Villafana, Ann Marie C. (USAFLS) From: Villafana, Ann Marie C. (USAFLS) Sent: Thursday, July 31, 2008 9:20 AM To: Lee, Dexter (USAFLS) Subject: Re: Got your message Hi Dexter. I thought Judge Marra required it to be filed but it has not been filed so they may have just "produced" it in discovery. Tein filed something under seal a couple of days ago but obviously I don't know what it was. A different plaintiff's attorney called me on Tuesday and asked if he could get a copy and I said no. I would ask Jeff how he wants to handle. Original Message From: Lee, Dexter (USAFLS) To: Villafana, Ann Marie C. (USAFLS) Cc: Acosta, Alex (USAFLS); Sloman, Jeff (USAFLS); Jacobus, Wendy (USAFLS) Sent: Wed Jul 30 21:29:23 2008 Subject: RE: Got your message Marie, As I understand it, the USAO-Epstein agreement has a confidentiality provision. It was filed under seal in state court. I seem to recall you telling me that Judge Marra ordered Michael Tein to file the agreement in the pending federal court civil actions under 18 U.S.C. 2255. Is that not correct? My impression from speaking with Edwards is that, if he is satisfied the agreement adequately punishes Epstein and protects his clients, then he will withdraw his lawsuit. If we are not in a position to produce the agreement, then we won't be able to adequately address his concerns. I filed our notice to court on Tuesday night. Edwards is in a real hurry to try to resolve this matter before the court acts on the notice. I wonder if he thinks Judge Marra will not hold another hearing and rule on the papers. I will call you tomorrow morning. Thanks. Dexter From: Villafana, Ann Marie C. (USAFLS) Sent: Wednesday, July 30, 2008 1:53 PM To: Lee, Dexter (USAFLS) Subject: Got your message Hi Dexter - As far as I know, the only place where the agreement has been filed is under seal in the state court. I don't think we could provide it without a subpoena or court order. 347 EFTA00193599

Stipulation, # (2) Exhibit July 17, 2008 Letter, it (3) Exhibit July 3, 2008 Letter)(Edwards, Bradley) 9:08-cv-80736 Notice has been electronically mailed to: Paul G. Cassell cassellpglaw.utah.edu Bradley James Edwards begbradedwardslaw.com Dexter Lee dexter.leegusdoi.gov, giovanni.coutardgusdoi.gov, USAFLS- HODKTOusdoi.gov Ann Marie C. Villafana ann.marie.c.villafanagusdoi.gov, shawn.ballgusdoi.gov 9:08-cv-80736 Notice has not been delivered electronically to those listed below and will be provided by other means. For further assistance, please contact our Help Desk at 1-888-318-2260.: The following document(s) are associated with this transaction: Document description:Main Document Original filename:n/a Electronic document Stamp: [STAMP dcecfStamp_ID=1105629215 [Date=8/1/2008] [FileNumber=5398771-0] [2b5306b93530dfc5af8c7a275dbd5c566875ec3dc16da227805a577da7ae0e217564 9a5268a5a2438792473b44b81ff6085fd967a1d94dcc80404f081f0461d3]] Document description:Exhibit Proposed Stipulation Original filename:n/a Electronic document Stamp: [STAMP dcecfStamp_ID=1105629215 [Date=8/1/2008] [FileNumber=5398771-1] [2457ae607b8a32a77d44129471ecO5d5d419cd01863ebc78e95eb23369212475e73f 77f0edd5fd8a4d3cb1f03e4f1b5a05f90e55d5888c02cc0c023cc29d0c34]] Document description:Exhibit July 17, 2008 Letter Original filename:n/a Electronic document Stamp: [STAMP dcecfStamp_ID=1105629215 [Date=8/1/2008] [FileNumber=5398771-2] [028a1255f1d8569c9c552990d05df60977c8f323394fc172a4471c5752bd8144c367 3368f8948f93af83f822d412b8644f5eba8384b5b2ff42ae80fa3333248a]] Document description:Exhibit July 3, 2008 Letter Original filename:n/a Electronic document Stamp: [STAMP dcecfStamp_ID=1105629215 [Date=8/1/2008] [FileNumber=5398771-3] [86cb55b1dd7964ba4ce672a9Ofe250f58bb0e850cadc806a13516064217b8353973f 9f53ec46d4342ab88d460e63c78793f0ea5191a9756dcbb2e2fd710810ce]] 346 EFTA00193600