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FBI VOL00009
EFTA00799605
176 sivua
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Case 9:08-cv-80736-KAM Document 403-19 Entered on FLED Docket 06/02/2017 Page 21 of 176 37. In mid-June 2008, Attorney Edwards contacted your Affiant to inform me that he represented Jane Doe 1 and another identified victim (not Jane Doe 2). Attorney Edwards asked to meet to provide me with information regarding Epstein. On June 19, 2008, Attorney Edwards sent me an email stating that he had "information and concerns that I would like to share" and that he wanted to meet with me to "discuss [his] plans." DE362-30. As noted in the email, he had one "client" at the time, who has been referred to in this suit as Jane Doe I, and he did not state that Jane Doe 1 wished to meet with me. (Id.) I invited Attorney Edwards to send to me any information that he wanted me to consider. At the time of my conversation with Attorney Edwards, I was still preparing to present charges against Epstein if Epstein succeeded in having the NPA set aside or if he failed to perform the terms of the NPA. I did not disclose the existence of the NPA to Edwards because I did not know whether the NPA remained viable at that time or whether Epstein would enter the state court guilty pleas that would trigger the NPA. I was aware that a final decision on Epstein's challenges to the NPA and the federal investigation was expected shortly, so I impressed upon Attorney Edwards that time was of the essence. Attorney Edwards sent nothing at that time, nor did he ever inform me that Jane Doe 1 and/or Jane Doe 2 wanted to confer with me before any resolution was reached. If anything had been provided by Edwards, Jane Doe 1, or Jane Doe 2, I would have reviewed it and shared it with my superiors. I also advised Attorney Edwards that he should consider contacting the State Attorney's Office. I was informed, however, that no contact with that office was made. At that time, attorney Edwards had also alluded to Jane Doe 2, so I advised him that, to my knowledge, Jane Doe 2 was still represented by Attorney James Eisenberg. He did not dispute or correct my understanding. 20 EFTA00799625
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Case 9:08-cv-80736-KAM Document 403-19 Entered on FLED Docket 06/02/2017 Page 22 of 176 38. On Friday, June 27, 2008, at approximate 4:15 p.m., I received a copy of Epstein's proposed state plea agreement and learned that Epstein's state court change of plea was scheduled for 8:30 a.m., Monday, June 30, 2008. The Palm Beach Police Department and I attempted to notify the victims about that hearing in the short time available to us. I specifically called attorney Edwards to provide notice to his clients regarding the hearing. I believe that it was during this conversation that Attorney Edwards notified me that he represented Jane Doe 2. I urged attorney Edwards to have his clients attend the hearing so that they could address the Court, if they wished, and I stressed the importance of the hearing. I never told Attorney Edwards that the state charges involved "other victims," and neither the state court charging instrument nor the factual proffer limited the procurement of prostitution charge to a specific victim. In fact, as mentioned in 1 37, supra, I had encouraged Attorney Edwards to contact the State Attorney's Office to discuss his client and the Epstein investigation with the state prosecutor. Attorney Edwards informed me that he could not attend the hearing but that someone would be present at the hearing. The case agents and I attended the hearing as members of the general public, and did not publicly announce our presence since we were there only as observers. Neither attorney Edwards nor any of his clients were present, and no one identified themselves to me, the FBI agents, or the state court as being present on behalf of the petitioners. /// /// /// 21 EFTA00799626
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Case 9:08-cv-80736-KAM Document 403-19 Entered on FLSD Docket 06/02/2017 Page 23 of 176 39. On July 3, 2008, attorney Edwards contacted me to discuss how the Epstein matter had been resolved and to raise concerns regarding that resolution. I shared the concerns that attorney Edwards raised with my superiors at the U.S. Attorney's Office. 40. 1 declare under penalty of perjury, pursuant to 28 U.S.C. § 1746, that the foregoing is true and correct to the best of my knowledge and belief. Executed this day of June, 2017. Marie Villafafia, Esq. 22 EFTA00799627
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Case 9:08-cv-80736-KAM Document 403-19 Entered on FLED Docket 06/02/2017 Page 24 of 176 EXHIBITS TO 6/2/2017 VILLAFARA DECLARATION Exhibit Number Description 1 January 24, 2007 letter from A. Marie Villafafia to James Eisenberg with attachment (redacted) 2 February 1, 2007 letter from James Eisenberg to A. Marie ViBala& (redacted) 3 February 5, 2007 fax from A. Marie Villafafia to James Eisenberg with attachments (redacted) 4 February 6, 2007 Authorization for Reimbursement of Unusual Expenses (redacted) 5 February 12, 2007 letter from James Eisenberg to A. Marie Villafaiia (redacted) 6 April 16, 2007 Order from Judge Middlebrooks (redacted) 7 December 13, 2007 letter from A. Marie Villafafia to Jay Lefkowitz (redacted) 8 January 26, 2015 Declaration of Timothy R. Slater, Section Chief, Federal Bureau of Investigation (redacted) 9 February 20, 2008 Deposition Transcript, State of Florida v. Jeffley Epstein (redacted) 10 June 12, 2009 Hearing Transcript, Jane Doe, et aL v. Jeffrey Epstein, S.D. Fla. Case No. 08-80119-CIV-Marra EFTA00799628
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Case 9:08-cv-80736-KAM Document 403-19 Entered on FLSD Docket 06/02/2017 Page 25 of 176 Exhibit 1 EFTA00799629
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Case 9:08-cv-80736-KAM Document 403-19 Entered on FLSD Docket 06/02/2017 Page 26 of 176 U.S. Department of Justice United Slates Attorney Southern District of FlOrida DELIVERY BY BAND James L. Bamberg, Esq. 250 S Australian Ave, Ste104 West Palm Beach, FL 33.401-5007 Dear Jim; 500 South Attain/too Ave, &Ito 400 act Pa& :Beach, FL 334W (50)1120-871 Amniotic 0008204777 January 24, 2007 Re; Federal _Subpoena have enclosed a new subpoena forTEM MS M I mentioned earlier, Ms. Millis nova target of this investigation and the United States ec s her testimonysolely ea avictim/wituess, Daring our last conyemationregarrling Ms. NiIM you indicated that she was unwilling to speak with us pursuant to a Kqtigar letter and that she also was unwilling to speak with the Sand intends to invoke the Fifth Amendment if questioned. Please maw with her to confirm whether this remains her position. 'filial pleas, advise in writing. Evenif Ms. Millis inclined to invoke her Fifth Amendment rights, she must still appear pursuant to the subpoena so that I may ask her questions that would not require the invocation of the FifthAmendment. If she still invokes, I intend to move to compel her answers. If you oryour client is unainulahle on February 6; 2007, plea.se lame know of another Tuesday when you are available. I also am concerned about a potential tonflibt 'gluten* in yourrepresentationotivIs; Ma In ease of future litigation regarding this lane, please provide me with information regarding who is paying (directly br indirectly) for yourservices on beludfof Ma; la the scope of your representatisand whether yop am taking .dlrection on this matter front anyone abort= Ms. MEIN If any fbtmal or infornuil joint defense agreements exist, Whether in writing or otherviises please provides copy of such agreements. lithe agreement is pUrebboral, please provide a written summary of its terms: GOVERNMENT EXHIBIT 4 1. Case No. 08-80736-CV-MARRA P4303736 EFTA00799630
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Case 9:08-cv-80736-KAM Document 403-19 Entered on FLSD Docket 06/02/2017 Page 27 of 176 JAWS EISENBERG, ESQ. JANUARY 24, 2007 PAus 2 I look forward to your response. By: Sincerely, IL Alexander Acosta Una States Attorney A. Marie Villafafla Assistant United States Attorney Case No. 08-80736-CV-MARRA P-003737 EFTA00799631
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Case 9:08-cv-80736-KAM Document 403-19 Entered on FLSD Docket 06/02/2017 Page 28 of 176 United States District Court AVM/ERN MISTNOT OF FLORIDA Ta nal SUBPOENA TO TESTIFY SUBPOENA FOR: Ell PERSON g DOCUMENTS OR OBJECT[S] YOU ARE HEREBY COMMANDED to appear and testify heronsthe Grand IirryortheUnitestStates District Court st the place, date and time SpedifiedbeloW. N,ACB: United Stales District Courthouse 701 Clematis Street West Pahn Desch, Florida $3401 Min DATE AND TIME: February 6, P07 1:001ase, YOU ARE ALSO COMMANDED tit king with you the rollowing d000ment(e) or objeot(s): *Muse coordinate your compliance with this subpoena and confirm the date and time, and location of your appearance With Special Agent NesbittKuyrkendall, Federal Bureau of Investigation, Telephone: (S61)-822-5946. This subpoena shall main in effect until you are granted leave to depart by the court or by an officer acting on behalf of the court Matt DEPTJTY CLERK DATE: January 23, 2007 This subpoena is *pod upon eppligetton of the led States.of Attica Name; Address and Thong Thirnber of Assistant U.S. Attorney Anulviturie C, Vilisfens AssittrtUS• Mom* 500 So. Australian Avenue, Suite 400 West Nintfieach, FL 3moi-05 'TO MI) 820-871f x3047 _ Fax: (56I) 802-1787 • *Vim applliobla, via •nOnet mMs,Whisawe Case No. 08-80736-CV-MARRA FORKORSI27 13-0804,88 EFTA00799632
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Case 9:08-cv-80736-KAM Document 403-19 Entered on FLSD Docket 06/02/2017 Page 29 of 176 Exhibit 2 EFTA00799633
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Case 9:08-cv-80736-KAM Document 403-19 Entered on FLSD Docket 06/02/2017 Page 30 of 176 EISENBERG & FOUTS, P.A. Attorneys At Law JAMES L. EISENBERG *sada Bor Board Cedilla) Criminal Trial layer. Natlonl BOAtli CITTrial Adtoamy Certified Colinlual rrhl Advatott KM ALOE sours OnoClatunkaCantrat Suite704,250 Australian Avenue Saufli,Wizt Pala Beach, FL334QI 561/659-200917=561/6513 180 February 1, 2007 A. Marie Villefana, Asst. U.S. Attorney 500 South Australian Avenue, Suite 400 West Palm Beach, FL 33401 Re; Grand hay Subpoena fbr Dear Marie, I received your hitter dated January 24, 2007.with regard to ANN= I must admit 1 forced myself to wait several'days to respond in order to "cool off" and not say anything I would regret later. Now that time has passed, allow me to respond appropriately. 1. If you want to force Ms. a single mother, to come to the to personally involo her Fifth Amendment nghts, she will be there. That does remain her position. My only request is that you a babysitter service for her' ebild. I will be there, but 1 am not paid to babysit and.Ms. should not have ju ay someone. It is this type of attitude, that your office refuses to acceptthe fact that it is Ms. MMs decision not to cooperate withthe government that upsets her. Your office fails to recogaite that merely coming to courtis a problem for a single mother like Ms, d, under these circumstances, appears to be a waste of time at best and, in her mind, person assment. 2. Rest assurcdthatthere Is no conflict °finis:west in rayrepresentation of Ms. M. la this. case I have alivays been asked and-eh/Myst:11 exercise independentjydgment to follow my client's independent will. The remainder of your questions as to this matter are really none of the. Goveniment's business. 3. 1 will share with you that one of the reasons for our firm position that Ms. Nvvill invoke her Fifth Amendment right and choose not tovoluntadly cooperate with the Government is our concern that the Government is not exercising independent judgment in this case, The history of this case bps been in the newspapers. The case is being prosecuted in State court,. Despitethe state court prosecution, the Town of Palm Beach Police Chief went on what can only be GOVERNMENT EXHIBIT Case No. 08-80736-CV-MARRA P-003732 EFTA00799634
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Case 9:08-cv-80736-KAM Document 403-19 Entered on FLSD Docket 06/02/2017 Page 31 of 176 A. Marie Villa.fata, Asst. U.S. Attorney February 1, 2007 Page Two described as a public rampagein the newspaper when the case was not prosecuted to his.liking that reminded me of a small child having apublio temper tantrum. In ro.Y thirty years of experience, I have never seen a law enforcement Officer like this publicly Make what appeared to be a political case In the newspaper for a prosecution and publicly criticize anyone who got in his way, including the eleCtedStateAttorney„ This resulted in, a fedond investigation one topic no oneremembers the Federal:Government ever beinginterested in prosecuting before. Although I am certain that you PerahnallY have not badyourdecision-mak:Mg process compromised, the appearance that your office is being influenced by the Town of Palm Beach Police Chiefs agenda is. very real. Under these• cirountstancesel don't see how any lawyer could advise ay client to voluntarily cooperate. Of special coneernis -Rattle Town ofFahn Beach Police have promoted prosecuting at leastone of the girls who allegedly gaire massages. One. final thought. My client and my fear that Ms. balcould be prosecuted is enhanced by the demand for the personal appearance made in your letter. Your initial Kastiger letterifall far shrift of granting the functional equivalent bfD0J imniutiity. Several months ago I was given the distinct impression through our conversations that you were going to obtain DOJ Immunity for Ms. IA Now the government is cbanging count for no apparent reason. This leads to speculation that the only reason for the turnabout is that prosecution in either state or federal cotes id being considered by someone, directed atyoupersonally. I want to repeat that youhitve always treated us with office should advise the TovaaPolice Chief to act in a similar fashion. Case No. 08-80736-CV-MARRA. P-003733 EFTA00799635
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Case 9:08-cv-80736-KAM Document 403-19 Entered on FLSD Docket 06/02/2017 Page 32 of 176 Exhibit 3 EFTA00799636
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Case 9:08-cv-80736-KAM Document 403-19 Entered on FLSD Docket 06/02/2017 Page 33 of 176 U.S. Departntent of tunic° United States Attorney SoatheraDistriet of Florida q. Marie Villaidlia 500 South Australian Ave, Suite 400' 11,-..• n..... t, 21401 FACSIMILE COVER SHEET TO: JIM EISENBERG, ESO, DATE: FAX NO. 561 659-2380 # OF PAGES: FEDER NO. RE: FebtuarV .5, 2007 FROM: A MARIE V/LLAF ASSISTANT V. B. ATTORNEY last th 17r4-- Thee- (5cug 1/Le commE .19(At izoitt a ji)tet. d.thk OV-howe_ afrua burs JO- Todik (40- 6eppreztau 44 GOVERNMENT EXHIBIT S' 3 • Case No. 08-80736-CV-MARRA P-003745 EFTA00799637
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Case 9:08-cv-80736-KAM Document 403-19 Entered on FLSD Docket 06/02/2017 Page 34 of 176 11.$,Department of Justice United StarCs. Attorney Southern District ofFlorida shOWouth AmamiIlan Ave, Suite 400 February 5, 2007 nnuv0ix BY }WO 148/1M MEI c/o lames I,. RiSenberg, Sgq, 250 S Australian Aye, Ste704 West Palm Beach, FIM401-5007 Re: Dear Ms, lv This letter confirms thvunderstanding between yourself and the United States Attorney's Office /brute Southern District•of Florida. You have represented that you till truthfully answer questions of the federal government in its investigation of the procurement of prostitutes, amongst others. You Will supply complete and netball 1 OIM -0 • 0 the attorneys and law eadbrcement °effects of the federal government and to any Molt may conduct an investigation, as well as in any other proceeding related to or growing out of this investigation. The obligation of borthitil disclosure includes your obligation to provide the attorneys and law enforcement Officers of the federalgovernment with any demo:bents, records or other tangible evidence within your.custody or Control relating in the matters about ithich you are questioned. IL'Ouwill neither attempt to protect Any person or entity through /hiss information pr omission, nor falsely iniplicate any person or entity. No statements provided by you on this date in this matter pursuant to this agreement will be offered into evidence in snyetirninal case against you, exceptduring aprosecntion forperj toy and/or iivinga false statement. &Weyer, ifit determined that you have tnaboriallyviolated any provision • of tine agteomeut, all statements made by you shall be admissible in evidence against you in auy. proceeding, The federal government remains 'free to use information derived from the testimony dire.ctly or indirectly for the purpose of obtaining leads to other Oldie's*, Wbicl 'may need against you. You expressly Waive any right to aim that. mob evidence should not be introdueed because it was obtained as a result of the grand jury tosfilminy. Furthermore, the federal govenuilent may use statements made in the grand jury testimony and all evidence derived directly or indirectly therefrom for the purpose of cross-exataination, ifyOu testify daily trial or if.You Case No. 0g-80736-CV-MARRA P-003739 EFTA00799638
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Case 9:08-cv-80736-KAM Document 403-19 Entered on FLSD Docket 06/02/2017 Page 35 of 176 1Y18.11.4111 FBBIWARY 5,2007 ?Akin 2 suborn testimony that contradicts your prior Statements and testiniony! No additional promises, agreements and conditions havebeen entexedisto otherthanthose set forth in this letter and none Will be entered into unless in writing and signed by all patties. Since*, Aletitnnsier Acosta United States Attorney A. Mario Villareal Assistant United States:Aitomey T have read this agreement and discussed it with•ply attorney, and T hereby acknowledge that it fhlly sets -font my agreement with the office of the United States Attorney for the Southern District of Florida. I state that there have been no additional promises, agreements pt representations-made to me by any officiala ofthe United States in connection with this matter. Dated: February , 2007 'West Palm Beach, Florida witnessed by: lames la limber Attorney feel= Case No. 08-80736-CV-MARRA P-003740 EFTA00799639
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Case 9:08-cv-80736-KAM Document 403-19 Entered on FLSD Docket 06/02/2017 Page 36 of
176
U.S. Department of Justice
United States Attorney
SoutheitrDistrictof Florida
.500 South Australian Ave45)ibe-400.
;I'm; fiabliBiach. Pt j3401
February 5, 2007
DELIVERY rir HAND
Ames L. Eisenberg, Esq.
250 t Australian Ave, Stc 704
West Palm Beach, FL 33401-5007
Rer
Dear Mr. Eisenberg:
I am writing to• clarify the ground rules for the interview with your pliant, TM
Ivaryour olienr), to occur February
, 2007.
As I mentioned earlier, MS. lvillis not a target 0t sUbject of this investigation, but
instead is being interviewed solely is a victim/Witness, Homier, to address your concern
aboµt criminal exposure, if your (silent complies with rieryprOviSion of this agreement, then
the United States Attorney's Office for the Southern District of Florida (".this (gibe s) will
treat all statements made by your clientduring the interview as statements made pursuant to
Rule 11(i) of the Federal Rules of Criminal itooechnie. This is not a grant of immunity,
Which can be given only with approval of the Iustice Department, but protect? your client
from having the statements made by her during the interview ftpm being used against her
directly. To guard against anymisunderstandings onnearning the interview of your O0114
this letter sets feath the terms of this agreement. .
Your client agrees to be fully interviewed, that is, to provide information Correcting
your client's knowledge of, and participation in criminal aetivity, including but not limited
. to the procurement of prostitutes. Theprotection$ this letter applies to an interview that
will be conchieted by this Office, Special Agents ofthelleclerall3ureau ofinvegtigafton, and
any other federal law enforcement agency this Office may require. Under this agreement,
no. information disclosed by your client during The interview will be offered in evidence
against her in any criminal or thin proceeding, proVided that your client complies with.this
sgrednent and that the information your client finishes is truthfldrcomplete, and accurate:
If, however, y.our 'Aleut gives materially false, incomplete, or misleading information;
Case No. 08-80736-CV-MARRA
P-003741
EFTA00799640
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Case 9:08-cv-80736-KAM Document 403-19 Entered on FLSD Docket 06/02/2017 Page 37 of 176 James 04.,. SENBIllte, ESQ. EIMIWARY 2, 2007 PAGE 2. then this Office may use such information in any matter or proceeding and your Client is subject tO prosecution for perjury, obstruction of justice, and making false Statements government agencies. Any such Prosecution maybe based UpOrrinfoimatiOn provided by your client during the course of the interview, and such Mfortnation, belittling your client's • statements, will be admissible against your client it any grand jury or other proceeding. • ThegoVetement also may use statements made by your Client in the interview and all evidence derived directly or hi:tiredly therefrom for the purpose of' iMpetiohment or cross-ccamination if she testifies at any trial-or hearing,' and/or-in any rebuttal case-against your' client in a criminal trial in whic4h she is a defendant. or a witness, These provisions are necessary to ensure that your client does not make or offer any false representation at statement in an?' proeCoding. or to a government agency or ooxmnit perjury during any testintony, Yourclient further agrees that attorneys for the United States may be present at the interview, and agrees not to seek.disqualiflcation of any such government attorney from any proteeding or trial her-Ruse of their participation at the interview. • The entire agreement between the 'nited States and your client is set forth in this letter. No additional promises, agreements, or conditions have been entered into and none will be entered into unleis in writing and signed by all parties. If the fbmgoing accurately reflects the understanding and agreement between this Offlceandyour client, it is requested that you and your nitwit exectite this letter as provided below, Sincerely, it Alexander Acosta 'United States AttOniey BY: A. Marie ViilafhPia • . Assistant United States Attorney I taivereceived this letter from my.attorney, Iranes.L. liisertberg, Iisquire, have read it end discussed it with thy attorney, and I hereby acknowledge that it fidly sets forth my understanding and agteendant with the Office oftheThitedStates Attorney forte Southern Case No. 08-80736-CV-MARRA P-003742 EFTA00799641
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Case 9:08-cv-80736-KAM Document 403-19 Entered on FLSD Docket 06/02/2017 Page 38 of 176 ,Lithiss L. BISENBERO ESq. RI ; P 2, PAGES' District of Florida, I state that there have been no additional promises or representations made to me by any official of the United States Govermtent or by my attorney in connection with this matter, Dated: Witnessed by: Mims t", Eisenberg, Batlike Case No. 08-80736-CV-MARRA P-003743 EFTA00799642
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Case 9:08-cv-80736-KAM Document 403-19 Entered on FLSD Docket 06/02/2017 Page 39 of 176 Exhibit 4 EFTA00799643
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Case 9:08-cv-80736-KAM Document 403-19 Entered on FLSD Docket 06/02/2017 Page 40 of 176 U.S. Department of Justice Authorization for Reimbursement of Unueual Expenses of Fact Wit:desires Request for Unusual Expense(o) of Fact Witness (For United States Attorney's Office Use Only) Control# . a on o our West- Palm 2. Court boded Nurfiber 3. Requesting AUSA A. M04 Vitarta, 5. °intact Person 6. Contact Person Ntimber 90 zoq - /041- "7 7. Witness Name& , agm a one • t. tyl,c sfh #, SSN Ma . & Vendor Name & Address, Phone it, TIN/S$N 9. Paytnent to hepatic' to: a M- 10. Recsiptfinvolce Is: 11. Type of Unusual Expense: Medically Necessary Item (Attached SuppodIng Statement) lapopendeet Care Excess Leda Ing/Per Diem El Travel &Transportation K Pretrial Conference Waiver K other 12. Explanation: Tht. f.A))5" 44 41:LO a- StYiall tomic6Lpteei- had. no &rya ti?i*Ctell fe-e CICA-41 co/AAie kAhfi ted- CELLS x'10" Gulta C. Ca. 18.Start Date of -Seivide imo/DANS) ZIG /0 "7 14. End Date of Service (MO/DA/YR) 2 —/to 107 IS:Amount 16. JustlfiCation: GOVERNMENT I EXHIBIT 17. I hereby certify thatthe expenses and Semites listed on.thls document are.approPriate and are within the Federal laws and regulations. I fully understand that I can be held personally liable or be subject to casetfilnaty action for Inipropedy using government funds or services that exceed delegated authority or that violate Federal laws or regulations, signaium of Requesting AUSA 18. Name & Tale of Approving Official Date 19, Dale (MO/DA/YR) 20. Signature of Approving Official Case No. 08-80736-CV-MARRA Form P-003744 EFTA00799644