Villafana, Ann Marie C. (USAFLS) From: Villatana, Ann Marie C. (USAFLS) Sent: Wednesday, July 09, 2008 12:22 PM To: Acosta, Alex (USAFLS); Lee, Dexter (USAFLS) Cc: Sloman, Jeff (USAFLS); Atkinson, Karen (USAFLS) Subject: Revised Declaration I removed the sentence about why the Palm Beach Police contacted FBI for assistance. I notice that the language regarding my securing pro bono counsel for C.W. was removed. I think it shows how far we went out of our way to protect the victims, especially Mr. Edwards' clients. Is it alright to put it back in? A. Marie Villafana Assistant U.S. Attorney 561 209-1047 Tracking: 614 EFTA00194402

so.uu rnA poloODU640 USAO WPB CONFRM TRANSMISSION OK ********************* *** TX REPORT *** *Its*************ssxs* TX/RX NO. 0708 CONNECTION TEL. 19549241530. SUBADDRESS CONNECTION ID ST. TIME 07/09 14:59 USAGE T 01'11 PGS. SENT 5 RESULT OK United States Attorney's Office Southern District of Florida 500 S. Australian Ave.; Suite 400 West Paint Beach,.FL 33401-6235 • DATE: r TO: (3pa_awarol ORGANIZATION: FAX #: SUBJECT: FROM: MarcA IA/ (561) 820;8711 (561) 820-8777 (Fax) 4. NUMBER OF PAGES. INCLUDING THIS PAGE: COMMENTS: si EFTA00194403

rah DOLOUOUBVI USXO WPB CONFRM TRANSMISSION OK ***************t4.4*** It** TX REPORT *** ********************* TX/RX NO 0708 CONNECTION TEL 19549241530 SUBADDRESS CONNECTION ID ST. TIME 07/09 14:59 USAGE T 01'11 PGS. SENT RESULT OK United. States Attorney's Office Srill &ern District of Florida 5011 S. Australian Ave., Suite 400 West ?atm Beach, FL 33401-6235 . DATE. —ilgior 1O. rtkot-chuyan ORGANIZATION: • • - @jolt: rt FAY, #- SUBJECT: FROM: Matiat VII (561) 820-8711 (561) 820-8777 (Fax) NUMBER OF PAGES. INCLUDING THIS PAGE: COMMENTS: 1. 'C 4. EFTA00194404

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 9, 2008 VIA FACSIMILE Brad Edwards, Esq. The Law Offices of Brad Edwards & Associates, LLC 2028 Street, Suite 202 Hollywood, Florida 33020. Re: Jeffrey Epstein/MEM NOTIFICATION OF IDENTIFIED VICTIM Dear Mr. Edwards: 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-009454AXXXMB and 2008-cf- 009381=O(MB) and was sentenced to a term of twelve months' imprisonment to be followed by an additional six months' imprisonment, followed by twelve months of 1 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 EFTA00194405

BRAD EDWARDS, ESQ. NOTIFICATION OF IDENTIFIED VICTIM JULY 9, 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 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, (561) 659-8300. 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 notice of that denial to the undersigned. Please thank your client for all of her assistance during the course of this examination and express the heartfelt regards ofSt self and Special Agents Kuyrkendall and Richards for the health and well-being of Ms. M. R. ALEXANDER ACOSTA UNITED STATES ATTORNEY By: A. MARIE VILLAFANA ASSISTANT U.S. ATTORNEY cc: • Jack Goldberger, Esq. EFTA00194406

U.S. Department of Justice United States Attorney Southern District of Florida 500 South Australian Ave, Suite 400 West Palm Beach, FL 3340! (561)820-8711 Facsimile: (561)8204777 July 9, 2008 VIA FACSIMILE Brad Edwards, Esq. The Law Offices of Brad Edwards & Associates, LLC 2028 MIEStreet, Suite 202 Hollywood, Florida 33020. Re: jeffreLS'IN OF IDENTIFIED VICTIM Dear Mr. Edwards: By virtue of this letter, the United States Attorney's Office fo istrict 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-009454AXXXMB 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 EFTA00194407

BRAD EDWARDS, ESQ. NOTIFICATION OF IDENTIFIED VICTIM...BM JULY 9, 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 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, MIS 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 Atterbuty Goldberger and Weiss, 250 Australian Avenue South, Suite 1400, West Palm Beach, FL 33401, (561) 659-8300. 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 notice of that denial to the undersigned. Please thank your client for all of her assistance during the course of this examination and express the heartfelt regards of Special Agents Kuyrkendall and Richards for the health and well-being of Ms. IL ALEXANDER ACOSTA UNITED STATES ATTORNEY By: A. MARIE VTLLAFAICIA ASSISTANT U.S. ATTORNEY ec: Jack Goldberger, Esq. EFTA00194408

U.S. Department of Justice ftE COB United States Attorney Southern District of Florida SOO South Australian Ave.. Suite 400 West Palm Beach FL 33401 (561) 820-8711 Facsimile: (561) 8204777 July 9, 2008 VIA FACSIMILE Brad Edwards, Esq. The Law Offices of Brad Edwards & Associates, LLC 2028 ME Street, Suite 202 Hollywood, Florida 33020. Re: Jeffrey Epstein/ NOTIFICATION OF IDENTIFIED VICTIM Dear Mr. Edwards: 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-009454AXXXMB 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 EFTA00194409

BRAD EDWARDS; ESQ. NOTIFICATION OF IDENTIFIED VICTIM AAA 9, 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 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 enumerate 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, (561) 659-8300. 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 notice of that denial to the undersigned. Please thank your client for all of her assistance during the course of this examination and express the heartfelt regards of 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. CSA1) A. MARIE VILLAFARA ASSISTANT U.S. ATTORNEY EFTA00194410

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 9, 2008 VIA FACSIMILE Brad Edwards, Esq. The Law Offices of Brad Edwards & Associates, LLC 2028 Street, Suite 202 Hollywood, Florida 33020. Re: Jeffrey Epstein : NOTIFICATION OF IDENTIFIED VICTIM Dear Mr. Edwards: By virtue of this letter, the United States Attorney's Office f 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-009454AXXXMB and 2008-cf- 00938 1 AXXXMB) 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 EFTA00194411

BRAD EDWARDS, ESQ. NOTIFICATION OF IDENTIFIED VICTIM JULY 9, 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 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, (561) 659-8300. 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 notice of that denial to the undersigned. Please thank your client for all of her assistance during the course of this examination 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 VILLAFARA ASSISTANT U.S. ATTORNEY cc: Jack Goldberger, Esq. EFTA00194412

July 9, 2008 "Agri:, eat ',cwt/ Ale ite.41: : att Acts:- • J ,i 44, .,keei-St. ft ,4”-'1,i•Avir 11.: , r ,ity. - ,..≥r..•4 .” •I tic. t. :. Asfo, ,. k .v ...t .r.4., ,:-...• lio.. ,„„,taia . IY9;-:. £ $: . - ..• 'c.c.s!, Ct. .til 'A'17, *.- , ,i i . • ittk ef kg: •"'""41,0:14..tic• •:;p:..,-;:titi •-••,,,,,.., , • .....• ° etzt.::-ele:t..,-.M.N `strVv-)..); 7-e- .• • i , ,..•::1* ;fr.: • • JOSEPH R.ATTERBURY •t JACK A.GOLDBERGER JASON S.WEISS "Board Certified Criminal Trial Attorney Member of New Jersey & Florida Bars A. Marie C. Villafana, Esq. Assistant United States Attorney United States Attorney's Office 500 South Australian Avenue 4th Floor, Suite 400 West Palm Beach, Florida 33401 SENT VIA E-MAIL & FACSIMILE (561) 820-8777 Re: Jeffrey E. Epstein Dear Ms. Villafana: Thank you for your letter to me dated July 8, 2008 and the draft document dated, e-mailed and faxed to me at my office on June 30, 2008, styled "Notification of Identified Victims." I would like to address a few related issues. First, please note that we have several requests concerning any such notification. Specifically, we request that: (a) Any notification be sent to any individual by mail (or served upon their attorney, to the extent known), and we respectfully object to any service by hand, a method of service which carries the concomitant risk of conversations regarding the notification that potentially would place the federal authorities in a position of being advocates for civil litigation; (b) Any notification be effectuated by a separate mailing to each individual without the inclusion of any language that appeared on the second page of your June 30, 2008 memorandum; i.e. rather than including in each notification a large section listing "identified individuals" with redactions other than the name of the recipient (which we contend would be a clear and impermissible signal to any individual that the notification is a broad notification to numerous other alleged victims). Rather, a simple one page notification directed only to the recipient, and limited to the information currently on the first page of your draft memorandum would suffice. One Clearlake Centre, Suite 1400 250 Australian Avenue South West Palm Beach, EL 33401 p 561.659.8300 f 561.835.8691 www.agwpa.com EFTA00194413

(c) You eliminate from any notification any language that is currently contained in the "acknowledgment" section of the June 30, 2008 memorandum; and (d) You supplement the notification with the Government's previously made representation that it is not vouching for the veracity of any claim by any identified individual. See Letter from J. Sloman to E. MO 0/25/07). Second, please note also that we do not understand your request that Mr. Epstein and his attorneys execute the rider / acknowledgment contained within your June 30 hand-delivered draft. Specifically, we do not believe that the Non-Prosecution Agreement requires Mr. Epstein's execution of any such additional stipulation. Because we want to ensure that Mr. Epstein continues to strictly comply with the letter of the parties' agreement, we respectfully ask that you explain why you believe that the Non-Prosecution Agreement requires execution of your stipulation. Our understanding of the Non-Prosecution Agreement is that it does not require Mr. Epstein to "acknowledge" anything not already contained within the four corners of the written agreement. The agreement certainly contains no written term obligating that he "waive any evidentiary challenge to the introduction of a copy" of any "Notification of Identified Victims" in "any judicial proceeding between any identified individual" and Mr. Epstein, as your memorandum currently requests. Further, please note that your June 30 stipulation, as drafted, is not limited to Section 2255 proceedings. Rather, your June 30 draft requires Mr. Epstein to waive evidentiary challenges in "any judicial proceeding" - - which clearly exceeds the bounds of the parties' written agreement. Third, I would respectfully request that you provide me with the names of the "pro bono lawyers" who, you indicated to me at our June 30 meeting at my office, were intending to represent certain persons identified on your June 30 draft notification, as well as any knowledge that the Government has as to how they were selected, and what communications the Government has had with them to date. Finally, please know that it is Mr. Epstein's firm intent to fulfill strictly each term and condition of his Non-Prosecution Agreement with the Government. Nothing in this letter should be construed, however, as waiving any defense that may be available to Mr. Epstein under the parties' written agreement. I look forward to your response. Until then, I remain, trul yours, Ja A. Goldberger : Jeffrey Epstein EFTA00194414

U.S. Department of Justice United States Attorney Southern District of Florida 500 South Australian Ave., Suite 400 West Palm Beath, FL 33401 (56!) 820-87!! Facsimile: (561) 820-8777 July 9, 2008 VIA FACSIMILE Jack A. Goldberger, Esq. Atterbury, Goldberger & Weiss, P.A. One Clearlake Centre, Suite 1400 250 Australian Ave S. West Palm Beach, FL 33401-5015 Re: Jeffrey Epstein Dear Mr. Goldberger: Thank you for your letter of today's date regarding theproposed Victim Notification. Let me address some of the items in your letter. We have no objection to doing individual mailings. The Notification was drafted in that way in order to minimize the number of documents that Mr. Epstein would sign. Now that you have raised an objection to signing the Acknowledgment, each notification will list • only the victim who is being notified. In light of Mr. Epstein's refusal to sign the Acknowledgment, the Acknowledgment portion has been deleted and the notification has been slightly modified in order to provide more complete information and it has been formatted as a letter rather than a more formal "Notification" document. We will not be including any statement that the U.S. Attorney's Office is not vouching for the veracity of any claim. As you know, the U.S. Attorney's modification of the 2255 portion of the Agreement now limits our victim list to those persons whom the United States EFTA00194415

JACK GOLDBERGER, ESQ. • Jinx 9, 2008 PAGE 2 was prepared to include in an indictment. This means that, pursuant to Justice Department policy, these are individuals for whom the United States believes it has proof beyond a reasonable doubt that each of them was a victim of an enumerated offense. There will be no statement one way or the other regarding the validity of any claim. You have asked for an explanation of why I believe the Acknowledgment portion is required by the terms of the Agreement. Under a strict reading of the Agreement, it is not required, other than to Acknowledge that the United States has performed its obligation of providing Mr. Epstein with a list of identified victims following his guilty plea and sentencing. The purpose of the Acknowledgment was to create one single document incorporating the parties' agreement on The single topic of the right to proceed under 18 U.S.C. § 2255. This would avoid litigation regarding the victims' rights to have access to the original Non-Prosecution Agreement. Without such an express Acknowledgment by Mr. Epstein that the Notice contains the substance of that Agreement, I believe that the victims will have a justification to petition for the entire agreement, which is contrary to the confidentiality clause that the parties have signed. If you believe that particular words are objectionable, I am happy to consider a modification. As I mentioned to you last week, I will provide you with the names of the attorneys currently representing the victims when we have compiled all of that information. Some of the victims are represented by attorneys from the South Carolina Victim Assistance Network and the Maryland Crime Victims Resource Center, both of which were recommended by a victims' rights organization that receives grants from the Justice Department. If you have any suggestions for a modification of the Acknowledgment, please let me know. Sincerely, R. Alexander Acosta United States Attorney By: cc: Karen Atkinson, AUSA A. Marie Villafana Assistant United States Attorney EFTA00194416

U.S. Department of Justice United States Attorney. Southern District of Florida A. Marie Villafaita 500 S. Australian Aye, 4th Floor West Palm Beach, Florida 33401 (561) 8204711 TO: Facsimile (561) 820-8777 FACSIMILE COVER SHEET Jack Alan Goldberger DATE: July 9, 2008 # OF PAGES: RE: 3 FAX NO. 561-835-8691 PHONE NO. 561 659-8300 Jeffrey Epstein FROM: A. MARIE VILLAFANA, Assistant U.S. Attorney PHONE NO. 561 209-1047 COMMENTS: EFTA00194417

P. 1 * * * TRANSMISSION RESULT REPORT ( JUL. 9.2008 4:05PM ) * * * TTI USA° WPB FL DATE TIME ADDRESS MODE TIME PAGE RESULT PERS. NAME FILE JUL. 9. 4:04PM 5618358691 TES • : BATCH L : SEND LATER S : STANDARD A-: ASYNC MODE C : CONFIDENTIAL : FORWARDING D : DETAIL 1-: MIL_STD MODE 0'36" P. 3 OK 412 P : POLLING E : ECM F : FINE G-: RICOH-MG3/COMPATIBLE MODE M : MEMORY > : REDUCTION EFTA00194418