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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

EFTA00193954

651 pages
Pages 421–440 / 651
Page 421 / 651
Villafana, Ann Marie C. (USAFLS) 
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. 
Victim 
lineation and Nc 
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 Villafana 
Assistant U.S. Attorney 
500 S. Australian Ave, Suite 400 
West Palm Beach, FL 33401 
Phone 561 209-1047 
Fax 561 820-8777 
Tracking: 
692 
EFTA00194374
Page 422 / 651
Villafana, Ann Marie C. (USAFLS) 
From: 
Villafana, Ann Marie C. (USAFLS) 
Sent: 
Tuesday, July 08, 2008 5:43 PM 
To: 
Lee, Dexter (USAFLS); Acosta, Alex (USAFLS); Sloman, Jeff (USAFLS) 
Subject: 
FW: Epstein: Victim Notification Letter 
Alex, Dexter, and Jeff — in my draft declaration I reference the original victim notification letter that was objected to by 
the defense. Here it is as it was sent to Jay Lefkowitz on November 28, 2007. 
Thanks. 
From: Villafana, Ann Marie C. (USAFLS) 
Sent: Wednesday, November 28, 2007 4:47 PM 
To: Jay Lefkowitz 
Cc: Sloman, Jeff (USAFLS); Acosta, Alex (USAFLS) 
Subject: Epstein: Victim Notification Letter 
Dear Jay: 
Jeff asked that I forward the victim notification letter to you. It is attached. 
Thank you. 
Victim 
lotification Ltr.pd 
A. Marie Vil!aloha 
Assistant U.S. Attorney 
500 S. Australian Ave, Suite 400 
West Palm Beach, FL 33401 
Phone 561 209-1047 
Fax 561 820-8777 
641 
EFTA00194375
Page 423 / 651
Villafana, Ann Marie C. (USAFLS) 
From: 
Acosta, Alex (USAFLS) 
Sent: 
Tuesday, July 08, 2008 6:17 PM 
To: 
Lee, Dexter (USAFLS); Sloman, Jeff (USAFLS) 
Cc: 
Villafana, Ann Marie C. (USAFLS); Jacobus, Wendy (USAFLS) 
Subject: 
RE: Draft Response in Jane Doe 
Here is a second draft, with small rewrites 
I reduced the discussion of negotiations. The agreement has a confidentiality clause. I note this, because if we disclose 
too much, then we will be sued by the other side for breach of that clause. 
In other words, we need to disclose and discuss without going too far — unless ordered to do so by the court. 
victim_resp.wpd 
From: Lee, Dexter (USAFLS) 
Sent: Tuesday, July 08, 2008 5:29 PM 
To: Acosta, Alex (USAFLS); Sloman, Jeff (USAFLS) 
Cc: Villafana, Ann Marie C. (USAFLS); Jacobus, Wendy (USAFLS) 
Subject: Draft Response in Jane Doe 
Alex and Jeff, 
Here is a draft response to the emergency petition filed by Jane Doe in the Epstein case. Our first argument is that Doe 
had no rights under 18 U.S.C. 3177(a)(5) since that provision does not apply where there are no "court proceedings' in 
federal court, and none were contemplated, as long as Epstein complied with the non-prosecution agreement. 
The 
second argument is that the government used its best efforts to comply, since the A/G guidelines permitted us to not 
notify victims of the proposed plea negotiations if the proposed plea involved confidential information or conditions, or 
there is another need for confidentiality. Article IV, Section B(2)(C)(3). 
The government exercised Its discretion and 
determined that keeping the terms confidential was necessary in order to obtain the best agreement. 
In particular, 
the government wanted Epstein to make a significant concession on one of the elements in 18 U.S.C. 2255. 
I am speaking with Kim Herd at EOUSA regarding the government's position. In particular, the first argument will have 
to be cleared by DOJ before I can assert it. Please feel free to make any comments. Thanks. 
Dexter 
« File: victim_resp.wpd » 
640 
EFTA00194376
Page 424 / 651
Villafana, Ann Marie C. (USAFLS) 
From: 
Lee, Dexter (USAFLS) 
Sent: 
Tuesday, July 08, 2008 7:42 PM 
To: 
Villafana, Ann Marie C. (USAFLS) 
Subject: 
Revised Declaration & Response 
Marie, 
Alex has reviewed my draft response and your final declaration. He wanted to leave out specific details regarding the 
plea negotiations, since plea discussions are normally held in confidence. Also, he wanted to leave out Epstein's 
attorneys' undue haste in hurling accusations of misconduct at the prosecution, since that does not address the claims 
presented by petitioner. 
I have revised the response and your declaration accordingly. Please review both to ensure they are accurate. Thanks. 
Dexter 
victim_resp_USA 
Villafana 
rev.wpd 
ieclaration-v2.wp 
639 
EFTA00194377
Page 425 / 651
Villafana, Ann Marie C. (USAFLS) 
From: 
Villafana, Ann Marie C. (USAFLS) 
Sent: 
Tuesday, July 08, 2008 8:04 PM 
To: 
Lee, Dexter (USAFLS); Acosta, Alex (USAFLS); Sloman, Jeff (USAFLS) 
Subject: 
Re: Revised Declaration & Response 
Hi Dexter and Alex. Changes look good. I have to correct one paragraph tomorrow 
morning and it should be good to go as soon as we send out the notifications. 
Thank you. 
 
 Original Message  
From: Lee, Dexter (USAFLS) 
To: Villafana, Ann Marie C. (USAFLS) 
Sent: Tue Jul 08 19:41:56 2008 
Subject: Revised Declaration & Response 
Marie, 
Alex has reviewed my draft response and your final declaration. 
He wanted to 
leave out specific details regarding the plea negotiations, since plea 
discussions are normally held in confidence. 
Also, he wanted to leave out 
Epstein's attorneys' undue haste in hurling accusations of misconduct at the 
prosecution, since that does not address the claims presented by petitioner. 
I have revised the response and your declaration accordingly. 
both to ensure they are accurate. 
Thanks. 
Dexter 
«victim_resp_USArev.wpd» «Villafana Declaration-v2.wpd» 
Please review 
638 
EFTA00194378
Page 426 / 651
Recipient 
Read 
Lee. Dexter (USAFLS) 
Read: 7/9/2008 9:18 AM 
Acosta. Alex (USAFLS) 
Read: 7/9/2008 9:33 AM 
Atkinson. Karen (USAFLS) 
Read: 7/9/2008 9:20 AM 
Stomas). Jeff (USAFLS) 
Read: 7/9/2008 9:13 AM 
Kuyrkendall. E N. (FBI) 
Richards. Jason R. (FBI) 
637 
EFTA00194379
Page 427 / 651
Villafana, Ann Marie C. (USAFLS) 
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 
Attachments: 
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 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 
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receiving certain types of file attachments. Check your e-mail security settings 
to determine how attachments are handled. 
Tracking: 
636 
EFTA00194380
Page 428 / 651
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. 
635 
EFTA00194381
Page 429 / 651
Villafana, Ann Marie C. (USAFLS) 
From: 
Villafana, Ann Marie C. (USAFLS) 
Sent: 
Wednesday, July 09, 2008 9:19 AM 
To: 
Richards, Jason R. (FBI) 
Subject: 
RE: Emailing: victim_resp_USArev corrected.wpd 
Thank you. 
A. Marie Villafaha 
Assistant U.S. Attorney 
561 209-1047 
 
Original Message 
From: Richards, Jason R. (FBI) 
Sent: Wednesday, July 09, 2008 9:14 AM 
To: Villafana, Ann Marie C. (USAFLS) 
Subject: Re: Emailing: victim_resp_USArev corrected.wpd 
Hi Marie, 
We interviewed TM on 4/24/2007. 
 
 Original Message  
From: Villafana, Ann Marie C. (USAFLS) <[email protected]> 
To: Lee, Dexter (USAFLS); Acosta, Alex (USAFLS) 
Cc: Atkinson, Karen (USAFLS); Sloman, Jeff (USAFLS) 
Sent: Wed Jul 09 09:10:39 2008 
Subject: Emailing: victim_resp_USArev corrected.wpd 
«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 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. 
634 
EFTA00194382
Page 430 / 651
Villafana, Ann Marie C. (USAFLS) 
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. 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. 
633 
EFTA00194383
Page 431 / 651
Villafana, Ann Marie C. (USAFLS) 
From: 
Villafana, Ann Marie C. (USAFLS) 
Sent: 
Wednesday, July 09, 2008 9:22 AM 
To: 
Acosta, Alex (USAFLS); Lee, Dexter (USAFLS) 
Cc: 
Atkinson, Karen (USAFLS); Sloman, Jeff (USAFLS) 
Subject: 
Emaiting: Villafana Declaration-v2 final.wpd 
Attachments: 
Villafana Declaration-v2 final.wpd 
Attached is the revised declaration. Please let me know if any other changes are 
required. I am off to Court but should be back by 11:30. 
Thank you. 
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 are handled. 
632 
EFTA00194384
Page 432 / 651
Recipient 
Read 
Lee, Dexter (USAFLS) 
Read: 7/9/2008 9:30 AM 
Acosta, Alex (USAFLS) 
Atkinson, Karen (USAFLS) 
Read: 7/912008 9:30 AM 
Sloman, Jeff (USAFLS) 
Read: 7/9/2008 9:25 AM 
Jacobus, Wendy (USAFLS) 
Read: 7/9120089:53 AM 
631 
EFTA00194385
Page 433 / 651
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. 
Tracking: 
630 
EFTA00194386
Page 434 / 651
Villafana, Ann Marie C. (USAFLS) 
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 Villafaha 
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. So I 
notified Edwards to inform his three clients, and PBPD tried to notify six 
629 
EFTA00194387
Page 435 / 651
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. 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. 
628 
EFTA00194388
Page 436 / 651
Villafana, Ann Marie C. (USAFLS) 
From: 
Stamen, Jeff (USAFLS) 
Sent: 
Wednesday, July 09,2008 9:57 AM 
To: 
Lee, Dexter (USAFLS); Villatana, 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 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 Villafana 
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) 
627 
EFTA00194389
Page 437 / 651
Villafana, Ann Marie C. (USAFLS) 
From: 
Acosta, Alex (USAFLS) 
Sent: 
Wednesday, July 09, 2008 10:38 AM 
To: 
Villafana, Ann Marie C. (USAFLS); Lee, Dexter (USAFLS) 
Cc: 
Atkinson, Karen (USAFLS); Sloman, Jeff (USAFLS) 
Subject: 
RE: Emailing: Villafana Declaration-v2 final.wpd 
A few thoughts: 
1. bottom of page 5/ top of page 6 -- were we talk about the "Throughout the 
negotiations, ... recompense." Should we cite to Decl para 8? 
2. Next para -- cite to para 8 should be cite to para 10. 
3. Right before the next para starting with On Friday, should we discuss the 
content of para 9, where the same attorney that now complains had an opportunity 
to communicate with our office and didn't. What I find particularly compelling 
about that point is that Edwards had, or should have had, knowledge of this 
agreement because his clients were told of the agreement previously. Cite para 
8. In fact, maybe this should be a separate argument III -- he, or his clients, 
had prior knowledge and didn't complain until now. Thoughts? 
4. In para 2 of the declaration, do we need the last sentence hitting the State 
Attorney? 
 
Original Message 
From: Villafana, Ann Marie C. (USAFLS) 
Sent: Wednesday, July 09, 2008 9:22 AM 
To: Acosta, Alex (USAFLS); Lee, Dexter (USAFLS) 
Cc: Atkinson, Karen (USAFLS); Sloman, Jeff (USAFLS) 
Subject: Emailing: Villafana Declaration-v2 final.wpd 
Attached is the revised declaration. Please let me know if any other changes are 
required. I am off to Court but should be back by 11:30. 
Thank you. 
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 are handled. 
626 
EFTA00194390
Page 438 / 651
Recipient 
Read 
&omen, Jeff (USAFLS) 
Read: 7/9/2008 11:49 AM 
Lee, Dexter (USAFLS) 
Read: 7/9/2008 11:49 AM 
Acosta, Alex (USAFLS) 
Read: 7/9/2008 11:55 AM 
Atkinson, Karen (USAFLS) 
Jacobus, Wendy (USAFLS) 
Read: 7/9/200812:29 PM 
625 
EFTA00194391
Page 439 / 651
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 Villafafia 
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. 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. 
Tracking: 
624 
EFTA00194392
Page 440 / 651
Villafana, Ann Marie C. (USAFLS) 
From: 
Villafana, Ann Marie C. (USAFLS) 
Sent: 
Wednesday, July OS, 200811:49 AM 
To: 
Sloman, Jeff (USAFLS); Lee, Dexter (USAFLS); Acosta, Alex (USAFLS) 
Cc: 
Atkinson, Karen (USAFLS); Jacobus, Wendy (USAFLS) 
Subject: 
RE: Emailing: victim_resp_USArev corrected.wpd 
Attachments: 
image001.png 
Here is the language from the Agreement. I will leave it to you to interpret whether disclosing part of the substance of the 
Agreement requires sealing or othenvise. 
The parties anticipate that this agreement will not be made p 
public record. If the United States receives a Freedom of In 
Act request or any compulsory process commanding the dis 
the agreement, it will provide notice to Epstein before mi 
disclosure. 
A. Marie Villafafia 
Assistant U.S. Attorney 
561 209-1047 
 
Original Message---
From: Sloman, Jeff (USAFLS) 
Sent: Wednesday, July 09, 2008 9:57 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 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 
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