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ent, Jeffrey Epstein, in consultation with Gerald Lefcourt, Esq. and Lilly Ann Sanchez, Esq., as well as nu
please do so through AUSA Villafana, and, in her absence, AUSA Atkinson. On September 24, 2007, your client, Jeffrey Epstein, in consultation with Gerald Lefcourt, Esq. and Lilly Ann Sanchez, Esq., as well as numerous other nationally-renowned lawyers, including but not limited to Harvard Law Professor Alan D
ee of Defendant JEFFREY EPSTEIN prepared a written telephoF message for Defendant JEFFREY EPSTEIN's review regarding a telephone call received from T.M. and Jane Doe #12 that stated: "They are available all weekend and maybe pane Doe #13] too". 20 EFTA00225764 (83) On or about December 30, 2004,
or more telephone calls to a telephone used by Jane Doe #7. (58) On or about July 16, 2004, Defendant placed a telephone call telephone used by T.M. (59) On or about July 17, 2004, one of Defendant JEFFREY EPSTEIN's employees prepared a written telephone message for Defendant JEFFREY EPSTEIN's
a telephone call to a telephone used by Jane Doe #8. D (56) On or about July 15, 2004, Defendant placed a telephone call to a telephone used by T.M. (57) On or about July 16, 2004, Defendant placed one or more telephone calls to a telephone used by Jane Doe #7. (58) On or about July 16, 2004
tant prosecutor Dahlia Weiss and thereby influence the outcome of the State prosecution, that assertion is frivolous. Mr. Goldberger was retained by Gerald Lefcourt after Mr. Epstein already had been indicted by the Grand Jury. Mr. Lefcourt had never heard the name Dahlia Weiss when he hired Mr. Goldberger, and
tion, that assertion is frivolous. Mr. Goldberger was retained by Gerald Lefcourt after Mr. Epstein already had been indicted by the Grand Jury. Mr. Lefcourt had never heard the name Dahlia Weiss when he hired Mr. Goldberger, and had no idea that Mr. Goldberger's law partner was married to a sex-crimes p
to a telephone used by Jane Doe #10. 17 EFTA00225823 (58) On or about July 16, 2004, Defendant placed a telephone call to a telephone used by T.M. (59) On or about July 17, 2004, one of Defendant JEFFREY EPSTEIN's employees prepared a written telephone message for Defendant JEFFREY EPSTEIN's
Defendant JEFFREY EPSTEIN employed L.G. to perform, among other things, services as a personal assistant. 1) Defendants JEFFREY EPSTEIN and paid T.M., H.R., and A.F. to perform, among other things, recruiting services. 4. Defendant JEFFREY EPSTEIN owned a property located at 358 El Brillo Way,
e of Defendant JEFFREY EPSTEIN prepared a written telephone message for Defendant JEFFREY EPSTEIN's review regarding a telephone call received from T.M. and Jane Doe #12 that stated: "They are available all weekend and maybe [Jane Doe #lp] too". 20 EFTA00225820 (83) On or about December 30, 2004
ees to comply with them. R. ALEXANDER ACOSTA UNITED STATES ATTORNEY Dated: Dated: Dated: / 9-910 7 Dated: By: AS Y JEFFREY EPSTEIN RAL EFCOUR ESQ. OUNSEL TO JF_FER .Y EPSTEIN LILLY ANN SANCHEZ, ESQ. ATTORNEY FOR JEFFREY EPSTEIN Page 7 of 7 EFTA00179267 By signing this agreement, Eps
t and agrees to comply with them. R. ALEXANDER ACOSTA UNITED STATES ATTORNEY Dated: By: Dated: 77a,_ Dated: Dated: ASSISTANT U.S. ATTORNEY GERALD LEFCOURT, ESQ. COUNSEL TO JEFFREY EPSTEIN LILLY ANN SANCHEZ, ESQ. ATTORNEY FOR JEFFREY EPSTEIN Page 7 of 7 lb TA' EFTA00179266 By signing this agreem
_ Dated: Dated: ASSISTANT U.S. ATTORNEY GERALD LEFCOURT, ESQ. COUNSEL TO JEFFREY EPSTEIN LILLY ANN SANC
fied, including notification letters that were sent. DE 14. Attached to that Declaration are copies of redacted letters provided to victims "C.W.", "T.M.", and "S.R." by AUSA and the FBI's Victim-Witness Specialist Twiller Smith, DE 14. In addition, appended to the Declaration are AUSA Villafana's le
ocess Investigative Privilege 26 5/22/2007 email from Andy Lourie to Matt Menchel and Jeff Sloman (cc: Marie Villafaita) re letter received from Gerald Lefcourt discussing a meeting to discuss Epstein investigation Work Product Deliberative Process 27 5/23/2007 email from Jason Richards to Marie Villafa
13905 E-mail, Andrew Lourie to Matthew Menchel, Jeff Sloman, and Marie Villafana, May 22, 2007, 3:11 p.m., FW: Jeffrey Epstein, with c-mail from Lcfcourt to Lourie, Villafana, and Lilly Ann Sanchez (May 22, 2007, 2:05 p.m.), attached Atty work-product Page 11 of 14 EFTA00191260 Bates Range Descr
13872 E-mail, Andrew Lourie to Matthew Menchel, Jeff Sloman, and Marie Villafana, May 22, 2007, 3:11 p.m., FW: Jeffrey Epstein, with e-mail from Lefeourt to Lourie, Villafana, and Lilly Ann Sanchez (May 22, 2007, 2:05 p.m.), attached Atty work-product Suppl. Box 3 P-013873 E-mail Menchel to Villaf
parties to this litigation 59 12/11/2007 email from Marie Villafafia to Jeff Sloman and Alex Acosta regarding call with lawyer for Jane Doe #2 (T.M.) Work Product Deliberative Process 60 12/3/2007 emails between Marie Villafatta, Alex Acosta, and Jeff Sloman regarding history of plea negotia
hereby states that he understands the conditions of this Non- Prosecution Agreement and agrees to comply with them. Dated: JEFFREY EPSTEIN Dated: GERALD LEPCOURT, ESQ. COUNSEL TO JEFFREY EPSTEIN Dated: UNITED STATES ATTORNEY Page 5 of S US_Atty_Cor 0087 EFTA00184715 Case 9:08-cv-80736-KAM Document 361-
ated: VILLAFARA ASSISTANT U.S. ATTORNEY GERALD LEFCOURT, ESQ. COUNSEL TO JEFFREY EPSTEIN LILLY ANN SANC
to Bradley Edwards' three clients, T.M.. C.W., and S.R.' Your Affiant's letter to C.W. was provided by the FBI. (Ex. I ). Your Affiant's letter to T.M. was hand-delivered by myself to T.M. at the time that she was interviewed (Ex. 2).= Both C.W. and T.M. also received letters from the FBI's Victim-
se the U.S. Attorney's modification limited Epstein's liability to victims whom the United States was prepared to name in an indictment. In light of T.M.'s prior statements to law enforcement, your Affiant could not in good faith include T.M. as a victim in an indictment and, accordingly, could not i
that he register as a sex offender. In a letter drafted, but not sent, to U.S. Attorney Alexander Costa and obtained by Page Six, Epstein's lawyer. Gerald Lefcourt, writes, "Doing so will have a profound impact (on Epstein) both immediately and forever after. Not only will he be restricted to a wholly inapprop
ws owner Mort Zuckerman, pleaded guilty to a state charge in exchange for the feds' dropping their probe into possible federal criminal violations. Lefcourt argues that only the feds have demanded that Epstein register. "despite the fact that the state was of the view that Mr. Epstein's conduct did not
e of Defendant JEFFREY EPSTEIN prepared a written telephone message for Defendant JEFFREY EPSTEIN's review regarding a telephone call received from T.M. and Jane Doe #12 that stated: "They are available all weekend and maybe [Jane Doe #18] too". 20 Case No. 08-80736-CV-MARRA P-013469 EFTA00230374
more telephone calls to a telephone used by Jane Doe #7. (48) On or about July 5, 2004, Defendant placed a telephone call to a telephone used by T.M. 14 Case No. 08-80736-CV-MARRA P-013463 EFTA00230368 (49) In or around July 2004, Defendant JEFFREY EPSTEIN masturbated in the presence of Jan
(e) Deliberative Process P-013981 5/22/2007 email from Andy Lourie to Matt Menchel and Jeff Sloman (cc: Marie Villafafia) re letter received from Gerald Lefcourt discussing a meeting to discuss Epstein investigation Work Product Deliberative Process P-013982 5/23/2007 email from Jason Richards to Marie Vi
Marie Villafafia) re letter received from Gerald Lefcourt discussing a meeting to discuss Epstein investig
t Deliberative Process P-014440 12/11/2007 email from Marie Villafafia to Jeff Sloman and Alex Acosta regarding call with lawyer for Jane Doe #2 (T.M.) Work Product Deliberative Process P-014441 12/12/2007 emails between Marie Villafafia, Frederica Devlin, and Bob Senior regarding planning indi
6(e) Deliberative Process P-013981 5/22/2007 email from Andy Lourie to Man Menchel and Jeff Sloman (cc: Marie Villafaila) re letter received from Gerald Lefcourt discussing a meeting to discuss Epstein investigation Work Product Deliberative Process P-013982 5/23/2007 email from Jason Richards to Marie Vi
Marie Villafaila) re letter received from Gerald Lefcourt discussing a meeting to discuss Epstein investig
t Deliberative Process P-014440 12/11/2007 email from Marie Villafafta to Jeff Sloman and Alex Acosta regarding call with lawyer for Jane Doe #2 (T.M.) Work Product Deliberative Process P-014441 12/12/2007 emails between Marie Villafafta, Frederica Devlin, and Bob Senior regarding planning indi
6(e) Deliberative Process P-013981 5/22/2007 email from Andy Lourie to Man Menchel and Jeff Sloman (cc: Marie Villafaila) re letter received from Gerald Lefcourt discussing a meeting to discuss Epstein investigation Work Product Deliberative Process P-013982 5/23/2007 email from Jason Richards to Marie Vi
Marie Villafaila) re letter received from Gerald Lefcourt discussing a meeting to discuss Epstein investig
t Deliberative Process P-014440 12/11/2007 email from Marie Villafafta to Jeff Sloman and Alex Acosta regarding call with lawyer for Jane Doe #2 (T.M.) Work Product Deliberative Process P-014441 12/12/2007 emails between Marie Villafafta, Frederica Devlin, and Bob Senior regarding planning indi
atthew Menchel E-mail, Marie Villafana to Gerald Lefcourt, dated September 10, 2007 5:23 p.m., RE: Jeffrey
Sanchez Letter to Lilly Ann Sanchez, Esq., dated August 3, 2007, RE: Jeffrey Epstein (2 pages), Author: Matthew Menchel E-mail, Marie Villafana to Gerald Lefcourt, dated September 10, 2007 5:23 p.m., RE: Jeffrey Epstein (2 pages with 4 page draft Non-Prosecution Agreement) E-mail, Marie Villafana to Gerald Le
o. 2: (a) Letter to Miss C.W., dated June 7, 2007, RE: Crime Victims' and Witnesses' Rights (2 pages); Author: A. Marie Villafana. Letter to Miss T.M., dated August 11, 2006, RE: Crime Victims' and Witnesses' 1 EFTA00191186 Rights (2 pages); Author: A. Marie Villafana. Letter to C.W., dated Jan
Entities connected to both Gerald Lefcourt and T.M.

Jeffrey Epstein
PERSON
Alexander Acosta
PERSON
United States
LOCATIONthe Southern District
LOCATIONLeon Black
PERSON
Alan Dershowitz
PERSONJack Goldberger
PERSON
A. Marie Villafana
PERSONAnn Sanchez
PERSONRoy Black
PERSON
Department of Justice
ORGANIZATIONFBI
ORGANIZATION
Kenneth Marra
PERSON
George W. Bush
PERSON
Jay Lefkowitz
PERSON
Ken Starr
PERSON
Palm Beach Police Department
ORGANIZATION
Bradley Edwards
PERSONJane Doe
PERSON
Prince Andrew
PERSON