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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

EFTA00225378

294 pages
Pages 161–180 / 294
Page 161 / 294
best to get counseling for all of our needy victims, but I just can't stress enough how 
important it is for these girls to have a resolution in this case. The `please be patient' 
answer is really wearing thin, especially when Epstein's group is still on the attack while 
we are forced to wait on the sidelines. Your guidance is needed." (Exhibit C-2) I followed 
up on March 19 and 22, 2008 to let everyone know that Epstein was subpoenaing victims 
and was using particularly aggressive means of service — having the Sheriff's Office serve 
the subpoenas at the places of work, calling them into the Dean's Office at their colleges, 
etc. I explained that Epstein was issuing these subpoenas in the context of the state criminal 
case — even though these victims were not named victims in the state criminal case, and I 
asked FAUSA Sloman to try to have Epstein's attorneys stop this contact as it was 
inconsistent with Epstein's alleged interest in resolving the matter (Exhibit C-3). I do not 
believe that anyone contacted Epstein's attorneys about this. I worked to secure pro bono 
counsel for as many victims as possible so that Epstein would only be able to contact them 
through counsel (id.). My concerns about the victims' mental health were brought to the 
attention of management in emails and telephone calls throughout the entire period from 
2006 through 2008 and probably into 2009. 
o. Even after Epstein enter his guilty plea and was sentenced, there were a number of material 
breaches. Every time I tried to enforce the agreement and enforce the Office's authority to 
proceed to indictment, the Office would accept Epstein's excuse that he received "bad 
advice" from his attorneys and then he would "cure" the breach. With regard to the work 
release, either Roy Black or Jay Lefkowitz informed me that USA Acosta had agreed, after 
the NPA was signed, that Epstein would be allowed to participate in work release like any 
other state prisoner — in direct contravention of discussions and communications that Karen 
Atkinson and I had with the defense. I was not allowed to invoke this as a breach. 
2. Identify any occasion during which you were or felt pressured, intimidated, 
threatened, coerced, or in any other manner inappropriately influenced to 
take a position or action in the Epstein case with which you disagreed or which 
caused you concern, and the individuals, if any, with whom you discussed such 
concerns. 
Throughout this memo, I have listed a number of disagreements. In broad categories, I 
disagreed with: (1) meeting with defense counsel before the investigation was completed and 
disclosing to them our charging strategy; (2) members of the Executive Division engaging in plea 
and strategy discussions outside the presence of the prosecution team and encouraging defense 
counsel to avoid the prosecution team; (3) entering into pre-indictment plea negotiations; (4) 
agreeing to delay the litigation regarding Epstein's computer equipment while pursuing plea 
negotiations; (5) entering into an agreement deferring federal prosecution; (6) entering into any 
agreement that required a sentence of only 18 months' (or even 24 months') imprisonment; (7) 
agreeing to a length of a sentence and then trying to find a charge with a statutory max to match; 
(8) reaching an agreement without conferring with the victims, the agents, or even the prosecution 
team; (9) refusing to hear from/meet with the victims even after meeting repeatedly with Epstein's 
representatives; (10) during the drafting of the NPA, allowing Epstein's attorneys to complain 
directing to the First Assistant and U.S. Attorney when they were dissatisfied with answers from 
the line AUSA and West Palm Beach supervisors; (11) repeatedly overruling my efforts to hold 
Epstein to the original terms, including reducing the term of imprisonment from 24 months down 
to 18; (12) dismissing my repeated warnings that the attorneys were not negotiating in good faith 
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and were delaying for strategic reasons; (13) repeatedly ceding our discretion to the defense, for 
example, agreeing that they could review and comment on victim notification letters and decide 
whether or not we could provide notice; (14) even after the NPA was signed, continuing to water 
it down, with the Addendum, the 12/19/07 Acosta letter, and then later offering Epstein the option 
of not having to provide the attorney-representative for the victims; (15) refusing to allow the 
agents and Ito notify the victims about the terms of the NPA and about the change of plea; (16) 
allowing Epstein to continue to enjoy the benefits of the NPA even after he failed to promptly 
perform its terms and filed specious delays in order to try to negotiate better terms or win a battle 
of attrition; (17) refusing to defend me from the false allegations of prosecutorial misconduct; (18) 
refusing to step in and protect the victims from harassment from Epstein's attorneys when Epstein 
was "appealing" to DC; and (19) allowing Epstein to repeatedly breach the NPA and then claim 
that he just got bad advice from his lawyers and "cure" the breaches. 
At various times during the investigation, negotiations, etc., I spoke with a number of 
people about my disagreements with the Office, including my supervisor, Karen Atkinson, my co-
counsel, John McMillan, Special Agents Kuyrkendall and Richards, AUSAs Lynn Kirkpatrick, 
Susan Roe, E.J. Yera, and DOJ Trial Attorneys Tammie Gregg and Myesha Braden. On several 
occasions, I drafted emails about re-assigning the case because the Office's handling of the matter 
was so contrary to my methods. I shared at least one of these with Ms. Atkinson (Exhibit C-4). 
She counseled against sending it. The agents asked me not to leave the case because they believed 
that, if I left, the case would simply disappear. I couldn't disagree with them. 
Criminal Chief Menchel's response to my email in July 2007 was, in my mind, 
inappropriate and meant to intimidate. It is, quite frankly, unheard of, for a Criminal Chief to 
engage in plea negotiations without the line AUSA's knowledge, much less blessing. And the 
offer that was made was inexplicable. To this day, I do not understand the NPA — 24 months/18 
months — it is a completely random amount of time. Allowing a federal defendant to plead guilty 
to state charges also is completely unheard of. No one has ever explained to me where the idea 
originated from. For Mr. Menchel to suggest that my judgment was questionable or that I was 
unable to handle "major" cases was obviously meant to "put me in my place." In my July 13, 2007 
response to Mr. Menchel, I wrote: 
With respect to your questions regarding my judgment, I will simply say that 
disagreements about strategy and raising concerns about the forgotten voices of the 
victims in this case should not be classified as a lapse in judgment. This Office 
should seek to foster spirited debate about the law and the use of prosecutorial 
discretion. I know of other instances where disagreements about the application of 
the law to different defendants and defense attorneys has resulted in a call for the 
resignation of the AUSA who dared to challenge the Executive Office's 
conclusions. I find that very disheartening. However, my first and only concern in 
this case (and my other child exploitation cases) is the victims. If our personality 
differences threaten their access to justice, then please put someone on the case 
whom you trust more, and who will also protect their rights. 
After my response to Mr. Menchel, I know that he spoke with Anne Ruth Schultz, who 
was Chief of Appeals at the time, about moving me to the Appellate Section. 
The results of the disagreements catalogued above were communicated to me (orally or via 
e-mail) as decisions of the Executive Division. They sometimes followed extensive debate. They 
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sometimes followed no debate. I was sometimes heard on the issue; other times I knew nothing 
about it until I received the directive. There were times that I learned of communications between 
defense counsel and the Executive Division where concessions were made only after the decision 
was made. Many of these decisions were incorrect, in my opinion, but I did not believe that they 
were illegal. As a line AUSA, I was duty bound to follow the directives of the U.S. Attorney, 
which I did. I do not know that following a direct order from the Executive Division would qualify 
as coercion — even if it follows very strong objections. 
I felt strongly that we should have conferred with the victims before entering into the NPA 
and that we should have informed them of the change of plea and sentencing. I felt strongly that 
Epstein's attorneys were given unprecedented access to members of the Executive Division, and 
that the victims were given no access -- I could not even talk with them about plea negotiations or 
notify them about the plea hearing. At one point, my assistant and I had letters and envelopes 
ready to be stuffed and put through the franking machine and we received notice from Miami that 
they could not go out. While I felt that conferring was the right thing to do, as noted above, the 
AG Guidelines vest discretion in the U.S. Attorney, so I could not say that USA Acosta's decision 
was illegal. I also believed that, because the resolution of the federal case rested on Epstein's state 
guilty plea, the federal victims were entitled to notice of the state hearing. But I could not say that 
USA Acosta's decision that the CVRA was limited to notice of federal proceedings was illegal. 
I think that pressure was brought in more subtle ways. For example, I believe that one of 
the reasons why USA Acosta did not take an aggressive stance against the prosecutorial 
misconduct claims against me was because he disliked my insistence on pushing the case forward. 
After the NPA was signed, USA Acosta recommended that I transfer to the Civil Division. 
I agreed to meet with them and talk about their work. Despite USA Acosta's recommendation, I 
decided not to follow his recommendation, and I stayed in the criminal division. 
Please advise if further information is needed. 
Sincerely, 
dal Marta rilliskrages. 
A. Marie Villafaila 
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BAKER,DONELSON 
100 116111 STREET • BALTIMORE, MARYLAND 21202 • 410.685.1120. bakerdonelson.com 
JONATHAN BRAN 
Direct Dial: 410.862.1073 
E-Mail [email protected] 
May 10, 2019 
VIA EMAIL °N4" 
Laura Ingersoll 
Counsel, Office of Professional Responsibility 
U.S. Department of Justice 
950 Pennsylvania Avenue, N.W. — Room 3266 
Washington, D.C. 20530 
Re: OPR Investigation Relating to Jeffrey Epstein Federal Criminal Investigation 
Dear Ms. Ingersoll: 
Attached please find the written response of Assistant United States Attorney A. Marie 
Villafafia to the letter of Jeffrey R. Ragsdale, dated April 2, 2019, regarding the criminal 
investigation of Jeffrey Epstein. AUSA Villafafia separately has sent you encrypted disks 
containing the exhibits referenced in her written response, and has emailed other exhibits that 
were not included on the disks. 
Mr. Ragsdale's letter also requested background information concerning AUSA 
Villafafia's professional background and experience. The remainder of this letter provides that 
information. 
A native of Minnesota, A. Marie Villafafia graduated from Cornell University and the 
University of California, Berkeley, School of Law. She was admitted to the California Bar in 
1995, to the Minnesota Bar in 1997, and to the Florida Bar in 2005. She is currently an active 
member of the Florida Bar, and maintains inactive status in California and Minnesota. 
Ms. Villafafia began her legal career as a judicial law clerk to the Honorable David F. 
Levi, United States District Judge for the Eastern District of California, from 1993 to 1994. Ms. 
Villafafia then worked in private practice for seven years, including as a litigation associate at 
Morrison & Foerster in San Francisco and a trial associate with Dorsey & Whitney, LLP, in 
Minneapolis, Minnesota, and London, England. Ms. Villafafia remained in civil practice, 
specializing in intellectual property litigation until 2001, when she was hired by the United 
States Attorney's Office in Miami. 
While she enjoyed civil practice, Ms. Villafafia for many years had wanted to be an 
Assistant United States Attorney. Two early career mentors — Judge Levi and Portia Moore from 
Morrison & Foerster — had worked at U.S. Attorney's Offices and they, like many former 
4822.5464-M66vI 
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ALABAMA • FLORIDA • GEORGiA • LOUISIANA • MARYLAND • M1SS!SSIPPI• SOUTH CAROLINA • TENNESSEE • TEXAS • VIRGINIA • WASHINGTON, D.C. 
EFTA00225541
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Laura Ingersoll 
May 10, 2019 
Page 2 of 7 
AUSAs, described the job as the best of their careers. Ms. Villafafia also wanted to serve her 
community. She was in the first generation of her family to graduate from college. She is the 
only member of her family to get an advanced degree. Personal experiences left her deeply 
committed to wanting to create safer communities for victims of crime. After several years of 
waiting for an opening at the USAO in Minneapolis, when Ms. Villafafia's brother moved to the 
West Palm Beach area, she applied for a position at the U.S. Attorney's Office for the Southern 
District of Florida. 
On September 10, 2001, Ms. Villafafia began serving as an Assistant United States 
Attorney in the Southern District of Florida. She did a rotation through the Appellate Section 
and then joined the Major Crimes Section from late September 2001 until January 2004. While 
in that unit, she handled reactive cases and short-term investigations and cases, including 
narcotics, firearms, child exploitation offenses, immigration matters, credit card fraud, bank 
robbery, violent offenses, and supervised release violations. While serving in that unit, she was 
also selected as one of the Southern District of Florida's first Project Safe Neighborhood 
prosecutors. 
In January 2004, AUSA Villafafia transferred to the West Palm Beach Office. In 2006, 
the U.S. Department of Justice initiated Project Safe Childhood, and, in recognition of her 
expertise in child exploitation matters, AUSA Villafalia became the Southern District of 
Florida's first Project Safe Childhood coordinator. From 2004 through early 2009, AUSA 
Villafaha handled the bulk of the child exploitation cases in West Palm Beach, as well as other 
cases involving violent crime, gangs, narcotics, firearms, immigration, and white collar matters. 
In March 2009, AUSA Villafafia was selected as the first Chief of the Special 
Prosecutions North Section, which was a new section in the Fort Lauderdale Office that would 
work on Project Safe Childhood and Project Safe Neighborhood prosecutions. In late 2010, 
when a new U.S. Attorney was sworn in, AUSA Villafafia asked that she be transferred back to 
the West Palm Beach Office, because the daily commute to Fort Lauderdale was both taxing and 
time consuming and it was exacerbating a then undiscovered medical condition from which she 
was suffering. 
Since 2010, AUSA Villafafia has been assigned to the West Palm Beach Office and is 
now the liaison to the Greater Palm Beach County Health Care Fraud Task Force. Since 
returning to West Palm Beach, AUSA Villafafia's caseload has shifted more towards economic 
crimes, but she has worked on a wide array of cases including insurance fraud, varying types of 
health care fraud, human trafficking, drug diversion, and bank fraud. 
According to CourtLink, AUSA Villafafia was counsel of record in 445 criminal matters 
in the Southern District of Florida. This number does not include all of the 2255 petition and 
appeals AUSA Villafafia has handled, but does include search warrants and pen registers that she 
sought. Of these approximately 445 cases, a number of matters are noteworthy: 
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Laura Ingersoll 
May 10, 2019 
Page 3 of 7 
As the Southern District of Florida's first Project Safe Childhood Coordinator, she 
personally handled dozens of child exploitation cases. 
It appears from a review of Westlaw and Courtlink research, that AUSA Villafafia was 
the first prosecutor in the Southern District of Florida to convince the court to recognize the 
rights of a victim's family to appear and speak to the Court about the proper sentence: 
• 
U.S.'. William Charles O'Neil, 04-Cr-80040 
The victim's mother remains in touch with AUSA Villafafia to this day. 
From Westlaw and Courtlink research, it appears that AUSA Villafafia was the first 
prosecutor in the Southern District of Florida to advocate for the appointment of a guardian ad 
litem for minor victims in connection with a criminal prosecution. 
• 
U.S.'. Jimmy Oliver, 06-Cr-80023 
• 
U.S.'. Marion Yarbrough, 07-Cr-80099 
From Westlaw and Courtlink research, it appears that AUSA Villafafia was the first 
prosecutor in the Southern District of Florida to charge enticement of a minor based upon use of 
a cellular phone. 
U.S.'. McDaniel, 06-Cr-80058 
From Westlaw and Courtlink research, it appears that AUSA Villafafia was the first 
prosecutor in the Southern District of Florida to charge a violation of the child pornography 
advertising statute. 
U.S.'. Frank Grasso, 05-Cr-80111 
From Westlaw and Courtlink research, it appears that AUSA Villafafia was the first 
prosecutor in the Southern District of Florida to charge failure to register as a sex offender. 
AUSA Villafafia trained other prosecutors and agents on how to investigate and prosecute those 
cases. 
U.S.'. Alfonso Diaz Cardenas, 07-Cr-80108 
AUSA Villafafia assisted in the drafting of Eleventh Circuit Pattern [Criminal] Jury 
Instructions related to child exploitation offenses, including clarifying that, in cases of actual 
contact with a child, there is no requirement of proving the defendant's knowledge of age. 
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Laura Ingersoll 
May 10, 2019 
Page 4 of 7 
According to inquiries with DOJ's Health Care Fraud Section, Ms. Villafaila was the first 
prosecutor in the nation to charge sex trafficking in connection with a health care fraud case. 
U.S.'.
0 
 Kenneth Chatman, 17-Cr-80013 (subject of an American Greed episode, 
CNBC, Season 12, Episode 10 "Florida Rehab Gone 
" July 2, 2018) 
Chatman was the first of several cases to target fraud in connection with substance abuse 
treatment. To date, AUSA Villafafia has convicted 30 individuals, including six licensed 
medical or mental health professionals, for related offenses: 
II 
U.S. . Kenneth Chatman, et al., 17-Cr-80013 
O 
U.S. . Barry Gregory, 17-Cr-80033 
I
fl 
U.S. . Richard Botero, et al., 17-Cr-80070 
O 
U.S. . Tovah Lynn Jasperson, et al., 17-Cr-80194 
U 
U.S.'. Jeffrey Williams, 17-Cr-80195 
U 
U.S. . Albert Jones Saye, l7-Cr-80229 
O 
U.S. . John Skeffington, et al., 18-Cr-80018 
O 
U.S. . Anthony Jackson, 18-Cr-80040 
U 
U.S. . Lanny Fried, 18-Cr-80100 
O 
U.S.'. 13osco Vega, 18-Cr-80101 
fl 
U.S.'. Mark Hollander, 18-Cr-80102 
O 
U.S.'. Larry Weisberg, 18-Cr-80108 
U 
U.S. I. Kenneth MI
-Kolb, 18-Cr-80121 
I 
O 
U.S. . Arman Abovyan, et al., 18-Cr-80122 
fl 
U.S.'. Hamilton Wayne, et al., 18-Cr-80165 
O 
U.S.'. Ethan Wayne, 18-Cr-80168 
The Chatman case resulted in AUSA Villafafia being awarded the 2018 Council of the 
Inspectors General on Integrity and Efficiency Award and the 2017 National Healthcare Anti-
Fraud Association Investigation of the Year Award. This series of investigations has been 
nominated for this year's FBI Director's Award and the Florida Insurance Fraud Education 
Committee's Award. 
At the request of DOJ's Office of Legislative Affairs, AUSA Villafafia has provided 
advice on Congress' recent legislation on fraud involving sober homes and treatment facilities. 
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Laura Ingersoll 
May 10, 2019 
Page 5 of 7 
AUSA Villafafia's prosecution of a member of Guatemala's Kaibil military branch led to 
war crimes investigations and prosecutions of numerous high-ranking military and political 
figures in Guatemalan and international courts, and resulted in her receipt of the Justice 
Department's 2011 National Crime Victims' Rights Service Award. The case was the subject of 
an award-wining documentary entitled "Finding Oscar" and numerous television shows and 
podcasts. 
U.S.'. Gilberto Jordan, 10-Cr-80069 
AUSA Villafafia prosecuted the leader and numerous members of the Krazy Locos street 
gang in Palm Beach County (an MS-13 affiliate) for two murders in connection with 
racketeering activity and numerous firearms, drug, and sex trafficking offenses. 
U.S.'. Jonathan a, 
et al., 09-Cr-80091 
U.S.'. Ivan Santiago, 09-Cr-80135 
U.S.'. Itzel Candela-Campos, 10-Cr-80042 
AUSA Villafafia prosecuted 57 individuals, including 21 medical professionals, for 
charges related to staged accidents and chiropractic clinic fraud. According to information 
received from victim insurance companies, the prosecutions resulted in a 50% decrease in 
fraudulent auto insurance claims in Palm Beach County as well as changes to state legislation. 
AUSA Villafafia received the Attorney General's Award for Fraud Prevention and the [EOUSA] 
Director's Award for this series of cases. She also received Prosecutor of the Year awards from 
the Coalition Against Insurance Fraud and the Florida Insurance Fraud Education Committee for 
her work in these cases. 
• 
U.S.'. Vladimir Lopez, et al., 11-Cr-80106 
• 
U.S.'. Ketty a, 
et al., 11-Cr-80211 
• 
U.S.'. Obelio Rodriguez, et al., 12-Cr-80107 
• 
U.S.'. Yuliet Tapanes, et al., 12-Cr-80108 
• 
U.S.'. M 
Adams, 12-Cr-80112 
• 
U.S.'. Iris Roca, 13-Cr-80109 
• 
U.S.'. Olinda Rodriguez, 13-Cr-80110 
AUSA Villafafia successfully handled the appeal in the matter of U.S.'. Damian Baston 
(14-14444 (11th Circuit)), arguing for full restitution for victims of sex trafficking and for the 
right of the United States to prosecute sex trafficking that occurred outside the United States but 
originated in the United States. 
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Laura Ingersoll 
May 10, 2019 
Page 6 of 7 
From Westlaw and Courtlink research, it appears that AUSA Villafaha was the first 
prosecutor in the Southern District of Florida to charge violations of the federal money 
transmitting statute. 
• 
U.S. 1 Nolaco-Argueta, 02-Cr-20465 
Significant Sentences: 
130 years' imprisonment for Jimmy Oliver, who had molested numerous female 
family members over several decades. (06-Cr-80023) 
• 
Life plus 135 years for Jonathan 
, head of the Krazy Locos gang, for 
ordering two murders and an attempted murder in aid of racketeering and other 
offenses (09-Cr-80091) 
Life imprisonment plus 35 years for Manuel Medina for murder in aid of 
racketeering and other offenses (09-Cr-80091) 
40 years' imprisonment for Marion Yarbrough, who had enticed a Florida girl to 
board a bus to Kentucky where he repeatedly abused her sexually (07-Cr-80099) 
40 years' imprisonment for Mark Joseph Harvey, who was found in possession of 
over 1 million images of child pornography, organized in files by age and subject 
matter, and who had previously sexually abused family members (09-Cr-80023) 
• 
30 years' imprisonment for Ivan Isidro Santiago, co-head of the Krazy Locos 
gang, for his role in two murders and an attempted murder in aid of racketeering 
and other offenses (09-Cr-80091 and 09-Cr-80135) 
27.5 years for Kenneth Chatman, who had forced female patients of his substance 
abuse treatment program into prostitution (17-Cr-80013) 
• 
25 years for Frank Grasso, who used social media to advertise for child 
pornography (05-Cr-80111) 
• 
20 years for Jonathan Earl Clark on charges of enticement of a minor and child 
pornography (08-Cr-80067) 
• 
20 years for Eric Runyan on charges of distribution of obscenity to a minor and 
enticement (12-Cr-80115) 
• 
19 years for Alejandro Tomas for aiding and abetting murder in aid of 
racketeering (09-Cr-80091) 
• 
15 years for Christopher 
-Chamberlain on a charge of aggravated assault 
in connection with the Krazy ocos case (09-Cr-80091) 
• 
14 years for Lucas Phelps on charges of enticement of a minor and transmission 
of obscene material to a child. Phelps had previously been adjudicated delinquent 
on three counts of sexual battery. (05-Cr-80020) 
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Laura Ingersoll 
May 10, 2019 
Page 7 of 7 
• 
12 years for John Walsh on charges of distribution of child pornography (05-Cr-
80185) 
• 
11 years for Silverio Macedonio-Gregorio for aiding and abetting murder in aid of 
racketeering and other offenses (09-Cr-80091) 
• 
10 years for Thomas Bohannon on charges of enticement of a minor (05-Cr-
80023) 
• 
10 years for Gilberto Jordan on charges of false statements on immigration 
application for failing to disclose his involvement in war crimes in Guatemala 
(10-Cr-80069) 
• 
8 years for Christopher Prindle for possession of child pornography (04-Cr-
80156) 
If you have any questions about any of the above information and the information 
included AUSA Villafafia's attached letter, please contact me at your convenience. 
Very truly yours, 
BAKER, DONELSON, BEARMAN, 
CALDWELL & BERKOWITZ, PC 
/s/ 
Jonathan Biran 
JB/smr 
Enclosures/Attachment 
cc: AUSA A. Marie Villafafia 
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U.S. Department of Justice 
United States Attorney 
Southern District of Florida 
500 South Australian Ave., Suite 400 
West Palm Beach, FL 33401 
(561) 820-8711 
Facsimile: (56!) 820-8777 
July 10, 2008 
NOTIFICATION OF IDENTIFIED VICTIM 
NOTICE: IN ACCORDANCE WITH TITLE 18, UNITED 
STATES CODE, SECTION 3509(d) AND FLORIDA LAW, 
THE ATTACHED DOCUMENT IS TO BE TREATED AS 
CONFIDENTIAL AND SHALL NOT BE DISCLOSED 
EXCEPT IN CONNECTION WITH A LEGAL 
PROCEEDING. 
EFTA00225548
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THEODORE J. LEOPOLD, ESQ. 
NOTIFICATION OF IDENTIFIED VICTIM 
Jutx 10, 2008 
PAGE 2 OF 2 
had been tried federally and convicted of an enumerated offense. For purposes 
of implementing this paragraph, the United States shall provide Mr. Epstein's 
attorneys with a list of individuals whom it was prepared to name in an 
Indictment as victims of an enumerated offense by Mr. Epstein. Any judicial 
authority interpreting this provision, including any authority determining 
which evidentiary burdens if any a plaintiff must meet, shall consider thatit is 
the intent of the parties to place these identified victims in the same position 
as they would have been had Mr. Epstein been convicted at trial. No more; no 
less." 
St
ough this letter, this Office hereby provides Notice that your client, 
is an individual whom the United States was prepared to name as a victim o. an 
enumerated offense. 
Should your client decide to file a claim against Jeffrey Epstein, his attorney, Jack 
Goldberger, asks that you contact him at Atterbury Goldberger and Weiss, 250 Australian 
Avenue South, Suite 1400, West Palm Beach, FL 33401. 
Please understand that neither the U.S. Attorney's Office nor the Federal Bureau of 
Investigation can take part in or otherwise assist in civil litigation; however, if you do file a 
claim under 18 U.S.C. § 2255 and Mr. Epstein denies that your client is a victim of an 
enumerated offense, please provide written documentation of that denial to the undersigned. 
Please thank your client for all of her assistance during the course of this investigation 
and express the heartfelt regards of m self and Special Agents Kuyrkendall and Richards for 
the health and well-being of Ms. 
R. ALEXANDER ACOSTA 
UNITED STATES ATTORNEY 
By: 
cc: 
Jack Goldberger, Esq. 
...•••••••• 
. MARIE VELLAFARA 
ASSISTANT U.S. ATTORNEY 
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U.S. Department of Justice 
United States Attorney 
Southern District of Florida 
500 South Australian Ave., Suite 400 
West Palm Beach, FL 33401 
(561)8204711 
Facsimile: (56!) 8204777 
July 10, 2008 
VIA FACSIMILE AND U.S. MAIL 
Theodore J. Leopold, Esq. 
Ricci—Leopold, P.A. 
2925 PGA Boulevard, Suite 200 
Palm Beach Gardens, FL 33410 
Re: 
Jeffrey Epstein/Saige Gonzalez: NOTIFICATION OF 
IDENTIFIED VICTIM.
Dear Mr. Leopold: 
• By virtue of this letter, the United States Attorney's Office for the Southern District 
of Florida asks that you provide the following notice to your client, 
On June 30, 2008, Jeffrey Epstein (hereinafter referred to as "Epstein) entered a plea 
of guilty to violations of Florida Statutes Sections 796.07 (felony solicitation of prostitution) 
and 796.03 (procurement of minors to engage in prostitution), in the 15th Judicial Circuit in 
and for Palm Beach CoUnty (Case Nos. 2006-d-009454/OOOOAB and 2008-cf-
009381AXXXMB) and was sentenced to a term of twelve months' imprisonment to be 
followed by an additional six months' imprisonment, followed by twelve months of 
Community Control 1, with conditions of community confinement imposed by the Court. 
In light of the entry of the guilty plea and sentence, the United States has agreed to 
defer federal prosecution in favor of this state plea and sentence, subject to certain 
conditions. 
One such condition to which Epstein has agreed is the following: 
"Any person, who while a minor, was a victim of a violation of an offense 
enumerated in Title 18, United States Code, Section 2255, will have the same 
rights to proceed under Section 2255 as she would have had, if Mr. Epstein 
EFTA00225550
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U.S. Department of Justice 
FILE COPY i 
United States Attorney 
Southern District of Florida 
.14.•411 Mr. 
500 South Australian Ave., Suite 400 
West Palm Beach, FL 33401 
(561) 820-8711 
Facsimile: (561) 820-8777
July 10, 2008 
NOTIFICATION OF IDENTIFIED VICTIM 
NOTICE: IN ACCORDANCE WITH TITLE 18, UNITED 
STATES CODE, SECTION 3509(d) AND FLORIDA LAW, 
THE ATTACHED DOCUMENT IS TO BE TREATED AS 
CONFIDENTIAL AND SHALL NOT BE DISCLOSED 
EXCEPT IN CONNECTION WITH A LEGAL 
PROCEEDING. 
EFTA00225551
Page 175 / 294
JEFFREY HERMAN, ESQ. 
NOTIFICATION OF IDENTIFIED VICTIM ANGELIQUE GARCIA (NEE CAVALLARO) 
JULY 10, 2008 
PAGE 2 OF 2 
rights to proceed under Section 2255 as she would have had, if Mr. Epstein 
had been tried federally and convicted of an enumerated offense. For purposes 
of implementing this paragraph, the United States shall provide Mr. Epstein's 
attorneys with a list of individuals whom it was prepared to name in an 
Indictment as victims of an enumerated offense by Mr. Epstein. Any judicial 
authority interpreting this provision, including any authority determining 
which evidentiary burdens if any a plaintiff must meet, shall consider that it is 
the intent of the parties to place these identified victims in the same position 
as they would have been had Mr. Epstein been convicted at trial. No more; no 
less." 
Through this letter, this Office hereby provides Notice that your client, 
), is an individual whom the United States was prepared to name as a 
victim of an enumerated offense. 
Should your client decide to file a claim against Jeffrey Epstein, his attorney, Jack 
Goldberger, asks that you contact him at Atterbury Goldberger and Weiss, 250 Australian 
Avenue South, Suite 1400, West Palm Beach, FL 33401. 
Please understand that neither the U.S. Attorney's Office nor the Federal Bureau of 
Investigation can take part in or otherwise assist in civil litigation; however, if you do file a 
claim under 18 U.S.C. § 2255 and Mr. Epstein denies that your client is a victim of an 
enumerated offense, please provide written documentation of that denial to the undersigned. 
Please thank your client for all of her assistance during the course of this investigation 
and express the heartfelt regards of myself and Special Agents Kuyrkendall and Richards for 
the health and well-being of Ms. Garcia. 
R. ALEXANDER ACOSTA 
UNITED STATES ATTORNEY 
By: 
C/ "Z. 
A. MARIE VILLAFANA 
ASSISTANT U.S. ATTORNEY 
cc: 
Jack Goldberger, Esq. 
EFTA00225552
Page 176 / 294
U.S. Department of Justice 
United States Attorney 
Southern District of Florida
500 South Australian Ave.. Suite 400 
West Palm Beach, FL 33401 
(561)820-8711 
Facsimile: (561) 820-8777 
July 10, 2008 
VIA FACSIMILE AND U.S. MAIL 
Jeffrey Herman, Esq. 
Herman & Mermelstein, P.A. 
18205 Biscayne Boulevard 
Suite 2218 
Miami, Florida 33160 
Re: 
Jeffrey Epstein/Angelique Garcia (née Cavatiara): 
NOTIFICATION OF IDENTIFIED VICTIM 
Dear Mr. Herman: 
By virtue of this letter, the United States Attorney's Office for the Southern District 
of Florida asks that you provide the following notice to your client, 
Garcia. 
On June 30, 2008, Jeffrey Epstein (hereinafter referred to as "Epstein) entered a plea 
of guilty to violations of Florida Statutes Sections 796.07 (felony solicitation of prostitution) 
and 796.03 (procurement of minors to engage in prostitution), in the 15th Judicial Circuit in 
and for Palm Beach County (Case Nos. 2006-cf-009454AXXXMB and 2008-cf-
009381AXX3CMB) and was sentenced to a term of twelve months' imprisonment to be 
followed by an additional six months' imprisonment, followed by twelve months of 
Community Control 1, with conditions of community confinement imposed by the Court. 
In light of the entry of the guilty plea and sentence, the United States has agreed to 
defer federal prosecution in favor of this state plea and sentence, subject to certain 
conditions. 
One such condition to which Epstein has agreed is the following: 
"Any person, who while a minor, was a victim of a violation of an offense 
enumerated in Title 18, United States Code, Section 2255, will have the same 
EFTA00225553
Page 177 / 294
U.S. Department of Justice 
United States Attorney 
Southern District of Florida 
500 South Australian Ave., Suite 400 
West Bohn Beach, FL 33401 
(561)820-8711 
Facsimile: (561) 820-8777 
July 10, 2008 
NOTIFICATION OF IDENTIFIED VICTIM 
NOTICE: IN ACCORDANCE WITH TITLE 18, UNITED 
STATES CODE, SECTION 3509(d) AND FLORIDA LAW, 
THE ATTACHED DOCUMENT IS TO BE TREATED AS 
CONFIDENTIAL AND SHALL NOT BE DISCLOSED 
EXCEPT IN CONNECTION WITH A LEGAL 
PROCEEDING. 
EFTA00225554
Page 178 / 294
RICHARD WILLITS, ESQ. 
NCYFIFICATION OF IDENTIFIED VICTIM 
ANDRIANO 
JULY 10, 2008 
PAGE 2 OF 2 
of implementing this paragraph, the United States shall provide Mr. Epstein's 
attorneys with a list of individuals whom it was prepared to name in an 
Indictment as victims of an enumerated offense by Mr. Epstein. Any judicial 
authority interpreting this provision, including any authority determining 
which evidentiary burdens if any a plaintiff must meet, shall consider that it is 
the intent of the parties to place these identified victims in the same position 
as they would have been had Mr. Epstein been convicted at trial. No more; no 
less." 
Through this letter, this Office hereby provides Notice that your client, 
is an individual whom the United States was prepared to name as a victim of an 
enumerated offense. 
Should your client decide to file a claim against Jeffrey Epstein, his attorney, Jack 
Goldberger, asks that you contact him at Atterbury Goldberger and Weiss, 250 Australian 
Avenue South, Suite 1400, West Palm Beach, FL 33401. 
Please understand that neither the U.S. Attorney's Office nor the Federal Bureau of 
Investigation can take part in or otherwise assist in civil litigation; however, if you do file a 
claim under 18 U.S.C. § 2255 and Mr. Epstein denies that your client is a victim of an 
enumerated offense, please provide written documentation of that denial to the undersigned. 
Please thank your client for all of her assistance during the course of this investigation 
and express the heartfelt regards of m self and Special Agents Kuyrkendall and Richards for 
the health and well-being of Ms. 
R. ALEXANDER ACOSTA 
UNITED STATES ATTORNEY 
By: 
A. MARIE V1LLAFAN- A 
ASSISTANT U.S. ATTORNEY 
cc: 
Jack Goldberger, Esq. 
EFTA00225555
Page 179 / 294
U.S. Department of Justice 
United States Attorney' 
Southern District of Florida 
.500 South Australian Ave., Suite 400 
West Palm Beach, FL 33401 
(561)820-8711 
Facsimile: (561) 820-8777 
July 10, 2008 
VIA FACSIMILE AND U.S. MAIL 
Richard H. Willits, P.A. 
2290 10th Avenue North, Suite 404 
Lake Worth, FL 33461 
Re: 
Jeffrey Epstein/Carolyn 
NOTIFICATION OF 
IDENTIFIED VICTIM 
Dear Mr. Willits: 
By virtue of this letter, the United States Attorney's Office for the Southern District 
of Florida asks that you provide the following notice to your client, 
On June 30, 2008, Jeffrey Epstein (hereinafter referred to as "Epstein) entered a plea 
of guilty to violations of Florida Statutes Sections 796.07 (felony solicitation of prostitution) 
and 796.03 (procurement of minors to engage in prostitution), in the 15th Judicial Circuit in 
and for Palm Beach County (Case Nos. 2006-cf-009454/OOaMB and 2008-cf-
009381AXXXMB) and was sentenced to a term of twelve months' imprisonment to be 
followed by an additional six months' imprisonment, followed by twelve months of 
Community Control 1, with conditions of community confinement imposed by the Court. 
In light of the entry of the guilty plea and sentence, the United States has agreed to 
defer federal prosecution in favor of this state plea and sentence, subject to certain 
conditions. 
One such condition to which Epstein has agreed is the following: 
"Any person, who while a minor, was a victim of a violation of an offense 
enumerated in Title 18, United States Code, Section 2255, will have the same 
rights to proceed under Section 2255 as she would have had, if Mr. Epstein 
had been tried federally and convicted of an enumerated offense. For purposes 
EFTA00225556
Page 180 / 294
U.S. Department of Justice 
United States Attorney 
Southern District of Florida 
•
 
500 South Australian Ave., Suite 400 
West Palm Beach, FL 33401 
(561) 820-8711 
Facsimile: (561) 820-8777 
Jply.10, 2008 
NOTIFICATION OF IDENTIFIED VICTIM 
NOTICE: IN ACCORDANCE WITH TITLE 18, UNITED 
STATES CODE, SECTION 3509(d) AND FLORIDA LAW, 
THE ATTACHED DOCUMENT IS TO BE TREATED AS 
CONFIDENTIAL AND SHALL NOT BE DISCLOSED 
EXCEPT IN CONNECTION WITH A LEGAL 
PROCEEDING. 
EXHIBIT B-67 
EFTA00225557
Pages 161–180 / 294