EFTA00179797

A. Marie Villafaita 
Assistant U.S. Attorney 
500 S. Australian Ave, Suite 400 
West Palm Beach, FL 33401 
Phone 561 209-1047 
Fax 561 820-8777 
148 
EFTA00179957

Villafana, Ann Marie C. (USAFLS) 
From: 
Villafana, Ann Marie C. (USAFLS) 
Sent: 
Wednesday, August 20, 2008 4:13 PM 
To: 
Irene_Rivera©fisd,uscourts.gov 
Subject: 
Proposed Order in Jane Doe 1 and 211. United States 
Hi Irene — Dexter Lee forwarded a proposed protective order in the Jane Doe case on Friday, but we never 
received a signed order. 1 think it might be because he didn't formally file it via CM/ECF, so if you want me to 
re-file it, I will do so right away. 
Thank you! 
A. Marie Villafafla 
Assistant U.S. Attorney 
500 S. Australian Ave, Suite 400 
West Palm Beach, FL 33401 
Phone 561 209-1047 
Fax 56I 820-8777 
149 
EFTA00179958

Villafana, Ann Marie C. (USAFLS) 
From: 
ViHelena, Ann Marie C. (USAFLS) 
Sent: 
Wednesday, August 20, 2008 4:06 PM 
To: 
Lee, Dexter (USAFLS) 
Subject: 
Did you ever get the signed Protective Order from Judge Marra? 
Iii Dexter 
I am wondering if the Protective Order got lost in the shuffle. Let me know and I will contact his 
CRD to check up on it. 
Thank you. 
A. Marie Villafaha 
Assistant U.S. Attorney 
500 S. Australian Ave, Suite 400 
West Palm Beach, FL 33401 
Phone 561 209-1047 
Fax 561 820-8777 
Tracking: 
150 
EFTA00179959

Recipient 
lee, Dexter (USAFIS) 
151 
Read 
Read: 8f20(2008411 PM 
EFTA00179960

Villafana, Ann Made C. (USAFLS) 
From: 
Villafana, Ann Marie C. (USAFLS) 
Sent: 
Wednesday, August 20, 2008 3:47 PM 
To: 
Acosta, Alex (USAFLS); Sloman, Jeff (USAFLS); Senior, Robert (USAFLS); Atkinson, Karen 
(USAFLS) 
Subject: 
Emailing: 080820 Villafana Ltr to Lefkowitz and Black.wpd 
Attachments: 
080820 Villafana Ltr to Lefkowitz and Black.wpd 
I have attached my proposed response to Jay Lefkowitz. Please let me know if you 
have any changes, I would like to try to get this out today, if possible. 
The message is ready to be sent with the following file or link attachments: 
080820 Villafana Ltr to Lefkowitz and Black.wpd 
Note: To protect against computer viruses, e-mail programs may prevent sending or 
receiving certain types of file attachments. Check your e-mail security settings 
to determine how attachments are handled. 
Tracking: 
152 
EFTA00179961

Recipient 
Acosta, Alex (USAFLS) 
Sloman. Jeff (USAFLS) 
Senior, Robert (USAFLS) 
Atkinson, Karen (USAFLS) 
153 
Read 
Read: 8/20/2008 3:50 PM 
Read: 8/20/2008 4:17 PM 
EFTA00179962

Villafana, Ann Marie C. (USAFLS) 
From: 
Vittafana, Ann Marie C. (USAFLS) 
Sent: 
Wednesday, August 20, 2008 9:24 AM 
To:. 
Acosta, Alex (USAFLS); Sloman, Jeff (USAFLS); Senior, Robert (USAFLS), Atkinson, Karen 
(USAFLS) 
Subject: 
Response from Jay Letkowitz 
Hi all -Jay sent this by fax on Monday evening. I am off to mag court, but should be back around 11:30. 
My first thought is, if they wish to limit the list to those girls identified prior to the signing of the non-pros 
agreement, that is fine, but then I get to prosecute him on the rest. 
I am going to send Jay a quick e-mail telling him that I just got his fax because of the closure of the office and I 
will respond more fully this afternoon or tomorrow morning. 
080818 
kowitz Ltr to Villa 
A. Marie Villafafta 
Assistant U.S. Attorney 
500 S. Australian Ave, Suite 400 
West Palm Beach, FL 33401 
Phone 561 209-1047 
Fax 561 820-8777 
Tracking: 
160 
EFTA00179963

Recipient 
Acosta, Alex (USAFLS) 
Slomen, Jeff (USAFLS) 
Senior, Roben (USAFLS) 
Atkinson, Karen (USAFLS) 
Kuyrkendeli. E N (FBI) 
Richards, Jason R. (FBI) 
161 
Read 
Read: 8/20/2008 9:29 AM 
EFTA00179964

Villafana, Ann Marie C. (USAFLS) 
From: 
Villafana, Ann Marie C. (USAFLS) 
Sent: 
Wednesday, August 20, 2008 9:24 AM 
To: 
Acosta, Alex (USAFLS): Stoman, Jeff (USAFLS); Senior, Robert (USAFLS), Atkinson, Karen 
(USAFLS) 
Subject: 
Response from Jay Lefkowltz 
Hi all — Jay sent this by fax on Monday evening. I am off to mag court, but should be back around I I :30. 
My first thought is, if they wish to limit the list to those girls identified prior to the signing of the non-pros 
agreement, that is fine, but then I get to prosecute him on the rest. 
I am going to send Jay a quick e-mail telling him that I just got his fax because of the closure of the office and I 
will respond more fully this afternoon or tomorrow morning. 
080818 
kowla Ur to Villa 
A. Marie Villafafta 
Assistant U.S. Attorney 
500 S. Australian Ave, Suite 400 
West Palm Beach, FL 33401 
Phone 561 209-1047 
Fax 561 820-8777 
162 
EFTA00179965

Villafana, Arm Marie C. (USAFLS) 
From: 
Villafana, Ann Marie C. (USAFLS) 
Sent: 
Tuesday, August 19, 2008 12:06 PM 
To: 
Sloman, Jeff (USAFLS) 
Subject: 
Bob J 
Hi Jeff, I hope your flight went alright. The wind up here has been awful. The 
Podhurst firm is closed today so I will try Bob tomorrow morning. 
Take care. 
163 
EFTA00179966

Villafana, Ann Marie C. (USAFLS) 
From: 
Villafana, Ann Marie C. (USAFLS) 
Sent: 
Monday, August 18, 2008 2:54 PM 
To: 
Sloman, Jeff (USAFLS) 
Subject: 
Are you free? 
Hi Jeff — I know that Miami is closed, but if you have a moment, can you give me a call at my desk? 561-209-
1047. 
Thanks. 
A. Marie Villafaha 
Assistant U.S. Attorney 
500 S. Australian Ave, Suite 400 
West Palm Beach, FL 33401 
Phone 561 209-1047 
Fax 561 820-8777 
Tracking: 
164 
EFTA00179967

Recipient 
Sioman. Jett (USAFI.S) 
t65 
Read 
Read: 8118,2048 2:59 PM 
EFTA00179968

Villafana, Ann Marie C. (USAFLS) 
From: 
Kuyrkendall, E N. (FBI) 
Sent: 
Monday, August 18, 2008 12:43 PM 
To: 
Villafana, Ann Marie C. (USAFLS) 
Subject: 
Re: Victim List 
Sorry for the delay. I discussed with Jason, we believe that is everyone at least everyone that was forthcoming. It appears 
a FOIA has been filed. I'm trying to ensure no docs are provided a this time. It appears they were specific wanting JE's 
employees 302s. 
From: ViHelena, Ann Marie C. (USAFLS) 
To: Richards, Jason R.; Kuyrkendall, E N. 
Sent: Fri Aug 15 12:15:38 2008 
Subject: Victim List 
Hi guys — if we were going to expand our list to include victims we know about but weren't ready to charge in 
an indictment, who would we include besides Tatum? 
A. Marie Villafafia 
Assistant U.S. Attorney 
500 S. Australian Ave, Suite 400 
West Palm Beach, FL 33401 
Phone 561 209-1047 
Fax 561 820-8777 
166 
EFTA00179969

Villafana, Ann Marie C. (USAFLS) 
From: 
Lee, Dexter (USAFLS) 
Sent: 
Friday, August 15, 2008 4:53 PM 
To: 
Villafana, Ann Marie C. (USAFLS) 
Subject: 
FW: Jane Doe # 1 and # illr. United States, Case No. 08-80736-CIV-MARRA/JOHNSON 
Marie, 
I filed this earlier this afternoon. 
Dexter 
From: Lee, Dexter (USAFLS) 
Sent: Friday, August 15, 2008 3:23 PM 
To: [email protected] 
Subject: Jane Doe # 1 and # 4. United States, Case No. 08-80736-C1V-MARRA/JOHNSON 
Hon. Kenneth A. Marra 
United States District Judge 
Dear Judge Marra: 
Pursuant to the Court's direction at the conclusion of yesterdays Status Conference, attached please find a proposed 
Order to Produce and Protective Order which has been reviewed and agreed to by counsel for petitioners and the 
government. 
Respectfully, 
Dexter A. Lee 
Assistant U.S. Attorney 
Protective 
Order_final.wpd 
167 
EFTA00179970

Villafana, Ann Marie C. (USAFLS) 
From: 
Villafana, Ann Marie C. (USAFLS) 
Sent: 
Friday, August 15, 2008 4:51 PM 
To: 
Lee, Dexter (USAFLS) 
Subject: 
Filing the proposed order 
Hi Dexter— Are you going to file the proposed order? If not, please e-mail whatever the final, final is and I will 
file it with the Court. Thanks. 
A. Marie VillafaRa 
Assistant U.S. Attorney 
500 S. Australian Ave, Suite 400 
West Palm Beach, FL 33401 
Phone 561 209-1047 
Fax 561 820-8777 
168 
EFTA00179971

Villafana, Ann Marie C. (USAFLS) 
From: 
Villafana, Ann Marie C. (USAFLS) 
Sent: 
Friday, August 15, 2008 4:51 PM 
To: 
Stoman, Jeff (USAFLS) 
Subject: 
Got your message 
Sounds like good news. I'll call you on Monday unless a firestorm breaks over the weekend. 
.4. Marie Villafaha 
Assistant U.S. Attorney 
500 S. Australian Ave, Suite 400 
West Palm Beach, FL 33401 
Phone 561 209-1047 
Fax 561 820-8777 
Tracking: 
169 
EFTA00179972

Recipient 
Sloman, ae11(USAFLS) 
170 
Read 
Read: 8/15/2008 4:51 PM 
EFTA00179973

Recipient 
[email protected] 
Roy BLACK 
Atkinson, Karen (USAFLS) 
Acosta, Alex (USAFLS) 
Stornan. Jeff (USAFLS) 
Senior, Robert (USAFLS) 
Lee. Dexter (USAFLS) 
176 
Road 
Read: 8/15/2008 2'13 PM 
Read: 8/15/2008 2:24 PM 
EFTA00179974

Villafana, Ann Marie C. (USAFLS) 
From: 
Lee, Dexter (USAFLS) 
Sent: 
Friday, August 15, 2008 2:05 PM 
To: 
Villafana, Ann Marie C. (USAFLS) 
Cc: 
Sloman, Jeff (USAFLS) 
Subject: 
RE: New proposed response to Jay 
Something which is a nullity lacks any legal import. 
If it has been withdrawn, 
then the item had import at one time, but it no longer does. If the December 
2007 letter is viewed as an offer, there was no acceptance, or it has been 
rejected. 
Consequently, the offer no longer has an legal import. 
We are obligated to provide a copy of the non-prosecution agreement to 
petitioners, whatever that agreement is. 
If the December 2007 letter never 
became a part of the agreement, and the government and Epstein are in agreement 
as to that issue, then we can produce the September 2007 agreement and the 
addendum. 
Are we at that point? 
Dexter 
 
Original Message 
From: Villafana, Ann Marie C. (USAFLS) 
Sent: Friday, August 15, 2008 1:54 PM 
To: Lee, Dexter (USAFLS) 
Cc: Sloman, Jeff (USAFLS) 
Subject: FW: New proposed response to Jay 
Importance: High 
Dexter -- If we call it "a nullity" instead of "withdrawn" how does that affect 
the issue with the Jane Does? 
A. Marie Villafaha 
Assistant U.S. Attorney 
500 S. Australian Ave, Suite 400 
West Palm Beach, FL 33401 
Phone 561 209-1047 
Fax 561 820-8777 
 
Original Message 
From: Sloman, Jeff (USAFLS) 
Sent: Friday, August 15, 2008 1:52 PM 
To: Villafana, Ann Marie C. (USAFLS); Senior, Robert (USAFLS); Acosta, Alex 
(USAFLS); Lee, Dexter (USAFLS); Atkinson, Karen (USAFLS) 
Subject: RE: New proposed response to Jay 
Marie, 
Please substitute the word "withdrawn" in the first sentence with "a nullity" 
179 
EFTA00179975

Jeff 
 
Original Message 
From: Villafana, Ann Marie C. (USAFLS) 
Sent: Friday, August 15, 2008 1:49 PM 
To: Senior, Robert (USAFLS); Acosta, Alex (USAFLS); Sloman, Jeff (USAFLS); Lee, 
Dexter (USAFLS); Atkinson, Karen (USAFLS) 
Subject: RE: New proposed response to Jay 
Here is my proposal after speaking with Jeff. 
Dear Jay and Roy: 
Thank you for your response to my earlier e-mail. Our communications with 
Mr. Black and later with Mr. Lefkowitz were solely to determine what Mr. Epstein 
considered to be the terms of the Non-Prosecution Agreement. We appreciate your 
answering our question with finality. You have now made clear that Mr. Epstein 
did not accept the December modification, and accordingly, the offer to make that 
modification is hereby withdrawn. 
Pursuant to our Agreement, I will prepare an Amended Notification that 
contains the names of additional identified victims. As you know, Judge Davis 
had selected the Podhurst firm to serve as the attorney representative for the 
victims. Assuming that Mr. Josefsberg is still amenable to the appointment, we 
will provide him with the victim list so that he may begin his service. 
Finally, as you are aware, the United States has been ordered to produce the 
Non-Prosecution Agreement. In accordance with that Order, we will produce the 
September Agreement with the October Addendum signed by your client. We 
understand that Mr. Goldberger did not provide the state court with a true copy 
of the complete Agreement, and he should take steps to correct that error. 
A. Marie Villafana 
Assistant U.S. Attorney 
500 S. Australian Ave, Suite 400 
West Palm Beach, FL 33401 
Phone 561 209-1047 
Fax 561 820-8777 
 
Original Message 
From: Senior, Robert (USAFLS) 
Sent: Friday, August 15, 2008 1:34 PM 
To: Acosta, Alex (USAFLS); Villafana, Ann Marie C. (USAFLS); Sloman, Jeff 
(USAFLS); Lee, Dexter (USAFLS); Atkinson, Karen (USAFLS) 
Subject: Re: New proposed response to Jay 
Shouldn't we formally withdraw the offer as opposed to considering it a nullity ? 
180 
EFTA00179976