Telephone Call Hi Jay — Can you give me a specific time for the call so that 1 can conference call you and Karen? Thank you. Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 Phone Fax 561 820-8777 251 EFTA00227166 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 oostmasterekirkland.com, and destroy this communication and all copies thereof, including all attachments. 252 EFTA00227167 USAFLS) From: Sent: To: Cc: Subject: Ina Telephone Call III Jay —Can you give me a specific time for the call so that I can conference call you and Karen? Thank you. A. Marie Villafaila Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach. FL 33401 Phone Fax 561 820-8777 253 EFTA00227168 From: Sent: hursday, August 14, 2008 11:33 AM To: Roy BLACK Subject: Call with Jay Lefkowitz Hi Roy — Sony to bother you early in the morning. Jay Lefkowitz is supposed to call soon to discuss the agreement. We would prefer to have you on the call as well. Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach FL 33401 Phone Fax 561 820-8777 254 EFTA00227169 From: Sent: To: Cc: Subject: Jay Lefkowitz Wednesday. August 13. 2008 10 00 PM Roy BLACK Re: Electronic Copy of my Fax Thx Marie - speak tomorrow. I will call you around 1130-1200. Jay From: Sent: 0 To: Jay Leflcowitz Cc: "Roy BLACK" <RBLACK®royblack.com> Subject: Electronic Copy of my Fax Jay — Here is a scanned version of the fax, in case you have already left. «Lefkowitz 080813008.pcff>> Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 Phones Fax 561 820-8777 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 postmasterakirkland.com, and destroy this communication and all copies thereof, including all attachments. 258 EFTA00227170 From: Sent: To: Cc: Subject: oy Electronic Copy of my Fax PM lay Here is a scanned version of the fax, in case you have already left. Lefkowitz 080813008.pdf Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach FL 33401 Phone Fax 561 820-8777 259 EFTA00227171 From: Sent: To: Are you reachable? Thanks — Jay Wednesday. August 13. 2008 4:40 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 postmasterakirkland.com, and destroy this communication and all copies thereof, including all attachments. 266 EFTA00227172 From: Sent: To: Cc: Subject: Dear Roy - e nes ay, i l l ist 1 : PM Roy BLACK Jeffrey Epstein Judge Marra has set us for a status conference tomorrow afternoon in Jane Doe v. United States. Given Judge Marra's past rulings, I anticipate that he may order us to turn over the agreement, so we need to get this issue resolved today, if at all possible. Thank you, NNW Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 Phone Ulla Fax 561 820-8777 Tracking: 267 EFTA00227173 From: Sent: es ay, ugt. ...I.P.It To: Roy BLACK Cc: IIIIIIIIIIIPPIPIIIIIIIMIIIIINIS) Subject: Full Agreement Hi Roy — This is what I have provided to Lanna as representing the full agreement and it is what I have described in my Declaration with the Court. Epstein Agrmt001.pdf Thank you. PR IPPRIey 500 S. Australian Ave, Suite 400 West Palm Reach, FL 33401 Phone Fax 561 820-8777 272 EFTA00227174 From: Sent: To: Subject: Roy BLACK [RBLACK©royblack coml Re Call Ok. I will call at 4:15 your time. Original Message From: To: Roy < LA < roy ac .com> Sent: 8/12/2008 3:42:04 PM Subject: Call Hi Roy tied up until 4:15. Can we call you then? Or would you like to call us? Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 Phone 561 209-1047 Fax 561 820-8777 275 EFTA00227175 miallopmemillumpamileu From: MillaMilininin Sent: Tuesday, August 12, 2008 3:42 PM To: Roy BLACK Subject Call Hi Roy — Karen is tied up until 4:15. Can we call you then? Or would you like to call us? memonnume Assistant U.S. Attorney 500 S. Australian Aye, Suite 400 West Palm Beach, FL 33401 Phon. Fax 561 820-8777 276 EFTA00227176 Sent: Tuesday, August 12, 2008 12:07 PM To: Roy BLACK Subject: RE: Jeffrey Epstein Hi Roy -- Can you give me a call? We need to discuss something. Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West P lm Be h F 33401 Phone Fax 561 820-8777 Original Message From: Roy BLACK [mailto:[email protected]] Sent: Monda , Au ust 11, 2008 11:40 PM To: Subject: Jeffrey Epstein Marie: I have conferred with the lawyers on the team. They all thank you for agreeing to oppose any disclosure of the 9/24/07 agreement. We firmly believe this document is not discoverable in the civil cases. However if the court rules against you on this we request that you further ask that any disclosure be subject to a strong protective order prohibiting dissemination to anyone except counsel to the petitioners. We are particularly concerned because civil lawyers are more apt to publicize something like