EFTA00190318

I am out of town. What is it about? 
>>> "Villafana, Ann Marie C. (USAFLS)'<Ann.Marie.C.Villafana©usdoj.gov> 
07/30/08 11:44 AM >» 
Dear Roy: Arc you available this afternoon to discuss the Epstein 
matter? Please let me know what time works best for you. 
Thank you. 
A. Marie Villafalia 
Assistant U.S. Attorney 
500 S. Australian Ave, Suite 400 
West Palm Beach, FL 33401 
Phone 561 209-1047 
Fax 561 820-8777 
283 
EFTA00190358

Villafana, Ann Marie C. (USAFLS) 
From: 
Villafana, Ann Marie C. (USAFLS) <[email protected]> 
Sent: 
Wednesday, July 30, 2008 2:32 PM 
To: 
Roy BLACK 
Subject: 
RE: Jeffrey Epstein 
Iii Roy -- It relates to the performance of the criminal Non-Prosecution Agreement. 
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: Roy BLACK [mailto:RBLACKaroblack.coml
Sent: Wednesday, July 30, 2008 1:18 PM 
To: Villafana, Ann Marie C. (USAFLS) 
Subject: Re: Jeffrey Epstein 
lain out of town. What is it about? 
>>> "Villafana, Ann Marie C. (USAFLS)" <[email protected]> 
07/30/08 11:44 AM >>> 
Dear Roy: Are you available this afternoon to discuss the Epstein 
matter? Please let me know what time works best for you. 
Thank you. 
A. Marie Villafaila 
Assistant U.S. Attorney 
500 S. Australian Ave, Suite 400 
West Pahn Beach, FL 33401 
Phone 561 209.1047 
Fax 561 820.8777 
278 
EFTA00190359

Villafana, Ann Marie C. (USAFLS) 
From: 
Roy BLACK <[email protected]> 
Sent: 
Wednesday, July 30, 20081:18 PM 
To: 
Villafana, Ann Marie C. (USAFLS) 
Subject: 
Re: Jeffrey Epstein 
I am out of town. What is it about? 
>>> "Villafana, Ann Marie C. (USAFLS)" <[email protected]> 
07/30/08 11:44 AM >>> 
Dear Roy: Are you available this afternoon to discuss the Epstein 
matter? Please let me know what time works best for you. 
Thank you. 
A. Marie Villafana 
Assistant U.S. Attorney 
500 S. Australian Ave, Suite 400 
West Palm Beach, FL 33401 
Phone 561 209-1047 
Fax 561 820-8777 
275 
EFTA00190360

Villafana, Ann Marie C. (USAFLS) 
From: 
Villafana, Ann Marie C. (USAFLS) <[email protected]> 
Sent: 
Wednesday, July 09, 2008 3:59 PM 
To: 
Jack Goldberger 
Subject: 
RE: Epstein contact 
Great. Thanks. Just faxed a letter to you. I have to rim to an appointment but will be in tomorrow morning. 
A. Marie Villa 
Assistant U.S. Attorney 
561 209-1047 
From: Jack Goldberger [mailto:[email protected]] 
Sent: Wednesday, July 09, 2008 3:56 PM 
To: Villafana, Ann Marie C. (USAFLS) 
Subject: RE: Epstein contact 
Dear Marie, 
I am the contact person . My office address is sufficient for contact 
jack 
From: Villafana, Ann Marie C. (USAFLS) [mailto:[email protected]] 
Sent: Wednesday, July 09, 2008 1:16 PM 
To: Jack Goldberger 
Cc: Atkinson, Karen (USAFLS) 
Subject: Epstein contact 
Dear Jack: I have received your letter and am considering it now. One of the questions I had asked you last 
week was whether you are the person whom attorneys for the victims should contact if they decide to file any 
claim. Are you the person? And, if so, what, if any, contact information would you like me to provide? 
Thank you. 
A. Marie Villafaiia 
Assistant U.S. Attorney 
561 209-1047 
221 
EFTA00190361

Villafana, Ann Marie C. (USAFLS) 
From: 
Roy BLACK <[email protected]> 
Sent: 
Thursday, August 07, 2008 4:34 PM 
To: 
Villafana, Ann Marie C. (USAFLS) 
Subject: 
Re: Notification of Possible Compelled Disclosure of theNon-Prosecution Agreement 
Marie I am working on this and will get back to you. 
 
Original Message 
From: "Villafana, Ann Marie C. (USAFLS)" <[email protected]> 
To: Roy BLACK <RBLACK©royblack.com> 
Cc: Dexter (USAFLS) Lee <[email protected]> 
Cc: Karen (USAFLS) Atkinson <[email protected]> 
Sent: 8/7/2008 3:57:52 PM 
Subject: Notification of Possible Compelled Disclosure of the Non-Prosecution Agreement 
Dear Roy: 
In accordance with paragraph 13 of the Non-Prosecution Agreement, I ant providing notice of possible compulsory process 
commanding the disclosure of the Agreement. As I'm sure you know, two of Mr. Epstein's victims have filed suit against the United 
States alleging that the government violated their rights as victims by not consulting them prior to entering into the Non-Prosecution 
Agreement. 
As part of their response to one of the government's filings, the victims asked the Court to order the production of the Non-Prosecution 
Agreement. The deadline for the government to respond is August 15th and we intend to oppose the motion based upon the 
confidentiality provision. I have attached a copy of the victims' pleading for your review. 
In connection with this, we want to make certain that we arc making consistent representations to the judiciary regarding the contents 
of the Agreement. I know that Jack Goldberger filed the Agreement under seal in the state court in accordance with the state judge's 
order. Can you provide us with a copy of what Jack filed, so that, if we are ordered by the federal court to disclose the agreement, it is 
exactly the same as what has been filed in the state court? 
Thank you again for your assistance. 
Regards, 
Marie 
<<DE19_08080I_Victime Rcsp to Notice.pdf>> 
A. Marie Villafa0a 
Assistant U.S. Attorney 
500 S. Australian Ave, Suite 400 
West Palm Beach, FL 33401 
Phone 561 209.1047 
Fax 561 820-8777 
306 
EFTA00190362

Villafana, Ann Marie C. (USAFLS) 
From: 
Villafana, Ann Marie C. (USAFLS) <[email protected]> 
Sent: 
Thursday, August 07, 2008 4:36 PM 
To: 
Roy BLACK 
Subject: 
RE: Notification of Possible Compelled Disclosure of theNon-Prosecution Agreement 
Thank you, Roy. Your help is greatly appreciated. 
A. Marie Villafaila 
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: Roy BLACK linailto:RB1,ACKerovblack.contl
Sent: Thursday, August 07, 2008 4:34 PM 
To: Villafana, Ann Marie C. (USAFLS) 
Subject: Re: Notification of Possible Compelled Disclosure of theNon-Prosecution Agreement 
Marie I am working on this and will get back to you. 
 
Original Message 
From: "Villafana, Ann Marie C. (USAFLS)" <Ann.Marie.C.Villafana®usdoj.gov> 
To: Roy BLACK <RBLACK®royblack.com> 
Cc: Dexter (USAFLS) Lee <[email protected]> 
Cc: Karen (USAFLS) Atkinson <Karen.Alkinson®usdoj.gov> 
Sent: 8f7/2008 3:57:52 PM 
Subject: Notification of Possible Compelled Disclosure of the Non-Prosecution Agreement 
Dear Roy: 
In accordance with paragraph 13 of the Non-Prosecution Agreement, I am providing notice of possible compulsory process 
commanding the disclosure of the Agreement. As I'm sure you know, two of Mr. Epstein's victims have filed suit against the United 
States alleging that the government violated their rights as victims by not consulting them prior to entering into the Non-Prosecution 
Agreement. 
As part of their response to one of the government's filings, the victims asked the Court to order the production of the Non-Prosecution 
Agreement. The deadline for the government to respond is August 15th and we intend to oppose the motion based upon the 
confidentiality provision. I have attached a copy of the victims' pleading for your review. 
In connection with this, we want to make certain that we are making consistent representations to the judiciary regarding the contents 
of the Agreement. I know that Jack Goldberger filed the Agreement under seal in the state court in accordance with the state judge's 
order. Can you provide us with a copy of what Jack filed, so that, if we arc ordered by the federal court to disclose the agreement, it is 
exactly the same as what has been filed in the state court? 
Thank you again for your assistance. 
Regards, 
Marie 
307 
EFTA00190363

<<DE19_08080I_Vicrims' Resp to Notice.pdt>> 
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 
308 
EFTA00190364

Villafana, Ann Marie C. (USAFLS) 
From: 
Villafana, Ann Marie C. (USAFLS) <[email protected]> 
Sent: 
Tuesday, August 12, 2008 9:08 AM 
To: 
Roy BLACK 
Subject: 
RE: Jeffrey Epstein 
Roy, thank you for your response and your assistance. I will forward your request to Dexter Lee, who is representing the United 
States in the civil suit. 
Can you please ask Jack Goldberger to send me an exact copy of what was filed under seal in the state court? I want to insure that all 
of us are presenting the same packet of documents as the final agreement. 
Regards, 
Marie 
A. Marie Villafafla 
Assistant U.S. Attorney 
500 S. Australian Ave, Suite 400 
West Palm Beach, FL 33401 
Phone 561 209-1047 
Fax 561 820-8777 
 
Original Message 
From: Roy BLACK [email protected] 
Sent: Monday, August 11, 2008 11:40 PM 
To: Villafana, Ann Marie C. (USAFLS) 
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 this than those 
of us who litigate on the criminal side of the docket. You may recall one lawyer standing on the bridge to palm beach railing over his 
misconceptions of the case. This is the typical vehicle they use to get more plaintiffs. You had also asked what documents were 
disclosed in the state court. As part of counsels obligation to fully disclose any promises or inducements which led to the plea 
agreement, the 9/24/07 agreement was filed with the court. It was filed under seal. Once again I want to re-assure you that Mr. Epstein 
and his counsel intend to stand by their agreements. If you or anyone in the USAO have any concern about a possible breach please 
call or email me again so we can discuss any dispute or misunderstanding and allay any concerns. Thanks again. Roy 
313 
EFTA00190365

Villafana, Ann Marie C. (USAFLS) 
From: 
Lanna Belohlavek <[email protected]> 
Sent: 
Tuesday, August 12, 2008 11:35 AM 
To: 
Villafana, Ann Marie C. (USAFLS) 
Subject: 
RE: Non-Prosecution Agreement in Epstein Case 
Marie 
The 7 page agreement was filed under seal with the attached signature pages. 
As to a transcript, you would have to contact court administration and arrange for that together with payment. 
Good luck. 
From: Villafana, Ann Marie C. (USAFLS) [mailto:[email protected]] 
Sent: Tuesday, July 01, 2008 11:51 AM 
To: Lanna Belohlavek 
Cc: Atkinson, Karen (USAFLS) 
Subject: Non-Prosecution Agreement in Epstein Case 
Hi Lanna — I am attaching the agreement, with addenda, for filing with the Court under seal. 
We also noticed a couple of "misstatements" during the change of plea and wanted to call them to your 
attention. First, the Division of Corporations' documents show that the Florida Science Foundation was 
incorporated in November 2007, not a "couple of years ago" as reported by Mr. Epstein. The address provided 
for the "office" of the Florida Science Foundation is Jack Goldberger's office suite, and neither the office 
building directory nor the office suite door reflects that such a business is located there, and neither the security 
guard nor any building tenant that FBI questioned knows of the existence of such a business. And, of course, 
Mr. Epstein could not have been working there "every day" when he hasn't been in Palm Beach County in the 
past six months. 
We will leave it to your discretion as to whether this should be brought to the Court's attention. 
<<Epstein Agrmt001.pdf» 
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 
314 
EFTA00190366

U.S. Department of Justice 
United States Attorney 
Southern District of Florida 
500 South Australian Ave., Suite 400 
West Bairn Beach, FL 33401 
(561)820-8711 
Facsimile: (561) 820-8777 
July 22, 2008 
VIA FACSIMILE 
Michael R. Tein, Esq. 
Lewis Tein, P.L. 
3059 Grand Avenue, Suite 340 
Coconut Grove, FL 33133 
Re: 
Jeffrey Epstein 
Dear Mr. Tein: 
In response to your letter of July 21, 2008, the United States hereby provides 
notice that the United States Attorney has determined, based upon reliable evidence, that, 
during the period of the Non-Prosecution Agreement, Jeffrey Epstein has willfully 
violated the conditions of the Agreement. A "breach of any one of these conditions 
allows the United States to elect to terminate the agreement and to investigate and 
prosecute Epstein and any other individual or entity for any and all federal offenses." 
The Non-Prosecution Agreement called for Mr. Epstein to plead guilty to a child 
sex offense; to serve eighteen months imprisoned at the Palm Beach County Jail, 
followed by twelve months of home confinement; and to accept a list of victims who 
could file suit against Mr. Epstein for damages. Recently, several of the designated 
victims sought relief. In response, Mr. Epstein sought a stay of those proceedings based 
on the fact that an ongoing federal investigation exists. This argument was forwarded 
despite the aforementioned agreement wherein the United States Attorney's Office agreed 
not to prosecute Mr. Epstein if he complies with the terms of the Agreement. 
The portion of the agreement concerning compensation to victims is extremely 
material to the Agreement and is not being honored by Mr. Epstein. To complete the 
performance of his contractual obligations, Mr. Epstein must submit to suit under 18 
U.S.C. § 2255 and admit that the Identified Victims are victims of an offense enumerated 
in that section. By seeking to stay all civil litigation, during what you assert is the term 
of the Non-Prosecution Agreement, Mr. Epstein is avoiding performance of that essential 
contractual term. 
EFTA00190367

M 
!AEI. R. TEIN, ESQ. 
JULY 22, 2008 
PAGE 2 
Accordingly, the United States Attorney's Office hereby provides timely notice of 
Mr. Epstein's breach of the Non-Prosecution Agreement. Pursuant to the Agreement, the 
United States Attorney's Office may initiate its prosecution within sixty (60) days of 
giving notice of the violation. 
Sincerely, 
R. Alexander Acosta 
United States Attorney 
By: 
A Marie Villafana 
Assistant United States Attorney 
cc: 
Karen Atkinson, Esq. 
EFTA00190368

Villafana, Ann Marie C. (USAFLS) 
From: 
Jay Lefkowitz [email protected]> 
Sent: 
Thursday, August 14, 2008 2:39 PM 
To: 
Villafana, Ann Marie C. (USAFLS) 
Cc: 
Atkinson, Karen (USAFLS); [email protected] 
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 
- Villafana, Ann Marie C. (USAFLS)" 
<[email protected]> 
08/14/2008 12:44 PM 
To <[email protected]> 
cc 'Atkinson, Karen (USAFLS)" <KarenAtkinson©uadoj.gov> 
Subject Follow-up point 
Eli 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. 
A. Marie Villafalia 
Assistant U.S. Attorney 
500 S. Australian Ave, Suite 400 
West Palm Beach, FL 33401 
Phone 561 209-1047 
Fax 561 820-8777 
**0*******************•**********************•****** 
ankle*** 
323 
EFTA00190369

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 postmaster8kirkland.com, and 
destroy this communication and all copies thereof, 
including all attachments. 
324 
EFTA00190370

Villafana, Ann Marie C. (USAFLS) 
From: 
Villafana, Ann Marie C. (USAFLS) <[email protected]> 
Sent: 
Thursday, August 14, 2008 3:27 PM 
To: 
Jay Lefkowitz 
Cc: 
Atkinson, Karen (USAFLS); 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 19th 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. 
A. Marie Villafana 
Assistant U.S. Attorney 
500 S. Australian Ave, Suite 400 
West Palm Beach, FL 33401 
Phone 561 209-1047 
Fax 561 820-8777 
From: Jay lefkowItz [mallto:[email protected]] 
Sent: Thursday, August 14, 2008 2:39 PM 
329 
EFTA00190371

To: Villafana, Ann Marie C. (USAFLS) 
Cc: Atkinson, Karen (USAFLS); [email protected] 
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 
"Villatana, Ann Marie C. (USAFLS)-
<Ann.Marie.C.VIllefanaeusdoi.gov> 
08/14/2008 12:44 PM 
To <letkowazakakland corn> 
cc "Allunson. Karen (USAF1S)" <Karen [email protected] 
Subject Follow-up point 
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. 
A. Marie VillafaPia 
Assistant U.S. Attorney 
500 S. Australian Ave, Suite 400 
West Palm Beach, FL 33401 
Phone 561 209-1047 
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 
330 
EFTA00190372

return e-mail or by e-mail to postmasterekirkland.com, and 
destroy this communication and all copies thereof, 
including all attachments. 
331 
EFTA00190373

Villafana, Ann Marie C. (USAFLS) 
From: 
Jay Lefkowitz <[email protected]> 
Sent: 
Friday, August 15, 200810:53 AM 
To: 
Villafana, Ann Marie C (USAFLS) 
Cc: 
Atkinson, Karen (USAFLS); Roy BLACK Martin Weinberg 
Subject: 
Re: Follow-up point 
Marie - thanks for responding to my email. You have narrowed down some of the implementation issues. 
As I told you this morning, we cannot accept your contention that Mr. Epstein is bound by an agreement he 
didn't sign as opposed to one he did sign, particularly in light of my written communications to your 
office dated December 21, 2007 and December 26, 2007. However, before we can make a determination 
whether to adopt the December language as you have now explained it, we need to confer with our client, which 
we will be able to do within the next two weeks. 
I look forward to speaking with you soon to resolve these issues. 
Jay 
From: "Villafana, Ann Marie C. (USAFLS)" [Ann.Marie.C.Villafana®usdoj.gov] 
Sent: 08/14/2008 03:27 PM AST 
To: Jay Lefkowitz 
Cc: "Atkinson, Karen (USAFLS)" <Karen.Atkinson®usdoj.gov>; "Roy BLACK" 
<[email protected]> 
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 19thletter 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 
332 
EFTA00190374

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. 
A. Marie Villafafia 
Assistant U.S. Attorney 
500 S. Australian Ave, Suite 400 
West Palm Beach, FL 33401 
Phone 561 209-1047 
Fax 561 820-8777 
From: Jay Lefkowitz [mailto:[email protected]] 
Sent: Thursday, August 14, 2008 2:39 PM 
To: Villafana, Ann Marie C. (USAFLS) 
Cc: Atkinson, Karen (USAFLS); [email protected] 
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 
"Villalana, Ann Mario C. (USAFLS)-
cAnn.Mario.C.VIllalanaeusdoi.gov> 
08/14/2008 12.44 PM 
To <lelticnvitzigkiatlanclreom,
cc `Atkinson, Karen (USAFLS)" <[email protected]> 
Subject Follow-up point 
Hi Jay — I forgot to mention that I can no longer argue that the Court shouldn't force us to produce the 
333 
EFTA00190375

agreement because we have already provided the victims with the relevant portion when 1 now understand from 
you that I have NOT provided them with the relevant portion. 
A. Marie VilIola& 
Assistant U.S. Attorney 
500 S. Australian Ave, Suite 400 
West Palm Beach, FL 33401 
Phone 561 209-1047 
Fax 561 820-8777 
le* **************************** 
*Ileft*********fc#4******* 
******* 
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. 
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. 
***it*** ***** ***************** ****************************** 
334 
EFTA00190376

Villafana, Ann Marie C. (USAFLS) 
From: 
Villafana, Ann Marie C. (USAFLS) <[email protected]> 
Sent: 
Thursday, August 21, 2008 5:32 PM 
To: 
[email protected]; Roy BLACK 
Cc: 
Atkinson, Karen (USAFLS) 
Subject: 
Jeffrey Epstein 
Attachments: 
080821 Villafana ltr to Lefkowitz and Black.pdf; DE26_080821_Protective Order.pdf 
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'. United States litigation. 
«080821 Villafana IV to Lefkowitz and Black.pdf>> 
<<DE26_080821_Protective Order.pdf >> 
A. Marie Villafaila 
Assistant U.S. Attorney 
500 S. Australian Ave, Suite 400 
West Palm Beach, FL 33401 
Phone 561 209-1047 
Fax 561 820-8777 
377 
EFTA00190377