EFTA00190318

Villafana, Ann Marie C. (USAFLS) 
From: 
Villafana, Ann Marie C. (USAFLS) <[email protected]> 
Sent: 
Wednesday, July 09, 2008 9:23 AM 
To: 
Lee, Dexter (USAFLS); Acosta, Alex (USAFLS) 
Cc: 
Atkinson, Karen (USAFLS); Sloman, Jeff (USAFLS); Jacobus, Wendy (USAFLS) 
Subject: 
RE: Emailing: victim_resp_USArev corrected.wpd 
I was planning to redact all of that infommtion prior to scanning it and attaching Exhibit Stickers. I think we should do so even if this 
is filed under seal. 
A. Marie Villafa0a 
Assistant U.S. Attorney 
561 209-1047 
 
Original Message 
From: Lee, Dexter (USAFLS) 
Sent: Wednesday, July 09, 2008 9:22 AM 
To: Villafana, Ann Marie C. (USAFLS); Acosta, Alex (USAFLS) 
Cc: Atkinson, Karen (USAFLS); Sloman, Jeff (USAFLS); Jacobus, Wendy (USAFLS) 
Subject: RE: Emailing: victim_resp_USArev corrected.wpd 
Marie, 
I will sign the response. Since this case involves girls who were minors when the crimes were committed, and there is a 
confidentiality provision in the deferral of prosecution agreement with Epstein, I believe this should be filed under seal. Otherwise, 
we'll have to go through each letter and excise the names, addresses, and other identifying information on the three girls. 
Dexter 
 
Original Message 
From: Villafana, Ann Marie C. (USAFLS) 
Sent: Wednesday, July 09, 2008 9:11 AM 
To: Lee, Dexter (USAFLS); Acosta, Alex (USAFLS) 
Cc: Atkinson, Karen (USAFLS); Sloman, Jeff (USAFLS) 
Subject: Emailing: victim_resp_USArev corrected.wpd 
Dexter and Alex -- I fixed a couple of typos and entered the correct information about the dates when the letters were sent. I also 
included the information about all three of Edwards' clients, T.M., C.W., and S.R. 
At the end, I also corrected the information regarding the notifications of the victims about the change of plea. I called Edwards on 
Friday, but I'm not sure whether we spoke that day or if he called me over the weekend. And the agents and I didn't start making calls 
together until Monday after the hearing. Sol notified Edwards to inform his three clients, and PI3PD tried to notify six victims, I 
think. I didn't want the court to think that we tried to notify all 33 girls. 
I will make similar changes to my declaration and send that to you shortly. 
Also, I notice there is no signature block. Do you want me to sign and file? Or will you do that, Dexter? Thanks. 
The message is ready to be sent with the following file or link attachments: 
victim_resp_USArev con•ected.wpd 
194 
EFTA00190538

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. 
195 
EFTA00190539

Villafana, Ann Marie C. (USAFLS) 
From: 
Lee, Dexter (USAFLS) <[email protected]> 
Sent: 
Wednesday, July 09, 2008 9:53 AM 
To: 
Villafana, Ann Marie C (USAFLS); Acosta, Alex (USAFLS) 
Cc: 
Atkinson, Karen (USAFLS); Sloman, Jeff (USAFLS); Jacobus, Wendy (USAFLS) 
Subject: 
RE Emailing: victim_resp_USArev corrected.wpd 
Alex and Jeff, 
Do you have any preference for filing under seal or a public filing? If we can protect the identities of the minor victims in a public 
filing, that is one less reason to file it under seal. The other considerations are the government's confirmation that Epstein was under 
federal investigation, and the confidentiality provision in the deferral of prosecution agreement with Epstein. 
It's actually easier to file it electronically, and the general policy is that documents filed in court are public. 
Dexter 
---Original Message-----
From: Villafana, Ann Marie C. (USAFLS) 
Sent: Wednesday, July 09, 2008 9:23 AM 
To: Lee, Dexter (USAFLS); Acosta, Alex (USAFLS) 
Cc: Atkinson, Karen (USAFLS); Sloman, Jeff (USAFLS); Jacobus, Wendy (USAFLS) 
Subject: RE: Emailing: victim_resp_USArev corrected.wpd 
I was planning to redact all of that information prior to scanning it and attaching Exhibit Stickers. I think we should do so even if this 
is filed under seal. 
A. Marie Villafa0a 
Assistant U.S. Attorney 
561 209-1047 
----Original Message----
From: Lee, Dexter (USAFLS) 
Sent: Wednesday, July 09, 2008 9:22 AM 
To: Villafana, Ann Marie C. (USAFLS); Acosta, Alex (USAFLS) 
Cc: Atkinson, Karen (USAFLS); Sloman, Jeff (USAFLS); Jacobus, Wendy (USAFLS) 
Subject: RE: Emailing: victim_resp_USArev corrected.wpd 
Marie, 
I will sign the response. Since this case involves girls who were minors when the crimes were committed, and there is a 
confidentiality provision in the deferral of prosecution agreement with Epstein, I believe this should be filed under seal. Otherwise, 
we'll have to go through each letter and excise the names, addresses, and other identifying information on the three girls. 
Dexter 
----Original Message--
From: Villafana, Ann Marie C. (USAFLS) 
Sent: Wednesday, July 09, 2008 9:11 AM 
To: Lee, Dexter (USAFLS); Acosta, Alex (USAFLS) 
Cc: Atkinson, Karen (USAFLS); Sloman, Jeff (USAFLS) 
Subject: Emailing: victim_resp_USArev corrected.wpd 
196 
EFTA00190540

Dexter and Alex -- I fixed a couple of typos and entered the correct information about the dates when the letters were sent. I also 
included the information about all three of Edwards' clients, T.M., C.W., and S.R. 
At the end, I also corrected the information regarding the notifications of the victims about the change of plea. I called Edwards on 
Friday, but I'm not sure whether we spoke that day or if he called me over the weekend. And the agents and I didn't start making calls 
together until Monday after the hearing. So I notified Edwards to inform his three clients, and PBPD tried to notify six victims, I 
think. I didn't want the court to think that we tried to notify all 33 girls. 
I will make similar changes to my declaration and send that to you shortly. 
Also, I notice there is no signature block. Do you want me to sign and file? Or will you do that, Dexter? Thanks. 
The message is ready to be sent with the following file or link attachments: 
victim_resp_USArev corrected.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. 
197 
EFTA00190541

Villafana, Ann Marie C. (USAFLS) 
From: 
Sloman, Jeff (USAFLS) <[email protected]> 
Sent: 
Wednesday, July 09, 2008 957 AM 
To: 
Lee, Dexter (USAFLS); Villafana, Ann Marie C. (USAFLS); Acosta, Alex (USAFLS) 
Cc: 
Atkinson, Karen (USAFLS); Jacobus, Wendy (USAFLS) 
Subject 
RE: Emailing: victim_resp_USArev corrected.wpd 
Doesn't the confidentiality provision obligate us to file it under seal? 
-----Original Message----
From: Lee, Dexter (USAFLS) 
Sent: Wednesday, July 09, 2008 9:53 AM 
To: Villafana, Ann Marie C. (USAFLS); Acosta, Alex (USAFLS) 
Cc: Atkinson, Karen (USAFLS); Sloman, Jeff (USAFLS); Jacobus, Wendy (USAFLS) 
Subject: RE: Emailing: victim_resp_USArev correeted.wpd 
Alex and Jeff, 
Do you have any preference for filing under seal or a public filing? If we can protect the identities of the minor victims in a public 
filing, that is one less reason to file it under seal. The other considerations arc the government's confirmation that Epstein was under 
federal investigation, and the confidentiality provision in the deferral of prosecution agreement with Epstein. 
It's actually easier to file it electronically, and the general policy is that documents filed in court are public. 
Dexter 
---Original Message—
From: Villafana, Ann Marie C. (USAFLS) 
Sent: Wednesday, July 09, 2008 9:23 AM 
To: Lee, Dexter (USAFLS); Acosta, Alex (USAFLS) 
Cc: Atkinson, Karen (USAFLS); Sloman, Jeff (USAFLS); Jacobus, Wendy (USAFLS) 
Subject: RE: Emailing: victim_resp_USArev corrected.wpd 
I was planning to redact all of that information prior to scanning it and attaching Exhibit Stickers. I think we should do so cycn if this 
is filed under seal. 
A. Marie Villafa0a 
Assistant U.S. Attorney 
561 209-1047 
----Original Message-----
From: Lee, Dexter (USAFLS) 
Sent: Wednesday, July 09, 2008 9:22 AM 
To: Villafana, Ann Marie C. (USAFLS); Acosta, Alex (IJSAFLS) 
Cc: Atkinson, Karen (USAFLS); Sloman, Jeff (USAFLS); Jacobus, Wendy (USAFLS) 
Subject: RE: Emailing: victim_resp_USArev corrected.wpd 
Marie, 
I will sign the response. Since this case involves girls who were minors when the crimes were committed, and there is a 
confidentiality provision in the deferral of prosecution agreement with Epstein, I believe this should be filed under seal. Otherwise, 
we'll have to go through each letter and excise the names, addresses, and other identifying information on the three girls. 
198 
EFTA00190542

Dexter 
---Original Message----
From: Villafana, Ann Marie C. (USAFLS) 
Sent: Wednesday, July 09, 2008 9:1 I AM 
To: Lee, Dexter (USAFLS); Acosta, Alex (USAFLS) 
Cc: Atkinson, Karen (USAFLS); Sloman, Jeff (USAFLS) 
Subject: Emailing: victim_resp_USArev corrected.wpd 
Dexter and Alex -- I fixed a couple of typos and entered the correct information about the dates when the letters were sent. I also 
included the information about all three of Edwards' clients, T.M., C.W., and S.R. 
At the end, I also corrected the information regarding the notifications of the victims about the change of plea. I called Edwards on 
Friday, but I'm not sure whether we spoke that day or if he called me over the weekend. And the agents and I didn't start making calls 
together until Monday after the hearing. So I notified Edwards to infomi his three clients, and PBPD tried to notify six victims, I 
think. I didn't want the court to think that we tried to notify all 33 girls. 
I will make similar changes to my declaration and send that to you shortly. 
Also, I notice there is no signature block. Do you want me to sign and file? Or will you do that, Dexter? Thanks. 
The message is ready to be sent with the following file or link attachments: 
victim_resp_USArev corrected.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. 
199 
EFTA00190543

Villafana, Ann Marie C. (USAFLS) 
From: 
Lee, Dexter (USAFLS) <[email protected]> 
Sent: 
Wednesday, July 09, 2008 12:28 PM 
To: 
Villafana, Ann Marie C. (USAFLS); Acosta, Alex (USAFLS) 
Subject: 
RE: Victim Notification 
Marie, 
DOJ wanted us to hold off sending this out until we get clearance to file our document this afternoon. Will 
that pose any problems? 
Dexter 
From: Villafana, Ann Marie C. (USAFLS) 
Sent: Tuesday, July 08, 2008 5:37 PM 
To: Acosta, Alex (USAFLS); Lee, Dexter (USAFLS) 
Subject: Victim Notification 
Ili Alex and Dexter — Here is the proposed notification that was provided to Epstein's counsel last week. 
c< File: Victim Identification and Notification Final with Goldberger sig revised.wpd >> 
Assuming that they don't sign it tomorrow, I would remove the bottom portion that calls for Epstein's signature 
and incorporate some instructional language along with notice that Jack Goldberger is the contact person for 
any civil litigation. 
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 
200 
EFTA00190544

Villafana, Ann Marie C. (USAFLS) 
From: 
Villafana, Ann Marie C. (USAFLS) <[email protected]> 
Sent: 
Wednesday, July 09, 2008 12:34 PM 
To: 
Lee, Dexter (USAFLS) 
Cc: 
Acosta, Alex (USAFLS) 
Subject: 
RE: Victim Notification 
Hi Dexter — Jack Goldberger's response just arrived"— I am sending it in a separate e-mail. I need to revise the 
letter and make sure Alex and Jeff approve before it goes out, so it won't be ready until later this afternoon. I 
just need to make sure that it goes out before I file my Declaration, since I swear that it has gone out to Attorney 
Edwards. 
Thanks. 
A. Marie Villafana 
Assistant U.S. Attorney 
561 209-1047 
From: Lee, Dexter (USAFLS) 
Sent: Wednesday, July 09, 2008 12:28 PM 
To: Villafana, Ann Marie C. (USAFLS); Acosta, Alex (USAFLS) 
Subject: RE: Victim Notification 
Marie, 
Dal wanted us to hold off sending this out until we get clearance to file our document this afternoon. Will 
that pose any problems? 
Dexter 
From: Villafana, Ann Marie C. (USAFLS) 
Sent: Tuesday, July 08, 2008 5:37 PM 
To: Acosta, Alex (USAFLS); Lee, Dexter (USAFLS) 
Subject: Victim Notification 
Alex and Dexter— Here is the proposed notification that was provided to Epstein's counsel last week. 
<< File: Victim Identification and Notification Final with Goldberger sig revised.wpd >> 
Assuming that they don't sign it tomorrow, I would remove the bottom portion that calls for Epstein's signature 
and incorporate some instructional language along with notice that Jack Goldberger is the contact person for 
any civil litigation. 
A. Marie Villafaila 
201 
EFTA00190545

Assistant U.S. Attorney 
500 S. Australian Ave, Suite 400 
West Palm Beach, FL 33401 
Phone 561 209-1047 
Fax 561 820-8777 
202 
EFTA00190546

Villafana, Ann Marie C. (USAFLS) 
From: 
Villafana, Ann Marie C. (USAFLS) <[email protected]> 
Sent: 
Wednesday, July 09, 2008 12:42 PM 
To: 
Lee, Dexter (USAFLS); Acosta, Alex (USAFLS); Sloman, Jeff (USAFLS) 
Cc: 
Atkinson, Karen (USAFLS) 
Subject: 
Emailing: Villafana Declaration-v2 final.wpd 
Attachments: 
Villafana Declaration-v2 final.wpd 
<<Villafana Declaration-v2 final.wpd>> Hi all -- I think this includes everyone's thoughts. If any changes are needed, please 
let me know. 
The message is ready to be sent with the following file or link attachments: 
Villafana Declaration-v2 final.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 arc handled. 
203 
EFTA00190547

Villafana, Ann Marie C. (USAFLS) 
From: 
Lee, Dexter (USAFLS) <[email protected]> 
Sent: 
Wednesday, July 09, 2008 1:17 PM 
To: 
Herd, Kim (USAEO); Neal, Kristina (USAEO) 
Cc: 
Manning, Katharine (USAEO); Villafana, Ann Marie C. (USAFLS) 
Subject: 
RE: Victim Notification 
Kim, 
The consensus is that there's nothing to talk to Edwards about because the agreement has been signed and 
the federal case is over. We will not be reaching out to Edwards to get an extension. 
As to the draft notice, Epstein's lawyers raised a similar concern. 
Dexter 
From: Herd, Klm (USAEO) 
Sent: Wednesday, July 09, 2008 1:07 PM 
To: Lee, Dexter (USAFLS); Neal, Kristina (USAEO) 
Cc: Manning, Katharine (USAEO) 
Subject: RE: Victim Notification 
Our concern is that the list of individuals contains the names of minors. Have you thought about just listing 
initials? Or not providing the entire list to each victim? 
Also — any word from victim counsel on an extension? 
From: Lee, Dexter (USAFLS) 
Sent: Wednesday, July 09, 2008 12:29 PM 
To: Herd, Kim (USAEO); Neal, Kristina (USAEO) 
Subject: FW: Victim Notification 
From: Villafana, Ann Marie C. (USAFLS) 
Sent: Tuesday, July 08, 2008 5:37 PM 
To: Acosta, Alex (USAFLS); Lee, Dexter (USAFLS) 
Subject: Victim Notification 
Ili Alex and Dexter — Here is the proposed notification that was provided to Epstein's counsel last week. 
<< File: Victim Identification and Notification Final with Goldberger sig revised.wpd >> 
Assuming that they don't sign it tomorrow, I would remove the bottom portion that calls for Epstein's signature 
and incorporate some instructional language along with notice that Jack Goldberger is the contact person for 
any civil litigation. 
204 
EFTA00190548

A. Marie ViIlajafia 
Assistant U.S. Attorney 
500 S. Australian Ave, Suite 400 
West Palm Beach, FL 33401 
Phone 561 209-1047 
Fax 561 820-8777 
205 
EFTA00190549

Villafana, Ann Marie C. (USAFLS) 
From: 
Villafana, Ann Marie C. (USAFLS) <[email protected]> 
Sent: 
Wednesday, July 09, 2008 1:19 PM 
To: 
Lee, Dexter (USAFLS); Herd, Kim (USAEO); Neal, Kristina (USAEO) 
Cc: 
Manning, Katharine (USAEO) 
Subject: 
RE: Victim Notification 
The Notification specifically provided that each victim would receive a copy with the names of all other victims 
redacted. We also have provided the list only by hand delivery to counsel for Mr. Epstein with a cover sheet 
advising them that disclosing the names to anyone could violate federal and/or state law. That cover sheet will 
accompany the victim notification even when it is sent to the victims themselves. 
A. Marie Villafana 
Assistant U.S. Attorney 
561 209-1047 
From: Lee, Dexter (USAFLS) 
Sent: Wednesday, July 09, 2008 1:17 PM 
To: Herd, Kim (USAEO); Neal, Kristina (USAEO) 
Cc: Manning, Katharine (USAEO); Villafana, Ann Marie C. (USAFLS) 
Subject: RE: Victim Notification 
Kim, 
The consensus is that there's nothing to talk to Edwards about because the agreement has been signed and 
the federal case is over. We will not be reaching out to Edwards to get an extension. 
As to the draft notice, Epstein's lawyers raised a similar concern. 
Dexter 
From: Herd, Kim (USAEO) 
Sent: Wednesday, July 09, 2008 1:07 PM 
To: Lee, Dexter (USAFLS); Neal, Kristina (USAEO) 
Cc: Manning, Katharine (USAEO) 
Subject: RE: Victim Notification 
Our concern is that the list of individuals contains the names of minors. Have you thought about just listing 
initials? Or not providing the entire list to each victim? 
Also — any word from victim counsel on an extension? 
206 
EFTA00190550

From: Lee, Dexter (USAFLS) 
Sent: Wednesday, July 09, 2008 12:29 PM 
To: Herd, Kim (USAEO); Neal, Krisdna (USAEO) 
Subject: FW: Victim Notification 
From: VIllafana, Ann Marie C (USAFLS) 
Sent: Tuesday, July 08, 2008 5:37 PM 
To: Acosta, Alex (USAFLS); Lee, Dexter (USAFLS) 
Subject: Victim Notification 
Hi Alex and Dexter— Here is the proposed notification that was provided to Epstein's counsel last week. 
<< File: Victim Identification and Notification Final with Goldberger sig revised.wpd >> 
Assuming that they don't sign it tomorrow, I would remove the bottom portion that calls for Epstein's signature 
and incorporate some instructional language along with notice that Jack Goldberger is the contact person for 
any civil litigation. 
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 
207 
EFTA00190551

Villafana, Ann Marie C. (USAFLS) 
From: 
Herd, Kim (USAEO) <[email protected]> 
Sent: 
Wednesday, July 09, 2008 1:20 PM 
To: 
Villafana, Ann Marie C. (USAFLS); Lee, Dexter (USAFLS); Neal, Kristina (USAEO) 
Cc: 
Manning, Katharine (USAEO) 
Subject: 
RE: Victim Notification 
Great, thanks! 
From: Villafana, Ann Marie C. (USAFLS) 
Sent: Wednesday, July 09, 2008 1:19 PM 
To: Lee, Dexter (USAFLS); Herd, Kim (USAEO); Neal, Kristina (USAEO) 
Cc: Manning, Katharine (USAEO) 
Subject: RE: Victim Notification 
The Notification specifically provided that each victim would receive a copy with the names of all other victims 
redacted. We also have provided the list only by hand delivery to counsel for Mr. Epstein with a cover sheet 
advising them that disclosing the names to anyone could violate federal and/or state law. That cover sheet will 
accompany the victim notification even when it is sent to the victims themselves. 
A. Marie Villelaila 
Assistant U.S. Attorney 
561 209-1047 
From: Lee, Dexter (USAFLS) 
Sent: Wednesday, July 09, 2008 1:17 PM 
To: Herd, Kim (USAEO); Neal, Kristina (USAEO) 
Cc: Manning, Katharine (USAEO); Villafana, Ann Marie C. (USAFLS) 
Subject: RE: Victim Notification 
Kim, 
The consensus is that there's nothing to talk to Edwards about because the agreement has been signed and 
the federal case is over. We will not be reaching out to Edwards to get an extension. 
As to the draft notice, Epstein's lawyers raised a similar concern. 
Dexter 
From: Herd, Kim (USAEO) 
Sent: Wednesday, July 09, 2008 1:07 PM 
To: Lee, Dexter (USAFLS); Neal, Kristina (USAEO) 
Cc: Manning, Katharine (USAEO) 
Subject: RE: Victim Notification 
208 
EFTA00190552

Our concern is that the list of individuals contains the names of minors. Have you thought about just listing 
initials? Or not providing the entire list to each victim? 
Also — any word from victim counsel on an extension? 
From: Lee, Dexter (USAFLS) 
Sent: Wednesday, July 09, 2008 12:29 PM 
To: Herd, Kim (USAEO); Neal, Kristina (USAEO) 
Subject: FW: Victim Notification 
From: Villafana, Ann Marie C. (USAFLS) 
Sent: Tuesday, July 08, 2008 5:37 PM 
To: Acosta, Alex (USAFLS); Lee, Dexter (USAFLS) 
Subject: Victim Notification 
Hi Alex and Dexter - Here is the proposed notification that was provided to Epstein's counsel last week. 
<< File: Victim Identification and Notification Final with Goldberger sig revised.wpd >> 
Assuming that they don't sign it tomorrow, I would remove the bottom portion that calls for Epstein's signature 
and incorporate some instructional language along with notice that Jack Goldberger is the contact person for 
any civil litigation. 
A. Marie Villafatla 
Assistant U.S. Attorney 
500 S. Australian Ave, Suite 400 
West Palm Beach, FL 33401 
Phone 561 209-1047 
Fax 561 820-8777 
209 
EFTA00190553

Villafana, Ann Marie C. (USAFLS) 
From: 
Villafana, Ann Marie C. (USAFLS) <[email protected]> 
Sent: 
Wednesday, July 09, 2008 2:06 PM 
To: 
Lee, Dexter (USAFLS) 
Subject: 
RE: Government's Motion to Seal 
Dexter— You want to seal my declaration as well, right? Please let me know and I will change accordingly. 
Thanks. 
A. Marie Vilkialia 
Assistant U.S. Attorney 
561 209-1047 
From: Lee, Dexter (USAFLS) 
Sent: Wednesday, July 09, 2008 1:47 PM 
To: Villafana, Ann Marie C. (USAFLS) 
Subject: Government's Motion to Seal 
Marie, 
In preparation for this afternoon's filing, I have prepared a motion to seal, which is attached. I did not 
include Epstein's name and made general assertions regarding the confidentiality of the negotiations. Please 
have someone sign both the motion to seal, and the government's response, for me. We then need to 
prepare a sealed document tracking sheet, to accompany the motion. 
An original and one copy of the sealed document should be placed in two separate envelopes, with the case 
number written on the outside. An original and one copy of the motion to seal should be filed with the Clerk. 
Thanks. 
Dexter 
« File: victim_Mot_seal.wpd » 
210 
EFTA00190554

Villafana, Ann Marie C. (USAFLS) 
From: 
Lee, Dexter (USAFLS) <[email protected]> 
Sent: 
Wednesday, July 09, 2008 2:13 PM 
To: 
Villafana, Ann Marie C. (USAFLS) 
Subject: 
RE: Government's Motion to Seal 
Marie, 
Yes, both the response, your declaration, and the attachments to your declaration, are to be sealed. 
Dexter 
From: Villafana, Ann Marie C. (USAFLS) 
Sent: Wednesday, July 09, 2008 2:06 PM 
To: Lee, Dexter (USAFLS) 
Subject: RE: Government's Motion to Seal 
Hi Dexter — You want to seal my declaration as well, right? Please let me know and I will change accordingly. 
Thanks. 
A. Marie Vilfgfairn
Assistant U.S. Attorney 
561 209-1047 
From: Lee, Dexter (USAFLS) 
Sent: Wednesday, July 09, 2008 1:47 PM 
To: Villafana, Ann Marie C. (USAFLS) 
Subject: Government's Motion to Seal 
Marie, 
In preparation for this afternoon's filing, I have prepared a motion to seal, which is attached. I did not 
include Epstein's name and made general assertions regarding the confidentiality of the negotiations. Please 
have someone sign both the motion to seal, and the government's response, for me. We then need to 
prepare a sealed document tracking sheet, to accompany the motion. 
An original and one copy of the sealed document should be placed in two separate envelopes, with the case 
number written on the outside. An original and one copy of the motion to seal should be filed with the Clerk. 
Thanks. 
Dexter 
EFTA00190555

« File: victim_Mot_seal.wpd » 
213 
EFTA00190556

Villafana, Ann Marie C. (USAFLS) 
From: 
Villafana, Ann Marie C. (USAFLS) <[email protected]> 
Sent: 
Wednesday, July 09, 2008 3:52 PM 
To: 
Lee, Dexter (USAFLS) 
Subject: 
RE: Governments Motion to Seal 
Everything is out. Copies will be sent to you via inter-office. Thank you, Dexter, as usual, you came to the 
rescue! 
Can I ask one more favor? Will you e-file a notice of appearance? That way notices of hearings will come to 
both of us. I have to run to an appointment, but you can get me on the cell phone. 
Thanks. 
A. Marie Villafafla 
Assistant U.S. Attorney 
561 209-1047 
From: Lee, Dexter (USAFLS) 
Sent: Wednesday, July 09, 2008 2:13 PM 
To: Villafana, Ann Marie C. (USAFLS) 
Subject: RE: Governments Motion to Seal 
Marie, 
Yes, both the response, your declaration, and the attachments to your declaration, are to be sealed. 
Dexter 
From: Villafana, Ann Marie C. (USAFLS) 
Sent: Wednesday, July 09, 2008 2:06 PM 
To: Lee, Dexter (USAFLS) 
Subject: RE: Governments Motion to Seal 
Hi Dexter — You want to seal my declaration as well, right? Please let me know and I will change accordingly. 
Thanks. 
A. Marie Villafana 
Assistant U.S. Attorney 
561 209-1047 
218 
EFTA00190557