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This is an FBI investigation document from the Epstein Files collection (FBI VOL00009). Text has been machine-extracted from the original PDF file. Search more documents →

FBI VOL00009

EFTA00185206

310 pages
Pages 221–240 / 310
Page 221 / 310
Case 9:08-cv-80736-KAM Document 216-1 Entered on FLSD Docket 07/27/2013 Page 13 of 
14 
Bates Range 
Description 
Privilege(s) Asserted 
Suppl. Box 3 
P413934 
Thru 
P-013936 
Draft Letter, marked "Confidential," 
to 
corrections 
from 
Deliberative Process 
Privilege 
Attorney Work Product 
with handwritten 
Suppl. Box 3 
P-013937 
Thru 
P-013939 
Draft Letter, 
to Professor Paul 
Deliberative Process 
Privilege 
Attorney Work Product 
G. Cassell, with handwritten corrections 
Suppl. Box 3 
P413940 
Thru 
P-013942 
Draft Letter, marked "Confidential: 
To 
O ned b Addressee Only," 
, with handwritten corrections 
Be 
to 
Deliberative Process 
Privilege 
Attorney Work Product 
Suppl. Box 3 
P-013943 
E-mail, 
2011, 11:19 
., RE: 
for our review with e-mail 
a 
to 
and 
to 
) attached 
to 
May 5, 
to 
Deliberative Process 
Privilege 
Attorney Work Product 
Re-write of Epstein letters 
from 
5, 2011, 11:08 
.
and 
Ma 5, 2011, 11:10 M.), 
(May 5, 2011, 10:41 
Suppl. Box 3 
P-013944 
E-mail 
to 
11:17 
, RE: Re-write 
our review, with e-mail 
a 
5, 
to 
and 
to 
attached 
May 5, 2011, 
for 
to 
.), 
.), 
Deliberative Process 
Privilege 
of Epstein letters 
from 
2011, 
11:08 
ay 5, 2011, 11:01 
(May 5, 2011, 10:41), 
Suppl. Box 3 
P-013945 
E-mail, 
to 
. May 4, 2011, 5:01 
e- 
Deliberative Process 
Privilege 
p.m., RE: draft letters 
mail from 
to 
4:57 p.m. attached 
in Epstein matter, with 
(May 4, 2011, 
Suppl. Box 3 
P-013946 
E-mail, 
to 
May 4, 
Law Enforcement 
investigatory record, atty 
work product; deliberative 
process privilege 
2011, 4:08 p.m., RE: FYI on the Florida matter 
Suppl. Box 3 
P-013947 
E-mail, 
to 
May 3, 2011, 
for 
atty work product; law 
enforcement investigatiory 
record 
12:23 p.m., RE: 
OPR Inquiry — request 
information, with post-it note attached with 
handwritten attorney notes on tele 'hone call 
between 
and 
with 
and 
Suppl. Box 3 
P-013948 
Thru 
P-013951 
E-mail 
to 
and 
atty work-product 
May 3, 2011, 12:30 p.m., FW: OPR 
Inquiry — request for information, with attached 
e-mails. Handwritten attorney notes on margin 
Page 13 of 14 
EFTA00185426
Page 222 / 310
Case 9:08-cv-80736-KAM Document 216-1 Entered on FLSD Docket 07/27/2013 Page 14 of 
14 
Bates Range 
Description 
Prig ilege(s) Asserted 
Suppl. Box 3 
P-013952 
Thru 
P-013953 
E-mail, 
to 
March 
atty work-product; any-
client privilege 
16, 2011, 10:52 
., RE: Referral of Cassell 
Wiest for Investi 1 ation, with e-mail from 
to 
and 
(March 15 2011 7:21 p.m. attached 
Suppl. Box 3 
P-013954 
Thru 
P-013955 
E-mail, 
to 
OPR, 
December 16, 2010, 10:59 
., FW: 
OPR 
Referral — Allegation of Misconduct — U.S. 
Attome 's Office S.D.Fla., with e-mail from 
to 
(December 16, 2010, 
10:22 
.), attached. 
Handwritten attorney 
any work-product, any-
client privilege 
notations. 
Suppl. Box 3 
P-013956 
Thru 
P-013846 
Fourteen (14) pages of handwritten attorney notes 
on case, telephone interviews with DOJ attorneys 
atty work-product 
Page 14 of 14 
EFTA00185427
Page 223 / 310
, 
Case 9:08-cv-80736-KAM Document 329 Entered on FLSD Docket 06/23/2015 Page 1 of 2 
UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
Case No. 08-80736-Civ-Marra/Matthewman 
JANE DOE #1 AND JANE DOE #2, 
Petitioners, 
I.
UNITED STATES OF AMERICA, 
Respondent. 
UNITED STATES' NOTICE OF FILING SECOND SUPPLEMENTAL PRIVILEGE LOG 
Pursuant to the Court's June 18, 2013 Omnibus Order (DE 190), the Respondent, United 
States of America, by and through the undersigned Assistant United States Attorney, hereby gives 
notice of its filing of its Second Supplemental Privilege Log. The index has been marked with 
Bates Numbers P-013970' thru P-014923. 
The documents referenced in the Second Supplemental Privilege Log will be delivered 
today to the Chambers of U.S. District Judge Kenneth A. Marra for ex parse in camera review, 
pursuant to the Court's Omnibus Order. 
Respectfully submitted, 
WIFREDO A. FERRER 
UNITED STATES ATTORNEY 
By: 
Assistant United States Attorney 
Florida Bar No. 0018255 
500 South Australian Ave, Suite 400 
West Palm Beach. FL 33401 
Telephone: 
Facsimile: 
Please note that, while preparing the Second Supplemental Privilege Log, the undersigned 
discovered an error on the Supplemental Privilege Log, that is, the last entry states that the last document 
bears Bates Numbers P-013956 thru P-013846. The correct Bates range for that document is P-013956 
thru P-013969 [14 pages]. 
1 
EFTA00185428
Page 224 / 310
Case 9:08-cv-80736-KAM Document 329 Entered on FLSD Docket 06/23/2015 Page 2 of 2 
CERTIFICATE OF SERVICE 
I HEREBY CERTIFY that on June 23, 2015, I electronically filed the foregoing 
document with the Clerk of the Court using CM/ECF. According to the Court's website, 
counsel for all parties are able to receive notice via the CM/ECF system. 
Assistant United 
United States Attorney 
SERVICE LIST 
Jane Does 1 and 2 
United States, 
Case No. 08-80736-CIV-MARRA/MATTHEWMAN 
United States District Court, Southern District of Florida 
Brad Edwards, Esq., 
Fanner Jaffe Weissing Edwards Fistos Lehrman 
425 N Andrews Ave Ste 2 
Fort Lauderdale, FL 33301-3268 
[email protected] 
954-524-2820 
Fax: 954-524-2822 
Paul G. Cassell 
S.J. Quinney College of Law at the 
University of Utah 
332 S. 1400 E. 
Salt Lake City, Utah 84112 
(801) 585-5202 
Fax: (801) 585-6833 
E-mail: casselp®law.utah.edu 
Attorneys for Jane Doe # 1 and Jane Doe # 2 
2 
EFTA00185429
Page 225 / 310
Case 9:08-cv-80736-KAM Document 329-1 Entered on FLSD Docket 06/23/2015 Page 1 of 18 
JANE DOE'. UNITED STATES 
COURT FILE NO. 08-80736-CV-MARRA 
SECOND SUPPLEMENTAL PRIVILEGE LOG - BOX #4 
Bates Range 
Description 
Privilege(s) Asserted 
P-013970 
thru 
P-013971 
11/29/2006-12/1/2006 emails between 
and prison 
Work Product 
Investigative Privilege 
Privacy Act 
employee regarding attempted contact with potential witness 
P-013972 
5/18/2007 email from 
to 
informing him 
Work Product 
6(e) 
Deliberative Process 
Investigative Privilege 
of intent to subpoena Roy Black's private investigator and steps taken to 
obtain DOJ authorization 
P-013973 
thru 
P-013976 
5/18/2007 emails between 
and expert witness regarding 
Work Product 
6(e) 
Investigative Privilege 
securing pre-indictment consultation contract 
P-013977 
thru 
P-013979 
5/21/2007 email from 
to 
(CEOS) re 
Work Product 
6(e) 
Deliberative Process 
Investigative Privilege 
2423(b) charging question 
P-013980 
5/21/2007 email from 
to 
and 
Work Product 
6(e) 
Deliberative Process 
regarding guidance on grand jury presentation 
P-013981 
5/22/2007 email from Andy 
to 
and 
Work Product 
Deliberative Process 
(cc: 
) re letter received from Gerald Lefcourt discussing 
a meetin to discuss E 
in invest' ation 
P-013982 
5/23/2007 email from
to 
re extradition 
Work Product 
A/C privilege 
Investigative Privilege 
research 
P-013983 
thru 
P-013984 
5/23/2007 emails between 
and 
Work Product 
Deliberative Process 
regarding decision to meet with counsel for Epstein 
Page 1 of 18 
EFTA00185430
Page 226 / 310
Case 9:08-cv-80736-KAM Document 329-1 Entered on FLSD Docket 06/23/2015 Page 2 of 18 
Bates Range 
Descri t lion 
Privilege(s) Asserted 
P-013985 
thru 
P-013989 
6/14/2007-6/21/2007 emails between 
6(e) 
Work Product 
Deliberative Process 
Investigative Privilege 
and 
regarding addendum to 
Pros Memo, grand jury presentation and changes to indictment, and 
meetin with counsel for E stein 
P-013990 
thru 
P-013991 
6/26/2007 email from 
to 
, 
Work Product 
Deliberative Process 
and 
addressing arguments regarding interstate nexus for 
2422 
char es 
P-013992 
thru 
P-013994 
7/3/2007-7/4/2007 emails between 
and 
6(e) 
Work Product 
Investigative Privilege 
Deliberative Process 
regarding extension of time to respond to subpoenas requested by Lilly 
Ann Sanchez and possible resolution of case 
P-013995 
thru 
P-014010 
6/12/2007-7/6/2007 series of emails between 
and 
Work Product 
Investigative Privilege 
Privacy Act 
AUSAs 
and 
re an earlier unrelated 
investigation of Epstein 
P-014011 
thru 
P-014025 
7/3/2007-7/13/2007 email chain between 
and 
6(e) 
Work Product 
Deliberative Process 
Investigative Privilege 
regarding disagreement on 
plea negotiations and 
written request for meeting between USAO management and victims 
P414026 
thru 
P-014027 
7/16/2007 email from 
to 
and 
6(e) 
Work Product 
Deliberative Process 
Investigative Privilege 
regarding correspondence from Roy Black and Motion to Quash 
P-014028 
thru 
P-014030 
7/18/2007 emails from 
to 
and 
6(e) 
Work Product 
Deliberative Process 
Investigative Privilege 
regarding Motion to Quash grand jury subpoena and 
supporting affidavit filed by Roy Black 
P-014031 
thru 
P414032 
7/19/2007 email chain between 
6(e) 
Work Product 
Deliberative Process 
Investigative Privilege 
Attorney-Client Privilege 
S/A 
and S/A 
regarding potential 
service of target letters 
Page 2 of 18 
EFTA00185431
Page 227 / 310
Case 9:08-cv-80736-KAM Document 329-1 Entered on FLSD Docket 06/23/2015 Page 3 of 18 
Bates Range 
Desert • tion 
Privilege(s) Asserted 
P-014033 
7/19/2007 email from 
to 
and 
Work Product 
6(e) 
Investigative Privilege 
Deliberative Process 
regarding planned service of target letters 
P-014034 
7/26/2007 email from 
to 
and 
6(e) 
Work Product 
Deliberative Process 
Investigative Privilege 
regarding proposed changes to the indictment 
P-014035 
7/31'2007 email from 
to 
Work Product 
Deliberative Process 
and 
summarizing proposed plea terms as per 
recommendation 
P-014036 
7/31/2007-8/2/2007 email chain between 
Work Product 
Deliberative Process 
Investigative Privilege 
and 
regarding plea negotiations 
P-014037 
8/2/2007 email drom 
to 
Work Product 
Deliberative Process 
Investigative Privilege 
and 
with draft response to Epstein counsel regarding 
ement 
P-014038 
thru 
P-014041 
8/2/2007 emails between 
, Andy 
and 
Work Product 
Deliberative Process 
regarding letter received from Lilly Ann Sanchez 
P-014042 
8/3/2007 Email from 
I 
to 
Work Product 
Deliberative Process 
Investigative Privilege 
and 
regarding draft response to 
correspondence from Epstein counsel and planned investigative steps if 
a 
ment cannot be reached. 
P-014043 
thru 
P-014044 
Emails dated 8/6/2007 from 
to 
and 
regarding 
correspondencea to his 
arture. 
Work Product 
Deliberative Process 
P-014045 
thru 
P-014046 
8/7/2007 email chain between= 
, and 
Work Product 
Deliberative Process 
Investigative Privilege 
Alex Acosta regarding meeting to discuss Epstein matter 
Page 3 of 18 
EFTA00185432
Page 228 / 310
Case 9:08-cv-80736-KAM Document 329-1 Entered on FLSD Docket 06/23/2015 Page 4 of 18 
Bates Range 
Desert . tion 
Privilege(s) Asserted 
P-014047 
8/7/2007 email from 
to Andy 
regarding deadline 
Work Product 
Deliberative Process 
Investigative Privilege 
set for Epstein plea and Epstein's plan to demand a meeting with CEOS. 
P-014048 
8/7/2007 email from 
to 
regarding 
Work Product 
Deliberative Process 
Investigative Privilege 
Epstein meeting 
P-014049 
thru 
P-014050 
8/7/2007 email chain from 
to 
Work Product 
Deliberative Process 
Investigative Privilege 
and Alex Acosta regarding Epstein meeting 
P-014051 
8/8/2007 emails between 
and 
Work Product 
Deliberative Process 
Investi ative Privilege 
(CEOS) regarding case staffing and plea negotiations 
P-014052 
8/8/2007 email chain between 
Alex Acosta, 
Work Product 
Deliberative Process 
Investigative Privilege 
and 
regarding 
"The meeting on Epstein" 
P-014053 
8/8/2007 email from 
to 
regarding 
Work Product 
Investigative Privilege 
Deliberative Process 
plea negotiations, guideline calculations, and assistance in preparing 
case for trial 
P-014054 
8/8/2007 email from 
I 
to Alex Acosta, 
Work Product 
6(e) 
Investigative Privilege 
Deliberative Process 
and 
regarding planning 
meeting with Epstein counsel and service of target letters 
P-014055 
8/10/2007 Electronic correspondence from 
to expert 
witness regarc_ljgn: to . ics for expert testimon 
Work Product 
P-014056 
8/10/2007 email from = 
to 
regarding 
Work Product 
target letters and sta in motion to com . 1 . roduction of com . uters 
P-014057 
8/30/2007 email from 
to 
and 
regarding press 
covers • e of meetin with Ken Starr 
Work Product 
P-014058 
9/4/2007-9/6/2007 emails between 
and 
Work Product 
Deliberative Process 
regarding planned participation of FBI ASAIC at 9/7/2007 meeting with 
Epstein defense team 
Page 4 of 18 
EFTA00185433
Page 229 / 310
Case 9:08-cv-80736-KAM Document 329-1 Entered on FLSD Docket 06/23/2015 Page 5 of 18 
Bates Ran e 
Description 
Privil e s Asserted 
P-014059 
thru 
P-014061 
9/6/2007 emails between 
Work Product 
Deliberative Process 
and 
regarding status of plea 
negotiations, draft agreements, and need to confer with victims 
P-014062 
thru 
P-014068 
9/10/2007-9/14/2007 emails between 
I 
and Alex 
Acosta regarding final plea negotiations, finalizing details with State 
Attorney's Office and final revisions to indictment pack: a 
Work Product 
Deliberative Process 
6(e) 
Investigative Privilege 
P-014069 
9/10/2007 email from 
to 
and = 
Work Product 
6(e) 
Investigative Privilege 
regarding Acosta inquiry about FBI investigation into State 
grand ' 
roceedin 
P-014070 
thru 
P-014074 
9/11/2007 emails between 
Work Product 
Deliberative Process 
Investigative Privilege 
Attorney-Client Privilege 
, and 
regarding changes 
to the draft indictment and status of plea negotiations 
P-014075 
thru 
P-014089 
9/10/2007-9/11/2007 emails between 
Alex Acosta, and 
Work Product 
Deliberative Process 
regarding modifications to the proposed Non-Prosecution 
A eement 
P-014090 
thru 
P-014102 
9/13/2007 emails from 
I 
to 
Alex Acosta, 
and 
regarding plea to 
federal charges recommending 18 USC 403 or 1512(d), or 47 USC 
223(aX1)(3); response that Epstein was only willing to plead to assault 
on the plane; and rejection of facts supporting assault on the plane 
charge 
Work Product 
Deliberative Process 
P-014103 
thru 
P-014107 
9/13/2007-9/14/2007 emails regarding 
research 
Work Product 
regarding victim trust fund set up in Alaska child exploitation case 
P-014108 
thru 
P-014134 
9/17/2007-9/19/2007 emails between 
I 
Alex Acosta, 
and 
regarding negotiations of a federal plea and a non-prosecution 
agreement 
Work Product 
Deliberative Process 
Page 5 of 18 
EFTA00185434
Page 230 / 310
Case 9:08-cv-80736-KAM Document 329-1 Entered on FLSD Docket 06/23/2015 Page 6 of 18 
Bates Range 
Description 
Privilege(s) Asserted 
P-014135 
thru 
P-014149 
9/19/2007-9/20/2007 emails between 
, 
Work Product 
Deliberative Process 
and 
regarding plea negotiations with counsel for 
E stein 
P-014150 
thru 
P-014156 
9/20/2007 emails between 
and 
Work Product 
Deliberative Process 
regarding plea agreement to federal charges and factual proffer 
P-014157 
thru 
P-014160 
9/21/2007 emails between 
I 
and 
Work Product 
Deliberative Process 
= 
and 
regarding revisions to the 
non- • rosecution agreement 
P-014161 
9/21/2007 email from 
I 
to Alex Acosta, 
Work Product 
Deliberative Process 
and 
regarding review of Epstein 
indictment 
c 
e 
P-014162 
thru 
P-014170 
9/24/2007 series of emails between 
Alex Acosta, and 
Work Production 
Deliberative Process 
regarding plea negotiations and revisions to non- 
prosecution agreement 
P-014171 
thru 
P-014174 
9/23/2007-9/24/2007 series of emails between Alex Acosta, 
Work Product 
Deliberative Process 
. 
and 
regarding 
proposed revisions to non-prosecution a reement 
P-014175 
thru 
P-014203 
9/20/2007-9/24/2007 emails between Alex Acosta, 
nd 
Work Product 
Deliberative Process 
regarding revisions to the non-prosecution agreement 
P-014204 
thru 
P-014205 
9/24/2007 emails between 
and 
Work Product 
Deliberative Process 
regarding notifying Palm Beach Police Chief and victims about 
agreement 
P-014206 
thru 
P-014216 
9/24/2007-9/25/2007 emails between Alex Acosta, 
n
---
and Rolando 
regarding Lefkowitz email about 
keeping agreement from becoming public and confidentiality provision 
in agreement 
Work Product 
Deliberative Process 
P-014217 
thru 
P-014238 
10/5/2007-10/16/2007 emails between 
Work Product 
Deliberative Process 
and Alex Acosta re selection of Special Master and negotiation of 
revision/addendum to Non-Prosecution Agreement 
Page 6 of 18 
EFTA00185435
Page 231 / 310
Case 9:08-cv-80736-KAM Document 329-1 Entered on FLSD Docket 06/23/2015 Page 7 of 18 
Bates Range 
Descriris 
Privilege(s) Asserted 
P-014239 
thru 
P-014242 
10/18/2007 emails between 
and 
regarding 
Work Product 
Deliberative Process 
Epstein's request to delay his change of plea 
P-014243 
thru 
P-014251 
10/19/2007 emails between 
and 
regarding 
Work Product 
Deliberative Process 
Special Master's Selection of Attorney Representative 
P-014252 
thru 
P-014275 
10/22/2007-10/31/2007 emails between 
Alex Acosta, and 
Work Product 
Deliberative Process 
regarding negotiation of Addendum to Non-Prosecution 
Agreement and drafting of correspondence regarding scope of Special 
Master's duties and selection criteria 
P-014276 
10/31/2007 email from 
to 
Work Product 
Attorney-Client Privilege 
Investigative Privilege 
6(e) 
Also contains information subject to 
privacy rights of victims who are not 
parties to this litigation 
regarding attempts to interview additional witnesses/victims 
P-014277 
thru 
P-014282 
11/2/2007-11/5/2007 emails between 
and 
Work Product 
Deliberative Process 
regarding drafting 11/5/2007 letter from Siouan to Lefkowitz 
P-014283 
thru 
P-014284 
11/5/2007-11/7/2007 emails from 
to 
Work Product 
Deliberative Process 
inquiring about status of matter and contact by Epstein investigators 
with victims 
P-014285 
thru 
P-014298 
11/8/2007-11/14/2007 emails between 
Work Product 
Deliberative Process 
Attorney-Client Privilege 
and 
regarding response to objections 
raised by Epstein counsel and efforts to charigt date
 
ea 
P-014299 
thru 
P-014307 
11/14/2007-11/19/2007 emails between MI 
Alex Acosta, and 
regarding communications with State Attorney's Office and 
Sheriff's Office in an attempt to insure that Epstein was ineligible for 
work release 
Work Product 
Deliberative Process 
Attorney-Client Privilege 
Page 7 of 18 
EFTA00185436
Page 232 / 310
Case 9:08-cv-80736-KAM Document 329-1 Entered on FLSD Docket 06/23/2015 Page 8 of 18 
Bates Range 
Desui ,it
 
Privilege(s) Asserted 
P-014308 
thru 
P-014310 
11/19/2007 emails between 
and 
Work Product 
Deliberative Process 
about efforts by Epstein's counsel to change date for change of 
plea 
P-014311 
thru 
P-014329 
11/19/2007-11/28/2007 emails between 
Work Product 
Deliberative Process 
Attorney-Client Privilege 
6(e) 
Also contains information subject to 
privacy rights of victims who are not 
parties to this litigation 
and 
regarding drafting victim 
notification letter of upcoming plea 
P-014330 
thru 
P-014337 
11/28/2007 correspondence between 
and 
regarding Lefkowitz 11/27/2007 
email discussing presentation to DAAG 
Work Product 
Deliberative Process 
P414338 
thru 
P414354 
11/29/2007-12/1/2007 emails between 
Alex Acosta, 
and 
regarding draft 
response to Jay Leflcowitz and victim notification letters 
Work Product 
Deliberative Process 
P414355 
thru 
P-014361 
12/3/2007 emails between 
Villafafia, Alex Acosta, and 
Work Product 
Deliberative Process 
regarding history of plea negotiations and drafting response to 
correspondence from Jay Lekowitz and Ken Starr 
P-014362 
thru 
P414402 
12/3/2007-12/5/2007 cones • • ndence between Alex Acosta, 
, and 
about drafting and sending the 12/4/2007 Acosta letter 
to Ken Starr 
Work Product 
Deliberative Process 
6(e) 
Attorney-Client Privilege 
P-014403 
thru 
P-014414 
12/6/2007 emails between 
Work Product 
Deliberative Process 
, Alex Acosta, 
and 
regarding correspondence from Ken Starr, request for a 
meeting from Epstein counsel, and need to notify victims of upcoming 
plea 
P-014415 
thru 
P-014420 
12/6/2007-12/7/2007 emails between 
Work Product 
Deliberative Process 
and Alex Acosta regarding draft victim 
notification letter 
Page 8 of 18 
EFTA00185437
Page 233 / 310
Case 9:08-cv-80736-KAM Document 329-1 Entered on FLSD Docket 06/23/2015 Page 9 of 18 
Bates Range 
Description 
Privilege(s) Asserted 
P-014421 
thru 
P-014428 
12/6/2007-12/7/2007 emails between 
and 
regarding request from State 
Attorney's Office for draft plea proffer 
Work Product 
Deliberative Process 
6(e) 
Attorney-Client Privilege 
Investigative Privilege 
P-014429 
thru 
P-014439 
12/9/2007-12/12/2007 emails between 
4 
and 
regarding drafting response to personal attacks and 
Work Product 
Deliberative Process 
upcoming meet.irt with Ken Starr 
P-014440 
12/11/2007 email from 
to 
and Alex Acosta 
Work Product 
Deliberative Process 
regarding call with lawyer for Jane Doe #2 (T.M.) 
P-014441 
12/12/2007 emails between 
 
and 
Work Product 
Deliberative Process 
6(e) 
regarding planning indictment review 
P-014442 
12/14/2007 email from 
to 
Alex Acosta, 
Work Product 
Deliberative Process 
and 
regarding state cases mentioned by Epstein's 
counsel 
P-014443 
12/14/2007 email from 
Villafafia to Alex Acosta, 
, 
and 
with draft letters to State 
Attome 's Office and victims 
Work Product 
Deliberative Process 
P-014444 
12/17/2007 email from 
to 
inquiring about 
Work Product 
Deliberative Process 
case status and informing Sloman regarding agent concern about victim 
notifications 
P-014445 
thru 
P-014447 
12/19/2007 email from 
to Alex Acosta and 
Work Product 
Deliberative Process 
6(e) 
summarizing research into other cases where individuals were charged 
with violating 2422(b) based u m
iShe use of a telephone 
P-014448 
thru 
P-014454 
12/19/2007 emails between 
Alex Acosta, and 
Work Product 
Deliberative Process 
regarding drafting response to concerns raised durin: December 
14, 2007 meeting between Epstein counsel Alex Acosta, 
, 
the FBI SAIC, and 
Page 9 of 18 
EFTA00185438
Page 234 / 310
Case 9:08-cv-80736-KAM Document 329-1 Entered on FLSD Docket 06/23/2015 Page 10 of 
18 
Bates Range 
Desert don 
Privilege(s) Asserted 
P-014455 
thru 
P-014456 
12/19/2007 email from 
to Alex Acosta, 
Work Product 
Deliberative Process 
6(e) 
Also contains information subject to 
privacy rights of victims who are not 
parties to this litigation 
and 
regarding challenge to state charge raised by 
Epstein counsel during 12/14/2007 meeting 
P-014457 
thru 
P-014464 
12/20/2007 emails between 
and 
regarding 
Work Product 
Deliberative Process 
6(e) 
Also contains information subject to 
privacy rights of victims who are not 
parties to this litigation 
inquiries from State Attorney's Office regarding Epstein plea to state 
charge and facts supporting state plea 
P-014465 
thru 
P-014485 
12/18/2007-12/21/2007 emails between 
and other 
Work Product 
6(e) 
AUSAs regarding other instances of charging 2422(b) based on the use 
of a telephone as a "fa.ilf 
interstate commerce" 
P-014486 
12/21/2007 email from
to 
with thoughts on 
Work Product 
Deliberative Process 
recent correspondence from Jay Lefkowitz raising concerns about 
interpretation of the 
.1 folrosecution Agreement 
P-014487 
12/27/2007 email from 
to Alex Acosta and 
Work Product 
Deliberative Process 
regarding proposed approach to providing potential notice of breach of 
non- rosecution agreement 
P-014488 
thru 
P-014499 
12/27/2007 emails between 
Alex Acos 
regarding Jay 
Lefkowitz letter of 12/26/2007 
Work Product 
Deliberative Process 
P-014500 
1/2/2008 email from 
to Alex Acosta and 
Work Product 
Deliberative Process 
regarding telephone conversation with State Attorney's Office about 
delay in Epstein state plea. 
P-014501 
thru 
P-014506 
1/2/2008 emails between Alex Acosta, 
and 
Work Product 
Deliberative Process 
regarding requests from Alex Acosta to 
for information 
related to the handling of the investigation by the State Attorney's Office 
Page 10 of 18 
EFTA00185439
Page 235 / 310
Case 9:08-cv-80736-KAM Document 329-1 Entered on FLSD Docket 06/23/2015 Page 11 of 
18 
Bates Range 
lion 
Privilege(s) Asserted 
P-014507 
thru 
P-014508 
1/2/2008 emails from 
to Alex Acosta and 
roil 
Work Product 
Deliberative Process 
6(e) 
regarding renewed plea negotiations for federal plea agreement 
P-014509 
thru 
P-014519 
1/3/2008 emails between 
Alex Acosta, and 
Work Product 
Deliberative Process 
regarding Alex Acosta telephone conference with Jay Lefkowitz where 
Lefkowitz admitted that he never intended to have Epstein plead guilty 
to an offense that required sex offender re istration. 
P-014520 
1/ 
from 
to 
and ME 
Attorney client privilege 
Deliberative Process 
Investigative Privilege 
(Small 
regarding renewed plea negotiations and press coverage o
E stein matter. 
P414521 
thru 
P-014522 
to Alex Acosta, 
, 
Work Product 
Deliberative Process 
6(e) 
Privacy Act 
and 
regarding proposed 
additional investigative steps in Epstein case. 
P-014523 
1/9/
 
to 
Alex Acosta, and 
Work Product 
Deliberative Process 
regarding informing Jay Lefkowitz that a CEOS 
attorney would join the SDFL team regarding the Epstein case and 
would review the rosecution and defense materials. 
P-014524 
thru 
P-014550 
1/ /2 8-1/14/2008 emails between 
, and 
regarding 
assigning a CEOS attorney to the investigation, meeting with the CEOS 
attorney and victims in Florida, the results of the meetings and planned 
additional meetings, and revisions to the indictment in light of the 
meetin s. 
Work Product 
Deliberative Process 
Attorney-client privilege 
Investigative Privilege 
6(e) 
P-014551 
1/17/2008 email from 
to 
regarding 
Attorney-client privilege 
Investigative Privilege 
Also contains information subject to 
privacy rights of victims who are not 
parties to this litigation 6(e) 
updated summary charts for indictment preparation, meetings with 
victims, and victim notification letters from FBI 
P-014552 
1/23/2008 email from 
to 
and Alex Acosta 
Work Product 
Deliberative Process 
regarding FBI involvement in meeting in DC 
Page 11 of 18 
EFTA00185440
Page 236 / 310
Case 9:08-cv-80736-KAM Document 329-1 Entered on FLSD Docket 06/23/2015 Page 12 of 
18 
Bates Range 
Descri Lion 
Privilege(s) Asserted 
P-014553 
thru 
P-014556 
1/25/2008 emails between 
d 
Work Product 
6(e) 
Deliberative Process 
Inveitigative Privilege 
Also contains information subject to 
privacy rights of victims who are not 
parties to this) litigation 
regarding press coverage of case and strategic decism
i .sigegar 
g 
revisions to initial indictment 
P-014557 
1/25/2008 email from 
to 
and 
6(e 
Attorney-client privilege 
Investigative Privilege 
Also contains information subject to 
privacy rights of victims who are not 
parties to this litigation 
regarding research for purposes oli lluin.l
i  Jury 
subpoenas. 
P-014558 
1/29/2008 email from 
to 
and 
regarding status o meeting in DC and concerns regarding 
la
Work Product 
Deliberative Process 
6(e) 
Investigative Privilege 
P-014559 
thru 
P414562 
1/28/2008-1/29/2008 emails between 
1 
a
MillRlird 
IF 
Work Product 
6(e) 
Investigative Privilege 
Also contains information subject to 
privacy rights of victims who are not 
parties to this litigation 
regarding scheduling victim interviews on 1 31/2008- 1 
8 
P-014563 
thru 
P-014565 
1/30/2008 emails between MI 
Alex Acosta, and . 
Work Product 
Deliberative Process 
6(e) 
Also contains information subject to 
privacy rights of victims who are not 
parties to this litigation 
regarding Lefkowitz email about lawsuit filed against Epstem 
by one of the victims identified during the state investigation. 
Page 12 of 18 
EFTA00185441
Page 237 / 310
Case 9:08-cv-80736-KAM Document 329-1 Entered on FLSD Docket 06/23/2015 Page 13 of 
18 
Bates Range 
Desert, 
Privilege(s) Asserted 
P-014566 
thru 
P-014568 
1/31/2008 emails between 
and 
Work Product 
Investigative Privilege 
Attorney-client privilege 
Also contains information subject to 
privacy rights of victims who are not 
es to this litigation 
regarding interviews with victims. 
P-014569 
thru 
P-014573 
1/31/2008-2/1/2008 emails between 
Alex 
Work Product 
Deliberative Process 
6(e) 
Attorney-Client Privilege 
Also contains information subject to 
privacy rights of victims who are not 
parties to this litigation Investigative 
Privilege 
Acosta, 
and Alan Santiago 
regarding results of additional victim-witness interviews and requesting 
intervention with CEOS to move review process along 
P-014574 
thru 
2/20/2008-2/21/2008 emails between 
Work Product 
Deliberative Process 
6(e) 
Si al Mandelker
P-014583 
Alex Acosta, 
and 
regarding 
status of CEOS plans to meet with counsel for Epstein and status of 
indictment review 
P-014584 
that 
P-014622 
2/12/2008-2/22/2008 emails between 
Work Product 
Attorney-Client Privilege 
Investigative Privilege 
6(e) 
Also contains information subject to 
privacy rights of victims who are not 
parties to this litigation 
, 
and 
analyzing facts 
gathered from grand jury investigation and discussing strategy for 
drafting revised indictment 
P-014623 
thru 
P-014627 
2/25/2008 emails between 
and Caroline Heck 
Work Product 
Deliberative Process 
6(e) 
regarding ethical issue about whether or not to present proposed revised 
indictment to new grand 'u 
P-014628 
2/25/2008 email from 
Villafafta to 
Work Product 
Deliberative Process 
6(e) 
and 
regarding result 
lc .msult, 
with Caroline Heck 
about grand jury question 
Page 13 of 18 
EFTA00185442
Page 238 / 310
Case 9:08-cv-80736-KAM Document 329-1 Entered on FLSD Docket 06/23/2015 Page 14 of 
18 
Bates Range 
Descri • tion 
Privilege(s) Asserted 
P-014629 
2/26/2008 email from 
to 
regarding 
Work Product 
Deliberative Process 
CEOS review and draft indictment package 
P-014630 
thru 
P-014631 
2/26/2008 email from 
to 
regarding 
Work Product 
Deliberative Process 
Investigative Privilege 
6(e) 
2/25/2008 correspondence to Jay Lefkowitz further extending 
the plea deadline for Epstein 
P-014632 
thru 
P-014646 
2/21/2008-2/27/2008 emails between 
Work Product 
Deliberative Process 
6(e) 
Investigative Privilege
and 
regarding notifying 
DOJ's Civil Rights Division regarding the status of the case and the 
planned indictmen and the draft written notification 
P-014647 
thru 
P-014649 
2/28/2008 emails between 
and Susan Roe regarding 
Work Product 
Investigative Privilege 
6(e) 
related investigation, potential investigatory leads, and CEOS review 
P-014650 
thru 
P-014653 
2/27/2008-2/28/2008 emails between 
Work Product 
Investigative Privilege 
Attorney-client privilege 
6(e) 
Also contains information subject to 
privacy rights of victims who are not 
parties to this litigation 
and 
regarding review of evidence received 
pursuant to subpoenas and planned interviews of additional potential 
victim-witnesses 
P-014654 
thru 
P-014655 
2/29/2008 emails between 
, 
a 
, 
Work Product 
Deliberative Process 
Investigative Privilege 
6e 
and 
regarding continuing investigation and status of 
CEOS review 
P-014656 
thru 
P-014665 
3/4/2008-3/5/2008 emails between 
and 
Work Product 
Attorney-client privilege 
6(e) 
Investigative Privilege 
Also contains information subject to 
privacy rights of victims who are not 
parties to this litigation 
regarding search warrant and victim contact with attorneys 
Page 14 of 18 
EFTA00185443
Page 239 / 310
Case 9:08-cv-80736-KAM Document 329-1 Entered on FLSD Docket 06/23/2015 Page 15 of 
18 
Bates Range 
- Descri ti 
Privilege(s) Asserted 
P-014666 
thru 
P-014693 
3/5/2 
Work Product 
 
Deliberative Process 
6(e) 
Investigative Privilege 
an 
regarding meeting in DC, additional 
information to prepare for meeting, and new information from ongoing 
investi 
• 
P-014694 
thru 
P-014706 
3/10/2 
- / 
008 emails be 
Work Product 
Deliberative Process 
Attorney-client privilege 
, Krishna Patel, 
, E.J. Yera, and 
about Epstein attempts to contact victims and finding 
c m...
sel f 
P-014707 
thru 
P-014711 
3/12/2 8 emails betwee
o 
and 
n=
il
,
regarding CEOS meeting with Epstein counsel 
Work Product 
P414712 
thru 
P-014716 
3/14/2008 emails between 
regarding complete 
indictment package for 
e 
Work Product 
Deliberative Process 
6(e) 
P-014717 
thru 
P-014721 
1St 
an
-3/d17E1210.0Y8ereamreaigsarbedintwg search 
eent
t application and 
execution of search warrant 
Work Product 
Attorney client privilege 
Investigative Privilege 
Also contains information subject to 
privacy rights of victims who are not 
parties to this litigation 
P-014722 
thru
P-014727 
I 
cli
tilialiails 
, and 
regarding corrections 
Work Product 
Deliberative Process 
6(e) 
Attorney-Client Privilege 
Also contains information subject to 
privacy rights of victims who are not 
parties to this litigation 
to indictment package and proposed grand jury presentation 
Page 15 of 18 
EFTA00185444
Page 240 / 310
Case 9:08-cv-80736-KAM Document 329-1 Entered on FLSD Docket 06/23/2015 Page 16 of 
18 
Bates Range 
Description 
Privilege(s) Asserted 
P-014728 
thru 
P-014742 
3/14/2008-3/19/2008 emails between 
Nesibtt 
S.mkendall 
, and 
about Epstein attempts to contact victims 
and finding counsel for victims 
Work Product 
Deliberative Process 
Attorney-client privilege 
Also contains information subject to 
privacy rights of victims who are not 
parties to this litigation 
P-014743 
thru 
P-014780 
3/19/2008-3/21/2008 emails between 
(CEOS), Alexandra Gelber (CEOS), 
and 
about meeting between Esptein counsel and CEOS and follow-up 
uestions 
Work Product 
6(e) 
Deliberative Process 
Investi alive Privilege 
P-014781 
thru 
P-014800 
3/111- //
 00 
n ,
ails between 
and 
regarding waiting for DC's decision regarding Epstein's challenges to 
NPA; status of ongoing investigation; problems with Epstein's counsel 
contacting victims in the guise of deposing them for the state criminal 
action; and securing pro bono counsel for those victims to represent 
them in connection with the depositions 
Work Product 
Deliberative Process 
Investigative Privilege 
6(e) 
P-014801 
thru 
P-014810 
3/28/2008 emails between 
, 
Work Product 
6(e) 
Investigative Privilege 
Deliberative Process 
and 
regarding status of DC 
review of case and preparing for grand jury presentation 
P-014811 
thru 
P-014829 
3/31/2008 emails between 
6(e) 
Work Product 
Deliberative Process 
Investigative Privilege 
and 
regarding status of ongoing investigation, 
planned presentation to grand jury, continued delay in awaiting decision 
from Washington, DC, and • roblems with victims bein harassed 
P-014830 
thru 
P-014837 
4/2/2008 emails between 
Alex Acosta, 
and 
regarding efforts by Jay Lefkowitz and Ken Stan.. 
with Alex Acosta and instructions to direct • uestion to 
and 
Deliberative Process 
Work Product 
Attorney-Client Privilege 
Page 16 of 18 
EFTA00185445
Pages 221–240 / 310