Villafana, Ann Marie C. (USAFLS) From: Lee, Dexter (USAFLS) <[email protected]> Sent: Tuesday, July 08, 2008 4:29 PM To: Villafana, Ann Marie C. (USAFLS) Subject: FW: Epstein CVRA Case Attachments: Villafana Declaration re victim notification.wpd; DE1_080707_Petition.pdf Marie, Can you scan the letters and send them to me by e-mail? Thanks. Dexter From: Neal, Kristina (USAEO) Sent: Tuesday, July 08, 2008 4:02 PM To: Lee, Dexter (USAFLS) Cc: Herd, Kim (USAEO) Subject: FW: Epstein CVRA Case Good Afternoon. Kim and I are taking a look at the petition and affidavit that you sent and were wondering if it would be possible for you to send us a copy of the letters that were sent to the victims in this case. The AUSA refers to attached copies in her affidavit at #3. We are working on this and will respond to you ASAP. Thanks. Kris Neal Kristina Neal Attorney Advisor LECC/Vie t i lll Witness Staff EOUSA (202) 305 2538 From: Lee, Dexter (USAFLS) Sent: Tuesday, July 08, 2008 1:37 PM 20 EFTA00190504

To: Herd, Kim (USAEO) Subject: Epstein CVRA Case Ms. Herd. Attached please find the emergency petition filed yesterday afternoon, and a draft declaration from the AUSA. Our response is due on Wednesday, July 9, 20O8, at close of business. Thanks for your assistance. Dexter Lee (305) 961-9320 «Villafana Declaration re victim notification.wpd» «DE1_080707_Petition.pdf» 21 EFTA00190505

DRAFT DRAFT DRAFT DRAFT UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 08-80736-Civ-Marra/Johnson JANE DOE 1. UNITED STATES OF AMERICA DECLARATION OF A. MARIE VILLAFAAA 1, I, A. Marie Villafana, do hereby declare that I am a member in good standing of the Bar of the State of Florida. I graduated from the University of California at Berkeley School of Law (BoaIt .) in 1993. After serving as a judicial clerk to the Hon. David F. Levi in Sacramento, California, I was admitted to practice in California in 1995. I also ant admitted to practice in all courts of the states of Minnesota and Florida, the Eighth, Eleventh, and Federal Circuit Courts of Appeals, and the U.S. District Courts for the Southern District of Florida, the District of Minnesota, and the Northern District of California. My bar admission status in California and Minnesota is currently inactive. I am currently employed as an Assistant United States Attorney in the Southern District of Florida and was so employed during all of the events described herein. 2. I was the Assistant United States Attorney assigned to the investigation of Jeffrey Epstein. The case was investigated by the Federal Bureau of Investigation ("FBI"). The federal investigation was initiated in 2006 at the request of the Palm Beach Police Department ("PBPD") into allegations that Jeffrey Epstein and his personal assistants had used facilities of interstate commerce to induce young girls between the ages of thirteen and seventeen to engage in prostitution, amongst EFTA00190506

other offenses. PRPD had asked for federal assistance after it perceived that Mr. Epstein was receiving preferential treated from the Palm Beach County State Attorney's Office ("SAO"). 3. Throughout the investigation, when a victim was identified, victim notification letters were provided to her both from your Affiant and from the FBI's Victim-Witness Specialist. Attached hereto are copies of the letters provided to two of Bradley Edwards clients, T.M. and C.W.' The letter to C.W. was hand-delivered by the FBI agents. The letter to T.M. was hand-delivered by myself to T.M. at the time that she was interviewed. 4. Throughout the investigation, the F81 agents, the FBI's Victim-Witness Specialist, and your Affiant had contact with C.W. Attorney Edwards other client, T.M., was represented by counsel and, accordingly, all contact with T.M. was made through that attorney. That attorney was lames Eisenberg, and his fees were paid by Jeffrey Epstein, the target of the investigation! 'Attorney Edwards filed his Motion on behalf of "Jane Doe," without identifying which of his clients is the purported victim. Accordingly, I will address facts related to both C.W. and T.M. Both of those clients were victims of Jeffrey Epstein's while they were minors beginning when they were fifteen years old. 2.the undersigned does not know when Mr. Edwards began representing T.M. or whether T.M. ever formally terminated Mr. Eisenberg's representation. -2- EFTA00190507

S. In the summer of 2007, the U.S. Attorney's Office for the Southern District of Florida ("the Office") decided to enter into negotiations with Epstein to resolve the investigation. In September 2007, an agreement was reached. Pursuant to that agreement, Epstein was required to enter into negotiations with the SAO to enter into a guilty plea to the indictment already pending against him in state court, which charged felony solicitation of prostitution.3 Epstein also would have to convince the State Attorney's Office to file an Information charging him with a more serious offense, that is, an offense for which sex offender registration was required, specifically, the procurement of minors to engage in prostitution, and Epstein would have to plead guilty to that offense. Epstein also would have to negotiate a harsher sentence than the one requested by the State Attorney's Office, that is, eighteen months imprisonment, to be followed by twelve months of home confinement. Finally, Epstein would have to agree that the victims identified by the United States would be entitled to damages under federal law as though Epstein had been convicted at trial. This last provision was included at the Office's insistence, to put .the victims in the same position that they would have been if Epstein had been convicted at trial. 6. Prior to the final resolution, the agents and your Affiant made contact with several of the victims to advise them of this result. One of those victims who was contacted was T.M., via her attorney, James Eisenberg. Your Affiant informed Mr. Eisenberg that T.M. was on a list that would be submitted to Epstein of victims whom the Office had identified as being entitled to seek damages against Epstein. Your Affiant does not know whether Attorney Eisenberg ever provided this information to his client. However, less than twenty-four hours after this conversation, and before anyone from the Office had communicated the victim list to Epstein, attorneys for Epstein made contact with the Office complaining of the designation of T.M. as a victim. Epstein's attorneys used the designation of T.M. as a basis to allege prosecutorial misconduct against 3The indictment contained no reference to the victims' ages. -3- EFTA00190508

your Affiant, the agents, and others in the Office, and to raise those claims throughout the Office and up to the Department of Justice in Washington, D.C. 7. After the signing of the deferred prosecution agreement. your Affiant drafted a victim notification letter informing each victim of the resolution of the matter, the terms of the Agreement, and the date of the scheduled change of plea in state court. The Office provided a copy of that letter to Epstein's attorneys, who again complained about improper conduct by your Affiant and the agents. Epstein's counsel further argued that the CVRA did not apply because the proceedings would be held in state court, not federal court. The Office agreed to leave the issue of victim notification regarding the change of plea hearing to the State Attorney's Office, and your Affiant's letter was never sent to the victims. 8. Following several months of delay by Epstein's counsel, Epstein finally agreed to perform pursuant to the terms of the deferred prosecution agreement. On Friday, June 27, 2008, at approximate 4:15 p.m., your Affiant received a copy of the proposed state plea agreement and learned that the plea was scheduled for 8:30 a.m., Monday, June 30, 2008. Your Affiant, the agents, and the Palm Beach Police Department all attempted to provide notification to the victims, and your Affiant specifically called Attorney Edwards to provide notice to his clients regarding the hearing. Attorney Edwards informed your Affiant that he could not attend but that someone would be present at the hearing. Your Affiant attended the hearing, but none of Attorney Edwards' clients was present. -4- EFTA00190509

I declare under penalty of perjury, pursuant to 28 U.S.C. § 1746 that the foregoing is true and correct to the best of my knowledge and belief. Executed this day of February, 2007. A. Marie Villafafia, Esq. EFTA00190510

Case 1:08-cv-80736-KAM Document 1 Entered on FLSD Docket 07/07/2008 Firtaglyi DiD D.C. ELECT R UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA 08-80736-Civ-MARRA/JOHNSON CASE NO.: IN RE: JANE DOE, Petitioner. JULY 7, 2008 STEVEN M. LARIMORE CLERK U.S• DIST. CT. S.D. OF FLA. • MIAMI E:ners enc y VICTIM'S PETITION FOR ENFORCEMENT OF CRIME VICTIM'S RIGHTS ACT, 18 U.S.0 . SECTION 3771 COMES NOW the Petitioner, JANE DOE (hereinafter "Petitioner"), by and through her undersigned attorneys, pursuant to the Crime Victim's Rights Act, 18 U.S.C. Section 3771 ("CVRA"), and files this Petition for Enforcement in the above styled action as follows: I. Petitioner, an adult, as a minor child was a victim of federal crimes committed by JEFFREY EPSTEIN (hereinafter "Defendant"). These crimes included sex trafficking of children by fraud, in violation of 18 U.S.C. § 1591, use of a means of interstate commerce to entice a minor to commit prostitution, in violation of 18 U.S.C. § 2422, as well as wire fraud, in violation of 18 U.S.C. § 1343. The Defendant committed these crimes within the jurisdiction of the Southern District of Florida in Palm Beach County, Florida. 2. Upon information and belief, the Defendant is the subject of a federal criminal investigation conducted by the United States of America in the Southern District of Florida. The Defendant has recently been prosecuted and pleaded guilty, on June 30, 2008, in the Circuit Court for Palm Beach County to various similar state offenses including solicitation of minors for prostitution. 3. Upon information and belief, the Defendant is engaged in plea negotiations with thc Office of the United States Attorney for the Southern District of Florida concerning federal I W10 EFTA00190511

Case 1:08-cv-80736-KAM Document 1 Entered on FLSD Docket 07/07/2008 Page 2 of 10 v crimes which he is alleged to have committed against minor children, including the Petitioner. Such negotiations may likely result in a disposition of the charges in the next several days. 4. Under the CVRA, before any charges are filed against the Defendant, the Petitioner has the rights (among others) to notice of her rights under the CVRA, to confer with the prosecutors, and to be treated with fairness. As soon as charges are filed, the Petitioner has the rights (among others) to timely notice of court proceedings, the right not to be excluded from ilich proceedings, the right to be heard at such public proceedings regarding conditions of release, any plea, and any sentence, the right to confer with the attorney for the government. the right to restitution, and the right to be treated with fairness and with respect for her dignity and privacy. 5. The Petitioner has been denied her rights in that she has received no consultation with the attorney for the government regarding the possible disposition of the charges, no notice of any public court proceedings, no information regarding her right to restitution, and no notice of rights under the CVRA, as required under law. 6. The Petitioner is in jeopardy of losing her rights, as described above, if the government is able to negotiate a plea or agreement with the Defendant without her participation and knowledge. WHEREFORE, for the reasons outlined above, the Petitioner respectfully requests this Court to grant her Petition, and to order the United States Attorney to comply with the provisions of the CVRA prior to and including any plea or other agreement with the Defendant and any attendant proceedings. 2 20110 EFTA00190512

Case 1:08-cv-80736-KAM Document 1 Entered on FLSD Docket 07/07/2008 Page 3 of 10 MEMORANDUM I. THE CRIME VICTIMS' RIGHTS ACT MAKES CRIME VICTIMS INDEPENDENT PARTICIPANTS THROUGHOUT THE CRIMINAL JUSTICE PROCESS. In October 2004, Congress passed and the President signed into law the Crime Victims' Rights Act, Pub. L. No. 108-405, 118 Stat. 2251 (codified at 18 U.S.C. § 3771). Because this appears to be the first case involving the Act to come before this Court, a bit of background may be in order. A. The CVRA Gives Crime Victims Rights to Participate in the Criminal Justice Process. Congress passed the CVRA "to give crime victims enforceable rights to participate in federal criminal proceedings." Opinion at 14. Congress was concerned that in the federal system crime victims were "treated as non-participants in a critical event in their lives. They were kept in the dark by prosecutors too busy to care enough ... and by a court system that simply did not have a place for them." 150 CoNG. REC. S4262 (Apr. 22, 2004) (statement of Sen. Feinstein). To remedy this problem, Congress gave victims "the simple right to know what is going on, to participate in the process where the information that victims and their families can provide may be material and relevant ... ." Id. The CVRA gives victims of federal crimes a series of rights, including the right to notice of court proceedings, to be heard at plea and sentencing hearings, and to reasonably "confer with the attorney for the Government in the case." 18 U.S.C. § 3771(a). Victims also have a "right of access to the terms of a plea agreement ... ." In re Interested Party 1, 530 F.Supp. 2d 136, 2008 WL 134233 at *7 (D.D.C. 2008). The CVRA also assures victims broadly that they will "be treated with fairness." 18 U.S.C. § 3771(a)(8). 3 3 of 10 EFTA00190513

Case 1:08-cv-80736-KAM Document 1 Entered on FLSD Docket 07/07/2008 Page 4 of 10 isv Of course, these rights would be of little use to most crime victims unless they were told about them. To ensure that victims are notified of their rights, the CVRA directs employees of the Justice Department "and other departments and agencies of the United States engaged in the detection, investigation, or prosecution of crime" to use their "best efforts to see that crime victims are notified of ... the rights described [in the CVRA]." 18 U.S.C. § 3771(c)(1) (emphasis added). I B. The CVRA Gives Victims Rights During the Investigation of a Crime. The CVRA gives victims rights during the investigation of a crime. The Fifth Circuit recently reached this conclusion, holding: The district court acknowledged that "[tJhere are clearly rights under the CVRA that apply before any prosecution is underway." BP Prods., 2048 WI...501321 at *11,2008 U.S. Dist. LEXIS 12893, at *36. Logically, this includes the CVRA's establishment of victims' "reasonable right to confer with the attorney for the Government." 18 U.S.C. § 3771(a)(5). At least in the posture of this case (and we do not speculate on the applicability to other situations), the government should have fashioned a reasonable way to inform the victims of the likelihood of criminal charges and to ascertain the victims' views on the possible details of a plea bargain. In re Dean, 527 F.3d 391, 394 (51h Cir. 2008). The position that CVRA rights apply before charges have been filed is consistent with the Justice Department regulations under the CVRA, which explain that government officials "must advise a victim [about their rights under the CVRA) ... at the earliest opportunity at which it may be done without interfering with an investigation." A.G. GUIDELINES FOR VICTIM AND WITNESS I Further supporting this requirement is another statute, 42 U.S.C. § I0607(c)(3), which directs government officials to provide victims with "the earliest possible notice of," among other things, "the filing of charges against a suspected offender." 4 4 *110 EFTA00190514

Case 1:08-cv-80736-KAM Document 1 Entered on FLSD Docket 07/07/2008 Page 5 of 10 vet ASSISTANCE 23 (May 2005). And the plain language of the CVRA undergirds this conclusion, as it applies not simply to prosecutors but to government agencies "engaged in the detection [and] investigation ... of crime ... ." 18 U.S.C. § 3771(c)(1). Indeed, if there were any doubt, the plain language of the CVRA extends victims' right to situations "in which no prosecution is underway." 18 U.S.C. § 3771(dX3). IL PETITIONER IS A "VICTIM PROTECTED BY THE CVRA. Under the CVRA the crime victim is defined as "a person directly and proximately harmed as a result of the commission of a Federal offense ... ." 18 U.S.C. Section 3771(e). In particular, Defendant called Petitioner when she was a minor over a telephone (a means of interstate communication) requesting that she perform a massage in exchange for payment. As Defendant well knew, that request was fraudulent, as he not only intended to receive a massage, hut also intended to have her perform sexual acts in exchange for a cash payment to Petitioner. Only when Petitioner arrived at a Defendant's mansion as directed by Defendant, did Defendant reveal his true purpose of obtaining sexual favors in exchange for payment. This conduct violated 18 U.S.C. § 2422, which forbids using a means of interstate commerce to knowingly "induce" or "entice" a minor "to engage in prostitution." In addition, this conduct was both a use of "fraud" to obtain a commercial sex act, in violation of 18 U.S.0 § 1591, and use of wire communications to perpetrate a "scheme and artifice to defraud," in violation of 18 U.S.C. § 1343. It appears obvious that Petitioner was "directly and proximately" harmed by these crimes, thereby making her a victim under the CVRA. It should be emphasized that the CVRA "was designed to be a 'broad and encompassing' statutory victims' bill of rights." United States I. 5 Sof TO EFTA00190515

Case 1:08-cv-80736-KAM Document 1 Entered on FLSD Docket 07/07/2008 Page 6 of 10 Degenhardt, 405 F.Supp.2d 1341, 1342 (D. Utah 2005) (quoting 150 Cong. Rec. S4261 (daily ed. Apr. 22, 2004) (statement of Sen. Feinstein)). Congress intended the CVRA to dramatically rework the federal criminal justice system. In the course of construing the CVRA generously, the Ninth Circuit observed: "The criminal justice system has long functioned on the assumption that crime victims should behave like good Victorian children -- seen but not heard. The Crime Victims' Rights Act sought to change this by making victims independent participants in the criminal justice process." Kenna'. U.S. Dist. Court for C.D. Cal., 435 F.3d 1011, 1013 (9th Cir. 2006). Accordingly, because the CVRA is remedial legislation, courts should interpret it "liberally to facilitate and accomplish its purposes and intent." Elliott Industries Ltd. Partnership'. BP America Production Co., 407 F.3d 1091, 1118 (10th Cir. 2005) (noting remedial legislation should be "interpreted liberally to facilitate and accomplish its purposes and intent"). The CVRA itself suggests this conclusion by requiring that courts must treat crime victims with "fairness." United States'. Patkar, 2008 WL 233062 at *3 (D. Haw. 2008) (citing United States.. Turner, 367 F.Supp.2d 319, 335 (E.D.N.Y. 2005)). Not only must the CVRA as a whole be interpreted liberally, but its definition of "crime victim" requires a generous construction. After reciting the direct-and-proximate-harm language at issue here, one of the Act's two co-sponsors -- Senator Kyl -- explained that "[t]his is an intentionally broad definition because all victims of crime deserve to have their rights protected 150 Cong. Rec. SI 0912 (Oct. 9, 2004) (emphasis added). The description of the victim definition as "intentionally broad" was in the course of floor colloquy with the other primary sponsor of the CVRA and therefore deserves significant weight. See Kenna, 435 F.3d at 1015-16 (discussing significance of CVRA sponsors= floor statements). 6 ono EFTA00190516

Case 1:08-cv-80736-KAM Document 1 Entered on FLSD Docket 07/07/2008 Page 7 of 10 vet The definition of "crime victims" must thus be construed broadly in favor of Petitioner. She obviously qualifies as a "victim" under the CVRA. HI. PETITIONER IS ENTITLED TO NOTICE OF HER RIGHTS, AN OPPORTUNITY TO CONFER WITH THE PROSECUTORS AND TO BE TREATED WITH FAIRNESS. Because Petitioner is a "victim" under the CVRA, she has certain protected rights under the Act. Most important, the Act promises that she will have an opportunity to "confer with the attorney for the Government in the case." To date, Petitioner has not been given that right. This raises that very real possibility that the Government may negotiate and conclude a plea agreement with the Defendant without giving Petitioner her protected rights.2 Petitioner is entitled to have this conference with prosecutors before any final plea agreement is reached. The Fifth Circuit reached exactly this conclusion in a very recent case. In In re Dean, 527 F.3d 391 (5th Cir. 2008), the Government negotiated a plea agreement with the well-heeled corporate defendant without conferring with the victims. When the Government's failure was challenged in the Fifth Circuit, the Fifth Circuit concluded that the Government had indeed violated the CVRA. The Fifth Circuit observed: "In passing the [CVRAJ, Congress made the policy decision-which we arc bound to enforce-that the victims have a right to inform the plea negotiation process by conferring with prosecutors before a plea agreement is reached." Id. at 394. This Court is obligated to protect the rights of Petitioner. The CVRA directs that "IiIn any court proceeding involving an offense against a crime victim, the court shall ensure that the 2 On information and belief, roughly the same crimes were committed against several other young females. These victims, too, are in danger of losing their right to confer under the CVRA. 7 of 10 EFTA00190517

Case 1:08-cv-80736-KAM Document 1 Entered on FLSD Docket 07/07/2008 Page 8 of 10 crime victim is afforded the rights described in [the CVRA]." 18 U.S.C. § 3771(b)(1). The CVRA also confers on crime victims the right to "assert the rights described in [the CVRA]." 18 U.S.C. § 3771(d)(1). Therefore, this Court has its own independent obligation to intercede and ensure that the Government respects the rights of Petitioner under the CVRA. CONCLUSION The Petitioner requests the intervention of this Court to ensure that her rights are respected and accorded, as promised in the Crime Victims' Rights Act. DATED this 7th day of July, 2008. Respectfully Submitted, THE LAW OFFICE OF BRAD EDWARDS & ASSOCIATES, LLC Brad Edwards, Esquire Attorney for Petitioner Florida Bar #542075 2028 Street Suite 202 Hollywood, Florida 33020 Telephone: 954-414-8033 Facsimile: 954-924-1530 8 ono EFTA00190518

Case 1:08-cv-80736-KAM Document 1 Entered on FLSD Docket 07/07/2008 Page 9 of 10 CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the above and foregoing has been provided by United States mail and via facsimile to: ANN MARIE C. VILLAFANA, AUSA, United States Attorney's Office, 500 South Australian Avenue, Suite 400, West Palm Beach, Florida 33401, this 7th day of July, 2008. Brad Edwards, Esquire Attorney for Petitioner Florida Bar No. 542075 9 9 of 10 EFTA00190519

08 -89DOSSINA/rIPAPP NEntered on FLSD Docket 07/07/2008 'son 44 'Eat.I Om CIVIL COVER SHEET JS 44 cm Icon, sheet and the infomulion contained harm metiers eplace nor supplement the filingand setsice of pleadings. other papers a by local rules of :nun. This form approved by the Judicial Conference of the United Stain in Scolvmhci 1974, is required IX the ux of the (kik ix civil cockel street ISLE INS7RUC IILINS UN IRO RE' LOSE OF THE FORMS NOTICE: Attorneys MUST Indicate All Re-filed I. (a) PLAINTIFFS -6) r e: Dane Poe (b) Coonry of Residence of Fim Listed Plaintiff f;thri ea, in( EPS IN V.S. PLAINTIFF t As(' %I IC) Ira Vs. Adam. inol Temps**. Nissobcii t•La Cal le f 624.41,es d'ssooirtes tor S Ahn45-an Cfere-e .51./Cre 202. /41/ 400 0 • 1 Fe 33 O2O I V Check Carney Where AC0011 Arose 7 MIAMI. DADE 3 MONROE 3 BROWARD XPALM MACH DEFENDANTS Pt/ / resat 54 "t e c CFI klelry cl aD ) D.C. JULY 7, 2008 STEVEN M. 1. ARIMORE CLERK U.S. 01ST. CT. S.O. 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Real Prowl, 3 441 Vsilmig 3 441 Emplopmmtl 3 SO II amis. Acts1404.1•1441• 3 444 W•Ifav 443 Amos. is Diaabintot • 3 Emplossa, 3 444 Amer. 4 Onabilmat • U.S., X440 ODD ( Ad PAIN 3 4111 Notion, in VDay Stns.., Hato C : I 130 (4114tal 3 313 044th 004117 3 540 Maisdainua • Olbel 3 350 , i" Kolb 3 555 Prisesteedition 3 *30 I att. II. 6 PINnikfl or OVINJ a eill 7 VI IRS 10.i41 Parry : l• LS( 7500 I • 3 4.2 it "wallah" App...4.54 3 463 Han. 4.744.45.A lin Du ttttt 3 4" tub" I°. ... Aci•ii " . ORIGIN I Original Proem ing IPlec• Ph... - R- in Om flot Unts I 3 2 Removed from 3 3 Re-Med- &SIC Coon IKE VI below) Tram erred from 0 4 Reinstated a 0 5 moony dimi ct r.) 6 Muludistries Reopened (specify) Litigation Appeal to District 3 7 'Inge horn Magistrate Judgment VII. RELATED/RE-FILED (:ASE(S). a) Re-filed Case 0 YES ONO b) Related Cases 3 YES 3 NO kt int4,404/4, oar/ Mel JUDGE DOCK F.T NUMBER Ci t the U.S. Civil Statute under which you are filing and Write a Brief State-atm of Cause (Do sot titejorlsdktional statutes unless Mundt)* Crojble et9 A,Ps 4 ir itusc S77) re VII. CAUSE OF ACTION -frOs ion en be ho. If ocric i. ;44 $ 5ex OercenS •RS to c ot (Toes eA/ h r-cy Art 'oder # LENGTH OF TRIAL via 1 days estimated h sides to My entire easel REQUESTED IN COMPLAINT: O CHECK If THIS IS A CLASS ACTION DEMANDS UNDER F.R. C.P. 23 CHECK YES only if domande! In complaint; JURY DEMAND: 3 Yrs 3 No BOVE INFORMATION IS TRUE & CORRECT TO THE BEST 1W MY KNOWLEDGE SIUNATU DAtl FOR OFFICE ESE ONLY AMOUNT35 -0 re . MI CIFT 72‘190311, 50 4110 EFTA00190520