Villafana, Ann Marie C. (USAFLS) From: Sloman. Jeff (USAFLS) Sent: Monday, October 22, 2007 5:26 PM To: Villafana, Ann Marie C. (USAFLS); Acosta, Alex (USAFLS) Subject: Fw: Epstein Fyi Sent from my BlackBerry Wireless Handheld Original Message From: Sloman, Jeff (USAFLS) To: '[email protected]. <[email protected]> Sent: Mon Oct 22 17:23:30 2007 Subject: Re: Epstein I l I have not spoken to him b ' was our intention to assign the decision to select a lawyer to Judge not for him to represent the girls. We do not want to select the lawyer w o l represents the girls. I don't know who said he'd do it but it wasn't us. Sent from my BlackBerry Wireless Handheld Original Message From: Jay Lefkowitz <[email protected]> To: Sloman, Jeff (USAFLS) Cc: Acosta, Alex (USAFLS); Villafana, Ann Marie C. (USAFLS) Sent: Mon Oct 22 17:10:00 2007 Subject: Re: Epstein Jeff -- I will review these materials this evening and be in touch with you tomorrow with the expectation of wrapping this up by nd of the day. One question I have, however, is why you say that Judge is a non-starter. I understood that he was ready, willing and able to serve as the attorney representative. If you have had conversations with him and that is not the case, please let me know. I will go over the other issues you raise in your email and will look forward to speaking tomorrow. Thanks -- Jay "Sloman, Jeff (USAFLS)" <][email protected]> 2691 EFTA00225414

10/22/2007 04:40 PM To "Jay Lefkowitz" <[email protected]> cc "Acosta, Alex (USAFLS)" [email protected]>, "Villafana, Ann Marie C. (USAFLS)" <[email protected]> Subject Epstein Jay, The Judge issue is a non-starter. We've beaten that horse to death. Regarding your contention that "the attorney representative be told clearly that Mr. Epstein has agreed to pay the lawyer's hourly rate only for the time he or she spends working to effectuate settlements for the identified women," Alex and I agree that paragraph 7C is sufficient, Regarding the other points, we have made the following concessions: 1. Regarding the language concerning a lawyer whose firm is sizeable enough to litigate multiple trials simultaneously, I have removed paragraph 4 on page 3 of the letter. 2. Regarding the 150k statutory limit language, I have included a footnote which should satisfy your concern. 3. Regarding language there may be discovery to test the claims of alleged "victims", please see new paragraph 4 on page 3 which now states as criteria that the firm should have "Experience litigating against large law firms and high profile attorneys who may test the veracity of the victims' claims." I have attached the Addendum and the revised letter to Judge Jay, this needs to be concluded. Alex and I believe that this is as far w can go. Therefore, please advise me whether we have a deal no later than COB tomorrow, Tuesday, October 23, 2007. Thanks, Jeff Original Message From: Jay Lefkowitz [mailto:][email protected]] Sent: Friday, October 19, 2007 4:05 PM To: Sloman, Jeff (USAFLS) Subject: Re: Jeff - 2692 EFTA00225415

I have reviewed your proposed language and wanted to raise a few areas of concern. First, I am not sure why we are not just asking Judge to represent these women. If he is available, that would save us a whole a itional layer of process. I had thought that was initially the idea. I am not sure why you seem to be moving in another direction. I also cannot understand why the draft affirmatively requests that J select a lawyer whose firm is sizeable enough to litigate multiple trials simultaneously. That seems to be directly at odds with the purpose of the agreement, which is to facilitate out of court settlements. Indeed, to the extent any woman were to elect to bring an action against Mr. Epstein, she would not only be free to select any lawyer of her choice, but would be restricted from using the lawyer representative in this capacity due to the conflicts of interests that would cause. This part of your proposed language is of signficiant concern to me. Your letter also indicates the 150k statutory limit without reference to the pre-existing 50G limit. To be sure, any of the women are free to seek whatever settlement they want, but given the question that exists about the statutory amount, the letter should not state definitely that it will be 150k. In addition have omitted a few important items from your proposal. Given that Judge or any other potential attorney representative should understand the scope o e work, the language should make clear that there may be discovery to test the claims of alleged "victims." Finally, I think it is important that the attorney representative be told clearly that Mr. Epstein has agreed to pay the lawyer's hourly rate only for the time he or she spends working to effectuate settlements for the identified women. Jay Original Message From: "Sloman, Jeff (USAFLS)" [[email protected]] Sent: 10/17/2007 01:58 PM AST To: Jay Lefkowitz Subject: RE: <<071015 Special Master Letter2.wpd» Jay, Here's our proposed letter to the special master. Jeff Original Message From: Jay Lefkowitz [mailto:[email protected]] 2693 EFTA00225416

Sent: Tuesday, October 16, 2007 9:26 AM To: Sloman, Jeff (USAFLS) Subject: Jeff - is there a time today we can speak? How about 430 pm? *********************************************************** The information contained in this communication is confidential, may be attorney-client privileged, may constitute inside information, and is intended only for the use of the addressee. It is the property of Kirkland & Ellis LLP or Kirkland & Ellis International LLP. Unauthorized use, disclosure or copying of this communication or any part thereof is strictly prohibited and may be unlawful. If you have received this communication in error, please notify us immediately by return e-mail or by e-mail to [email protected], and destroy this communication and all copies thereof, including all attachments. #4********#4 , ###tt4c#4***********####*********************### #********####4 , 4, **************###*t#ti,*#*#44 , *********4.44.44 2k# The information contained in this communication is confidential, may be attorney-client privileged, may constitute inside information, and is intended only for the use of the addressee. It is the property of Kirkland & Ellis LLP or Kirkland & Ellis International LLP. Unauthorized use, disclosure or copying of this communication or any part thereof is strictly prohibited and may be unlawful. If you have received this communication in error, please notify us immediately by return e-mail or by e-mail to [email protected], and destroy this communication and all copies thereof, including all attachments. 2694 EFTA00225417

EXHIBITS TO WRITTEN RESPONSE OF A. MARIE VILLAFANA Exhibit # Date Description I 5/1/2006 Letter from Chief Rcitcr to State Attorney Krischer 2 5/23/2006 File Opening Documents 3 7/3/2007- 7/13/2007 Emails between Criminal Chief Matt Menchel and AUSA Villafaiia regarding plea negotiations. 4 7/31/2007 Tenn Sheet for Epstein Non-Prosecution Agreement 5 Undated File folder entitled 'Meeting Timeline' with contents 6 7/24/2006 Letter from Chief Reiter to victims informing them of FBI investigation 7 7/26/2006 South Florida Sun-Sentinel Article Regarding Chief Reiter's referral of case to FBI 8 8/2/2007 Lilly Ann Sanchez email to Matt Menchel with attached letter containing counter- proposal for plea to two years of 'supenised custody.' 9 8/24/2006- 10/24/2006 Entails betweenJim Eisenberg and Marie Villafana regarding #28 10 10/30/2006- 10/31-2006 Emails between Marie Vitt:liana and Guy Lewis regarding Lewis respresentation of Epstein II 11/8/2006- I/8/2007 Emails between Marie Villatana and Lilly Ann Sanchez regarding Sanchets representation of Epstein 12 8/4/2006 Victim Notification Letters 13 WI1/2006 Victim Notification Letters 14 1/17/07- 2/1/07 Correspondence between Lilly Ann Sanchez, Gerald Lelcourt, Andrew Laurie, A. Marie Villafrina, and John McMillan regarding 2/1/2007 Meeting 15 11/13/06- 1/22/07 Subpoenas to Adrian Mucinska and research re 6001 immunity 16 9/26/2006 Memo regarding Changes to Child Exploitation Statutes in Tide 18 17 2/6/2007 Transcript of Kuyrkendall Testimony 18 2/27/2007 Transcript of Kuyrkendall Testimony 19 3/15/2007 Victim Notification Letter 20 3/20/2007 Transcript of Kuyrkendall Testimony 21 4/24/2007 Transcript of Kiwrkendall Testimony 22 4/24/2007 ' I 't a irseript of #37 Testimony 23 5/8/2007 Presentation Materials 24 5/8/2007 Transcript of Kuyrkendall Testimony 25 5/8/2007 Transcript of Richards Testimony 26 5/14/07- 5/21/07 Emats between Andrew Laurie, Mau MencheLjeff Sloman, mid Marie Villakula 27 5/15/2007 Transcript of Kuyrkendall Testimony 28 5/22/07- 5/24/07 Emails between Andrew Laurie, Gerald Lel-court, Man Mencheljeff Sloman, Marie Villafaiia, Lilly Ann Sanchez, and Karen Atkinson regarding second meeting with counsel for Epstein 29 5/22/2007 Transcript of Kuyrkendall Testimony 30 6/7/2007 Victim Notification Letters 31 6/14/07- 6/21/07 Entails between Marie Villafaiia, Karen Atkinson, Andrew Laurie, Mau Menchel, and Jeff Martian regarding addendum to Pros Memo, grand jury presentation, changes to indictmer it. and meeting with counsel for Epstein. 32 6/25/2007 Letter from Gerald I efcourt tojeffrey Montan and Andrew Laurie regarding 6/26/2007 meeting and emails and notes regarding same. PRIVILEGED and CONFII)ENTIAL Page 1 of 10 CONTAINS 6(c) MATERIAL EFTA00225418

EXHIBITS TO WRITTEN RESPONSE OF A. MARIE VILLAFANA Exhibit 41 Date Description 33 7/6/2007 Letter from Gerald l.efcourt and Alan Dershonia toJeffrey Sloman and Andrei Londe arguing against federal prosecution. 34 7/13/2007 Letter from Roy Black to Marie Villa' la with handwritten attorney Lourie notes 35 7/25/2007 latter from Gerald l.efrourt and Alan Dershowia to Matthew Menchel arguing that no charge can or should be made under 18 U.S.C. S 2422(b). 36 7/26/2007 Email from Marie ViIlafaria to Matt Menchel and Andrew Lourie regarding proposed changes to indictment. 37 7/27/2007 - 8/8/2007 Research regarding 18 U.S.C. S 2255 38 7/81/2007 Email from Marie ViKaiak toJeff Molnar], Man Menchel, and Andrew Lourie summarizing proposed plea terms as per Menchel recommendation 39 7/81/07- 8/3/07 7/31/2007.8/3/2007 Entails between Jeff Montan, Matt Moretti, Andrew Louric, and Marie VilLafaria regarding plea negotiations, including draft response to Nutter counsel regarding proposed agreement 40 8/2/2007 Letter front Lilly Ann Sanchez to Matthew Menchel containing counter-proposal of 2 years' supervised custody with two additional years of probation and internal correspondence regarding same. I I 8/3/2007 Letter from Matthew Menchel to Lilly Ann Sanchez rejecting counterproposal, setting a deadline of 8/17/2007, and advising that LISA Acosta was not inclined to meet with counsel for Epstein, and internal entails regarding same. I.? 8/6/2007 Entails from Marie Villafaila to Cyndee Campos, Frederica Devlin, and Jeff Sloman to determine whether Malt Matchers 8/3/2007 letter went out before he resigned from the U.S. Attorney's Office. 43 8/7/2007 Entails between Drew Oosterbaan, Andrew Laurie, Marie Villafafia, Alex Acosta, Jeff Slontan, and Cyndee Campos regarding request front Epstein's counsel for meeting with CEOS and background of case l 1. 9/4/07- 9/6/07 Entails betweenJeff Molnar', Marie Villafak, Andrew Laurie, Drew Oosterbaan, and Rolando Garcia regarding planned meeting with Epstein defense team and need to confer with victims. I. 9/10/2007 Entails betweenJeff Sloman, Marie Villafafia,John McMillan, and Andrew Larne regarding USA Acosia's inquiry regarding the state grand jury investigation IS 9/10/07- 9/19/07 Entails between Alex Acosta, Jeff Montan, Andrew Laurie, Rolando Garcia, Karen Atkinson, Marie Villafafia, andJohn McMillan regarding plea negotiations 47 9/10/07- 9/11/07 Entails from Marie Viktoria to Gerakl I cfcourt with proposed Non-Prosecution Apvements PI 9/11/07- 9/13/07 Entails between Marie Vilkdafia and Drew Oosterbaan regarding proposed Non- Prosecution Agreement, including research on proposed tnist fund. 19 9/ 1 2/2007- 9/24/2007 Entails between Marie Villafidia and Jay I.elkowitz re plea negotiations 50 9/21/2007 Research re Florida Statutes 51 9/23/2007 Entails between Alex Acosta and Jay Lelkowitz re pica negotiations PRIVILEGED and CONFIDENTIAL. Page 2 of 10 CONTAINS G(e) MATERIAL EFTA00225419

EXHIBITS TO WRITTEN RESPONSE OF A. MARIE VILLAFANA Exhibit (t Date Description 52 9/24/2007 Signed non-prosecution agreement 53 6/18/2007 Letter to Gerald Lefcourt re subpoena to NES, LLC and Jute 26, 2007 meeting 54 5/21/2007 Email regarding guidance on grand jury presentation 55 12/3/2007 Entails from Marie VillafaLfia to Alex Acosta regarding research on proposed trust fund. 56 3/22/2007 Entails between Marie Villafafia and IRS supervisor regarding money laundering research 57 Case regarding nunicy laundering and aiding & abetting 58 2/12/2007 Entails between l'illafafia and Lilly Ann Sanchez regarding employee representation with Lourie and Villafafia handwritten notes 59 5/21/2007 Subpoena to Paul A. Lavery 60 6/18/2007 Subpoena to Witham Riley 61 «18/2007 Subpoena to Riley Kiraly 62 7/18/2007 Email from Villafaita to Matt Menthe! regarding Roy Black objection to subpoenas addressed to William Riley and Riley Kiraly 63 7/19/2007 Entails between A/Malaita, Menthe!, and Loire regarding service of target letters. 64 7/26/2007 Email from Villarafia to Man Menthe) and Andrew Londe regarding reconunended revisions to indictment 65 8/1/2007- 8/2/2007 Entails between Menthe! and Villakdre regarding plea negotiations 66 9/10/2007 Proposed Non-Prosecution Agreement provided to Gerald Leleourt on 9/10/2007 67 9/11/2007 Proposed Non-Prosecution Agreement incorporating Acosta edits provided to Gerald Lefeourt on 9/11/2007 68 6/18/2008- 6/19/2008 Entails between Villafafia, Krischer, Atkinson, Senior, Acosta, Sloman. and Garcia regarding Epstein's case with state court and how it might breach the NPA 69 12/14/2007 Draft letter to Kriseher front Acosta regarding Epstein filing as sex oftender 70 9/16/2008- 9/17/2008 Entails between Villarafia, Krischer, Belohlavek, Garcia, Sloman, and Atkinson regarding Palm Beach Daily News requesting copy of the NPA and discussion 71 «30/2008 Entail front Drew Oosterbaan rc Epstein guilty plea 72 11/14/2007 Entail from Villafafia to Stomata regarding meeting with State Attorney's Office about work release and sex offender registration 73 12/6/2007- 12/7/2007 Entails between Lamm Belohlavek, Marie Villafafia, and Jeff Sloman regarding a factual proffer for state plea 74 12/14/2007 Email from Villafafia to Acosta and Sloman regarding hl. Stat. 796.03 and 2255. 75 12/14/2007 Email front Villafafia to Acosta with three letters requested by Acosta 76 11/15/2007- 11/16/2007 Entails between Richards, Villafafia, Slontan, Garcia, Acosta, and Atkinson regarding work release 77 6/27/2008- «28/2008 Entails between Vilkifafia, Goklberger, and Black regarding issues with state plea agreement 78 «17/2008 Entail from Villafaita to Acosta, Sloman, Senior, Atkinson, and Garcia summarizing meeting with Krischer regarding Epstein's attempt to negotiate a new plea deal PRIVILEGE') and CONFIDENTIAL Page 3 of 10 CONTAINS 6(c) MATERIAL EFTA00225420

EXHIBITS TO WRITTEN RESPONSE OF A. MARIE VILLAFANA &hint # Date Description 79 6/27/2008 Entail from 3rillafaita to Montan summarizing conversation with Goldberger that Epstein would serve sentence in confinement '24-bouts-a-day 80 6/29/2008 Email from Kuyrkendall to Villafana regarding work release 81 7/3/2008 Email from Villafiula to Sloman providing update on meeting with Col Gauger at PBSO regarding work release 82 11/20/2008. 1 iip2 mow Entails between Villafafia, Senior, Acosta, Slontan, Atkinson, and Garcia regarding Epstein work release 83 12/9/2008 Research materials regarding Epstein's work release application 84 12/11/2008 VilLiana letter to Capt. Sleeth, Palm Beach Sheriffs Office, mganling Epstein's work release application 85 6/9/2009 Vadatla Memorandum to Sloman, Senior, Garcia, awl Atkinson seeking permission to declare breach with attachments awl proposal breach letter 86 6/9/2009 Signed indictment package 87 6/12/2009 Villafaiia letter to Goldberger providing notice of breach of NPA 88 6/15/2009 Villafana letter to Lclkowitz, Black, and Goldberger regarding history of Epstein's performance under the NPA 89 6/17(2009 Villafaila letter to Lelkowitz regarding monitoring future performance under the NPA 90 9/1/2009 Black letter to Montan seeking approval for Epstein to transfer community control to the Virgin Islands 91 9/18/2009 Villafaila letter to Black explaining Olfwe's concerns about Epstein's application for transfer to the Virgin Islands A-1 Timeline of Events B-1 Chart addressing Question B.2 11-2 11/19/2007 Plea notification letter datal 11/19/2007 B-3 11/27/2007 Plea notification letter dated 11/27/2007 at 7:11 pm (formatting problem convening from Word Perfect) B-4 11/28/2007 Victim notification letter prepared II/28/2007 at 9:42 pm B-5 12/1/2007 Victim notification letter prepared 12/1/2007 at 7:50 pm 1.6 12/7(2007 Victim notification letter prepared 12/7/2007 at 9:10 pm (formatting problem) 13-7 11/19/2007 Research rc Florida Statute 921.143 B-8 11/28/2007 Email chain between Jay Lelkowitz an dJeff Sloman forwarded to Marie Villaftula B-9 11/29/2007 Letter from Jay Lelkowitz to Alex Acosta re CVRA - victim notifwation letter B-10 II/30/2007 Letter from Alex Acosta to Jay Lefkowia rc Victim Notification letter B-11 12/5/2007 Letter from Ken Starr and Jay I adkowitz to Alex Acosta requesting updated draft victim letters B-12 12/6/2007 Letter from Jeff Mont an to Jay Lefkowitz attaching victim notification letter B-13 12/6/2007- 12/7/2007 Internal entails about need to notify victims of upcoming plea PRIVILEGED and CONFIDENTIAL. Page 4 of 10 CONTAINS 6(c) MKITRIAL EFTA00225421

EXHIBITS TO WRITTEN RESPONSE OF A. MANE VILLAFAHA Exhibit # Dale Description B-14 12/7/2007 Victim notification letters and envelopes that were never sent 13-15 12/7/2007 Letter from Lilly Ann Sanchez with 1/4/2008 plea date 13-16 12/14/2007 Draft Victim Notification Letter prepared I WI4/2007 at 9:57 pm (formatting problem) 13-17 12/14/2007 Email from Marie Villafana to Alex Acostadcff Sloman, Rolando Garcia, and Karen Atkinson with victim letter attached B-18 12/17/2007 Email from Marie Villafana to Jeff Sloman reiterating concerns about failure to notify victims 13.19 12/19/2007 Entails between Alex Acosta,JeffSloman, and Marie Villafafta with draft and final letter to Lilly Ann Sanchez, including promise not to provide victims with notice of state change of plea hearing. 13-20 19/11/2007 Email from Marie Villafana toJeff Sloman and Alex Acosta regarding call with Jim Eisenberg 13.21 12/21/2007 Letter from Jay Lefkowitz to Alex Acosta re wanting to sec victim list B.22 12/26/2007 Letter from Jay Lelkowitz. to Alex Acosta re right to review victim notification letter and belief that it should come from State Attorney's Office 13.23 3/10/2008. 3/12/2008 Entails regarding Epstein attempts to contact victims and finding counsel for victims 13-24 5/15/2008 Letter from Drew Oosterbaan toJay Lelkowitz denying challenge to federal prosecution 13.25 3/14/2008 Revised indictment package B-26 3/18/2008 Grand jury presentation materials and transcript 13-27 3/14/2008 Entails between Marie Villafana, Rolando Garcia, Karen Atkinson, Frederica Devlin, and Shawn Ball rc complete indictment package for Robert Senior review B-28 3/28/2008 Letter from Ken Starr to DAAG SW Mandelker with additional objections B-29 4/29/2008 Summary chart and outline for grand jury presentation B-30 4/29/2008 Draft Indictment 15-31 10/9/2007- 3/25/2008 FBI Interview Reports of— (10/05/2007, 3/20/2008, and 3/25/2008), #2 (10/10/2007), #14 (10/26/2007), #33 (10/02/2007), #20 (10/25/2007), #21 (10/0W2007), - (10/0W2007), — (10/02/2007), #40 (6/12/2007), and #35 (10/02/2007) 13-32 5/19/2008 Letter fromMI.310mm toJay Lefkowitz settingJune 2, 2008 deadline to comply with tenns and conditions of the NPA 1333 5/19/2008- 512712008 Ken Starr/Whitley letters to Deputy Attorney General Mark Filip 13-34 5/27/2008- 6/13/2008 Internal entails after CEOS letter rejecting appeal where Marie Villafana asks to indict andJeff/Alex advise Epstein will be given chance to perform 13-35 5/19/2008 Correspondence between Alex Acosta,Jeff Slomah, and Jay Lelkowitz 1336 5/19/2008 Email from Alex Acosta toJay Lefkowitz responding to Lefkowitz email 1337 5/19/2008 Kirkland & Ellis LIP, Response to letter by FAUSA Sloman dated 5/19/2008 - 10 pages (RFP8) B-38 5/27/2008 Emails between Bob Senior, Jell Montan, Marie Villafana, and Karen Atkinson regarding indictment review and no further plea negotiations B39 5/27/2008 Emails between Marie Villarafia and Karen Atkinson regarding report of new state pica deal PRIVILEGED and CONFIDENTIAL Page 5 of 10 CONTAINS 6(c) MATERIAL EFTA00225422

EXHIBITS TO WRITTEN RESPONSE OF A. MARIE V1LLAFANA &Wait # Date Description B-40 5/29/2008 Email from Jell Sloman to Marie Villafafta, Bob Senior, Karen Atkinson, E. Nesbitt KtnTkendaII, and Jason Richards informing them that l)AG Filip agreed to review matter and that grand jury presentation was canceled 13-41 8/28/2008 Letter front Michael Danchuk to Marie Villafaila regarding victim representation and filing suit against Epstein in state court 13-42 4/9/2008 Mai is Villafana letter to Richard II. Willits (formatting problem) 13-43 6/18/2008 Marie Villalana handwritten notes re calls with Brad Ed wards and Roy Black B-44 6/23/2008 John Roth letter to Kan Starr and Jay Lelkowitt 13-45 6/24/2008 Em.ias between Roy Black, Jack Goldberger, and Marie Villafaiia re wrap up 13-46 6/25/2008 Email from Jcff Montan to Marie Villafafia regarding conversation about 225.5 issue and enui of guilt' plea 1147 6/25/2008 Email from Jeff Sloman to Marie %Adana with attached revised victim notification letter 13-48 6/25/2008 Entails between Marie Villafaila,JcITSIontan, Bob Senior, Karen Atkinson, and Alex Acosta regarding draft of notification of victim list for Jeffrey Epstein counsel with attached drafts 13-49 6/23/2008 Entails betweenJeff Sloman, Bob Senior, and Marie Vitt& instructing Marie Villafana to inform Epstein's attorneys that lie had untiLlune 30 to enter a guilty plea and Villafaita email to Lelkowitz re same. 13-50 6/26/2008 Fax from FBI with final victim list B-51 6/27/2008 Confirmation from police and Epstein's counsel of plea on 6/30/2008 13-52 6/27/2008 Email from Villafaiia to Sloman inquiring about conversation with Chief Reiter. 13-53 6/28/2008 Entails between Villafafm andJeff Montan regarding Chief Reiter providing notifications to victims. B-54 1W7 /2007 Email fmmJeff Montan to Marie Villafana instructing her not to send victim notification letter 13-55 6/30/2008 Notes from calls with attonwys M. Danchuk, R. Willits, J. Herman, B. Edwards. T. Leopokl, and M. Dutko 13,56 6/80/2008 Draft notification of identified victims letters 13-57 7/8/2008 Letter from Marie %Palatal., to Jack Goldberger re victim notification letter 1348 7/8/2008 Letter from Jack Goklberger to Marie Villafaiia that he will respond on 7/9/2008 8.59 7/9/2008 Email from Marie Villafafta to Alex Acosta, Jeff Stoma, and Karen Atkinson re Goldberger letter 11-60 7/9/2008 letter from Marie Villafana to Jack Goldberger regarding notification of identified victims 13.61 7/9/2008 Letter fromJack Goldberger to Marie Villafaita re notification of identified victims B-62 7/10/2008 Letter front Marie Villafana to Jack Goldberger informing him that victim notifications will be provided on a rolling basis 11-63 7/10/2008 letter front Marie Villafana to Goldberger with final notification of identified victims PRIVILEGED and CONFIDENTIAL Page 6 of 10 CONTAINS 6(e) MATERIAL EFTA00225423

EXHIBITS TO WRITTEN RESPONSE OF A. MARIE VILLAFANA Exhibit # Date Description 11-61 7/10/2008 Letter fromJack Goldberger to Marie Villafana requesting list of all victims 11-65 7/10/2008 Email from Jeff Sloman to Marie Villafafta, Alex Acosta, Karen Atkinson, E Nesbitt Kuyrkendall, and Jason Richards regarding proposed response to Jack Goldberger 15-66 7/9/2008 Victim Notification Letters to inditiduals #35 and 43 13-67 7/10/2008 Victim Notification Letters to individuals #3, 8, 17, 25, 26, 37, and I I B-68 7/14/2008- 7/15/2008 Emails between Marie Villafana, E. Nesbitt Kuyrkendall,Jason Richards. and Twiler Smith re FBI victim notifications 15-69 7/18/2008- 7/21/2008 Emails between Marie Villafana, Jeff Montan, E. Nesbitt Kuyrkendall, Jason Richards, Dexter Lee, and Karen Atkinson rc preparation of victim notificatiot I letters and victim contact list and victims that Miler still needs to make contact with 13-70 7/21/2008 Victim Notification Letters to individuals NI, 2, 4, 9, IS, 14, 21, 23, 30, 32, and 38 B-71 8/5/2008 Email from Marie Villafaffa to Alex Acostajeff Montan, Bob Senior, and Karen Atkinson regarding analysis ofJeffrey Epstein agreement, with attached 6/24/2008 email from A. M. Villafafia to R. Black midi. Goldberger and attached Epstein agreement 13-72 8/5/2008 Email from Alex Acosta to Marie Villafatla, Bob Senior, Jeff Simian, Dexter Lee, and Karen Atkinson with attached suggestions to Superseding Non-Prosecution Agreement 13-73 8/7/2008 Email from Roy Black to Marie Villafana responding to 8/7/08 email providing notification of possible compelled disclosure of the Non-Prosecution Agreement B-74 8/6/2008 Email response from Bob Senior to Marie Villafaila regarding Roy Black's response to email B-75 8/12/2008 Email response from Bob Senior to Marie Villafana to request for conference call prior to call with Roy Black B-76 8/13/2008 Email from Bob Senior to Karen Atkinson, Alex Acosta, Jeff Montan, Dexter Lee, and Marie Villalatla regarding Epstein and call with Jay' Lefkowitz B-77 8/13/2008 Email response from Alex Acosta to Karen Atkinson, Bob Senior, Jeff Sloman, Dexter Lee, and Marie \Walt regarding final version of agreement B-78 8/13/2008 Letter front Marie Villafana to Lefkowitz regarding performance of the NPA 13-79 8/13/2008- 8/15/2008 Email chain between Alex Acosta, Karen Atkinson, Bob Senior, Jeff Montan, Dexter Lee, and Marie Villafana regarding scope of Epstein agreement and correspomletwe and telephone conference with Jay Lefkowitz B-80 8/14/2008 Email fromJay Lefkowitz to Marie Villafatia and Karen Atkinson re follow up point regarding victims 15-81 8/15/2008 Etnail from Bob Senior to Alex Acosta, Marie Villalafia,Jeff Sloman, Dexter Lee, and Kamen Atkinson questioning whether offer shoukl be withdrawn as opposed to considering it a nullity B-82 8/15/2008 Email chain between Marie Villafana, Alex Acosta,JeffSbman, Bob Senior, Karen Atkinson, and Dexter Lee re drat response to 8/15/2008 email fromJay Lefkowitz regarding implementation of the NPA PRIVILEGED and CONFIDENTIAL Page 7 of 10 CONTAINS 6(c) MATERIAL EFTA00225424

EXHIBITS TO WRITTEN RESPONSE OF A. MARIE VILLAFANA Exhibit # Date Description B-83 8/15/2008 Letter from Marie Villafaiia to Jay Lelkowitz and Roy Black re terms of NPA 8-84 8/18/2008 Letter fromJay tellowitz to Marie Villafana regarding restitution B-85 8/21/2008 Letter from Marie Villafaila to Jay I elkowilz and Roy Black re Special Master and draft Notification of Identified Victim B-86 8/22/2008 Letter from lay Lelkowitz to Marie Villafana regarding misstatements in 8/21/08 VilliditIR letter B-87 8/26/2008 Letter from Marie Villafaila to Jay Lelkowitz and Roy Black re victim's list 8-88 9/2/2008 Letter from Jay Lclkowitz to Marie Villafana agreeing that Goldberger should be listed as the contact person for civil suits and re victim representativeJosefsberes fees B-89 9/2/2008 Mailed Amended Victim Notification letters to #1 )12, #3 (via Richard H. Willits), #4, #13, #8 friaJeffrey Herman), #9, #10, #11, #14, #16, #I7 (via Theodore Leopold), #20, #21, #23, #24, #25 (viaJelfrey Herman), #26 biaJellity Herman), #30, #31, #32, #33, #37 (via Michael E. Dutko), #38, #44 biaJeffni Herman) 8-90 9/W2008 Victim notification letters to #36, #35 (via Brad Edwards), #42, #43 (via Brad Edwards) B-9I 9/12/2008 Notification of Identified Victim letter #39 B-92 9/15/2008 Mailed victim notification letters for #I8 and #32 15-93 9/17/2008- 11/4/2008 Entails and coorespondence with 'Ilie Florida Bar re victim notifications B-94 11/14/2008 Notification of Identified Victim letters to #20, #40 13-95 12/4/2008 Email from Karen Atkinson to Marie Villafaila in response to draft letter notifying victims of Epstein's work release B-96 12/5/2008 Email from Marie Villafaila to victim's attorneys with attached Work Release Notice 15-97 12/8/2008 Notification of NVotk Release letters to Spencer Kuvin,Jack Scuola, Michael Dutko, #11,1439 and #40 B-98 12/9/2008 Notification of Work Release letters to #4, #10, #16, #I8, #23, #24, #33, #38, #30 (personal note), #42 B-99 12/12/2008- 12/29/2008 Entails with attorneys for victims regarding Epstein work release 11-100 12/12/2008 Notification of Work Release letter to #42 B-101 12/12/2007 Entails between Marie Villafana, Frederica Devlin, and Bob Senior regarding planning indictment review B-102 1/7/2008 Email From Marie Villafaaa to Alex Acosta,Jeff Montan, Bob Senior, Karen Atkinson, and Rolando Gant regarding proposed additional investigative steps in Epstein case 13-103 1/9/2008• 1/14/2008 Entails between Marie Villafaiia, Drew Oosterbaan, Myesha Braden, Nesbitt Kuyrkendall, an dJason Richards regarding assigning a CEOS attorney to the investigation, meeting with the CEOS attorney and victims in Florida, the results of the meetings and planned additional meetings, and revisions to the indictment in light of the meetings II-104 1/10/2008 Email chain between Myesha Braden and Marie Villafaita regarding meeting on 1/11/2008 B-10.5 1/14/2008 Entail chain between Myesha Braden, Marie Villafafia, E. Nesbitt Kuyrkeimlall, and Jason Richards regarding meeting and additional 302s PRIVILEGED and CONFIDENTIAL. Page 8 410 CONTAINS 6(e) MATERIAL EFTA00225425

EXHIBITS TO WRITTEN RESPONSE OF A. MARIE VILLAFANA Exhibit It Date Description B-106 1/I7/2008 Agents compile evidence for Bob Senior indictment review B-107 1/25/2008 Email chain between Myesha Braden and Marie Villafafia regarding victim's names in indictment B-108 1/31/2008 Additional grand jury subpoenas B-109 1/28/2008• 2/1/2008 Entails between Marie Villafana,Jeff Sloman, Alex Acosta, Nesbit Kuyrkendall, Jason Richards, and Alan Santiago regarding results of additional victim-witness interviews and requesting intervention with CEOS to move review process along B-I 10 2/12/2008- 2/22/2008 Entails between Marie Villafana, E. Nesbitt Kuyrkendall, Jason Richards, and Myesha Braden re information for indictment/ongoing investigation B-111 2/20/2008- W21/2008 Entails between Drew Oosterbaan, Marie Villatana, Robert Senior,Jeff Montan, Sigal Mandelker, Karen Atkinson, Alex Acosta, Rolando Garcia and Myesha Braden regarding status of CEOS plans to meet with counsel for Epstein and status of indictment review B-112 245/2008 Email chain between Marie Villafana and Caroline regarding use of Grand Jury B-113 2/25/2008 Email from Marie Villafafia toJeffSlontan, Bob Senior, Rolando Garcia, Karen Atkinson, and Myesha Braden re staying with same grand jury or present to a different gnmd jury 13-114 2/26/2008 Email front Marie Villatana to Myesha Braden re CEOS independent review and concern about victim's mulles being released B-115 2/26/2008 Email response from Marie Villatalia to Jeff Sloman and Bob Senior with concerns regarding allowing Epstein to keep the same deal as before 13-116 2/27/2008 Email chain between Marie Villatana, David Weinstein, and Bob Senior re email to the Civil Rights Chief B-117 2/2W2008 Email chain between Marie Villatanajason Richards, and E. Nesbitt Kuyrkendall regarding further investigation B-118 2/29/2008 Entails betweenJeff Montan, Marie Villatafia, Robert Senior, and David Weinstein regarding continuing investigation and status of CEOS review B-119 3/12/2008 Email from E. Nesbitt Kuyrkendall to Marie Villafafia re affidavit for memory cards B-I20 3/17/2008 Two search warrants for digital camera memory cards 13-121 3/5/2008 Entails between Marie Villafafia and E. Nesbitt Kuyrkendall with attached email to Alex Acosta, Jeff Montan, Drew Oosterbaan, Robert Senior, Myesha Braden, Rolando Garcia, and Karen Atkinson regarding meeting in DC, additional information to prepare for meeting, and new information from ongoing investigation B-122 3/14/2008 Entails between Marie Villafafia, Rolando Garcia, Karen Atkinson, Frederica Devlin, and Shawn Ball regarding complete indictment package for Robert Senior fatal review B-123 6/3/2008 Letter from Jeff Sloman to Deputy Attorney General Mark Filip with auachmems B-124 4/21/2008- 5/9/2008 Emits between Marie Villataila,Jeff Sloman, Karen Atkinson, Bob Senior, E. Nesbitt Kuyrkendall, Jason Richards, and Drew Oosterbaan re status of grand jury presentation. and ongoing investigation, and delay PRIVILEGED and CONFIDENTIAL. Page 9 of 10 CONTAINS 6(c) MATERIAL EFTA00225426

EXHIBITS TO WRITTEN RESPONSE OF A. MARIE VILLAFASA Exhibit N Date Description 5/15/2008- Entails between Marie Villafana, Karen Atkinson. Bob Sentor,JeliSloman. am I 13-125 5/27/2008 agents regarding indictment review and status of investigation 13-126 5/30/2008 FBI-302 of 5/28/08 Interview of Individual #35 6/2/2008 4:25 pm Draft letter from Jeff Sloman to Deputy Attorney General 13-127 6/2/2008 Mark Hip 6/3/2008 10:40 am Draft letter fromJcff Sloman to Deputy Attorney General B-128 6/3/2008 Mark Hip Entails between Villafana and Kuyrkendall re subpoena issued to victimfwitness 13-129 6/6/2008 and need for additional subpoenas 13-130 6/17/2008 Application for 6001 immunity for grand jury witness Letter from Matthew W. Friedrich, Acting Assistant Attorney General. B-131 6/24/2008 authorizing application for a court order granting 6001 int:marl B-B2 6/20/2008 Request to travel to York for witness interviews in June 2008 and subpoena Entails between A. Marie Villafaria, E. Nesbitt Kuyrkendall, J. Richards, K. Atkinson, and R. Senior regarding grand jury time, witness subpoena, and B-133 6/23/2008 indictment 6/23/2008- Entails between Marie Villalirna and attorney for grand jury witness regarding 1 t-I34 6/26/2008 immunity and travel for grand jury appearance Entails between Marie Villafana and attorney for grand jury witness withdrawing 13-135 6/30/2008 subpoena c'- i 1/31/2008 Email from Marie Villafana to Jeff Mon tan and Alex Acosta regarding victims Email chain between Marie Villafana, David Weinstein,Jeff Montan, Bob Senior, Karen Atkinson, and Rolando Garcia with Epstein update from grand jury presentation and grant front theJustice Department to provide legal C-2 3/19/2008 representation to victims 3/19/2008- C-3 3/22/2008 rattails regarding victims being harassed by Epstein's investigators Draft of entail to be sent to Jeff and Matt stating that Villalana disagrees with promising to have a meeting with Lel-court or any of Epstein's other attorneys. 5/22/2007- Believes the prior meeting disclosed prosecution strafe*. and holding another meeting will disclose even more. If meeting is held, Villafalia will ask to have the case reassigned. Attached email correspondence between Andrew Lourie and G. O4 5/23/2007 Lefcourt Email from Matt Menchal to Marie Villatana and Andrew Louric regarding not C-5 .5/14/2007 having approval to proceed with an indictment or complaint 10/3/2007- Entail chain between Marie Villafana, Jeff Montan, and Jay Lefkonitz regarding C-6 10/5/2007 appointing special master 10/16/2007- Entails between Marie Villafana,Jeff Montan, Alex Acosta, and* Lelkowitz C-7 10/28/2007 regarding Special Master PRIVILMED and CONFIDENTIAL. Page 10 of 10 CONTAINS 6(e) MATERIAL EFTA00225427

EPSTEIN INVESTIGATION TIMELINE Date To From Re: Exhibit # 5/1/2006 State Attorney • ga y E B ' Krischer Michael S. Reiter, Chief of Police for Town of Palm Beach Letter urging State Attorney to proceed with probable cause affidavits and cast filing packages or to recuse himself i 5/23/2006 File Opening Documents for Operation Leap Year 2 7/24/2006 Michael S. Reiter, Chief of Police for Town of Palm Beach Letter noting that Palm Beach Police Chief was unhappy with State Attorney's handling of case and was referring matter to the FBI for investigation 6 7/26/2006 South Florida Sun-Sentinel Article Regarding Chief Reiter's referral of case to FBI _ 8/2/2006 Subpoena to Colonial Bank (return date 8/18/06) 8/2/2006 Subpoena to Washington Mutual (return date 8/18/06) 8/2/2006 Subpoena to Capital One (return date 8/18/06) 8/2/2006 Subpoena to Chase (return date 8/18/06) 8/2/2006 Subpoena to Hyperion Air, Inc. (return date 8/18/06) 8/2/2006 Subpoena to JEGE, Inc. (return date 8/18/06) 8/2/2006 Subpoena to David Neville Rodgers (return date 8/18/06) 8/2/2006 Subpoena to DTG Operations d/b/a Dollar Rent-a-car (return date 8/18/06) 8/2/2006 Subpoena to Royal Palm Beach Community High School (return date 8/18/06) 8/2/2006 Subpoena to Custodian of Records 15th Judicial District (return date 8/18/06) 8/4/2006 Victim Notification letters to Individuals #6, #9, #10, #11, #13, #15, #17, #18, #20, #23, #24, #25, #26, #27, #28, #29, #30, #31, #32, #38, #39, #41, #42, and #44 1 :! 8/11/2006 Victim Notification letters to Individuals #4, #5, #6, #9, #12, #13, #15, #19. #26, #28, #29, #31, #32, #34, #38, #39, #43, and #44 8/15/2006 Subpoena to (withdrawn) (return date 8/25/06) Privileged Confidential Page 1 of SI Contains 6(e) Material CVUIDIT A 1 EFTA00225428

EPSTEIN INVESTIGATION TIMELINE Date To From Re: Exhibit # 8/15/2006 Subpoena to Individual #4 (return date 8/25/06) 8/15/2006 Subpoena to Individual #28 (return date 8/25/06) 8/15/2006 Subpoena to Individual #44 (withdrawn) (return date 8/25/06) 8/23/2006 Subpoena to Individual #4 (return date 9/1/06) 8/23/2006 Subpoena to Individual #28 (return date 9/1/06) 8/23/2006 Subpoena to Reimer Employment Agency (return date 9/1/06) 8/23/2006 Subpoena to Evidence Custodian Palm Beach Police Department (return date 9/1/06) 8/24/2006 Villafalia Jim Eisenberg Email re Individual #28 9 8/28/2006 Subpoena to Custodian of Records State Attorney's Office (return date 9/15/06) 8/28/2006 Subpoena to Custodian of Records 15th Judicial District (return date 9/15/06) 9/13/2006 Subpoena to Good Samaritan Hospital (return date 9/22/06) 9/21/2006 Subpoena to The Dalton School (return date 9/29/09) 9/26/2006 Acosta, Mulvihill, Sloman, Noto, Waters, L°urie' Stefin, Atkinson, Garcia, Brown, Boscovich, Martinez Villafaila Memo regarding changes to Child Explotation Statutes in Tide 18 16 10/19/2006 Subpoena to Individual #28 (return date 10/27/06) 10/24/2006 Email chain between Villafaiia and Jim Eisenberg discussing Individual #28 9 10/30/2006 Villafatia Guy Lewis Email re representation of Jeffrey Epstein 10 10/31/2006 Villafatia Guy Lewis Email chain to set up call 10 11/8/2006 Lourie, Villafana ' cc: Menchel Sloman Email re Lilly Ann Sanchez/representation of Jeffrey Epstein Privileged Confidential Page 2 of 51 Contains 6(e) Material EFTA00225429

EPSTEIN INVESTIGATION TIMELINE Date To From Re: Exhibit # 11/13/2006 Subpoena to Bill Hammond (pilot) (return date 12/1/06) 11/13/2006 Subpoena to Larry Visoski (pilot)(return date 12/1/06) 11/13/2006 Subpoena to Janusz Banasiak (property manager)(retum date 12/1/06) 11/13/2006 Subpoena to Adriana Mucinska (former assistant) (return date 12/1/06) 15 I 1/15/2006 A. Marie Villafalia Lilly Ann Sanchez Gerald Lefcourt from New York and Lilly Ann Sanchez will be dealing with the U.S. Attorney's Office in the Jeffrey Epstein matter 1 1 11/16/2006 Lilly Ann Sanchez A. Marie Viilafan_a Request for documents and information necessary to the investigation 11/17/2006 Subpoena to Extra Touch Flowers (return date 2/6/07) 11/21/2006 Lilly Ann Sanchez A. Marie Villafaria Requesting a meeting to discuss 11/16/06 letter 11 11/29/2006 Lilly Ann Sanchez A. Marie Villafafia AUSA Villafatia will be out of district and will not be available for meeting during the proposed dates, but will schedule the meeting when she returns. 1 1 I 2/1/2006 A. Marie Villafalia Lilly Ann Sanchez Will check on the document requests and will schedule the meeting in the new year. 11 12/18/2006 Subpoena to Janusz Banasiak (property manager) (return date 1/12/07) 12/18/2006 Subpoena to (former assistant) (return date 1/12/07) 15 12/18/2006 Subpoena to Anthony Figueroa (return date 1/12/07) 1/5/2007 A. Marie Villafatia Lilly Ann cl. inchez Request for dates and times to schedule meeting 11 1/8/2007 Lilly Ann Sanchez A. Marie Vaifan_a Request for documents prior to setting meeting 1 1/17/200- Lilly Ann Sanchez Andrew Lourie Client wants to cooperate with the investigation, but requests for documents were overly broad. Provided shortened and narrowed list and request for documents to be provided by 1/25/07, so they could be reviewed prior to 2/1/07 meeting. 14 Privileged Confidential Page 3 of 51 Contains 6(e) Material EFTA00225430

EPSTEIN INVESTIGATION TIMELINE Date To From Re: Exhibit # 1/18/2007 A. Marie Villafaiia Lilly Ann Sanchez Because of the Palm Beach Police Department and the State Attorney's . investigation for almost two years, Epstein hired counsel for all employees so contact Ms. Sanchez for contact information for the attorneys. 14 I /22/2007 Andrew Lourie Sanchez Looking forward to the 2/1/07 meeting and expect to send documents previously provided to the Palm Beach County State Attorney's Office by 1/25/07. I I 1/22/2007 Research re NPAs and 6001 immunity I c 1/23/2007 Lilly Ann Sanchez A. Marie Nrillafafia Request for a list of the individuals who have accepted Epstein's offer of payment for representation and the names of their attorneys. 2/1/2007 A. Marie Villafafia Gerald B. Lefcourt Talking points and documents for 2/1/07 meeting 4 2/5/2007 A. Marie Villafatia Gerald B. Lefcourt Production of debit/credit card statement regarding Epstein's birthday and a purchase at Guys and Dolls made by Individual #18. 2/6/2007 Grand Jury Testimony of E. Nesbitt Kuyrkendall I - 2/12/2007 A. Marie Villafana Lilly Ann Sanchez Emails between Villafana and Lilly Ann Sanchez regarding employee representation with Laurie and Villafana handwritten notes 58 2/14/2007 Subpoena to Colonial Bank (return date 3/6/07) 2/14/2007 Subpoena to Palm Beach National Bank (return date 3/6/07) 2/14/2007 Subpoena to Western Union (return date 3/6/07) 2/14/2007 Subpoena to Western Union (return date 3/6/07) 2/14/2007 Subpoena to JP Morgan Chase (return date 3/6/07) 2/20/2007 Meeting (US: Andy Laurie, Marie Villafana, and Junior Ortiz, DEF: Lilly Sanchez and Gerald Lefcourt) 2/23/2007 A. Marie Villafaiia Gerald B. Lefcourt Excerpts of drafts of transcripts from recorded interviews of various witnesses taken during state's investigation. 2/27/2007 Grand Jury Testimony of E. Nesbitt Kuyrkendall 18 3/2/2007 Subpoena to Thomas Rofrano (return date 3/13/07) 3/2/2007 Subpoena to Johanna Sjoberg (return date 3/13/07) 3/2/2007 Subpoena to Christina (return date 3/13/07) 3/2/2007 Subpoena to Palm Beach County Health Dept (return date 3/13/07) 3/2/2007 Subpoena to Perry Bard, DC (return date 3/13/07) Privileged Confidential Page 4 of 51 Contains 6(e) Material EFTA00225431

EPSTEIN INVESTIGATION TIMELINE Date To From Re: Exhibit # 3/15/2007 Victim Notification letter to Individual #4 19 3/16/2007 Subpoena to Individual #29 (return date 3/27/07) 3/20/2007 Grand Jury Testimony of E. Nesbitt Kuyrkendall 20 3/20/2007 Subpoena to Individual #32 (return date 4/3/07) 3/22/2007 Villafatia Stefan Cassella Email re money laundering question 56 4/4/2007 Subpoena to Individual #37 (return date 4/17/07) 4/16/2007 Subpoena to Chase Bank USA, NA Atm: Jeff Sehr (return date 4/24/07) 4/16/2007 Subpoena to Adult Video Warehouse (return date 5/1/07) 4/16/2007 Subpoena to Eve's Garden (return date 5/1/07) 4/17/2007 Subpoena to Individual #28 (return date 5/1/07) 4/20/2007 Subpoena to Adult Video Warehouse (return date 5/1/07) 4/24/2007 Grand Jury Testimony of Special Agent E. Nesbitt Kuyrkendall 21 4/24/2007 Grand Jury Testimony of Individual #37 22 4/24/2007 Subpoena to New York Strategy Group, LLC Custodian of Records (return date 5/8/07) 4/24/2007 Subpoena to Hyperion Air, Inc. Custodian of Records (return date 5/8/07) 4/24/2007 Subpoena to JEGE, Inc. (return date 5/8/07) 5/8/2007 Grand Jury presentation materials 23 5/8/2007 Grand Jury Testimony of E. Nesbitt Kuyrkendall 24 5/8/2007 Grand Jury Testimony of Jason Richards 25 5/10/2007 A. Marie Villafatia Jack A. Goldberger Response to subpoenas JEGE, Inc. and Hyperion Air, Inc.. 5/14/2007 Marie Villafatia and Andrew Lourie Matthew Menchel Email re Operation Leap Year with email from Villafatia to Lourie and Menchel (5/14/07) attached 26/C-5 5/15/2007 Grand Jury Testimony of Special Agent E. Nesbitt Kuyrkendall 27 5/16/2007 Subpoena to American Express TRS Co., Inc. (return date 5/29/07) 5/17/2007 A. Marie Villafafia Jack A. Goldberger Extension of compliance deadlines until 5/29/07 for subpoena responses for JEGE, Inc. and Hyperion Air, Inc. Privileged Confidential Page 5 of 51 Contains 6(e) Material EFTA00225432

EPSTEIN INVESTIGATION TIMELINE Date To From Re: Exhibit # 5/18/2007 Matthew Menchel A. Marie Villafatia Email informing Menchel of intent to subpoena Roy Black's private investigator and steps taken to obtain DOJ authorization 26 5/21/2007 Matthew Menchel and Jeff Sloman A. Marie Villafatia Email seeking guidance on grand jury presentation 26/54 5/21/2007 Subpoena to Paul A. Lavery (return date 5/29/07) 59 5/22/2007 Andrew Cootie Gerald B. Lefcourt Letter requesting to meet with Matthew Menchel and Jeffrey Sloman and \ lc\ Acosta prior to an indictment being filed 28 5/22/2007 Matthew Menchel and Jeff Sloman; cc: A. Marie Villafalia Andrew Laurie Email re letter received from Gerald Lefcourt discussing a meeting to discuss Epstein investigation 5/22/2007 Grand Jury Testimony of Special Agent E. Nesbitt Kuyrkendall '() 5/23/2007 Karen Atkinson A. Marie Villafaila Draft of email to be sent to Sloman and Menchel stating that Villafatia disagrees with promising to have a meeting with Lefcourt or any of Epstein's other attorneys. Believes the prior meeting disclosed prosecution strategy and holding another meeting will disclose even more. If meeting is held, Villafaiii will ask to have the case reassigned. Attached email correspondence between Andrew Laurie and G. Lefcourt 28/C-4 5/31/2007 Subpoena to J. Epstein Virgin Islands Foundation, Inc. (return date 6/21/07) 5/31/2007 Subpoena to J. Epstein & Company, Inc. (return date 6/21/07) 5/31/2007 Subpoena to Epstein Interests (return date 6/21/07) 5/31/2007 Sub_poena to Financial Trust Company, Inc. (return date 6/12/07) 5/31/2007 Subpoena to Royal Palm Beach Community High School (return date 6/12/07) 6/1/2007 Gerald B. Lefcourt A. Marie Villafaiia Subpoenas for J. Epstein Virgin Islands Foundation, Inc., J. Epstein & Co., Inc., Epstein Interests, and Financial Trust Company, Inc. 6/1/2007 Folder entitled "(Victims) Additional 302's" containing reports of interviews conducted in June 2007, October 2007, and March 2008 Privileged Confidential Page 6 of 51 Contains 6(e) Material EFTA00225433

EPSTEIN INVESTIGATION TIMELINE Date To From Re: Exhibit # 6/7/2007 Victim Notification letters to Individuals #3, #9, #31, #38, #40, and #43 30 6/7/2007 Subpoena to Park A. Cadillac Limo Service (return date 6/26/07) 6/11/2007 Subpoena to Individual #40 (return date 6/26/07) 6/11/2007 Subpoena to All Star Taxi and Limo Service (return date 6/26/07) 6/11/2007 Subpoena to Airport Executive Towncar Service Dan Tischler (return date 6/26/07) 6/12/2007 A. Marie Villafafia Gerald Lefcourt Production response to 5/31/07 subpoenas to J. Epstein Virgin Islands Foundation, Inc., J. Epstein & Co., Inc., Epstein Interests, and Financial Trust Company, Inc. 6/13/2007 Subpoena to Majestic Theatre (return date 6/06/07) 6/13/2007 Subpoena to Broward Center for the Performing Arts (return date 6/26/07) 6/13/2007 Subpoena to Kravis Center for the Performing Arts (return date 6/26/07) 6/14/2007 31 6/14/2007-6/21/2007 Emails between Marie Villafaiia, Karen Atkinson, Andrew Lourie, Matt Menchel, and Jeff Sloman regarding addendum to Pros Memo, grand jury presentation and changes to indictment, and meeting with counsel for Epstein 6/18/2007 Gerald B. Lefcourt A. Marie Villafaiia tt . Leer thanking Lefcourt for accepting service of subpoena addressed to the Custodian of Records of NES, LLC and requesting acceptance of subpoena issued to New York Strategy Group, Inc. 53 6/18/2007 Subpoena to William Riley (return date 7/10/07) 60 6/18/2007 Subpoena to Riley Kiraly (return date 7/10/07) 6I 6/18/2007 Subpoena to NES, LLC (return date 7/10/07) 6/21/2007 Matthew Menchel A. Marie Villafafia Email re Meeting next week with emails from Menchel to Villafaiia (6/21/07) and Viliafaiia to Menchel (6/21/07) attached , 6/22/2007 Subpoena to Guys and Dolls (return date 7/10/07) 6/25/2007 Jeffrey Sloman and Andrew _ Lourie Gerald B. 12fcourt Letter containing overview of position of Epstein's counsel and the materials planned to present at 6/26/07 meeting with handwritten attorney (Villafatia) notes 32 Privileged Confidential Page 7 of 51 Contains 6(e) Material EFTA00225434

EPSTEIN INVESTIGATION TIMELINE Date To From Re: Exhibit # 6/25/2007 Man Mcnchel and Marie Villafatia Andrew Lourie Email entitled "Thoughts on Lefcourt's letter" 32 6 /26/2007 Meeting (US: Jeff Slotnan, Matt Manche', Marie Villafaila, Junior Ortiz, Nesbitt Kuyrkendall, DEF: Alan Dershowitz, Roy Black, Gerald Lefcourt and Lilly Sanchez) 6 2- 2007 Subpoena to Live Nation Theatrical/Broadway Across America (return date 7/10/07) 7/1/2007 Sanchez, Lefcourt Villafana Email re oustanding subpoenas and planned meeting for 7/11/07 7/3/2007 7/3/2007-7/13/2007 Email chain between Matt Menchel and Marie Villafalia regarding disagreement on Menchel's plea negotiations and written request for meeting between USAO management and victims 3 7/3/2007 7/3/2007-7/4/2007 Emails between Marie Villafaiia and Andrew Lourie regarding extension of time to respond to subpoenas requested by Lilly Ann Sanchez and possible resolution of case 7/6/2007 Jeffrey Sloman and Andrew Lourie Gerald B. Lefcourt and Alan Dershowitz Follow-up letter to 6/26/07 meeting including facts, law, and policy that should inform any decision made on how and whether to proceed 33 7/13/2007 Villafaila Roy Black Letter with handwritten attorney (Lourie) notes 34 7/13/2007 Matthew Menchel A. Marie Villafana Email re Epstein with email from Menchel (7/5/07), Villafana to Marche' (7/4/07) and Sloman to Villafana (7/3/07) attached 3 7/16/ 2007 Black Villafatia Response to letter regarding subpoena to Paul Lavery for computer equipment removed from Epstein's residence 7/16/2007 Matt Menchel and Andrew Lourie A. Marie Villafatia Email regarding correspondence from Roy Black and Motion to Quash Lavery subpoena 7/17/2007 Motion of Jeffrey Epstein to Intervene and Quash Grand Jury Subpoenas and Incorporated Memorandum of Law Privileged Confidential Page 8 of 51 Contains 6(e) Material EFTA00225435

EPSTEIN INVESTIGATION TIMELINE Date To From Re: Exhibit # 7/17/2007 Affidavit of Roy Black, Esq., in Support of Motion of Jeffrey Epstein to Intervene and to Quash Grand Jury Subpoenas and Incorporated Memorandum of Law 7/18/2007 Andrew Laurie and Matt Menchel Marie Villafana Email from Villafafia to Matt Menchel regarding Roy Black objection to subpoenas subpoenas addressed to William Riley and Riley Kiraly 7/19/2007 Villafana Mille Levy (USAPAE) Email regarding comments to Rule 16 about disclosing identifying information about victims 7/19/2007 Email chain between Marie Villafaiia, Andrew Lourie, Matt Menchel, S/A Jason Richards and S/A Eliasib Ortiz regarding potential service of target letters 63 7/19/2007 Preparing Motion for Post-indictment protective order 7/24/2007 Subpoena to Rachel Eve Lockwood (return date 8/14/07) 7/25/2007 Matthew Menchel Gerald B. Lefcourt and Alan Dershowitz Document entitled: "Data that strongly supports the arguments made that no charge can or should be made under 18 U.S.C. § 2422(b)" 35 7/26/2007 Matt Menchel and Andrew Laurie Marie Villafatia Email regarding proposed changes to indictment 3e 6 I 7/26/2007 Meeting where Criminal Chief Menchel announces that USA Acosta will offer a two-year state plea. Present: Matt Menchel, Marie Villafafia, Andy Lowrie (phone), Valerie Parlave, Junior Ortiz, Nesbitt Kuyrkendall, and Jason Richards 7/27/2007 Research re 18 U.S.C. § 2255 37 7/31/2007 Jeff Sloman, Matt Menchel, and Andrew Laurie Marie Villafafia Email summarizing proposed plea terms as per Menchel recommendation 4 and 38 7/31/2007 Meeting (US: Jeff Sloman, Matt Menchel, Marie Villafatia, Andy Laurie, Nesbitt Kuyrkendall and Jason Richards, DEF: Roy Black, Gerald Lefcourt and Lilly Sanchez) Privileged Confidential Page 9 of 51 Contains 6(e) Material EFTA00225436

EPSTEIN INVESTIGATION TIMELINE Date To From Re: Exhibit # 7/31/2007 U.S. Response to Motion of Jeffrey Epstein to Intervene and to Quash Grand Jury Subpoenas and Cross-Motion to Compel and Sealed Document Tracking Form with Sealed, Ex Parte Declarations 7/31/2007 7/31/2007-8/3/2007 Email chain between Jeff Sloman, Matt Menchel, Andrew Lourie, and Marie Villafaiia regarding plea negotiations 39 8/1/2007 8/1/2007-8/2/2007 Emails between Menchel and Villafaiia regarding plea negotiations 65 8/2/2007 Matthew Menchel Lilly Ann Sanchez As discussed at meeting, Epstein is prepared to resolve the matter via state forum. Proposal of 2 years supervised custody with two additional years of reporting to probation 8 and 40 8/2/2007 Emails between Matt Menthe', Jeff Sloman, Andy Louric, and Marie Villafana regarding letter received from Lilly Ann Sanchez 40 8/3/2007 Lilly Ann Sanchez Matthew Menchel 2 year term of incarceration is a non-negotiable minimum and U.S.Attomey Acosta is not inclined to meet with counsel for Epstein. Epstein must advise of his decision by 8/17/07. 41 8/3/2007 Matt Menchel, Andrew Louie, Jeff Sloman, Karen Atkinson Marie Villafaria Email regarding draft response to correspondence from Epstein counsel and planned investigative steps if agreement cannot be reached i I 8/6/2007 Cyndee Campos, Frederica Devlin and Jeff Sloman Marie Villa feta Emails regarding Matt Menchel's correspondence prior to his departure ; , 8/6/2007 Subpoena to Individual #3 (return date 8/21/07) 8/6/2007 Subpoena to Individual #43 (return date 8/12/07) 8/7/2007 Andy Lourie Marie Villafana Email regarding deadline set for Epstein plea and Epstein's plan to demand a meeting with CEOS I 1 8/7/2007 Email chain between Marie Villafalia, Cyndee Campos, and Alex Acosta regarding meeting to discuss Epstein matter 41, Privileged Confidential Page 10 of 51 Contains 6(e) Material EFTA00225437

EPSTEIN INVESTIGATION TIMELINE Date To From Re: Exhibit # 8/7/2007 Email chain from Jeff Sloman to Andrew Oosterbaan, Marie Villafaiia, and Alex Acosta regarding Epstein meeting 43 8/7/2007 Reply of Jeffrey Epstein to United States' Response to His Motion to Intervene and to Quash Grand Jury Subpoenas and Cross-Motion to Compel and Sealed Document Tracking Form 8/8/2007 Andrew Oosterbaan Marie Villafaiia Email regarding plea negotiations, guideline calculations, and assistance in preparing case for trial 43 8/8/2007 Research re 18 U.S.C. § 2255 37 8/15/2007 Subpoena to Bear Stearns (return date 9/4/07) 8/16/2007 Subpoena to Adam Perrylang (return date 9/4/07) 8/16/2007 Subpoena to Lesley Groff (return date 9/4/07) 8/16/2007 Subpoena to Jean-Luc Brunel (return date 9/4/07) 8/16/2007 Subpoena to Harry Beller (return date 9/11/07) 8/16/2007 Subpoena to Eric Gany (return date 9/11/07) 8/17/2007 Motion of William Riley and Riley Kiraly for an Extension of Time Nunc Pro Tunc to File Their Reply and Proposed Order 8/17/2007 Reply of William Riley and Riley Kiraly to the Government's Response to the Motion to Intervene and to Quash Grand Jury Subpoenas and Cross Motion to Compel 8/23/2007 A. Made Villafaiia Gerald Lefcourt Letter that he cannot accept service for Eric Gany 8/28/2007 A. Marie Villafaiia Nathan Z. Dershowitz Left messages with Sarah Kellen and to request if he can accept service on their behalf 8/30/2007 Jeff Sloman, Andrew Laurie, Drew Oosterbaan, John McMillan, Karen Atkinson Marie Villa fana I imail regarding press coverage of meeting with Ken Starr Privileged Confidential Page I I of 51 Contains 6(e) Material EFTA00225438

EPSTEIN INVESTIGATION TIMELINE Date To From Re: Exhibit # 8/30/2007 United States Surreply to Replies filed by Witness William Riley and Intervenor Jeffrey Epstein re Motion to Quash Grand Jury Subpoenas and Scaled Document Tracking Form and Supplemental Ex Parte Declaration 8/31/2007 Meeting (US: Drew Oosterbaan, Marie Villafalia, Nesbitt Kuyrkendall and Jason Richards) 9/4/2007 Jeff Sloman Marie Villafaiia 9/4/2007-9/6/2007 Emails between Jeff Sloman and Marie Villafalia regarding planned participation of FBI ASAIC at 9/7/07 meeting with Epstein defense team 44 9/6/2007 A. Marie Villafaiia Gerald 121Court Beller and Gany are represented by Nat Dershowitz. NES is working on getting the extra documents requested and the certification. 9/6/2007 Nathan Z. Dershowitz A. Marie Villafana Questioning representation of Sarah Kellen and 9/6/2007 Nathan Z. Dershowitz A. Marie Villafaiia Subpoena for Leslie Groff to appear for Grand Jury on 9/18/07 and anticipated topics 9/6/2007 Nathan Z. Dershowitz A. Marie vigafana Subpoenas for Harry Beller and Eric Gany to appear before GJ on 9/11/07. 9/7/2007 9:31 am draft Plea Agreement 9/7/2007 9:43 am draft Non-Prosecution Agreement 9/7/2007 1:15 pm draft Non-Prosecution Agreement 9/7/2007 1:17 pm draft Plea Agreement 9/7/2007 Meeting (US: Alexander Acosta, Drew Oosterbaan, Jeff Sloman, Marie Villafalia, and John McMillan, DFF: Kenneth Starr, Jay Lefkowitz, and Lilly Sanchez) 9/10/2007 5:17 pm draft Non-Prosecution Agreement 9/10/2007 J. Sloman A. Marie Villafaila Email re negotiations 46 9/10/2007 J. Sloman, J. McMillan A. Marie Villafaiia Email re state grand jury proceedings 45 9/10/2007 Jeff Sloman, Andrew Laurie A. Marie Villafatia Email re FBI 45 9/10/2007 Lefcourt Villafafia Email with 4 page NPA attached (RFP3) 47 Privileged Confidential Page 12 of 51 Contains 6(e) Material EFTA00225439

EPSTEIN INVESTIGATION TIMELINE Date To From Re: Exhibit # 9/10/2007 Proposed Non-Prosecution Agreement provided to Gerald Lefcourt on 9/10/2007 66 9/10/2007 9/10/2007-9/11/2007 Emails between Marie Villafidia, Alex Acosta, and Jeff Sloman regarding modifications to the proposed Non-Prosecution Agreement 46 9/10/2007 9/10/2007-9/14/2007 Emails between Marie Villafatia, Andrew Lourie, Jeff Sloman, Karen Atkinson, Rolando Garcia, Shawn Ball, and Alex Acosta regarding final plea negotiations, finalizing details with State Attorney's Office and final revisions to indictment package 46 9/11/2007 A. Lourie A. Marie Villafatia Email re meeting with G. Lefcourt with attached correspondence 46 9/11/2007 A. Lourie A. Marie Villafaiia Email re revised Agreement with attached correspondence 46 9/11/2007 A. Marie Villafalia . A Lourie Email re scheduling a meeting regarding finalizing the agreement with attached corresondcnce 46 9/11/2007 A. Marie Villafatla A. Oosterbaan Email re negotiations with attached correspondence 48 9/11/2007 A. Marie Villafatia Andrew Lourie Email regarding revised agreement - Plea to the 3 specified charges, a 30 month sentence, split 20 in jail and 10 in "community control," and agree that the girls are victims for purposes of damages. Also includes deadlines for a plea and sentencing date 46 9/11/2007 A. Oosterbaan A. Marie Villafaiia Email re status of negotiations with attached correspondence 48 9/11/2007 Lefcourt Villafatia Email with 4 page NPA attached .1- 9/11/2007 Proposed Non-Prosecution Agreement incorporating Acosta edits provided to Gerald Lefcourt on 9/11/2007 67 9/11/2007 Emails between Marie Villafatia, John McMillan, Drew Oosterbaan, Nesbitt Kuyrkendall, and Jason Richards regarding changes to the draft indictment and status of plea negotiations 46 9/11/2007 2:13 pm draft Non-Prosecution Agreement Privileged Confidential Page 13 of 51 Contains 6(e) Material EFTA00225440

EPSTEIN INVESTIGATION TIMELINE Date To From Re: Exhibit # 9/12/2007 A. Marie Villafatia Nathan Z. Dershowitz Ms. Groff will proceed by interview. 9/12/2007 Meeting (US: Andy Lourie, Rolando Garcia and Marie Villafafia, DEF: Jay Lefkowitz, Gerald Lefcourt and Jack Goldberger, STATE OF FLORIDA: Barry !Casket and Latina Belohlavek) 9/12/2007 A. Marie Villafalia; cc: Andrew Lowrie Jay Lefkowitz Email in response to A. Marie Villafafia's email stating that the Office is satisfied in principle with the agreement, but uncomfortable with the recommended federal charge due to jurisdiction. Response states that defense understands the concerns and will work to come up with a mutually acceptable solution. 49 9/13/2007 A. Acosta, J. Sloman, R. Garcia, K. Atkinson, A. Lourie A. Marie Villafafia Email re plea negotiations 46 9/13/2007 A. Lourie A. Marie Villafatia Email re plea negotiations with attached correspondence i6 9/13/2007 A. Lourie A. Marie Villafafia Email re charging strategy with attached correspondence 46 9/13/2007 A. Marie Villafatia A. Lourie Email re final negotiations with attached correspondence 46 9/13/2007 A. Marie Villafafia A. Oosterbaan Email re setting up trust fund k.< 9/13/2007 A. Marie Villafaila Jay Lefkowitz Misdemeanors 403, 1512(d) and 47 U S.0 223(a)(1)(B) 4') 9/13/2007 A. Marie Villafaiia Lourie Assault on the plane or conspiracy 46 9/13/2007 A. Oosterbaan A. Marie Villafaiia Email re trust agreement with attached correspondence 4S Privileged Confidential Page 14 of 51 Contains 6(e) Material EFTA00225441

EPSTEIN INVESTIGATION TIMELINE Date To From Re: Exhibit # 9/13/2007 Andrew Lourie, Alex Acosta, Jeff Sloman, Rolando Garcia, Karen Atkinson Manic vfflafitha in 1. ails regarding plea to federal charges recommending 18 U.S.C. 403 or 1512g, or 47 U.S.C. 223(a)(1)(B); response that Epstein was only willing to plead to assault on the plane; and rejection of facts supporting assault on the plane charge 46 9/13/2007 K. Atkinson, S. Bak). McMillan A. Marie Villafatia Email re indictment package In 9/13/2007 R. Garcia, J. slornan A. Marie Villafaria Email re conference call with J. Lefkowitz 46 9/13/2007 Subpoena to Wolf Camera (return date 9/25/07) 9/13/2007 6:36pm draft Plea Agreement 9/13/2007 6:55pm draft Information 9/13/2007 9/13/2007-9/14/2007 Entails regarding Marie Villafaria research regarding victim trust fund set up in Alaska child exploitation case t•-• 9/13/2007 Additions to pros memo/indictment - Individuals #3, #43, #38, #26, and #39 9/14/2007 A. Marie Villafaiia A. Loupe Email re charging strategy with attached correspondence ;6 9/14/2007 A. Marie viihfaria Jay Lefkowitz requesting draft to include 403 in lieu of 1512 .1() 9/14/2007 A. Marie Villafatia, A. Acosta , R. Garcia, A. Lowrie, K. Atkinson, S. Ball J. Sloman Email re finalizing documents 46 Privileged Confidential Page 15 of 51 Contains 6(e) Material EFTA00225442

EPSTEIN INVESTIGATION TIMELINE Date To From Re: Exhibit # 9/14/2007 J. Sloman, A. Acosta, A. Lourie, It. Garcia, K. Atkinson, J. McMillan, S. Ball A. Marie Villafafia Email re plea negotiations In 9/14/2007 Lefkowitz Villafatia Email - 1 page with two plea agreements attached, nine pages total ;9 9/14/2007 Villafafia, Acosta, Garcia, Laurie Sloman Proposed plea agreement and information - Lourie will help finalize .16 9/14/2007 8:47 am draft Information 9/14/2007 8:53 am draft Plea Agreement 9/14/2007 9:38 am draft Information 9/14/2007 9:48 am draft Plea Agreement 9/15/2007 2:29 pm draft Information 9/15/2007 2:46 pm draft Plea Agreement 9/15/2007 Lefkowitz Villafafia Email with attached Information and Plea Agreement 49 9/16/2007 Lefkowitz Villafaila Email re 11th Circuit cases on simple assault and found language with attached Epstein Plea Offer 49 9/16/2007 Villafafia Lefkowitz Email with attached 5 page Agreement 49 9/16/2007 Email chain between Lefkowitz and Villabfia regarding changing the documents to 1512 and language in the plea agreement 46 9/16/2007 12:00 pm draft Information 9/16/2007 12:09 pm draft Plea Agreement 9/16/2007 12:21_pm Lefkowitz proposed Agreement 9/16/2007 4:42 pm draft Plea Agreement 9/17/2007 A. Acosta A. Marie Villafafia Email re negotiation 46 9/17/2007 A. Marie Vi&fails Al Acosta Please make sure Lefkowitz understands that the Non-Prosecution agreement ex provided is only a draft and will still need final approval. 46 Privileged Confidential Page 16 of 51 Contains 6(e) Material EFTA00225443

EPSTEIN INVESTIGATION TIMELINE Date To From Re: Exhibit # 9/17/2007 A. Marie Villafana . Jay Lefkowttz Email requesting obstruction proffer that is already drafted and inquiring whether deferred prosecution agreement would be made public 49 9/17/2007 A. Marie Villafalia and Roy Black; cc: Gerald Lefcourt, John McMillan, Karen Atkinson, and Andrew Lourie . Jay Lefkowitz Response to email that Jenny from Judge Marra's office spoke with the Judge and he agreed to take the matter off the calendar. If a plea agreement is reached, USAO will withdraw the subpoena and Mr. Black will withdraw his Motion to Quash. 49 9/17/2007 A. Marie Villafaiist, R. Garcia, A. Lourie, K. Atkinson, J. McMillan A. Acosta Email re draft Agreement with attached correspondence 46 9/17/2007 Jay Lefkowitz A. Marie Villafaiia Options for plea: 1. Original agremeent where Epstein pleads only to state charges and serves his time in state, except that we can agree to only 18 months imprisonment. 2. Epstein pleads guilty to the state charges and also pleads to either two obstruction counts or to one count of violating 47 U.S.C. 223(a)(1)(B), with a joint non-binding recommendation of 18 months, so that he can serve his time federally. 3. I go back to the U.S. Attorney and ask him to agree to an ABA-plea to a 371 count (conspiracy to violate 2422(b)) with a binding 20-month recommendation so that he can serve all of his time in a federal facility. 4. Epstein pleads guilty to one obstruction count and serves part of his time federally and part state. 49 9/17/2007 Leflcowitz Villafaha - Email informing of removal of hearing on Motion to Quash from Judge Marra's calendar 49 Privileged Confidential Page 17 of 51 Contains 6(e) Material EFTA00225444

EPSTEIN INVESTIGATION TIMELINE Date To From Re: Exhibit # 9/17/2007 R. Garcia, A. Lourie A. Marie Villafaiia Email re negotiation strategy 46 9/17/2007 11:39 am draft Non-Prosecution Agreement 9/17/2007 11:42 am draft Non-Prosecution Agreement 9/17/2007 Rolando Garcia and Andrew Louric A. Marie Villafana- Emailre Epstein providing update re plea negotiations 46 9/17/2007 9/17/2007-9/19/2007 Entails between Marie Villafaiia, Rolando Garcia, Andrew Lowrie, Alex Acosta, Karen Atkinson, and John McMillan regarding negotiations of a federal plea and a non-prosecution agreement 16 9/18/2007 A. Acosta, A. Louric, R. Garcia, K. Atkinson, J. McMillan A. Marie Villafafia Email re negotiating strategy 16 9/18/2007 A. Marie Villafatia Acosta, Lourie, Garcia Epstein negotiations - you spent 12 hours working on drafts and you are advising that the end of negotiation is nearing 46 9/18/2007 A. Marie Villafatia . I av Lefkowitz ' Email chain regarding draft agreements. Lefkowitz suggests plead to one count of 1512, serve 12 months plus 1 year home confinement/supervised release, followed by 2 years of probation with 6 months being community control. Villafalia advises that USAO will not go below 18 months of prison/jail time. 49 9/18/2007 Rescheduled date for hearing on motion to quash subpoena for computer equipment (initially set for 9/13/2007) 9/18/2007 Andrew Louie, Rolando Garcia' Karen Atkinson A. Marie Villafana I:mail re Draft Agreements with email from Jay Lefkowitz (9/18/07) attached 49 9/18/2007 10:45 am draft Plea Agreement 9/18/2007 12:07 pm draft Plea Agreement Privileged Confidential Page 18 of 51 Contains 6(e) Material EFTA00225445

EPSTEIN INVESTIGATION TIMELINE Date To From Re: Exhibit # 9/18/2007 12:22 pm draft Plea Agreement 9/18/2007 1:37pm draft Information 9/18/2007 Garcia, Villafaiia Lourie Email stating new terms that Louric negotiated with Lefkowitz 9/19/2007 A. Laurie, R. Garcia, K. A. Marie Villafana Email re negotiating strategy with attached correspondence l6 9/19/2007 A. A. Marie Villafaiia A. Laurie Email re Epstein with internal U.S. Attorney's Office emails attached 46 9/19/2007 A. Marie Villafaria Jay Lefkowitz Forwarded to Laurie and R. Garcia - draft plea agreement issues l6 9/19/2007 Andrew Lourie, Rolando Garcia, Karen Atkinson A. Marie Villafana Email re Draft Plea Agreement with email from Lefkowitz to Villafana (9/19/07) and Lefkowitz to Villafana (9/19/07) attached 46 9/ 19/2007 Research re Federal Bureau of Prisons Designations 9/19/2007 11:46 am draft Information 9/20/2007 Belohlavek, Krischer Villafana Email chain discussing proposed joint meeting with Epstein's counsel to finalize all agreements 9/20/2007 Lourie Villafana Email forwarding federal plea agreement incorporating Acosta and Laurie comments 9/20/2017 Laurie Villafalia Email chain discussing factual proffer in support of federal plea 9/20/2017 Acosta, Laurie Villafafia Email summarizing call with Lefkowitz in response to Lefkowitz call to Acosta 9/20/2007 1:17pm draft Plea Agreement 9/20/2007 3:52 pm draft Plea Agreement 9/20/2007 Villafafia Lourie Email stating that Lefkowitz wants to remove registration requirement 9/20/2007 Villafana Laurie Email asking Villafana to call Lefkowitz and inform him that Epstein must plead to registrable offense Privileged Confidential Page 19 of 51 Contains 6(e) Material EFTA00225446

EPSTEIN INVESTIGATION TIMELINE Date To From Re: Exhibit # 9/21/20(17 Lowrie, Garcia Villafaiia Email informing Laurie of conversation with Lefkowitz about sex offender registration issue 9/21/2007 Villafafia, Belohlavek Krischer Email summarizing SAO negotiations with Goldberger, including Goldberger's request that Epstein not have to register as a sex offender 9/21/2007 Lourie, Garcia Villafana Email containing revised agreement incorporating some of Lefkowitz's language and highlighting 7755 negotiations 9/21/2007 Research re Florida Statutory Authorities and Bibliography 50 9/21/2007 2:05 pm draft Non-Prosecution Agreement 9/21/2007 Villafaiia, Garcia Laurie Response to email about Leficowitz's proposed language regarding immigration proceedings 9/21/2007 4:47 pm Epstein state plea jpl edits (Lefkowitz) 9/23/2007 Acosta, Laurie, Sloman, Villafatia Lefkowitz Email admitting that defense based their agreement to plead to 796.03 on a "mistaken assumption" and requesting that Epstein not have to register as a sex offender 51 9/23/2007 Lefkowitz, Laurie, Villafaiia Acosta Email response to Lefkowitz instructing Lefkowitz to deal directly with Laurie and Villafatia in negotiating agreement 51 9/23/2007 3:56 pm draft Non-Prosecution Agreement 9/23/2007 6:50 pm draft Non-Prosecution Agreement 9/23/2007 8:49 pm draft Non-Prosecution Agreement 9/24/2007 Acosta Sloman, Lowrie, Garcia, Villafaiia Email containing Acosta edits to Agreement 9/24/2007 Villafaiia Lefkowitz Email - 1 page with nine page NPA (3 signature pages) attached 9/24/2007 Weinberg, Laurie, Garcia Villafafia Email containing Acosta's final edits and asking to discuss potential victim representative 9/24/2007 Acosta, Sloman, Laurie, Garcia, Atkinson Villafafia Email containing final agreement as approved by both parties Privileged Confidential Page 20 of 5 I Contains 6(c) Nlaterial EFTA00225447

EPSTEIN INVESTIGATION TIMELINE Date To From Re: Exhibit # 9/24/2007 9:04 am draft Non-Prosecution Agreement 9/ 24/2007 10:12 am draft Non-Prosecution Agreement 9/24/2007 2:14 pm draft Non-Prosecution Agreement 9/24/2007 4:20 pm draft Non-Prosecution Agreement 9/24/2007 NPA signed 32 9/24/2007 Acosta, Garcia, Lourie Villafaiia Email containing signed agreement 9/25/2007 Scheduled date for Federal Indictment 9/30/2007 9/30/2007-10/1/2007 Email chain between Villafafia and Lefkowitz re telephone call with attached emails from 9/23/07, 9/16/07, and 9/15/07 10/1/2007 Folder entitled "(Victims) Additional 302's" containing reports of interviews conducted in June 2007, October 2007, and March 2008 10/1/2007 10/1/2007-10/31/2007 Additional negotiations regarding selection of Special Master 10/1/2007 10/1 /2007-10/31 /2007 JD#1 Notified regarding signing of NPA 10/1/2007 10/1/2007-10/31/2007 Investigation continues to try to identify addl victims 10/2/2007 Add'l client of Brad Edwards interviewed. She refuses to provide information. (She provides information on a later date). 10/3/2007 Lefkowitz Villafafia Email - 2 pages with one page attachment, Proposal for Selection of Attorney to Represent Victims C-6 10/5/2007 Villafafia Lefkowitz Email - 3 pages with four page unsigned letter from Lefkowitz to Villafafta C-6 10/5/2007 Sloman Villafafia Email forwarding letter from Lefkowitz re special master process C-6 10/7/2007 VilLsfaiia Sloman Email chain including correspondence between Sloman and Sanchez 10/8/2007 Sloman Lilly Ann Sanchez Letter - 3 pages 10/9/2007 Villafaiia Sloman Email attaching correspondence from Sanchez regarding Special Master Process 10/9/2007 illy Ann LS anchez Villafafia Email - 1 page with two page letter from Villafaha to Sanchez attached Privileged Confidential Page 21 of 51 Contains 6(e) Material EFTA00225448

EPSTEIN INVESTIGATION TIMELINE Date To From Re: Exhibit # 10/9/2007- 3/25/2008 FBI Interview Reports of ----- (10/05/2007, 3/20/2008, and 3/25/2008), #2 (10/10/2007), #14 (10/26/2007), #33 (10/02/2007), #20 (10/25/2007), #21 (10/03/2007), (10/03/2007), (10/02/2007), #40 (6/12/2007), and #35 (10/02/2007) B-31 1(1/10/2007 A(. ).t., Lefkowitz Letter - 6 pages 10/16/2007- 10/23/2007 Emails between Marie Villafafia, Jeff Sloman, Alex Acosta, and Jay Lefkowitz regarding Special Master C-7 10/22/2007 Lefkowitz Sloman Email - 3 pages with four page draft letter to Judge and two page Addendum to the NPA, attached 10/23/2007 Acosta Lefkowitz Letter - 3 pages 10/23/2007 Sloman, Villafafia Acosta Response to Leflcowitz's letter noting specific misrepresentation 10/24/2007 Lefkowitz, Acosta, Villafana Sloman Email - 1 page with two page Addendum to the NPA, and four page draft letter to Judge , attached 10/25/2007 Lefkowitz Cyndee Campos Email - 1 page with letter to Judge attached 10/25/2007 The Hon. Edward B. Jeffrey Sloman Background information to Special Master to appoint attorney for victims 10/29/2007 Deadline date for Epstein's plea and sentencing according to Non-Prosecution Agreement 10/30/2007 Villafafia Sloman Email attaching final addendum 10/30/2007 Final executed Addendum to the Non-Prosecution Agreement 10/31/2007 Lefkowitz Sloman Email - 2 pages 11/1/2007 USAO extends deadline for Epstein's plea and sentencing per request of Epstein's counsel 11/1/2007 Research re State Work Release Privileged Confidential Page 22 of 5I Contains 6(e) Material EFTA00225449

EPSTEIN INVESTIGATION TIMELINE Date To From Re: Exhibit # 11/2/2007 Research re Florida Administrative Code Chapter 33-601. Classification of Central Records: 33-601.602 Community Release Programs and 33-601.606 Placement of Inmates into Community Release Programs 11/5/2007 Lefkowitz Sloman Letter - 2 pages 11/8/2007 Jeffrey Sloman Jay Lefkowitz response to 11/5/07 letter stating that Epstein is complying fully with the Non Prosecution Agreement (with Villafana handwritten notes) 11/13/2007 Jay Lefkowitz Jeffrey Slomantwo Response to 11/8/07 letter stating that a guilty plea and sentencing more than months beyond the original deadline is unacceptable. The agreement as to the terms of the plea and sentencing and the new date for the change of plea and sentencing is to be provided by 11/16/07. 11/14/2007 Jeffrey Sloman Villafana Email regarding meeting with State Attorney's Office about work release and sex offender registration - , 11/15/2007 Villafaiia, Sloman, Garcia, Acosta, Atkinson Jason Richards 11/15/2007-11/16/2007 Emails regarding research on work release -6 11/16/2007 Sloman Lefkowitz Email - 1 Page 11/19/2007 Research re Florida Statute 921.143 Appearance of victim, next of kin, or law enforcement, correctional, or correctional probation officer to make statement at sentencing hearing; submission of written statement and Victim Notification Request Form B-7 11/19/2007 Plea Notification Letter B-2 11/23/2007 Unscheduled meeting between Jay Lefkowitz, Alan Dershowitz and Jeff Sloman. (Drop in by Lefkowitz and Dershowitz) 11/26/2007 Jason Richards PBSO D/S Harold Elliott Research re work release: PBSO Post Orders for the Work Release Program Privileged Confidential Page 23 of 5I Contains 6(e) Material EFTA00225450

EPSTEIN INVESTIGATION TIMELINE Date To From Re: Exhibit # 11/27/2007 Lefkowitz, Acosta, Villafatia Sloman Email responding to Lefkowitz's statement in his letter that he needs to conduct "due dilligence" on selection of Podhurst firm 11/27/2007 Plea Notification Letter at 7:11 pm )3-3 11/28/2007 A. Marie Villafaiia, A. Oosterbaan, R. Garcia A. Lourie Email re non-prosecution agreement with attached correpondence 11/28/2007 Alice S. Fisher, Assistant Attorney General Starr Letter - 3 pages re 18 U.S.C. 2255 11/28/2007 Lefkowitz, Acosta, Sloman' Lourie, Oosterbaan Villafana Email regarding Epstein's plan to appeal to DC and proposed victim notification letter B-8 11/28/2007 Victim notification letter prepared 11/28/2007 at 9:42 pm B-4 11/29/2007 A. Marie Villafalia Jeffrey Sloman Request to draft letter that sets forth brief history and nature of the case, followed by a chronology of the plea negotiations and vetting with CEOS that results from those meetings, and how the civil resolution evolved. 11/29/2007 A. Marie Villafaiia Jeffrey Sloman Forward of email chain between Jeff Sloman and Andrew Lourie advising that defense backtracked on two issues: They originally agreed to plead to the state felony that they thought was unregisterable (but did not tell us knowing we thought it was), but then discovered they were wrong and tried to get out of it. They tried several times to knock down the jail time after agreeing to the time. 11/29/2007 Acosta Lefkowitz Letter - 4 pages, 4 page CVRA proposed notice letter attached B 9 Privileged Confidential Page 24 of 51 Contains 6(e) Material EFTA00225451

EPSTEIN INVESTIGATION TIMELINE Date To From Re: Exhibit # 11/30/2007 Jay Lefkowitz R. Alexander Acosta Need to confer with A. Marie Villafafia and Jeffrey Sloman regarding 11/29/07 letter. Counsel has objected to several steps taken by the USAO to effectuate the terms of the agreement and if Epstein is dissatisfied with the Agreement, we stand ready to unwind the Agreement. B I() 11/30/2007 Kenneth Starr Alex Acosta Letter in response to 11/28/2007 letter to Assistant Attorney General Fisher. Outlines the history of negotiations with various counsel for Epstein illustrating how the Non-Prosecution Agreement was reached. Request to provide definitive statement signed by Epstein of his intention to abide by each and very term of the Agreement by dose of business on 12/14/2007, or will proceed with prosecution. 11/30/2007 Research re CVRA 12/1/2007 Victim notification letter prepared 12/1/2007 at 7:50 pm B-6 12/3/2007 Acosta Villafaiia Emails regarding research on proposed trust fund 55 12/4/2007 Kenneth Starr R. Alexander Acosta Response to 11/28/07 letter regarding concerns of Non-Prosecution Agreement. The intent is to place the victims in the same position as they would have been had Epstein been convicted at trial. 12/5/2007 R. Alexander Acosta Kenneth Starr and Jay Lefkowitz Epstein reaffirms Non-Prosecution Agreement. Have no knowledge of deadlines. Request for updated draft victim letters B-11 12/6/2007 Jay Lefkowitz Jeffrey Sloman Concern about Epstein's failure to set a timely plea and sentencing date. Still have no received the terms of the Plea Agreement with the State Attorney's Office. There has been no contact with the press from our office or the FBI. Letters to victims will be sent through the mail. Attached revised crime victim's rights letter It 12 12/6/2007 Lefkowitz Acosta Letter and facsimile transmission cover sheet re victim notification latter, B-12 12/6/2007 Lefkowitz Sloman Letter - 4 pages, 4 page CVRA proposed notice letter attached 12/6/2007 Starr Acosta Letter - 7 pages Privileged Confidential Page 25 of 51 Contains 6(e) Material EFTA00225452

EPSTEIN INVESTIGATION TIMELINE Date To From Re: Exhibit # 12/6/2007 Emails between Marie Villafana, Andrew Lourie, Cyndee Campos, Jeff Sloman, Alex Acosta, Karen Atkinson, and Nesbitt Kuyrkendall regarding correspondence from Ken Starr, request for a meeting with Epstein counsel, and need to notify victims of upcoming plea 12/6/2007 12/6/2007-12/7/2007 Emails between Marie Villafatia, Nesbitt Kuyrkendall, Jason Richards, Jeff Sloman, Cyndee Campos, Annette Castillo, Karen Atkinson, and Shawn Ball regarding request from State Attorney's Office for draft plea proffer B-13 12/6/2007 Villafana Belchlank 12/6/2007-12/7/2007 Emails between Villafana, Sloman, and Belohlavek regarding a factual proffer for state plea 73 12/7/2007 Acosta, Fisher, Sloman Starr//. Lefkowitz Letter stating the defense will respond to Acosta letter by 12/10/07, and attaching " the independent ethics opinions of Judge Herbert J. Stern and Joe D. Whitley" 12/7/2007 Alan Dershwitz Herbert J. Stem Letter - 27 pages 12/7/2007 Kenneth Starr R. Alexander Acosta Independent ethics opinions of Judge Herbert J. Stem and Joe D. Whitley regarding the federal investigation of this matter and the Section 2255 component of the Agreement. 12/7/2007 Lilly Ann Sanchez Jeffrey Sloman Signed Affirmation of the Non-Prosection Agreement and Addendum. Plea and sentencing hearing scheduled for 1/4/08 at 8:30 am before Judge Sandra McSorley. R I s 12/7/2007 Sloman Lilly Ann Sanchez Letter -1 pages with Affirmation signed by Epstein and Notice of Heating, State of Florida I. Jeffrey Epstein, attached 12/7/2007 Victim notification letter prepared 12/7/2007 at 9:10 pm B-6 12/7/2007 Unmailed victim notification letters B-14 12/10/2007 Contacted counsel for JD#2/Individual #25 (paid for by Epstein) to determine if he still represented JD#2/Individual #25 and whether he should receive upcoming victim notification B-19 12/11/2007 Sloman and Acosta Villafatia Email regarding call with Jim Eisenberg 8-20 Privileged Confidential Page 26 of 51 Contains 6(e) Material EFTA00225453

EPSTEIN INVESTIGATION TIMELINE Date To From Re: Exhibit # 12/11/2007 R. Alexander Mona Kenneth Starr and Jay Lefkowitz 2 separate letters to address problems with case. Letter 1 - Federal Investigators relied upon tainted evidence. Improper involvement and conduct of Federal authorities (specifically names Villafana). Letter 2 - Section 2255 and background of negotiations 12/11/2007 Epstein counsel object to including JD#2/Indivival #25 as "victim" and begin their appeals to Washington, DC 12/12/2007 Complete indictment package marked "Originals 12/12/07" 12/12/2007 Emails between Marie Villafatia, Frederica Devlin, and Bob Senior regarding planning indictment review B-1(il 12/12/2007 Revised indictment package finalized 12/13/2007 Lefkowitz Villafaiia Letter - 5 pages 12/14/2007 Alex Acosta, Jeff Sloman, Rolando Garcia, and Karen Atkinson Mane Villafana Email with draft letters to State Attorney's Office and victims B I - 12/14/2007 Draft Crime Victims' Rights - Notification of Resolution of Epstein Investigation letter B I 6 12/14/2007 Research re Florida Procurement and Sentencing Guidelines (745 So.2d 979, 761 So.2d 474397 So.2d 741, 715 So.2d 274, 919 So.2d 695, 701 So.2d 1181, 711 So.2d 1290) 12/14/2007 Draft letter to Krischer from Acosta regarding Epstein filing as sex offender 69 12/14/2007 Acosta; Sloman Villafan-a Email regarding Fl. Stat. 796.03 (procuring minors for prostitution) and 18 U.S.C. 2255 74 12/17/2007 Acosta Lefkowitz Email responding to inquiry from 12/14/07 meeting about why defense had waited so long to go to DC Privileged Confidential Page 27 of 51 Contains 6(e) Material EFTA00225454

EPSTEIN INVESTIGATION TIMELINE Date To From Re: Exhibit # 12/17/2007 Acosta Starr, Lefkowitz 110-page letter addressing inapplicability of procurement statute to Epstein's conduct, State Attorney's Office's belief that Epstein should not have to register inapplicability of 18 USC 2422 to Epstein's conduct; and reiteration of 2255 concerns. Attachment: 7/6/07 Lefcourt letter Sloman, Menchel, Lourie, and Villafafia with attachments 12/17/2007 Jeff Sloman Marie Villafafia Email inquiring about case status and informing Sloman regarding agent concern about victim notification B-18 12/19/2007 Alex Acosta, Jeff Sloman, and Janice LaClainche Marie Villafasia Email regarding challenge to state charge raised by Epstein counsel during 12/14/2007 meeting B-19 12/19/2007 Lilly Ann Sanchez Acosta Follow up letter from 12/14/07 meeting 12/20/2007 Emails between Marie Villafafia and Jeff Sloman regarding inquiries from State Attorney's Office regarding Epstein plea to state charge and facts supporting state plea 12/21/2007 11. Al Acostaer exand Jay Lefkowitz Knowledge of "list" of alleged victims is limited. Proposal deprives Epstein of his opportunity to test the validity of these women's claims that would have been extensively tested at trial. B-21 12/26/2007 R. Alexander Acosta Jay Lefkowitz We do not object that some form of notice be given to the alleged victims. We request the opportunity to review the notification. Believe they should be sent by State Attorney's Office instead of USAO. More arguments about 2255 language. B-22 1/2/2008 Alex Acosta and Jeff Sloman Marie Villafafia Email regarding renewed plea negotiations for federal plea agreement 1/2/2008 Alex Acosta and Marie Villafaria Jeffrey Sloman Email regarding telephone conversation with State Attorney's Office about delay in Epstein state plea Privileged Confidential Page 28 of 51 Contains 6(e) Material EFTA00225455

EPSTEIN INVESTIGATION TIMELINE Date To From Re: Exhibit # 1/2/2008 Emails between Alex Acosta, Marie Villafatia, and Jeff Sloman regarding requests from Alex Acosta to Marie Villafafia for information related to the handling of the investigation by the State Attorney's Office 1/3/2008 I :.mails between Marie Villafatia, Alex Acosta, and Jeff Sloman regarding Alex Acosta telephone conference with Jay Lefkowitz where Lefkowitz admitted that he never intended to have Epstein plead guilty to an offense that required sex offender registration 1/4/2008 Scheduled date for Epstein's self surrender according to the Non-Prosecution Agreement 1/7/2008 Alex Acosta, Jeff Sloman, Robert Senior, Karen Atkinson, and Rolando Garcia Marie Villafatia Email regarding proposed additional investigative steps in Epstein case B-102 1/8/2008 Trial date set for State of Florida vs. Epstein i 9 , fiw, 1/9/2008-1/14/2008 Emails between Marie Villafaila, Drew Oosterbaan, Myesha Braden, Nesbitt Kuyrkendall, and Jason Richards regarding assigning a CEOS attorney to the investigation, meeting with the CEOS attorney and victims in Florida, the results of the meetings and planned additional meetings, and revisions to the indictment in light of the meetings. B-103 1/10/20”, Email chain between Myesha Braden and Marie Villafaila regarding meeting on 1/11/2008 B-104 1/14/2008 Marie Villafatia, E. Nesbitt Kuyrkendall, Jason Richards Myesha Braden Email chain regarding meeting and additional 302s B-105 1/17/2008 Agents compile evidence for Bob Senior indictment review B-106 Privileged Confidential Page 29 of 5I Contains 6(e) Material EFTA00225456

EPSTEIN INVESTIGATION TIMELINE Date To From Re: Exhibit # 1/25/2008 Email chain between Myesha Braden and Marie Villafana regarding victim's names in indictment B-107 1/31/2008 Add'l grand jury subpoenas prepared and served B-108 1/31/2008 1/28/2008-2/1/2008 Emails between Marie Villafafia, Jeff Sloman, Alex Acosta, Nesbitt Kuyrkendall, Jason Richards, and Alan Santiago regarding results of additional victim-witness interviews and requesting intervention with CEOS to move review process along B 109 1/31/2008 Sloman, Acosta Villafafia Email regarding victims C-1 2/12/2008 2/12/2008-2/22/2008 Emails between Marie Villafatia, E. Nesbitt Kuyrkendall, Jason Richards, and Myesha Braden re information for indictment/ongoing investigation B-110 2/19/2008 Complete indictment package, including 3rd Supplement to Pros memo 2/20/2008 2/20/2008-2/21/2008 Emails between Drew Oosterbaan, Marie Villafafia, Robert Senior, Jeff Sloman, Sigal Mandelker, Karen Atkinson, Alex Acosta, Rolando Garcia and Myesha Braden regarding status of CEOS plans to meet with counsel for Epstein and status of indictment review B-111 2/25/2008 Lefkowitz Sloman Email providing deadline for Epstein to perform 2/25/2008 Email chain between Marie Villafafia and Caroline Heck regarding use B 11, of Grand Jury 2/25/2008 Jeff Sloman, Bob Senior, Rolando Garcia, Karen Atkinson, and Myesha Braden Marie Villafafia Email re result of conferring with Caroline Heck about whether or not to continue presentation to same grand jury or p to a different grand jury B 1 11 2/26/2008 Myesha Braden Marie Villafafia Email re CEOS independent review and concern about victim's names being released B -I 14 Privileged Confidential Page 30 of 51 Contains 6(e) Material EFTA00225457

EPSTEIN INVESTIGATION TIMELINE Date To From Re: Exhibit # 2/26/2008 Sloman, Senior Villafatia Email response with concerns regarding allowing Epstein to keep the same deal as before R I I; 2/27/2008 Lefkowitz Sloman Email - 2 pages 2/27/2008 Email chain between Marie Villafatia, David Weinstein, and Bob Senior re email to the Civil Rights Chief B I ll, 2/28/2008 Entails between Marie Villafafia and Susan Roe regarding related investigation, potential investigatory leads, and CEOS review 2/28/2008 Email chain between Marie Villafain, Jason Richards, and E. Nesbitt Kuyrkendall regarding further investigation R 1 i - 2/29/2008 Acoqa Lefkowitz Email - 1 page 2/29/2008 Emails between Jeff Sloman, Marie Villafafia, Robert Senior, and David Weinstein regarding continuing investigation and status of CEOS review li I I', 3/1/2008 ' FBI Reports of March 2008 interviews of additional wimess/victitn located in New York 3/1/2008 Folder entitled "(Victims) Additional 302's" containing reports of interviews conducted in June 2007, October 2007, and March 2008 3/5/2008 Emails between Marie Villafain and E. Nesbitt Kuyrkendall with attached email to Alex Acosta, Jeff Sloman, Drew Oosterbaan, Robert Senior, Myesha Braden, Rolando Garcia, and Karen Atkinson regarding meeting in DC, additional information to prepare for meeting, and new information from ongoing investigation B 121 3/7/2008 Lefkowitz Oosterbaan Email - 2 pages 3/10/2008 Lefkowin Oosterbaan Email - 2 pages 3/10/2008 Oosterbaan Lefkowitz Email - 1 page 3/10/2008 3/10/2008-3/12/2008 Emails between Marie Villafatia, Robert Senior, Myesha Braden, Krishna Patel, Nesbitt Kuyrkendall, E.J.Yen, and Karen Atkinson about Epstein attempts to contact victims and finding counsel for victims B-23 3/12/2008 Sub oena to ---- return date 4/15/08 3/12/2008 Subpoena to (return date 4/15/08) 3/12/2008 Villafalia Kuyrkendall Email re affidavit for the memory cards B-119 Privileged Confidential Page 31 of 51 Contains 6(e) Material EFTA00225458

EPSTEIN INVESTIGATION TIMELINE Date To From Re: Exhibit # .3/12/2008 3/12/2008-3/17/2008 Emails between Marie Villafatia, Nesbitt Kuyrkendall and E.J. Yera regarding search warrant application and execution of search warrant 3/13/2008 Sigal Mandelker Lefkowitz Email - 2 pages (CEOS) 3/14/2008 Emails between Marie Villafaila, Rolando Garcia, Karen Atkinson, Frederica Devlin, and Shawn Ball regarding complete indictment package for Robert Senior final review B-27/B- 122 3/14/2008 Revised indictment package B-25 3/17/2008 Search warrants for digital camera memory cards B-120 3/18/2008 Grand Jury presentation materials and testimony of Special Agent E. Nesbitt Kuyrkendall B-26 3/19/2008 Email chain between Marie Villafaiia, David Weinstein, Jeff Simian, Bob Senior, Karen Atkinson, and Rolando Garcia with Epstein update from grand jury presentation and grant from the Justice Department to provide legal representation to victims C-2 3/19/2008 3/19/2008-3/22/2008 Emails regarding victims being harassed by Epstein's investigators ( ; 3/20/2008 Vilialana Richard H. Willits Letter that he is representing Individual #3 3/21/2008 Responses to addil_grand jury subpoenas received 3/25/2008 Planned grand jury presentation (moved to 4/15/2008 then to 4/29/2008) 3/28/2008 Sigal Mandelker Starr Letter - 5 pages (CEOS) B-28 3/28/2008 Villafalia Danchuk Letter advising of representation of Individual #3 and that a lawsuit has been filed in Palm Beach County Circuit Court B-41 4/1/2008 Jay Lefkowitz Jeffrey Sloman Draft letter regarding termination of agreement Privileged Confidential Page 32 of 51 Contains 6(c) Material EFTA00225459

EPSTEIN INVESTIGATION TIMELINE Date To From Re: Exhibit # 4/2/2008 Emails between Marie Villafatia, Alex Acosta, Jeff Sloman, Karen Atkinson, Robert Senior, Rolando Garcia, and Nesbitt Kuyrkendall regarding efforts by Jay Lefkowitz and Ken Starr to speak with Alex Acosta and instructions to direct question to Marie Villafaila and Karen Atkinson 4/8/2008 Sigal Mandelker Starr Letter - 4 pages (CEOS) 4/9/2008 Willits Villafalla Letter in response to 3/28/08 letter from Willits B-42 4/21/2008 4/21/2008-5/9/2008 Emails between Marie Villafaiia, Jeff Sloman, Karen Atkinson, Bob Senior, E. Nesbitt Kuyrkendall, Jason Richards, and Drew Oosterbaan re status of grand jury presentation, and ongoing investigation, and delay B-124 4/22/2008 Office of Professional Responsibility A. Marie Villafafia Letter re Self-Report of Allegation of Conflict of Interest 4/28/2008 Sigal Mandelker Starr Letter - 4 pages (CEOS) 4/29/2008 Operation Leap Year Revised Indictment Summary chart (by Victim) and Grand Jury presentation Operation Leap Year B-29 4/29/ 2008 Draft Indictment 8-30 5/6/2008 Subpoena to Leigh Ann Murray (return date 5/6/08) 5/14/2008 Asst Atty General Fisher Starr Letter - 4 pages (CEOS) 5/15/2008 Jay Leflcowitz Andrew G. Oosterbaan Federal prosecution would not be improper or inappropriate. It -24 5/15/2008 CEOS and DAAG Fisher complete review of Epstein's appeal 5/15/2008 5/15/2008-5/27/2008 Emails between Marie Villafatia, Karen Atkinson, Bob Senior, Jeff Sloman, and agents regarding indictment review and status of investigation B-125 5/19/2008 Acosta Lefkowitz Email - 3 pages B-35 5/19/2008 Attv Deputy ' General Filip Starr/Whidey Letter - 8 pages 8-33 Privileged Confidential Page 33 of 51 Contains 6(e) Material EFTA00225460

EPSTEIN INVESTIGATION TIMELINE Date To From Re: Exhibit # 5/19/2008 Lefkowitz Cyndee Campos Email - 1 page with 5/19/08 letter attached B-35 5/19/2008 Lefkowitz Sloman Letter - 6 pages B-35 5/19/2008 Lefkowitz, cc: Sloman and Villafatia Acosta Response email to Lefkowitz's 5/19/08 email re Drew Oosterbaan letter, which is attached B-36 5/19/2008 Kirldand & Ellis LLP, Response to Letter by FAUSA Sloman dated 5/19/2008 - 10 pages B-37 5/19/2008 Lefkowitz Sloman Letter setting June 2, 2008 deadline to comply with terms and conditions of the NPA B-32 5/27/2008 Honorable Mark Filip, DAG Kenneth Starr Request for independent review of Epstein matter B-33 5/27/2008 Emails between A. Marie Villafana and Karen Atkinson regarding report of new state plea deal for J. Epstein 11-39 5/27/2008 Emails between A. Marie Villafaiia, Robert Senior, Jeff Sloman, and Karen Atkinson regarding potential renewed plea negotiations for J. Epstein and plans to review and review updated indictment package R ',K 5/27/2008- 6/13/2008 Internal emails after CEOS letter rejecting appeal where Marie Villafaiia asks to indict and Jeff/Alex advise Epstein will be given chance to perform B m 5/28/2008 Atkinson, Villafana, Garcia Villafana, Sloman Email chain regarding information from Barry Krischer, the State Attorney 5/28/2008 Lefkowitz Sloman Email - 1 page 5/28/2008 Soman, Villafana Atkinson Email chain regarding Epstein's request to do less time than 18 months 5/29/2008 Villafalia, Senior; cc: Atkinson, Kuyrkendall, Richards Sloman Email regarding DAG decision to consider Epstein's "appeal" and that GJ for Tuesday is off B-40 Privileged Confidential Page 34 of 51 Contains 6(e) Material EFTA00225461

EPSTEIN INVESTIGATION TIMELINE Date To From Re: Exhibit # 5/30/2008 FBI-302 of 5/28/08 Interview of Individual #35 13-126 6/2/2008 Villafatia Sloman Draft letter to DAG B-127 6/3/2008 Honorable Mark Filip, DAG Kenneth Starr Submission with documents for independent review 6/3/2008 Starr/Whitley John Roth Letter - 1 page 6/3/2008 Honorable Mark Filip , DAG Sloman 2nd draft letter to DAG B 12'1 6/3/2008 Draft letter to Deputy Attorney General Mark Filip regarding reasons to approve continued prosecution of J. Epstein B-128 6/6/2008 Emails between Marie Villafafia and E. Nesbitt Kuyrkendall and subpoena issued to victim/witness and need for additional subpoenas B-129 6/17/2008 Application for 6001 immunity for grand jury witness B-130 6/17/2008 Acosta, Sloman, Senior, Atkinson, Garcia Villafalia Email summarizing meeting with Krischer regarding Epstein's attempt to negotiate a new plea deal 78 6/18/2008 Villafafia Senior Email regarding call with Roy Black and response that Washington has not made a final decision 6 18/2008 Emails between A. Marie Villafafia, Robert Senior, Alex Acosta, Jeff Sloman, Rolando Garcia, and Karen Atkinson regarding telephone conference with Roy Black about allowing.). Epstein to accept state plea to 60 days' imprisonment 68 6/18/2008 Notes from call to Brad Edwards, counsel for #43, and notes from message to Roy Black and message from Roy Black B-43 6/19/2008 Barry Krischer; Karen Atkinson \ ill.it.ina Email re wrapping up the case 68 Privileged Confidential Page 35 of 51 Contains 6(e) Material EFTA00225462

EPSTEIN INVESTIGATION TIMELINE Date To From Re: Exhibit # 6/19/2008 Honorable Mark Filip, DAG Kenneth Starr Additional documents for independent review 6/19/2008 John Roth Stephanie D. Thacker Letter - 14 pages 6/20/2008 Request to travel to New York for witness interviews in June 2008 and subpoena B-132 6/23/2008 Lefkowitz/ Starr John Roth Letter - 1 page 8-44 6/23/2008 Emails between Jeff Sloman, Bob Senior, and Marie Villafatia instructing Marie Villafaiia to inform Epstein's attorneys that he had until June 30 to enter a guilty plea and Villafafia email to Lefkowirz re same B-49 6/23/2008 Villafaiia, Kuyrkendall, Richards, cc: Atkinson Senior Email regarding New York Jane Doe and awaiting a response from DAG's office 6/23/2008 Emails between A. Marie Villafafia, E. Nesbitt Kuyrkendall, J. Richards, K. Atkinson, and R. Senior regarding grand jury subpoena to victim/witness, revisions to indictment, planned grand jury presentation, and plans to supersede indictment IS Ill 6/23/2008 DAG Filip completes review of Epstein's appeal 6/23/2008 6/23/2008-6/26/2008 Emails between Marie Villafaiia and grand jury witne, regarding immunity and travel for grand jury appearance B 13d 6/24/2008 Letter from Matthew W. Friedrich, Acting Assistant Attorney General authorizing application for a court order granting 6001 immunity P, 1 'd 6/24/2008 Villafaiia Sloman Email re discussion about going to the change of plea regarding Jeffrey Epstein 6/24/2008 Villafaiia; cc: Jack Goldberger Roy Black Email chain regarding wrap up call B-45 Privileged Confidential Page 36 of 5 I Contains 6(e) Material EFTA00225463

EPSTEIN INVESTIGATION TIMELINE Date To From Re: Exhibit # 6/25/2008 Villafafia Sloman Email regarding having telephone discusion about 2255 issue and to discuss plea 8 6/25/2008 Villafafia Sloman Email with revised victim notification letter IS-47 6/25/2008 Emails between A. M. Villafaria, J. Sloman, R. Senior, K Atkinson, and A. Acosta regarding draft of notification of victim list for J. Epstein counsel with attached drafts 8-48 6/26/2008 Black and Goldberger Villafafia Email re proposed plea agreement and date and time of change of plea 6/26/2008 Villafaria Sloman Email regarding factual proffer 6/26/2008 Fax from FBI with victim list B-SO 6/27/2008 Black and Goldberger Villafaria Letter regarding plea agreement between Epstein and SA and that the proposed sentencing provision does not comply with the terms of the NPA 6/27/2008 Black and Goldberger Villafaria Emails between Villafana and Black/Goldberger about problems with state plea agreement 77 6/27/2008 Counsel for Epstein advise USAO of Epstein state court change of plea on 6/30/08 BSI 6/27/2008 AUSA Villafafia notifies Attorney Edwards of upcoming change of plea and urges his clients to attend 6/27/2008 USAO notifies Palm Beach Police Chief Reiter of upcoming change of plea. He states intention to notify as many victims as possible of hearing. 8-53 6/27/2008 Research re State Work Release 6/27/2008 Sloman, Atkinson Villafalia Email inquiring about conversation with Chief Reiter B-52 6/27/2008 Sloman Villafafia Email summarizing conversation with Goldberger that Epstein would serve sentence in confinement "24-hours-a-day" 79 6/28/2008 Emails between A. M. Villafalia, J. Sloman, A. Acosta, and IL Senior regarding correspondence with J. Goldberger and proposed change to state plea agreement 77 6/29/2008 \ 'illafafia Kuyrkendall Email regarding work release 80 Privileged Confidential Page 37 of Si Contains 6(e) Material EFTA00225464

EPSTEIN INVESTIGATION TIMELINE Date To From Re: Exhibit # 6/30/2008 Villafatia Mycsha Braden Email chain regarding Epstein sentencing 6/30/2008 Villafatia Susan Roc Email chain regarding news article 6/30/2008 Villataria Ted Leopold Email chain with response to 6/30/08 email from Villafana with contact info don 6/30/2008 Emails between Marie Villafana and attorney for grand jury wimess withdrawing subpoena B-I35 6/30/2008 Epstein enters guilty plea in state court in accordance with NPA. JD#1/Individual #43, JD#2/Individual #25, and counsel do not appear. ASA and counsel for Epstein disclose to state court judge existence of NPA, which is later incorporated into state court record. 6/30/2008 Notcs from calls to Michael Danchuk and Richard Willets, Jeff Herman, Brad Edwards, Ted Leopold, and Mike Dutko B-55 6/30/2008 Research re State Work Release 6/30/2008 Draft notification of identified victims letters to Guy Lewis, Jack Goldberger, and Roy Black B 5( 6/30/2008 Villafafia Oosterbaan Email regarding Epstein guilty plea and sentencing 71 6/30/2008 2008-2009 Epstein serves prison term 7/1/2008 Smachetti Villafana Email response stating that Villafana handled Epstein case but did not come up with the 18-month deal 7/1/2008 Villatatia Anne Schultz Email regarding Epstein plea 7/1/2008 Villatatia Smachetti Email chain regarding Epstein case 7/3/2008 Col. M. Gauger, Palm Beach Sheriffs Office A. Marie Villafana Email re Epstein work release with attachment 7/3/2008 Sloman Villafaila Email re victim's lawyer 7/3/2008 Villafatia Brad Edwards and Jay Howell Letter advising of representation of Epstein victims 7/3/2008 Villatafia Ted Leopold Email advising client names Privileged Confidential Page 38 of 51 Contains 6(e) Material EFTA00225465

EPSTEIN INVESTIGATION TIMELINE Date To From Re: Exhibit # 7/3/2008 Villafafia; cc: Acosta c.1/01),In Email response to 7/3/08 email from Villafafia regarding victims' lawyer 7/3/2008 Emails between A. M. Villafafia, J. Sloman, and A. Acosta regarding telephone conference with B. Edwards and regarding meeting with Sheriffs Office about work release program s I 7/7/2008 JD#1/Individual #43 files "Emergency Petition" 7/7/2008 Notes from calls to Mike Dutko, Brian Poulton, ASA, and Ted Leopold 7/7/2008 Notes of phone call with Roy Black held some time between 7/7/08 and 9/19/08 7/8/2(07; D. Lee, A. Acosta, J. Sloman A. Marie Villafafia Email regarding victim notification letter provided to counsel for J. Epstein on 11/28/2007 with attachment 7/8/2008 Goldberger Villafafia Letter re victim notification letters B-57 7/8/2008 Lee, Sloman, cc: Villafafia, Jacobus Acosta Email with attached second draft of response in Jane Doe case 7/8/200s Villafafia Goldberger Letter that he will respond on 7/9/08 B-58 7/9/2008 1 costa, Sloman, Atkinson; cc: Kuyrkendall and Richards Villafaila Email regarding response to Goldberger letter B-59 7/9/2008 Goldberger Villafafia Response to Goldberger's 7/9/08 letter re notification of identified victims B-60 7/9/2008 Lee, Villafalia, Acosta; cc: Atkinson, Jacobus Sloman Email chain regarding confidentiality provision and filing under seal for victim response 7/9/2008 Villafafia Goldberger Letter re Notification of Identified Victims B-61 7/9/2008 Victim Notification letters to Individuals #35 and #43 via Brad Edwards B-66 Privileged Confidential Page 39 of SI Contains 6(e) Material EFTA00225466

EPSTEIN INVESTIGATION TIMELINE Date To From Re: Exhibit # 7/9/2008 Govt responds to "Emergency Petition" 7/10/2008 Goldberger Villafafia Letter stating that government will provide victim notifications on a rolling basis B-62 7/10/2008 Villafalia Goldberger Letter requesting list of all victims B-64 7/10/2008 Goldberger Villafatia Letter with final notification of identified victims B-63 7/10/2008 Villafafia, Acosta, Atkinson, cc: Kuyrkendall, Richards Sloman Email regarding proposed response to Goldberger B 65 7/10/2008 Victim Notification letters to Individuals #3 (via Richard H. Willits), #8 (via Jeffrey Herman), ##17 (via Theodore J. Leopold), #25 (via Jeffrey Herman), #26 (via Jeffrey Herman), #37 (via Michael E. Dutko), and #44 (via Jeffrey Herman) B-67 7/11/2008 Hearing before Judge Marra 7/14/2008 7/14/2008-7/15/2008 Emails between A. M. Villafaria, E. Nesbitt Kuyrkendall, J. Richards, and T. Smith regarding FBI victim notifications and guidance regarding language to use and information to provide B 6', 7/17/2008 Villafafia, Acosta, Atkinson, Lee Sloman Email chain with revised draft of Tein letter 7/17/2008 Letter to Tein with attached fax cover sheet and transmission report 7/17/2008 Tein and Goldberger Villafaila Letter re Notice of Continued Pendency of Federal Criminal Action 7/18/2008 7/18/2008-7/21/2008 Emails between A. M. Villafacia, J. Sloman, E. Nesbitt Kuyrkendall, J. Richards, D. Lee, and IC Atkinson regarding preparation of victim notification letters, victim contact list, filing of victim notification letter in a civil proceeding, and contact by B. Edwards with one victim opining that sentence imposed was insufficient B-69 Privileged Confidential Page 40 of 51 Contains 6(e) Material EFTA00225467

EPSTEIN INVESTIGATION TIMELINE Date To From Re: Exhibit # 7/19/2008 Emails with other AUSAs in other districts and documents regarding disclosing identifying information about victims 7/21/2008 Goldberger Villafafia Letter with 11 additional victim notification letters 7/21/2008 Villafaila Goldberger Letter with attached Motion for Return of Property 7/21/2008 Villafaiia Kuyrkendall Email with list of victims that Twiler still needs to make contact with It 6') 7/21/2008 Villafaiia Tein Letter in response to 7/17/08 letter from Villafaiia 7/21/2008 Victim Notification letters to Individuals #1, #2, #4, #13, #9, #14, #21, #23, #30, #32, and #38 7/21/2008 Villafaiia; cc: Senior Sloman Email response to Vilkfaiia's 7/21/08 email regarding Motion for Return of Property in State Court 7/22/2008 Villafaiia K tz% rkcndall Email chain regarding victim addresses 7/22/2008 Emails between A. M. Vitiate's, A. Acosta, J. Sloman, R. Senior, K. Atkinson, E. Nesbitt Kuyrkendall, and J. Richards regarding 7/21/2008 letter from M. Tein announcing plan to stay the civil suits against J. Epstein and notification that B. Reinhart is counts! of record for S. Kellen in civil suits 7/23/2008 Emails between A. M. Villafaria and D. Lee regarding correspondence with counsel for]. Epstein and notice of breach 7/25/2008 Emails between A. M. Villafaria and K. Atkinson regarding extension of grand jury to allow for continued representation of J. Epstein case 7/30/2008 Villafaiia Atkinson Email regarding contact with Roy Black 7/30/2008 Villafaria Roy Black Email chain regarding call relating to the performance of the criminal Non- Prosecution Agreement 8/1/2008 Lee, Acosta; cc: Villafaiia, Jacobus, Senior Sloman Email chain regarding Jane Doe litigation 8/2/2008 Lee, Villafaiia Acosta Email re: Letter from Brad Edwards 8/5/2008 A. Acosta, J. Sloman R. , Senior, and K. Atkinson A. Marie Villafalia Email regarding analysis of Jeffrey Epstein agreement, with attached 6/24/2008 email from A. M. Villafaiia to R. Black and J. Goldberger and attached Epstein agreement It - 1 Privileged Confidential Page 41 of 51 Contains 6(e) Material EFTA00225468

EPSTEIN INVESTIGATION TIMELINE Date To From Re: Exhibit # 8/5/2008 Villafaiia, Senior, Sloman, Lee, cc: Atkinson Acosta Email with attached suggestions to Superseding Non-Prosecution Agreement B-72 8/6/2008 Villafatia, Acosta, Sloman, Atkinson Senior Email regarding filing in state court case 8/7/2008 Villafana Roy Black Email responding to 8/7/08 email providing notification of possible compelled disclosure of the Non-Prosecution Agreement B-73 8/6/2008 Villafatia Senior Response regarding Roy Black's response to email B-74 8/12/2008 Villafafia Senior Response to request for conference call prior to call with Roy Black B-75 8/13/2008 Atkinson, Acosta, Sloman, Lee, cc: Villafaiia Senior Email re Epstein and call with Jay B-76 8/13/2008 Atkinson, Senior, Sloman, Lee, cc: Villafafia Acosta Email response regarding final version of agreement B-77 8/13/2008 Lefkowitz Villafafia Letter regarding performance of the N PA 8-78 8/13/2008 Research re PBSO rules and regulations 8/13/2008 8/13/2008-8/15/2008 Emails between A. Acosta, K. Atkinson, R.. Senior, J. Sloman, D. Lee, and A. M. Villafafia regarding scope of Epstein agreement and correspondence and telephone conference with J. Lefkowitz B-79 8/14/2008 Villafana -;enior Email response to 8/14/08 email from Villafaiia advising Dexter disagrees with strategy 8/14/2008 Villafana, cc: Atkinson Lefkowitz Email re Follow up point regarding victims B-80 8/14/2008 Status Conf before Judge Marra Privileged Confidential Page 42 of 51 Contains 6(e) Material EFTA00225469

EPSTEIN INVESTIGATION TIMELINE Date To From Re: Exhibit # 8/15/2008 Acosta, Villafafia, Sloman, Lee, Atkinson Senior Email questioning whether offer should be withdrawn as opposed to considering it a nullity 13-81 8/15/2008 Email chain between Villafaiia, Acosta, Sloman, Senior, Atkinson, and Lee re draft response to 8/15/2008 email from Jay Leflcowitz regarding implementation of the NPA 13-82 8/15/2008 Lefkowitz and Black Villafaiia Letter re terms of NPA 13-83 8/15/2008 Villafatia, cc: Atkinson Le&owitz Email re Follow up point with attached entails from 8/14/08 8/18/2008 Villafaiia Leflcowitz Letter re restitution 13-84 8/21/2008 Leflcowitz and Black Villafafia Letter re Special Master and draft Notification of Identified Victim B-85 8/22/2008 Villafatia Lefkowitz Letter re misstatements in 8/21/08 Villafafta letter B-86 8/22/2008 Draft Victim Notification letter to Michael E. Dutko re Individual #37 8/25/2008 Emails between A. M. Villafafia, A. Acosta, J. Sloman, R. Senior, K. Atkinson, and D. Lee regarding letter received from J. Leflcowitz 8/26/2008 Lefkowitz and Black Villafatia Letter re victim's list B-87 8/26/2008 Villafaiia, cc: Acosta, Senior Sloman Email regarding changes to letter to Jay 9/2/2008 Villafatia Lefkowitz Letter agreeing that Goldberger should be listed as the contact person and re Josfsberg's fees B-88 9/2/2008 Emails between A. M. Villafaiia, D. Lee, R. Senior, and J. Sloman regarding revised victim notification Privileged Confidential Page 43 of 51 Contains 6(e) Material EFTA00225470

EPSTEIN INVESTIGATION TIMELINE Date To From Re: Exhibit # Mailed Amended Victim Notification letters to Individuals #1, #2, #3 (via 9/2/2008 Richard H. Willits), #4, #13, #8 (via Jeffrey Herman), #9, #10, #11, #14, #16, #17 (via Theodore Leopold), #20, #21, #23, #24, #25 (via Jeffrey B-89 Herman), #26 (via Jeffrey Herman), #30, #31, #32, #33, #37 (via Michael E. Dutko), #38, #44 (via Jeffrey Herman) 9/3/2008 Victim notification letters to Individuals #36, #35 (via Brad Edwards), #42, #43 (via Brad Edwards) B ()c Email chain regarding Epstein and recommendation on working with same 9/8/2008 Villafana Susan Roe team Michael 9/12/2008 Villafatia Danchuk Letter requesting copy of the settlement agreement 9/12/2008 Notification of Identified Victim letter. Individual #39 B-91 9/15/2008 Michael Danchuk Villafafia Letter in response to 9/12/08 letter from Danchuk 9/15/2008 Mailed victim notification letters for Individuals #18 and #32 B-92 9/17/2008- Emails and coorespondence with The Florida Bar re victim notifications B-93 11/4/2008 9/16/2008- Emails between Villafafia, Krischer, Belohlavek, Garcia, Sloman, and Atkinson 70 9/17/2008 regarding Palm Beach Daily News requesting copy of the NPA and discussion 9/17/2008 Lefkowitz, Black, and Villafatia Letter re Palm Beach Daily News requesting information about the NPA Goldberger 9/17/2008 Villafaila, Acosta, Senior, Lee, Atkinson •1( )man Email chain regarding obligation to sealing NPA 9/19/2008 Notes of calls to Bob Josefsberg Email agreeing with Villafalia's 10/8/08 email that a copy of the Response to 10/8/2008 Villafatia Senior Jane Does' Motion to Unseal the NPA should be mailed to Epstein's attorneys Privileged Confidential Page 44 of 51 Contains 6(e) Material EFTA00225471

EPSTEIN INVESTIGATION TIMELINE Date To From Re: Exhibit # 19/8/2008 Villafaiia Slornan Email response to Villafafia's 10/8/08 email advising to send a copy of pleading to Roy and Jay 10/8/2008 Villafaiia, Roy Black, cc: Atkinson, Lee Lefkowitz Email thanking Villafaiia for fowarding United States' Response to Petitioners' Motion to Unseal the Non-Prosecution Agreement with attached email from 10/8/08 10/16/2008 Villafaiia, Roy Black, cc: Atkinson, Lee Lefkowitz Email thanking Villafaila for forwarding the reply brief filed by Brad Edwards with attached 10/16/08 email 10/23/2008 10/23/2008-5/27/2008 ? Emails between A. Marie illafafia, Nesbitt Kuyrkendall, and J. Richards regarding plans to meet to prepare for indictment presentation, service of grand jury subpoenas, interviews of additional witnesses, and plea negotiation issue 10/27/2008 Villafafia Myesha Braden Email chain titled Things to do in West Palm 11/4/2008 Villafafia Senior Email thanking Villafatia for her 11/3/08 email advising she spoke with the Florida Bar 11/4/2008 Correspondence from Florida Bar Ethics Counsel regarding Florida Ethics Rules involved in distributing victim notification letters 11/14/2008 Notification of Identified Victim letters to Individuals #20, #40 B 9 I 11/17/2008 Villafaiia Lefkowitz Email chain regarding meeting 11/19/2008 Villafaiia; cc: Katherine W. Ezell and Amy Eden Robert C. Josefsberg Email with list of Epstein victims and representation 11/20/2008 Villafaiia Senior Email response to Villafaiia's 11/20/08 email advising that Epstein is on work release and request to indict him 82 11/21/2008 Villafaiia, Acosta, Sloman, Atkinson; cc: Garcia Senior Email advising Jeff Sloman is in agreement with approach and next steps 82 11/24/2008 Roy Black Villafafia Letter re work release program and research Privileged Confidential Page 45 of 51 Contains 6(e) Material EFTA00225472

EPSTEIN INVESTIGATION TIMELINE Date To From Re: Exhibit # 11/26/2008 Villafafia and cc: Atkinson Roy Black Email stating that Jeffrey Epstein has not breached his Non-Prosecution Agreement by performing work release 11/26/2008 Emails between A. M. Villafafia, J. Sloman, and R. Senior regarding email from It. Black about work release 12/3/2008 Villafalia Lefkowitz Email that he will not be attending meeting with Roy Black 12/4/2008 Villafatia Atkinson Email with attached draft letter to notify victims of Epstein's work release B-95 12/4/2008 Villafaiia; cc: Sloman Roy Black Email with attached Motion to Correct Sentence 12/5/2008 Brad Edwards, Esq. Villafaiia Email with attached Work Release Notice B-96 —12/5/2008 Herman Villafafia Email with attached Work Release Notice B-96 12/5/2008 Lefkowski, Villafaiia; cc: Atkinson Roy Black Email response to 12/5/08 email from Villafafia advising that Brad Edwards filed the Non-Prosecution Agreement in the Jane Doe case and has asked the Court to unseal it 12/5/2008 Robert C. Josefsberg Villafana Email with attached Work Release Notice B-96 12/5/2008 Ted Leopold Villafatia Email with attached Work Release Notice B-96 12/5/2008 Villafalia Sloman Email advising no objections to the draft letter for work release notice attached to Villafafia's 12/4/08 email 12/5/2008 Willits Villafaiia Email with attached Work Release Notice B 96 12/8/2008 Spencer Kuvin, Jack Scarola, Michael Dutko, #11, #39 Villafalia Email with attached Work Release Notice p, ir 12/8/2008 Notification of Work Release Letter to Individual #40 It ')- 12/8/2008 Florida Statute 796.03 Procuring person under age of 18 for prostitution 12/8/2008 Florida Statute 775.0837 Habitual misdemeanor offenders Privileged Confidential Page 46 of 51 Contains 6(c) Material EFTA00225473

EPSTEIN INVESTIGATION TIMELINE Date To From Re: Exhibit # 12/8/2008 Florida Statute 796.07 Prohibiting prostitution, etc.: evidence; penalties; definitions 12/9/2008 Notification of Work Release letters to Individuals #4, #10, #16, #18, #23, #24, #33, #38, #30 (personal note), #42 B-98 12/9/2008 Research re false statements on Epstein's application for work release 83 12/10/2008 Villafaria Senior Email requesting to speak with Villafafia regarding article about Epstein's work release 12/10/2008 Villafafia Sloman Email re Epstein work release letter 12/11/2008 Captain David Sleeth, Palm Beach Sheriffs Office A. Marie Villafaiia Letter regarding Work Release Application of Jeffrey Epstein stating that there are some inaccuracies and omissions in Mr. Epstein's file. ‘.\ 4 12/11/2008 Villafafia, cc: Senior Sloman Email advising a copy of the letter should be sent to Mr. Black 12/11/2008 Villafaiia , Sloman Senior Email chain regarding sending copy of letter to Mr. Black 12/12/2008 Villataria; cc: . Mitch Kitroser Spencer Kuvin Email response advising he will consult with client in response to Villatalia's 12/11/08 email re: Epstein work release 12/12/2008 Notification of Work Release letter to #42 8-100 12/12/2008- 12/29/2008 Emails with attorneys for victims regarding Epstein work release It 'F) 12/15/2008 Villafaiia, Sloman, Atkinson, cc: Kuyrkendall, Richards Senior Email chain regarding articles about Epstein 2/3/2009 Roy Black Josefsberg Email re payment Privileged Confidential Page 47 of SI Contain): 6(c) Material EFTA00225474

EPSTEIN INVESTIGATION TIMELINE Date To From Re: Exhibit # 2/11/2009 Amy Ederl, Evelyn Sheehan, Katherine W. Ezell, Bert Patton Josefsberg Email chain regarding payment and client's position 2/13/2009 Josefsberg Lefkowitz Letter re invoices are for services exceeding scope of services for which Epstein agreed to pay for 2/20/2009 Lefkowitz Josefsberg Response to 2/13/09 Lefkowitz letter 3/3/2009 Josefsberg Lefkowitz Response to 2/20/09 Josefsberg letter 6/8/2009 Robert Critton Katherine W. Ezell Letter re payment 6/9/2009 Sloman, Senior, Garcia, Atkinson Villafana Memorandum re Operation Leap Year: Request to Provide Notification of Breach 85 6/9/2009 File folder entitled "6/9/09 Signed Indictment" containing signed indictment package dated 6/9/2009 with corrections 86 6/9/2009 Indictment package signed again for presentation on 6/16/2009 6/11/2009 Villafatia Katherine W. I lizell Email re letter from Critton Denying any fees and hearing on 6/12/09 6/12/2009 Goldberger \ illafafia Letter re violation of NPA 87 6/12/2009 Villafaila 1.efkowitz Letter re response to Villafaila 6/12/09 letter giving notice of breach with attached Defendant Jeffrey Epstein's Notice of Withdrawal of Arguments I through VII of the Defendant's Motion to Dismiss Plaintiffs First Amended Complaint 6/12/2009 File folder entitled "6/12/09 Victim Notif. Log: containing chart with victim contact information and attorney notes regarding dates and type of contacts 6/12/2009 Transcript of Motion Hearing before judge Marra 6/15/2009 Lefkowitz, Black, and Goldberger N'illafatia Letter regarding history of Epstein's performance under the NPA 88 Privileged Confidential Page 48 of 51 Contains 6(e) Material EFTA00225475

EPSTEIN INVESTIGATION TIMELINE Date To From Re: Exhibit # 6/15/2009 Villafalia Lefkowitz Letter re Josefsberg's fees 6/16/2009 Villafafia Ka Katherine Ell W. Email with attachment 6/17/2009 Lefkowitz Villafafia Letter in response to Lefkowitis 6/15/09 letter ,..,) 6/19/2009 Villafafia Lefkowitz Letter re discussion regarding ongoing obligations per NPA 7/6/2009 Villalatia Spencer Kuvin Letter requesting copy of NPA 7/7/2009 Lefkowitz Villafarla - Letter in response to 6/19/09 letter 7/8/2009 Villafafia Critton Letter rc NPA with attached Defendant Epstein's Motion to Dismiss Plaintiffs Complaint (Jane Doe #8) 7/31/2009 Villafatia Spencer Kuvin Letter with follow up request for NPA 8/4/2009 Spencer Kuvin Villafana Letter in response to request for NPA 8/5/2009 Respondent BB's Motion to Supplement the Record (4D09-2554) 8/20/2009 Jeffrey Epstein's Response to Motion to Supplement the Record (4D09-2554) 9/1/2009 Roy Black A. Marie Villafaria Draft of letter regarding breach of Non Prosecution Agreement with handwritten attorney (Villafana) notes 9/1/2009 Sloman Roy Black Letter re Epstein wanting to transfer his supervision from State of Florida to the Virgin Islands 90 9/17/2008 Draft of letter regarding transfer of supervision to the Virgin Islands with attorney 9/18/2009 Black Villafana Letter in response to transfer of supervision to the Virgin Islands (Villafafia) Letter notes 9/29/2009 Hon. Jeffrey Colbath Adam Horowitz Letter that Epstein violated his No-Contact Order on 9/16/09 by coming within 10 feet of Horowitz's client, Individual #44, Jane Doe No. 4. 10/21/2009 Villafafia Roy Black Response to 9/18/09 letter 10/29/2009 Open file and request USAO# (2009R02690, Operation Stolen Globe) Privileged Confidential Page 49 of 51 Contains 6(e) Material EFTA00225476

EPSTEIN INVESTIGATION TIMELINE Date To From Re: Exhibit # 12/9/2009 Villafafia Roy Black Letter in response to 11/02/09 letter re Epstein's place of employment with attached Complaint against Scott Rothstein and Bradley J. Edwards 1/4/2010 Villafafia Spencer Kuvin Letter re computer seized by FBI 1/20/2010 Villafalia Roy Black Letter re attorney's fees 1/21/2010 Villafatia Roy Black Email re 1/20/10 letter 2/11/2010 Roy Black Villafafia Letter in follow up to meeting held week prior 2/18/2010 Villafatia Roy Black Letter in response to 2/11/10 letter from Villafatia 3/4/2010 Roy Black and Martin Weinberg Critton Letter on thoughts and issues concerning NPA 3/5/2010 Sloman, . Villafana, Senior Roy Black Letter renewing request for clarity as to what legal issues civil counsel can . itigated without causing breach of NPA 3/29/2010 Sloman, Villafana, Senior Roy Black Letter re Motion to Dismiss 4/2/2010 Roy Black Villafafia Letter re obligation to victims 7/1/2010 7/1/2010-7/31/2010 Epstein completed term of house arrest 9/8/2010 Administrative Order closing case 3/20/2011 Letter from Acosta re Epstein case 7/29/2011 Villafalia Lefkowitz Letter in response to 7/27/11 letter from Villafafia 8/1/2011 Emails between Richard Sudder, Assistant General Counsel, Executive Office for United States Attorneys, and Benjamin Greenberg, First Assistant U.S. Attorney, Southern District of Florida, regarding Formal Notice of Office- wide Recusal of Southern District of Florida dated July 28, August 3, August 24 and August 29, 2011 Privileged Confidential Page 50 of 51 Contains 6(e) Material EFTA00225477

EPSTEIN INVESTIGATION TIMELINE Date To From Re: Exhibit # 8/24/2011 Wilfredo Ferrer (U.S. Attorney, SDFL), Robert O'Neill (U.S. Attorney, MDFL), Benjamin Greenberg (FAUSA, SDFL), and Lee Bentley (FAUSA, MDFL) Richard Sudder Email regarding Formal Notice of Office-wide Recusal of Southern District of Florida. Cc's David MSODAG), Jay Macklin (USAEO), Thomas Anderson (USAEO), Tapken (USAEO), and James Read (USAEO) Privileged Confidential Page 51 of 51 Contains 6(e) Material EFTA00225478

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA FGJ 07-103(WPB) U.S. District Judge Donald M. Middlebrooks IN RE: GRAND JURY PROCEEDINGS SEALED ORDER GRANTING APPLICATION FOR PERMISSION TO DISCLOSE GRAND JURY MATERIAL THIS MATTER has come before the Court on the United States' Sealed Application for Permission to Disclose Grand Jury Material and for Entry of a Protective Order. The Court has considered the Motion and finds that: (I) the United States has shown a "particularized need" for the limited disclosure of materials related to matters occurring before the Grand Jury; (2) the United States has shown that the disclosure is "in connection with a judicial proceeding," that is, in connection with an administrative proceeding conducted by the Justice Department's Office of Professional Responsibility (OPR) arising out of a decision by United States District Judge Kenneth A. Marra in the matter of Jane Doe 1 and Jane Doe 2I United States, S.D. Fla. Case No. 08-80736-Civ-Marra; (3) the materials are needed to avoid an injustice in another proceeding, that is, the OPR administrative proceeding and any referrals to state bar authorities, other government agencies for law enforcement purposes, courts, and grand juries in accordance with OPR's Policies and Procedures; (4) the need for disclosure is greater than the need for continued secrecy; and (5) the request is structured to cover only the needed materials. EFTA00225479

Accordingly, the United States Attorney's Office for the Southern District of Florida, including Assistant United States Attorney A. Marie Villafafia, and the Justice Department's Office of Professional Responsibility may disclose to attorney Jonathan Biran matters occurring before the grand jury necessary to: (a) allow AUSA Villafafia to respond to OPR's written questions; (b) prepare for OPR's interview of AUSA Villafarla; and (c) participate fully in OPR's interview of AUSA Villafaiia. Disclosure shall be limited as set forth in the attached Protective Order. To the extent that AUSA Villafafla's May 10, 2019 Response to OPR's written questions and any drafts thereof disclosed any material that arguably referred to matters occurring before the grand jury, this Order is entered nuns pro tune to authorize those disclosures to Mr. Biran. This Order and the attached Protective Order shall be SEALED, except that copies may be provided to the U.S. Attorney's Office for the Southern District of Florida, which may provide copies to OPR and attorney Jonathan Biran. IT IS SO ORDERED. Done and Ordered in West Palm Beach, Fl ay of May, 2 19. Certified Copies Furnished to: AUSA A. Marie Villafaila ALD M. MIDDLEBROOKS UNITED STATES DISTRICT TT 1111W Certified to be a true and correct copy of the document on file Angola E. Noble, Clerk, Distri C 2 EFTA00225480

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA FGJ 07-103(WPB) U.S. District Judge Donald M. Middlebrooks IN RE: GRAND JURY PROCEEDINGS SEALED PROTECTIVE ORDER This matter came before the Court on the United States' Sealed Application for Permission to Disclose Grand Jury Material and for Entry of a Protective Order. Having granted the Application to Disclose Grand Jury Material in a separate Order, the Court hereby enters the following Protective Order, which governs the conditions for disclosure, maintenance, and destruction of any material containing "matters occurring before the grand jury" (hereinafter referred to as "grand jury material"). Accordingly, it is HEREBY ORDERED THAT: 1. The government is authorized nunc pro tune to produce to attorney Jonathan Biran of Baker Donelson grand jury material relevant to his representation of Assistant U.S. Attorney A. Marie Villafafia that is necessary to: (a) allow AUSA Villafafia to respond to OPR's written questions; (b) prepare for OPR's interview of AUSA Villafaila; and (c) participate fully in OPR's interview of AUSA Villafafia. 2. The government and Mr. Biran shall make efforts to minimize the amount of grand jury material produced to or maintained by Mr. Biran. Mr. Biran shall not be given copies of subpoenas, documents produced in response to subpoenas, transcripts, proposed or completed indictments, prosecution memoranda, or items prepared for use in front of the grand jury, but these Page 1 of 2 EFTA00225481

items may be shown to Mr. Biran and discussed in preparation sessions and during interviews. 3. Any hard copies of grand jury material provided to Mr. Biran shall not be photocopied and shall be securely maintained. 4. Any digital copies of grand jury material provided to Mr. Biran shall be encrypted. 5. Any grand jury material provided to Mr. Biran can only be reviewed by him and not by anyone else in his firm. 6. At the conclusion of the OPR proceedings and any related proceedings wherein Mr. Biran represents AUSA Villafaha, all grand jury material in Mr. Biran's possession shall be destroyed. Hard copy documents must be shredded and electronic documents must be deleted and purged. DONE AND ORDERED this ,i li day of May, Certified to be a true and correct copy of the document on file Angela E. Noble, Clerk, U S. Distr ct C ALD M. MIDDLEBROOKS UNITED STATES DISTRICT JUDGE I certify that I have read and agree to be bound by the terms of this Protective Order: Date: Jonathan Biran, Esq. Baker Donelson Page 2 of 2 EFTA00225482

STATEMENT OF A. MARIE VILLAFARA IN RESPONSE TO APRIL 2, 2019 LETTER FROM JEFFREY It RAGSDALE To the extent possible, I have provided all information relevant to your inquiry, including applicable documents. Due to the passage of time, updates to various software and hardware, and the crash of my work laptop several years ago, I no longer have every piece of relevant material and my memory may be imperfect.' I have organized the response to conform with the April 2, 2019 letter from Jeffrey R. Ragsdale to Jonathan Biran. Please note that there were numerous oral and written communications between others at the U.S. Attorney's Office and the Justice Department with counsel for Mr. Epstein. While in some cases I was told of the communications or cc'ed on emails or letters summarizing the communications, for many conversations, meetings, and emails, I do not have knowledge of what occurred. Introduction The investigation of Jeffrey Epstein and a series of co-conspirators, named "Operation Leap Year," officially began in May 2006. In theory, it was supposed to conclude on September 24, 2007 with the signing of a "Non-Prosecution Agreement" ("NPA").2 As will be discussed below, the investigation presented several issues of first impression and challenges related to obtaining evidence and securing the cooperation of witnesses. Nonetheless, I felt certain that the agents, my co-counsel, 'it a very strong case ag three rsonal assistants — Adriana Ross, a/k/a " and The case was presented for federal investigation by the Palm Beach Police Department after they felt that Jeffrey Epstein's legal team had put inappropriate pressure on the Palm Beach County State Attorney's Office to file only misdemeanor charges. Allegations of misconduct had been leveled against the local detective and the Police Chief and they reported being followed and harassed. As described below, the defense attorneys employed the same tactics at the federal level against myself and the FBI. With regard to the exhibits, whenever possible, I have used copies of original documents or "scanned" originals that were made at the time. In some cases, all that I have are the electronic documents (i.e., the Word Perfect letter that was printed, signed, and mailed or faxed). Because our computers no longer have Word Perfect, I have used "Quick Print" which has distorted the formatting. If I am providing something that I know is a "draft," I note that either in the text or in the exhibit list. The fact that something does not contain a signature does not mean that it is a draft, it just means that it was printed from the electronic version and I no longer have (or never had) a copy of the original. For example, I often drafted letters for the signatures of Andrew Lourie, Jeff Sloman, and Alex Acosta. Their assistants would have maintained the signed originals. In some cases, I would be provided with copies and sometimes I would not. I would usually notate my electronic files with "final" to know which was the final version, or the last- modified version. 2 For reasons set forth below, the investigation continued due to Epstein's post-NPA conduct. Page 1 of 58 EFTA00225483

Once the USAO opened the file, Epstein took the same approach that had been used with the State — at each level of review, he hired an attorney with a personal connection to the AUSA/USAJDOJ Attorney who was conducting the review. The attorneys raised a series of challenges to the veracity of the victims and the veracity of the state investigators, as well as quasi- Petite-policy arguments. When those failed, more formal legal analysis and federalism policy arguments were presented. Throughout this process, I wanted to keep my investigation as confidential as possible. For example, I did not see the benefit of telling Epstein's counsel that we had uncovered additional victims, that we had been able to corroborate victims' accounts, or the legal theories that we were pursuing. My objections to making these disclosures were all overruled. Also, unbeknownst to me, at least one supervisory AUSA was engaging in plea discussions with counsel for Epstein without consulting with me, the agents, or the victims. These discussions led to the creation of the NPA — an agreement that allowed Epstein to plead guilty to state charges in exchange for immunity for federal prosecution by the USAO for the Southern District of Florida. After the NPA was signed on September 24, 2007, when I attempted to notify the victims and enforce the agreement, the attacks became more personal. Epstein's attorneys raised the same policy arguments — which could have been raised prior to signing the NPA — as high as the DAG's Office, and coupled them with claims of prosecutorial misconduct. As these attacks occurred, the USAO — U.S. Attorney Alex Acosta and later First Assistant U.S. Attorney Jeff Sloman offered Epstein the option of simply "unwinding"3 the NPA — after all, he had never performed any part of it. In my mind it was unfathomable that Epstein would be allowed to spend months attacking not just the validity of our investigation and the validity of the NPA, but also making false allegations of prosecutorial misconduct against myself and FAUSA Sloman and still be allowed the benefit of what was, in my opinion, an unreasonably favorable agreement. Since everyone from the U.S. Attorney down to me agreed that the case was headed for a trial, the investigation continued, including identifying additional victims, conducting interviews, issuing grand jury subpoenas, drafting revised indictment packages, and presenting testimony to the grand jury. Epstein's clear intent to go to trial was on display during this period as he deposed victims identified only through the federal investigation in the guise of taking discovery in the state case. On June 23, 2008, John Roth in the DAG's Office issued his letter denying Epstein's final appeal. While USA Acosta allowed Epstein the benefit of the NPA, Epstein still tried to avoid several key parts of the NPA's terms, and would have escaped them but for my insistence. On June 30, 2008, Epstein entered his guilty plea in state court and was sentenced to 18 months' in the county jail in accordance with the terms of his state plea agreement and the NPA. Not long thereafter, I learned that Epstein had applied for work release and the Palm Beach County Sheriff's Office had granted the application. Prior to Epstein's guilty plea, the issue of work release had been specifically discussed with Epstein's counsel and they informed us that Epstein would not seek work release. The agents and I also met with the Sheriff's Office in advance of the plea and had been told that Epstein would not be eligible for work release. Accordingly, I provided my Notice of Breach, but was told by defense attorney Roy Black that, despite those specific conversations, USA Acosta himself agreed that Epstein would be eligible for any program 3 "Unwinding" was USA Acosta's term for mutual rescission — the USAO could file its charges and Epstein would have no obligations to plead guilty in state or federal court. Page 2 of 58 EFTA00225484

that the state offered, including work release. Because of this, I had to withdraw the Notice of Breach and could only write a letter to the Sheriff's Office pointing out all of the false statements contained in Epstein's application for work release and letters to the victims informing them that Epstein was in work release status. The Sheriff's Office never responded to or acknowledged my letter. On June 9, 2009, I prepared what I believe was the last Memorandum requesting authorization to issue a Notice of Breach and to indict Epstein. The Office authorized issuance of the Notice of Breach, and the Indictment Packs es was re-reviewed a roved, and signed, with arrest warrants for Jeffrey Epstein, and The Notice of Breach was served on June 12, 2009 at a hearing on pstein's Motion to Dismiss one of the civil suits filed by one of the victims identified during the federal investigation. Once again, Epstein was allowed to "cure" his breach, and we were not allowed to file the indictment. There were strong internal disagreements on a number of subjects, including: the handling of the meetings with Epstein's counsel; plea negotiations; the NPA generally; the failure to consult with the victims; continuing plea negotiations in the face of Epstein's clear bad faith; the refusal to defend me against personal attacks from Epstein's attorneys; the agreement to put off seeking Epstein's computer equipment; the consultations with Epstein's attorneys regarding victim notifications; the handling of the "appeals" to Washington; allowing delays during those "appeals," while Epstein's attorneys were harassing the victims and their family members; attempts by Epstein to renegotiate the term of imprisonment; attempts by Epstein to renegotiate the payment of damages to the victims and attorneys' fees to their attorney representative; allowing Epstein to participate in the work release program after specifically discussing it during plea negotiations; and repeatedly allowing Epstein to "cure" intentional breaches of the NPA. These were kept internal as I tried to deal professionally with opposing counsel. In the midst of all of the post-NPA back-and-forth with Epstein, was the Jane Doel United States litigation.° Despite the Office's request to be recused from the case, the Justice Department decided that there was no conflict of interest and I was tasked with serving as co-counsel. The Office asserted attorney-client, executive, work product, and deliberative process privileges, so all of the internal disagreements, pros memos, and indictments were not disclosed while all of my communications with opposing counsel (often at the behest of supervisors) were disclosed. After an initial flurry of filings, Brad Edwards, as counsel for the named plaintiffs, stated on the record that he believed that setting aside the NPA would not benefit his clients, and he sued Epstein on behalf of a number of victims under the NPA. I did what I could to assist Mr. Edwards, other attorneys, including Mr. Josefsberg, the attorney selected by the Special Master, and the Court, to locate victims, provide signed copies of the NPA, and answer questions. After all of the civil suits between Epstein and the victims were settled through the spectre of breaching the NPA, Mr. Edwards re-initiated the Jane Doe' United States litigation, asserting that his clients wanted to 4 A few days after Jeffrey Epstein entered his guilty plea in state court, attorney Brad Edwards filed suit on behalf of one of the victims identified in the federal investigation (later expanded to include a second victim who had been identified in the state investigation), alleging violations of the Crimelictims' Rights Act. The suit, which is still pending, is captioned Jane Doe I and Jane Doe 2 United States, 08-80736-CV-KAM. Page 3 of 58 EFTA00225485

set aside the NPA and see Mr. Epstein federally charged due to violations of the Crime Victims' Rights Act. In response to your questions, I have attempted to distill the past 13 years of emails, letters, research, pleadings, and conversations into a coherent document and attach the most relevant items. Given the sheer volume of materials involved here and the passage of time, while I have worked diligently to answer your questions as fully as possible, I certainly could have missed something amongst the thousands of pages of emails, drafts, and hard copy and electronic documents. If there are additional items or topics that need further explanation or more documentation, I can delve further. A. The Non-Prosecution Agreement 1. Describe the circumstances under which the investigation of Jeffrey Epstein was referred to the USAO, including when, why, how, and by whom the referral was made. Explain why the USAO decided to initiate a federal grand jury investigation into this matter, including what federal interests were perceived to be involved, and identify the individuals participating in the decision. Some time in early 2006, FBI Special Agent E. Nesbitt Kuyrkendall approached me about an investigation being conducted by the Town of Palm Beach Police Department ("PBPD"). I do not know how or when S/A Kuyrkendall was first contacted about the matter. The first mentions of the investigation were just passing comments during meetings on other matters. S/A Kuyrkendall and I were working on a number of different child exploitation matters at the time, along with ICE Special Agent David Malone. I remember generally that S/A Kuyrkendall mentioned an investigation of a wealthy man who lived on Palm Beach and recruited minors for sexual activity. During these casual conversations, I do not believe that Mr. Epstein's name was mentioned. If it was mentioned, it held no significance for me. I recall that S/A Kuyrkendall mentioned that PBPD had reached out to her because the Palm Beach County State Attorney's Office was leaning towards not charging the case at all or letting the defendant plead to a misdemeanor charge of solicitation of prostitution. At some point I told S/A Kuyrkendall that, if PBPD wanted to look into federal charges, I would need more information about the allegations and I encouraged her to set up a meeting. I recall S/A Kuyrkendall telling me that PBPD wanted to give the State Attorney's Office the opportunity to properly charge the case before presenting it for federal investigation and prosecution. In May 2006, I met with S/A Kuyrkendall and PBPD Detective Joe Recarey in the 4th Floor Conference Room at the U.S. Attorney's Office in West Palm Beach. I do not recall whether S/A Malone was present. Detective Recarey summarized the investigation into state criminal sexual conduct involving Epstein and his personal assistants. Briefly, Epstein, through his personal assistants, recruited girls and young womens — mainly from a local high school — to travel to his residence on Palm Beach to perform erotic massages. Although they had no massage training, the 5 I use these terms deliberately. "Girls" refers to females under the age of 18 and "young women" refers to females over the age of 18. When I refer to both groups jointly, I will use the term "females." Page 4 of 58 EFTA00225486

girls and young women were coached to massage Mr. Epstein in various states of undress. The sexual activity varied and included: Mr. Epstein masturbating himself at the end of the massage; having the females masturbate him; Mr. Epstein fondling the females' breasts and genitalia; using sex toys on the females; digital penetration of the females; sexual intercourse with Mr. Epstein; and Mr. Epstein observing while one of the girls had sex with one of his assistants. At the end of each "massage" session, Mr. Epstein or one of his assistants would pay the female involved. If the female involved in the massage was brought to Mr. Epstein's residence by a "recruiter," then the "recruiter" also would be paid. Detective Recarey did not have any information regarding any of the females traveling interstate or internationally to engage in sexual activity, but Det. Recarey reported that Mr. Epstein and his assistants traveled in and out of the Palm Beach International Airport on Epstein's private airplane. Det. Recarey stated that flight logs he had seen sometimes referred to passengers as "females," without names or ages, so it was possible that girls could have been on board, but Det. Recarey had not been able to confirm that. Det. Recarey stated that a search warrant had been executed on Mr. Epstein's residence and evidence had been seized, including message pads showing calls from females confirming that they would be coming to "work," which was the euphemism used for giving a "massage" — another euphemism for engaging in sexual activity for money. Det. Recarey also reported that it had appeared that Mr. Epstein had been "tipped oft" about the coming search warrant because all of the computer CPUs had been removed from the residence — the keyboards and screens were still in place, just the CPUs had been taken. Det. Recarey also reported that some surveillance cameras were in place but they had only recovered a limited amount of surveillance video. Det. Recarey stated that between 20 and 30 females had been identified [NB: I believe that he told me the exact number, I just don't recall that number now]. S/A Kuyrkendall and Det. Recarey asked me whether there were federal criminal charges that could be pursued. I remember getting up from the conference room, walking to my office, and getting my code book and walking back. I looked through 18 U.S.C. §§ 2422 (enticement of minors into prostitution/illegal sexual activity) and 2423 (travel for purposes of engaging in illegal sexual conduct).6 We talked through those statutes and the additional investigation that would be required to prove that they had been violated, but I told them that, if the evidence was there, it was a case that could be prosecuted federally. Det. Recarey then told me that his boss - PBPD Chief Michael Reiter — was still pressing the State Attorney's Office to arrest Epstein. d p ' of probable cause affidavits for the arrests of Jeffrey Epstein, and charging a large number of state criminal violations. Chief Reiter ad asked the Palm Beach County State Attorney, Barry Krischer, to authorize the arrests and he had refused. According to Det. Recarey, pressure had been brought to bear on SA Krischer by Epstein's attorneys, who included Guy Fronstin and Jack Goldberger (two personal friends of Krischer), and Alan Dershowitz. Det. Recarey stated that he and Chief Reiter were concerned that Epstein would be charged only with a misdemeanor or perhaps would not be charged at all. 6 As the investigation progressed, I looked into other federal crimes, but at that first meeting, I only remember looking at §§ 2422 and 2423. Page 5 of 58 EFTA00225487

I recommended that we begin the process of investigating whether there was a jurisdictional basis for federal charges, and S/A Kuyrkendall and Det. Recarey concurred. Det. Recarey asked that Chief Reiter be given an additional opportunity to convince the State Attorney to charge Epstein.' I explained that opening a case file and beginning a federal investigation would not preclude the State Attorney from charging Epstein. I then prepared the paperwork to open a file. The investigation was dubbed "Operation Leap Year" because there were approximately 29 young women and girls who had been identified through the State investigation. There were several aspects of the case that involved federal interests. First, as to the substantive crimes that Epstein was accused of committing, they involved the victimization of minor females through the use of facilities of interstate commerce (telephones and airports); and Epstein was traveling interstate and internationally to come to the Southern District of Florida to commit those offenses. During the course of the investigation, I often said that, if there were a trial, I would tell the jury that Jeffrey Epstein traveled to Florida to use Royal Palm Beach High School as his personal brothel. Second, the removal of the computer equipment from Epstein's home prior to the execution of the search warrant suggested possible public corruption at the Palm Beach County courthouse (where the search warrant application was signed) and also raised the possibility that Epstein may have been involved in the manufacture and/or possession of child pornography. Eradication of child pornography was a particular focus of Project Safe Childhood; its production and storage on computer equipment involved the use of items produced in interstate and foreign commerce; and child pornography was often distributed through facilities of interstate and foreign commerce. Third, Det. Recarey was suggesting that political or other pressure was being placed on an elected official (the State Attorney) to avoid or minimize criminal exposure for a person who committed numerous state crimes related to the exploitation of girls and young women. Setting aside the issue of prostitution, the sexual activity involving girls under the age of 16 could be charged as sex battery in the state. Ignoring those crimes suggested possible public corruption or, at the least, a miscarriage of justice. With regard to the logistics of opening the case file, the opening of files in West Palm Beach is relatively informal. In instances where an agent approaches a line AUSA directly (either because it is a duty matter or because the investigation is within the AUSA's area of expertise), the line AUSA will give his or her assistant the details of the case for the LIONS file-opening paperwork and then give a brief oral explanation of the case to his/her supervisor along with the paperwork. If the supervisor agrees that a file should be opened, he or she will normally sign the LIONS form on the spot and hand the file back to the AUSA. In this case, I prepared a file jacket; my assistant did the LIONS paperwork; I signed the conflict form; briefed my supervisor, Karen Atkinson; and she signed the LIONS paperwork assigning the case to me. This all occurred either on the day of the meeting with Detective Recarey and S/A Kuyrkendall or within a few days thereafter. Attached hereto as Exhibit 2 is the file opening paperwork and file jacket showing that the case was opened in LIONS on May 23, 2006. I do recall that at some time relatively soon after the file was opened, I did something that I had never done before or since. I initiated a meeting with the U.S. Attorney and the First 7 Although I did not know it at the time, on May I, 2006, Chief Reiter sent a letter to State Attorney Krischer asking Krischer to consider recusing himself from the case. (Exhibit 1.) Page 6 of 58 EFTA00225488

Assistant, Alex Acosta and Jeff Sloman, where I traveled to Miami and told them about the case. I recall that I explained the case and how the PBPD believed that Epstein had used political or other pressure to avoid serious punishment in Palm Beach County state court. That possibility troubled me greatly; hence, my request to meet with executive management. Messrs. Acosta and Sloman had the same reaction that I had the first time that Det. Recarey told me about Mr. Epstein — if I have never heard of him, how much influence could this person have? I remember specifically saying to them that I expected the case would be time and resource-intensive and I did not want to invest the time and the FBI's resources if the Office would just back down to pressure at the end. Messrs. Acosta and Sloman assured me that, if there was sufficient evidence to support the case, Mr. Epstein would be charged appropriately.8 2. Describe in detail your role, and the role of each other person in the USAO, the Federal Bureau of Investigation (FBI), and elsewhere within the Department of Justice — collectively herein "the government" — who was involved in the assessment of the viability and strength of the federal case against Mr. Epstein and in the decision to negotiate a pre-indictment resolution of the case. My Role I was the line AUSA assigned to the case. In conjunction with the case agents, I handled all aspects of the grand jury investigation — deciding what subpoenas to issue; whom to interview; whom to call to testify before the grand jury; what lines of inquiry to pursue to support various legal theories; I conducted legal research to support charges; I reached out to others throughout the Department and the federal government for information on previous investigations of Mr. Epstein, and for legal guidance on various aspects of the case (e.g., OEO, CEOS, SEC, SDNY, and AFMLS); along with the FBI agents and the FBI Victim-Witness Coordinator, I had direct contact with victims via interviews, meetings, and consultations regarding safety/privacy/mental health concerns; and I handled all court proceedings related to the investigation. When I felt that sufficient evidence had been collected to prove Mr. Epstein's guilt beyond a reasonable doubt, I drafted a prosecution memorandum, indictment, and related documents. I revised those documents in response to comments from those in the supervisory chain of command and, as explained below, after additional evidence was secured. I participated in some (but not all) of the meetings between members of the USAO and counsel for Jeffrey Epstein. I prepared briefing materials for management in preparation for those meetings and in response to issues raised during those meetings. Normally the assigned line AUSA handles plea negotiations, and I recommended that I enter into negotiations that would result in a joint federal and state resolution (i.e., a plea to federal 8 I do not have a contemporaneous memorandum and cannot find the date of the meeting. In a July 13, 2007 email exchange between myself and Criminal Chief Matt Menchel, I describe the meeting as follows: "I summarized the case and the State Attorney's Office's handling of it. I acknowledged that we needed to do work to collect the evidence establishing a federal nexus, and I noted the time and money that would be required for an investigation. I said that I was willing to invest that time and the FBI was willing to invest the money, but I didn't want to get to the end and then have the Office be intimidated by the high-powered lawyers. I was assured that that would not happen." (See Exhibit 3.) Page 7 of 58 EFTA00225489

charges in federal court and a plea to state charges in state court). I was reprimanded for doing so. Thus, as will be discussed in more detail below, I played no role in the decision to enter into a Non-Prosecution Agreement in exchange for Jeffrey Epstein's entry of a guilty plea to a state charge requiring a sentence of 18 months' imprisonment or Epstein's plea to federal charges resulting in a maximum sentence of 18 months' imprisonment (as will be explained below, Epstein's counsel repeatedly changed their minds about whether to take the federal route or the state route). Although I was tasked with drafting the agreements and Information, all of the documents were repeatedly and substantively revised by various supervisors, and I was responsible for incorporating those edits. I also was asked to sign the Non-Prosecution Agreement. When Epstein sought to have the Non-Prosecution Agreement set aside by "appealing" the matter to CEOS, the AAG, and the DAG, I handled the continued investigation of Epstein, including working with the FBI to identify additional victims, issue additional grand jury subpoenas, and prepare an updated indictment package. At the request of the U.S. Attorney, I also responded to inquiries from CEOS, the AAG, and the DAG's Office and drafted submissions on behalf of the USAO in response to arguments raised by Epstein's attorneys. I believe that I prepared a first draft of the Addendum to the Non-Prosecution Agreement, but others took the laboring oar on that document. I drafted numerous victim notification letters and responded to defense objections to those letters. I drafted the letter to the Special Master with the USAO's recommendations for the qualities to look for in the attorney representative for the victims. I monitored Epstein's compliance with the Non-Prosecution Agreement and served several breach notices. U.S. Attorney's Office Personnel AUSA Karen Atkinson (now retired): AUSA Atkinson was my direct supervisor. She reviewed indictment packages and other court-related matters and provided guidance and served as a "sounding board" for many of my concerns. As will be explained below, AUSA Atkinson did not participate in many of the meetings between the USAO and Epstein's counsel because Epstein's counsel "skipped her" in the chain of command, directing their communications to MAUSA9 Andrew Lourie, Criminal Chief Matt Menchel, First Assistant Jeff Sloman, and U.S. Attorney Alex Acosta. AUSA Atkinson did participate in meetings with the Palm Beach Sheriff's Office about Epstein's work release and several conference calls with defendant attorney Roy Black and others about Epstein's breaches of the Non-Prosecution Agreement. MAUSA Andrew Lourie (now in private practice): MAUSA Lourie was my second- line supervisor and head of the West Palm Beach office. Over the objection of myself and my co-counsel, he granted the request of Epstein's attorneys to meet to allow Epstein's attorneys to argue that the USAO should decline the matter. That began the series of meetings between all levels of the USAO and Epstein's counsel. MAUSA Lourie reviewed my work; asked me to conduct some specific research; and reviewed drafts of our responses 9 The Managing Assistant U.S. Attorney ("MAUSA") is the head of the West Palm Beach Office. Page 8 of 58 EFTA00225490

to legal arguments raised by Epstein's counsel. MAUSA Lourie also participated in conversations with the State Attorney, and directly participated in negotiations of the language to be used in the Non-Prosecution Agreement, federal Plea Agreement, and Information. He had numerous conversations with counsel for Epstein outside of my presence when they objected to my refusal to agree with their changes. MAUSA Lourie also communicated with the U.S. Attorney about the negotiations. He would then communicate changes from the defense and the U.S. Attorney to me to incorporate. Later, when Epstein's attorneys appealed to AAG Alice Fisher, Mr. Lourie was on detail as AAG Fisher's Chief of Staff and facilitated the meeting between Epstein's counsel and the AAG. AAG Fisher's written response was issued while MAUSA Lourie was still her Chief of Staff. I do not know who drafted the written response. Acting MAUSA Rolando Garcia (still with the USAO): When MAUSA Lourie was on detail with AAG Fisher's Office, Rolando Garcia was named the Acting MAUSA. He participated in at least one meeting with Epstein's attorneys and the State Attorney. Mr. Garcia also was involved in some of the negotiations regarding the language of the Non- Prosecution Agreement. He later reviewed at least one of the iterations of the indictment package and signed the indictment that was supposed to be presented to the grand jury in June 2009. Criminal Chief Matthew Menchel (now in private practice): Criminal Chief Menchel was the third line supervisor of the matter. Generally, West Palm Beach indictments are reviewed and approved by the MAUSA and are not reviewed by Miami. However, unusual or especially significant indictments are reviewed by the Criminal Chief. Criminal Chief Menchel reviewed and commented on the first proposed indictment package. His comments were incorporated into a revised indictment, and he possibly reviewed those changes. Criminal Chief Menchel participated in numerous meetings on the case, and had private conversations regarding resolution of the matter with Lilly Ann Sanchez, counsel to Mr. Epstein. Ms. Sanchez had formerly served as Deputy Chief in the Major Crimes Section at the USAO while Mr. Menchel was Chief of Major Crimes. As discussed below, on July 26, 2007, Criminal Chief Menchel announced to the investigative team that U.S. Attorney Acosta had decided to offer a two-year plea to Mr. Epstein. On August 3, 2007, Mr. Menchel sent a letter to Ms. Sanchez regarding that plea offer. Mr. Menchel left the U.S. Attorney's Office on that date to become a partner at Kobre & Kim in New York. First Assistant Jeffrey Sloman (now in private practice): FAUSA Sloman (later U.S. Attorney Sloman) was involved in telephone calls and meetings with counsel for Mr. Epstein; when Epstein's attorneys were dissatisfied with my proposed language for the Non-Prosecution Agreement, victim notification letters, letters to the Special Master, etc., they would frequently contact FAUSA Sloman directly to complain. FAUSA Sloman handled the bulk of the negotiations of the Addendum to the NPA. Epstein's attorneys later complained that FAUSA Sloman was biased because his daughter had been the victim Page 9 of 58 EFTA00225491

of a crime. One of Epstein's attorneys also falsely accused FAUSA Sloman (and me) of promising money to a victim in exchange for her willingness to accuse Epstein. U.S. Aftorney R. Alexander Acosta (now Secretary of the U.S. Department of Labor): USA Acosta served as the head of the U.S. Attorney's Office throughout the investigation of Jeffrey Epstein, including the decision to enter into a Non-Prosecution Agreement, negotiation of its terms, and attempts to enforce its terms. When Epstein's attorneys were dissatisfied with answers they received from me, MAUSA Lourie, and FAUSA Sloman, they would frequently contact USA Acosta directly. USA Acosta was directly involved in reviewing and revising the documents, including sending exact wording that he wanted incorporated into the agreement. There were some communications between USA Acosta and counsel for Epstein that I was not aware of at the time. For example, I did not know, until after I had sent a breach notice, that USA Acosta agreed that Epstein could be considered for work release. At some point after the NPA was signed, USA Acosta was recused from the Epstein matter. AUSA John McMillan (still at USA0): Early in the investigation, I asked AUSA McMillan if he would serve as co-counsel on the case. Before I joined the West Palm Beach Office, AUSA McMillan had handled the bulk of the child exploitation cases in West Palm Beach. He and I discussed how to structure the investigation and he joined me in opposing meeting with Epstein's attorneys prior to the completion of the investigation. He attended some of the meetings with Epstein's attorneys. When the Office overruled our positions and when it appeared that the case was not going to be charged, AUSA McMillan decided that he should focus on other cases. AUSA Bruce Reinhart (now U.S. Magistrate Judge): AUSA Reinhart was my office neighbor and colleague. At one point early in the investigation (I believe before I asked AUSA McMillan to serve as co-counsel), I sought AUSA Reinhart's counsel on strategies for how to handle Epstein's personal assistants — whether they should be charged or if we should seek immunity for them. Not long thereafter, AUSA Reinhart came to me and said that he was best friends with one of Epstein's attorneys, Jack Goldberger, and accordingly could not discuss the Epstein case with me any further. AUSA Reinhart left the U.S. Attorney's Office for private practice and later represented one of Epstein's assistants in the civil suits filed by Epstein's victims. AUSA Toni Barnes (now retired): Asset Forfeiture AUSA assigned to the Epstein case. I had a few brief meetings with AUSA Barnes to talk about the asset forfeiture aspects of the case. We discussed the charges under consideration and Epstein's assets that could be subject to forfeiture. AUSA Barnes had direct contact with the agents and the FBI's asset forfeiture coordinator about information/evidence that she needed to pursue forfeiture. AUSA Barnes provided the asset forfeiture language in the proposed indictments. Page 10 of 58 EFTA00225492

SLC Dexter Lee (still at USAO): SLC Lee was not directly involved in the Epstein investigation or negotiation of the NPA, but he has been lead counsel in the Jane Doe'. United States litigation. SLC Lee had contact with USA Acosta regarding his recusal, and with FAUSA Sloman and myself regarding self-reports to OPR about accusations of misconduct raised by Epstein's counsel. I also had contact with SLC Lee regarding a Florida Bar Complaint filed by a civil attorney for some of the victims who complained that my victim notification letters amounted to inappropriate business referrals to the attorney selected by the Special Master.1° Appellate SLC Anne Ruth Schultz (still at USAO): SLC Schultz was not directly involved in the Epstein investigation or negotiation of the NPA. It is my understanding that USA Acosta asked SLC Schultz to check my legal analysis. I also understand that Criminal Chief Matt Menchel contacted SLC Schultz about moving me to Appeals after I pointed out actions that I considered to be in violation of the Ashcroft memo and victims' rights legislation. I also understand that SLC Schultz may have knowledge of USA Acosta providing my prosecution memorandum to Criminal Appellate Chief Patty Stemler at Main Justice. Shawn Ball (still at USAO): My legal assistant during most of the Epstein investigation and its aftermath. She assisted with preparing indictment packages, victim notification letters, grand jury subpoenas, travel, expert witness contracts, and other items. Cyndee Campos/Annette Castillo (both still at USAO): Executive assistants to AUSA Acosta and FAUSA Sloman. They compiled correspondence between the USAO and counsel for Epstein; scheduled meetings; and dealt with inquiries from the press and DOJ. They may have information related to correspondence or communications between the Executive Division and Epstein's counsel that I am unaware of. FBI Personnel S/A Nesbitt Kuyrkendall (retired from FBI): Lead case agent on Operation Leap Year. She presented the case to the USAO, handled the bulk of the interviews, served subpoenas, and testified before the grand jury. She communicated directly with victims and hand- delivered the original victim notification letters. S/A Kuyrkendall also participated in meetings with some of the senior members of the USAO and counsel for Epstein. 1° The Florida Bar determined that my victim notification letters, which are included in the exhibits and advised the victims that they had the absolute right to select another attorney if they so desired, were not inappropriate solicitations and did not violate the Florida Bar Rules. The attorney who filed the complaint, Jeff Herman, later resigned from the Florida Bar due to disciplinary action taken against him. Page 11 of 58 EFTA00225493

S/A Jason Richards (still at FBI): Co-case agent with S/A Kuyrkendall. Became lead case agent during the post-guilty plea period (i.e., the interview of responding to FOIA requests, etc.). He conducted interviews, prepared reports, analyzed records, and communicated directly with victims. S/A Richards also participated in meetings with some of the senior members of the USAO and counsel for Epstein. S/A Tim Slater (still at FBI): Co-case agent with S/A Kuyrkendall until he was trans I e conducted interviews, including the original telephone interview with where she asked that the FBI have no further contact with her. He also prepared reports and analyzed records. Group Supervisor Eliasib ("Junior") Ortiz (still at FBI): GS Ortiz supervised S/As Kuyrkendall, Richards, and Slater. He also participated in meetings with some of the senior members of the USAO and counsel for Epstein. ASAC Valerie Parlave (still at FBI): ASAC Parlave supervised GS Ortiz. She attended the July 26, 2007 meeting where Criminal Chief Menchel announced the two-year plea offer. S/A Pryor: S/A Pryor participated in the interview of in Australia. S/A Gavin Gumbiner (still at FBI): S/A Gumbiner was the case agent on Operation Stolen Globe, which involved the investigation of Alfredo Rodriguez (Jeffrey Epstein's butler), who tried to sell evidence to Brad Edwards. Group Supervisor Michael Donohoe (retired from FBI): GS Donohoe replaced GS Ortiz as head of the violent crime group during the post-guilty plea period. He supervised S/As Richards, Pryor, and Gumbiner. Victim-Witness Coordinator Twiler Smith: Ms. Smith sent letters to victims, met with them in person. and assisted in finding counseling and other services for them. Justice Denar ment Personnel CEOS Deputy Chief Gelber (still at DOJ): Ms. Gelber was part of the team that reviewed the case and the NPA when Epstein "appealed" to DOJ. Ms. Gelber also is familiar with my work from a prior case that she and I worked on together as well as other PSC cases where I have consulted with her. CEOS Chief Drew Oosterbaan (now private in-house counsel): Mr. Oosterbaan reviewed and opined on the case and the NPA when Epstein "appealed" to DOJ. He also attended meetings in the SDFL with myself, the case agents, USAO supervisory staff, and Page 12 of 58 EFTA00225494

counsel for Epstein. I conferred with Mr. Oosterbaan about charging, staffing, and victim- related issues. CEOS Trial Attorney Myesha Braden (now at a non-profit): I first had contact with Ms. Braden when conducting research regarding some of the legal issues raised by the case (she was the CEOS Duty Attorney on the day that I called). After AUSA McMillan left the case, I contacted Mr. Oosterbaan about having a CEOS Trial Attorney co-chair the case and asked if Ms. Braden was available. She participated in interviews, discussed case strategy, and reviewed pros memos and indictments. Criminal Appellate Chief Patty Stemler (still at DOJ): At various times, I have heard that USA Acosta provided my pros memo to Chief Stemler and asked her to review my legal analysis. I have never asked Chief Stemler whether this actually occurred. SLC Anne Schultz may know whether this occurred. AAG Alice Fisher (now in private practice): After CEOS rejected the "appeal" from Mr. Epstein's attorneys, they asked for further review by AAG Fisher. She met with the attorneys and prepared a written opinion rejecting Epstein's arguments. Senior Associate Deputy Attorney General John Roth (now private in-house counsel): Following AAG Fisher's rejection, Epstein's attorneys asked for review by the DAG. I do not know whether Epstein's counsel met with the DAG, but they did present arguments to Mr. Roth, who was Chief of StafPSr. Associate Deputy Attorney General. Mr. Roth wrote a letter rejecting Epstein's arguments. Deputy Attorney General Mark Filip (now in private practice): Mark Filip was the Deputy Attorney General to whom Mr. Epstein's arguments were addressed. As noted above, I do not know if Mr. Filip met with Epstein's counsel, or if the meetings were only held with Mr. Roth. Others Whose Counsel I Sought During the Case: Assistant U.S. Attorney Susan Roe (still an AUSA in Seattle): AUSA Roe was not involved in the Epstein investigation. During the pendency of the Epstein investigation, she began investigating David Copperfield, who was a friend of Epstein, and we conferred with each other about strategy. I informed AUSA Roe of the difficulties in convincing the Office to prosecute Epstein. Attorney Advisor Tammie Gregg (still at DOJ): Ms. Gregg is a friend from my days at Dorsey & Whitney. She joined the Justice Department before I did and we have stayed in contact over the years. She had experience with USA Acosta when he was the head of the Civil Rights Section at Main Justice so I turned to her for advice in handling the Epstein situation. Page 13 of 58 EFTA00225495

Assistant U.S. Attorney E.J. Yera (still at DO.)): Mr. Yera and I were dating at the time of the Epstein investigation. (We are now married.) He was a more senior AUSA who was familiar with some of Epstein's counsel. I sought his advice on some of the issues — legal and non-legal — that arose during the case. Assistant U.S. Attorney Lynn Kirkpatrick (still at the USAO): Ms. Kirkpatrick and I are friends from my time in Miami. She was a supervisor in Miami although not in my chain of command. I would often speak or email with her just for advice. 3. Explain fully the process and circumstances leading to the decision to resolve the case through a non-prosecution agreement (sometimes referred to by defense counsel and the government as a deferred prosecution agreement, but described herein as the non-prosecution agreement). Explain why the government initially prepared to resolve the case through a federal plea agreement, but ultimately did not require Mr. Epstein to enter a plea in federal court. The explanation should identify the parties involved in the decision, the individual(s) responsible for all final decisions regarding the non-prosecution agreement and its terms, and the basis for the decision to resolve the case through a non-prosecution agreement. Let me preface with some background on how I normally handle investigations and prosecutions. When undertaking investigations, my normal practice is to meet with agents, confer with them about an investigative plan, and work together until the case is ready for indictment. I update my supervisors along the way, seek advice or guidance from supervisors and colleagues if an issue is especially complex or novel, and get approval for actions as required by the USAM, but I have always focused on learning as much as possible about the subject area, the defendant, and the facts related to the alleged crime — I want to be the subject matter expert in the courtroom. Then, once all of those items are completed, I prepare a comprehensive prosecution memo and proposed indictment, which are submitted for review. I believe strongly that investigations — especially child exploitation investigations — should be conducted as covertly as possible in order to protect the victims' privacy; to avoid harm to the accused's reputation if the accusation is determined to be false; and to maintain the sanctity of the investigation. In Mr. Epstein's case, these concerns were heightened for several reasons. First, victims identified during the state investigation had expressed fears of Epstein and building trust with them would require assurances that Epstein would not find out that they were talking with federal investigators. Second, the victims were between the ages of approximately 15 and 20" -- ages when women and girls might minimize or deny sexual abuse to avoid being labeled as "sluts." Third, Epstein had made allegations in the state case that the victims were only after money and that investigators were only after fame. Maintaining the investigation's confidentiality would delegitimize both of those allegations. It also would avoid interference/intimidation by Epstein and his counsel. " They had been 14 to 17 years old at the time of the sexual activity, but time had passed. Page 14 of 58 EFTA00225496

My confidentiality rule extends to pm-indictment communications with defendants and their attorneys. In cases where defendants are considered a flight risk, I generally have no contact pre-indictment. If proven, the crimes under investigation created a statutory presumption that the defendant was a risk of flight and a danger to the community, and Epstein had virtually unlimited resources to flee.'2 Our effort to maintain the confidentiality of the investigation was thwarted almost immediately by PBPD Chief Reiter. On July 24, 2006, Chief Reiter sent letters to some of the victims identified in the state investigation informing them that the State Attorney's Office had decided to proceed on a single charge of solicitation of prostitution. (Exhibit 6.) Chief Reiter encouraged the victims to contact the State Attorney's Office with any complaints about the handling of the matter. Chief Reiter then felt the need to disclose that he did "not feel that justice has been sufficiently served by the indictment that has been issued. Therefore, please know that his [sic] matter has been referred to the Federal Bureau of Investigation to determine if violations of federal law have occurred." (Id.). While Chief Reiter did not mention the USAO, Epstein's counsel certainly understood that engaging the FBI meant engaging the USAO. Chief Reiter's actions were published in the local newspaper. (Exhibit 7.) Because the federal investigation had been exposed by Chief Reiter, there was no ability to operate covertly, so we began serving subpoenas on persons and entities affiliated with Epstein. Beginning on August 2, 2006, a number of grand jury subpoenas were issued for bank information, information related to travel on Epstein's airplanes, school attendance records, rental car information, and other information that would corroborate statements made by victims (see Exhibit A-1). A subpoena also was issued for all of the evidence collected by the PBPD (see id.). Victim notification letters also were prepared that contained my contact information for the federal agents to provide to the victims identified during the PBPD investigation. (Exhibits 12 & 13.) As victims were interviewed by the federal agents, they would be provided with a copy of the notification letter. As additional victims were identified throughout the investigation, more letters were prepared. (Exhibits 19 & 30.) Subpoenas also were prepared for testimony and evidence from some victims who were believed to possess physical evidence that could corroborate contact with Epstein. (See Exhibit A-1.) One of the subpoenaed victims was Individual #28, who is referred to as Jane Doe #2 in the Jane Doe' United Stales litigation. When approached for an interview, Individual #28 refused to speak with the agents, and I remember S/A Kuyrkendall telling me that she felt that Individual #28 had tried to run over her foot as Individual #28 drove away. Individual #28 contacted Epstein when she received the letter and subpoena; Epstein put her in touch with his attorney, Jack Goldberger; and Goldberger had his friend, Jim Eisenberg, serve as Individual #28's lawyer while Epstein paid Eisenberg's fees. Individual #28 later told Brad Edwards that someone (Epstein, Goldberger, or Eisenberg) told her that "the government" planned to take away her baby. I don't know if that is true, but Eisenberg insisted that Individual #28 would not speak to us without 6001 immunity. (Exhibit 9.) Once it was granted, Individual #28 spoke of Epstein in glowing terms 12 To minimize the risk of flight, I conducted research on extradition and the FBI placed a travel watch Epstein, but especially in light of Epstein's ownership of an airplane capable of intercontinental travel and his foreign residences, the investigative team considered Epstein to be a substantial flight risk. Page 15 of 58 EFTA00225497

and in a way contradicted by other witnesses and evidence. The hiring of Eisenberg, the insistence on 6001 immunity — something that I had never faced before or since for a child victim — and the false exculpatory statements — all showed me how the defense would be approaching this case. The subpoenas and interviews apparently concerned Epstein because soon after I began trying to set up Individual #28's testimony, Epstein hired former U.S. Attorney Guy Lewis, who began contacting me by phone and email, asking to meet with me. I declined to meet because it is my policy not to meet during the pendency of a child exploitation investigation. Mr. Lewis expressed his client's willingness to cooperate with the investigation. (Exhibit 10.) When Mr. Lewis was unable to set a meeting, Epstein hired Lilly Ann Sanchez, another former AUSA from the Miami USAO. Ms. Sanchez began calling and emailing me in early November 2006. (Exhibit 11). Ms. Sanchez also expressed Epstein's interest in "cooperating" with the investigation. I knew that feigned cooperation would be used to ask for pre-trial release, so I tested the veracity of the offer of cooperation by asking for documents that would disprove many of Epstein's defenses.13 Sure enough, Ms. Sanchez objected to the requests as "overbroad." I politely declined the request for a meeting and then delayed setting up the requested meeting so that I would have time to complete the investigation. My co-counsel, John McMillan, and I agreed that a meeting at this early stage offered no benefit for us and only benefitted the defense. When Ms. Sanchez could not set a meeting with me, she skipped my immediate supervisor and contacted MAUSA Andy Lourie whom she knew from their time together in Miami. MAUSA Lourie told AUSA McMillan and me that he had agreed to meet with Ms. Sanchez and Gerald Lefcourt. AUSA McMillan and I told MAUSA Lourie that we had made a conscious decision not to meet with Epstein's attorneys and that we were opposed to a meeting. It was the first of many disagreements between management and the line AUSAs. MAUSA Lourie told us that we were "non-strategic thinkers" (his words) and that the meeting would result in convincing Sanchez and Gerald Lefcourt to bring Epstein in for an interview. It was condescending and, in our opinion, showed a lack of understanding of sex offenders generally and a lack of knowledge of this case. Gerald Lefcourt has represented Martha Stewart — the last thing he would do is bring his client in to face a possible "perjury trap." In the middle of this period, which started in November 2006 and ran through January 2007, USA Acosta and I traveled to Washington, DC at the beginning of December 2006 for the inaugural Project Safe Childhood Conference. Although I did not attach much significance to this at the time, in preparing this response, I began wondering whether the following event was orchestrated by Epstein and his counsel. During one of the first presentations at the conference, I was in a large auditorium and the speaker asked the audience a question. A man in the row in front of me introduced himself as the State Attorney from Palm Beach County (Barry Krischer) and answered the question. I had never met Mr. Krischer. After the seminar ended, USA Acosta came over and we all introduced ourselves. Mr. Krischer proceeded to deride PBPD Chief Reiter and the victims in the Epstein case — referring to them by name and talking about how some were paid thousands of dollars, used alcohol and drugs, and looked over 18. I tried to guide the two out of 13 For example, Epstein claimed that the massages were legitimate "medical" massages, so I wanted to see if he was taking tax deductions for medical expenses and getting other complementary medical treatment. Epstein also claimed that he was traveling to Florida to visit family and to maintain Florida residency. I asked for calendars and other documentation. Page 16 of 58 EFTA00225498

the auditorium to a more private area because I did not think it was a conversation meant for public consumption but they would not move. As the PSC Coordinator, I had overseen the invitations for the law enforcement representatives from the S.D. Fla., and Mr. Krischer had not been on the list. So I now wonder whether this "random" meeting was staged by Epstein. As you will see from the timeline (Exhibit A-1), in late January 2007, I created a file folder entitled "Research re NPAs and 6001 immunity." (Exhibit 15.) This was not research related to Non-Prosecution Agreements in connection with resolving the case against Epstein. In November poenas were served on two other Epstein employees — Janusz Banasiak Both initially asked for immunity. After speaking with Banasiak's attorney, r. anasi was satisfied with a standard Kastigar letter, but Ms. Mucinska's attorney was insistent on formal immunity, and as noted above, so was Individual #28. I don't believe that, prior to this investigation, I had ever prepared a request for 6001 immunity, so I was researching the process. The meeting with Ms. Sanchez and Mr. Lefcourt was set for February 1, 2007. As noted above, despite Ms. Sanchez' statements of Epstein's willingness to cooperate, she complained that my document requests were "overbroad," so MAUSA Lourie and I drafted a more specific list (Exhibit 14).14 Ms. Sanchez also asserted that Epstein had hired attorneys for all of his current and prior employees, but refused to provide me with a list of those employees and attorneys, wanting me to give her essentially a roadmap of my investigation. I refused (Exhibits 14 and A- 1). Instead, the agents and I continued to press forward with our investigation and I continued my extensive legal research in preparation for the meeting with Sanchez and Lefcourt. Although materials were supposed to be provided in advance, the "talking points" for the meeting with Sanchez and Lefcourt did not arrive until the morning of the February 1, 2007 meeting (Exhibit 14 at 8-32). The main themes were: 1. the PBPD investigation was biased; 2. the conduct at issue was "entirely local"; 3. Epstein did not know the victims were under 18; 4. none of the girls traveled in interstate commerce; 5. Epstein's travel was not for the purposes of engaging in illegal sexual activity; 6. victim and witness credibility issues weighed against filing charges; and 7. the Petite policy precluded prosecution (id.). While the letter covered all of these topics, I recall the meeting was focused primarily on challenges to the victims' credibility (e.g., one victim's MySpace page showed her smoking marijuana and posing provocatively); allegations of police overreaching; and the lack of evidence that Epstein knew the victims were under the age of 18. MAUSA Lourie, AUSA McMillan, and I were unpersuaded by the letter and the presentation, but I agreed that I should carefully review transcripts of the recorded statements given to PBPD for Brady issues." Since witness credibility was clearly at the fore, I undertook efforts " The requested documents and items were never provided. 15 As the investigation continued and we located and identified more victims, we eventually made a strategic decision that the initial indictment should exclude the group identified by the Page 17 of 58 EFTA00225499

to corroborate our victim statements and to undermine Epstein's potential defenses through subpoenas for a wide variety of documents (see Exhibit A-1). Subpoenas also were issued to some victims for photographs, gifts, and other records of direct or indirect contact with Epstein (see id). Presentation of background information to the grand jury began in February 2007 (Exhibits 17, 18, and 20). I continued to research potential charges against Epstein. Again, knowing how Epstein's attorneys would likely approach any trial in this matter, I wanted to prepare both a strong offense — by including all relevant charges for jury consideration and possible plea negotiations — and a strong defense — by including charges that would allow the admission of the widest range of relevant evidence. With that mindset, I researched money laundering and racketeering offenses in Chapter 95 because I knew that prostitution was a racketeering offense (see Exhibit 56). In addition to the IRS, I conferred with an attorney at the Asset Forfeiture and Money Laundering Section in DC who opined that Epstein's conduct could be a violation of 18 U.S.C. § 1960 and 2 or another currency offense because he caused the interstate transmission of funds related to prostitution (see Exhibit 57).16 The investigation continued at a brisk pace with Epstein's attorneys frequently seeking reviews from Messrs. Lourie and Menchel (see, e.g., Exhibit 58). [NB: They completely excluded my immediate supervisor, Karen Atkinson, throughout the process.] Because of this, and because the grand jury was very interested in the case, I tried to keep the Miami office up to date on what was happening. There also had been little feedback from Miami to the proposed indictment that had been provided in late April/early May. So, for example, on May 14, 2007,1 emailed Menchel and Lourie about Epstein's travel and asked whether I would be permitted to present the indictment the following day or proceed by way of criminal complaint (Exhibit 26 at 1). Mr. Menchel made clear that neither would be allowed (id.). That Friday, May 18, 2007, I emailed Chief Menchel again, notifying him that we had learned that the computers missing from Epstein's home at the time of the execution of the state search warrant were removed by a private investigator working for attorney Roy Black. After conferring with CCIPS, the Witness Immunity Unit at OEO, and my immediate supervisor, I planned to issue a grand jury subpoena for the equipment (id. at 2). I explained why the request was different than a subpoena to an attorney and how I would avoid seeking privileged information (id). I specifically asked Mr. Menchel if he had any comments or concerns but received no response (id)17 On Monday, May 21, 2007, I wrote to Chief Menchel and FAUSA Sloman for "guidance" and "a sense of the direction where we are headed" (id. at 3). Again, no response. On that day, PBPD and save them for a superseding indictment, if needed. At this point, however, the investigation was focused mainly on the same group. 16 I mention this because my efforts to collect financial documents to support potential money laundering charges —and also to corroborate victim statements — were later used as evidence of my "overreaching." 17 Again, I mention this because it would later be used — by Epstein's counsel and Chief Menchel — as evidence of overreaching. Page 18 of 58 EFTA00225500

having heard nothing in response to my 5/18/2007 email, I issued the subpoena to the private investigator (Exhibit 59). The following day, May 22, 2007, Mr. Lefcourt sent a letter to MAUSA Lourie stating: I understand from you that in the next month or two a decision will be made by your office whether to seek an indictment of Mr. Epstein. This will confirm that, prior to any such decision being made, I and other attorneys on behalf of Mr. Epstein will be given an opportunity to meet with you. Additionally, . . . if our meeting does not resolve the matter, we would like an opportunity to make a presentation first to Matthew Menchel, Chief of the Criminal Division, and Jeffrey Sloman, First Assistant United States Attorney, and then, again, if no resolution is reached, the opportunity to meet with United States Attorney Alexander Acosta. (Exhibit 28.) AUSA McMillan and I were not part of the conversation where MAUSA Lourie disclosed the timeline to Mr. Lefcourt, so I was surprised by the letter, which sought multiple opportunities to meet with members of the Executive Division. Mr. Lourie responded, again, without meeting with AUSA McMillan or me, stating: "I think we are on the same page . . . I did say that if you want to meet with me again, I am ready to do so. The wording of your letter, however, suggests implicitly that I agreed to contact you before a decision is made to seek an indictment of Mr. Epstein. If that was your understanding, then please allow me to clarify. Our investigation is ongoing and if we decide to seek an indictment, we don't intend to call Mr. Epstein's representatives to let him know that. Of course, in the interim, if you would like to make a presentation to us, we are willing to listen. ..." (Id.). I strenuously objected and drafted an email setting forth the reasons why (id.). I shared it with my supervisor and she advised me not to send it. I orally advised MAUSA Lourie that I objected to meetings, delays, and strategic disclosures in a case like this one — a child exploitation case with a large number of victims. Nevertheless, the meeting was set for June 26, 2007. As I predicted, the defense asked Mr. Menchel for a list of our legal theories. I told him that I did not want to share them, and Mr. Menchel directed me to give the defense the list anyway. On June 18, 2007, I sent a letter to Gerald Lefcourt listing all the charges under investigation (Exhibit 53). On June 14, 2007, I emailed the supervisory chain an addendum to the prosecution memo, asked about whether they wanted me to revise the indictment, and asked what materials they wanted prepared in advance of the June 26, 2007 meeting (Exhibit 31 at 1). I don't believe I received any responses. On June 21, 2007, I emailed Chief Menchel again asking who would be attending the June 26, 2007 meeting and how I could best prepare (id. at 3-4). I noted that he had been communicating directly with Ms. Sanchez about the meeting (id.). On June 25, 2007, Gerald Lefcourt provided written arguments for why Epstein should not be charged federally (Exhibit 32). The following day, Alan Dershowitz, Roy Black, Gerald Lefcourt, and Lilly Ann Sanchez presented their arguments to FAUSA Sloman and Chief Menchel. S/A Kuyrkendall, her supervisor, and I also attended (Exhibit 5). At some point during the Pagc 19 of 58 EFTA00225501

meeting, Chief Menchel told the defense attorneys that they needn't address the money laundering statutes. I think he referred to them as "silly," without even having the benefit of my conversations with IRS and AFMLS and my legal research.18 So Epstein's counsel focused on the child exploitation statutes. They falsely insisted that the use of the interne was needed for a 2422(b) charge and that some sort of force, fraud, or coercion was required for a 1591 charge because 16- and 17-year-old girls were "adults." They stated that there was no federal law prohibiting sex with children and one would be unconstitutional. After the meeting, MAUSA Lourie and I analyzed the materials (Exhibit 32). We both concluded that the defense had overstated the strength of their position (id.). MAUSA Lourie felt that the 2422(b) charges were stronger than the 2423(b) charges because we would need proof that having a sexual massage was a motivation for Epstein's travel (id.). My research showed that different circuits had different standards of proof on the "purpose of travel" element (id). I never received any feedback from Chief Menchel or FAUSA Sloman regarding Lefcourt's written presentation, but after the June 26, 2007 meeting, I was left with the impression that we were continuing towards indictment. On July 3, 2007, at 6:26 a.m., I sent an email to Jeff Sloman, Matt Menchel, and Andy Lourie advising them about calls I had received from Lilly Ann Sanchez seeking to delay subpoena responses and their plans to present our Office with additional analysis as well as their planned resolution with the State Attorney's Office (Exhibit 3). I informed everyone of my proposed response regarding the subpoenas and that I intended to invite Lilly Ann Sanchez to call me to discuss a resolution of the federal investigation that could include concurrent time, i.e., a plea to a federal charge with a recommendation that the federal sentence would run concurrently with the state sentence (See id.) I asked whether anyone had had different conversations with any attorneys for Epstein so that there would not be any miscommunication. Later that afternoon, Matt Menchel sent me an email (using Jeff Sloman's Blackberry) that read, "I told Lily that a state plea with jail time and sex offender status may satisfy the usa. It was a non-starter for them Matt". (Id.) Because I was in trial, I did not see Mr. Menchel's email, so my proposed email to Ms. Sanchez went out on July 4's at 4:07p.m. (Id) After my email to Ms. Sanchez went out, I saw Mr. Menchel's email, and I responded with a vehement objection, telling him that I believed his plea offer was "completely unacceptable to the FBI, ICE, the victims, and me [and that these] plea negotiations violate the Ashcroft memo, the U.S. Attorney's Manual, and all of the various iterations of the victims' rights legislation." (Id) I asked for the opportunity to make a presentation addressing the strengths of the case and the points raised by Epstein's attorneys — I felt that it was unfair that Epstein had been given numerous opportunities to meet with the management of the USAO and the victims had never had a similar chance (Id) Mr. Menchel responded by reprimanding me, stating, "[a]s you well know, the US Attorney has not even decided whether to go forward with a prosecution in this matter, thus you should have respected his position before engaging in plea negotiations." (Id) I had not engaged in any plea negotiations, Mr. Menchel had. Mr. Menchel also wrote, directly contrary to what USA Acosta and FAUSA Sloman told me at the initial meeting in Miami, "it was made clear to you by the US Attorney and the First Assistant from the time when you were first authorized to investigate Mr. Epstein that the office had concerns about taking this case because of petit [sic] policy and a 18 Epstein's lawyers seized on this later. Page 20 of 58 EFTA00225502

number of legal issues. Despite being told these things, you prepared a pros memo and indictment that included a definitive date for indictment." (Id.) Mr. Menchel also told me that my arguments that he had violated the Ashcroft memo, the USAM and other policies were not well taken because, as "Chief of the Criminal Division, I am the person designated by the US Attorney to exercise appropriate discretion in deciding whether certain pleas are appropriate and consistent with the Ashcroft memo and the USAM — not you." (Id.) Mr. Menchel also told me that I could not dictate a meeting. (Id.) On July 6, 2007, Gerald Lefcourt sent another letter further explaining why Epstein should not be charged with violations of § 2422(b) (Exhibit 33). Most of the letter raised policy arguments and the letter ended by expounding on Mr. Epstein's good works (id.). On July 13, 2007, after I finished my trial, I responded to Mr. Menchel's reprimand, noting my frustration over the Office's failure to provide me with any guidance on its position on the matter.19 I pointed out that I had handled this case the same as I had handled all of my other cases, by working with the agents to gather evidence and preparing an indictment package that established not just probable cause but proof beyond a reasonable doubt. I re-iterated that I was "asking to have the same courtesy that was extended to the defense attorneys extended to the FBI and an Assistant in the Office. ... [And,] my first and only concern in this case . . . 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." (Id.) Mr. Menchel never responded; nor did he allow me to make my requested presentation to USA Acosta. I do not know whether he shared my request with FAUSA Sloman or USA Acosta. Also on July 13, 2007, I received a letter from Roy Black complaining about the grand jury subpoena seeking Epstein's computer equipment (Exhibit 34). I shared the letter with MAUSA Lourie (his handwritten notes appear on the Exhibit) and together we drafted a letter in response (Exhibit 32 at 4). On July 16, 2007, Lilly Ann Sanchez sent my letter to Mr. Lourie, writing that "Gerald Lefcourt and I would like to speak to you further regarding [my letter] since we do not believe that Marie's letter was responsive to the issues raised by Roy Black." (Exhibit 32 at 1). Mr. Lourie and I had a conference call with Ms. Sanchez and Mr. Lefcourt and informed them that they would have to file a motion to quash the subpoena. We then advised Mr. Menchel of the history (Exhibit 62). On July 19, 2007, I sent an email to MAUSA Lourie and Chief Menchel asking for permission to serve target letters on three of Epstein's personal assistants and for guidance on language to be used in the target letters (Exhibit 63). Mr. Menchel responded that he was out of the District "but let's hold off on these until we decide what course of action we are going to take on epstein which should happen next week" (id.). 19 For example, on May 21, 2007, I wrote to Chief Menchel and FAUSA Sloman: "I have time set aside with the grand jury tomorrow, and I am wondering if you have a sense of the direction where we are headed — i.e., approval of an indictment something like the current draft, a complaint to allow for pre-indictment negotiations, an indictment drastically different from the current draft? I am concerned about confusing the grand jury, which is never a good thing. Any guidance?" (Exhibit 54). I did not receive a response. Page 21 of 58 EFTA00225503

After these exchanges and being reprimanded by Criminal Chief Menchel for raising those objections, I was not consulted again about a pre-indictment plea. On July 26, 2007, agents and supervisory personnel from the FBI and I traveled to a scheduled meeting with Chief Menchel in Miami. That morning, before departing for Miami, I sent an email to Mr. Menchel and MAUSA Lotuie that read, "in advance of our meeting this afternoon, I wanted to let you know my thoughts about some of the recommended changes [to the indictment] that we had discussed the last time I was in Miami . . ." (Exhibit 64). The FBI agents, their supervisor, their ASAIC, and I met with Mr. Menchel. Criminal Chief Menchel entered the meeting and announced to us that "Alex [Acosta] has decided to offer a two-year state plea." We were not asked our opinions and the meeting ended soon thereafter (see Exhibit 5). I remember feeling stunned. I don't remember saying anything at the meeting. In an attempt to provide some benefits to the victims and protections to the public, I asked that two terms be added to this two-year deal: (1) that the victims be provided compensation via 18 U.S.C. § 2255 as a substitute for restitution because Epstein was pleading to state charges; and (2) that Epstein be required to plead guilty to an offense requiring sex offender registration. The Office agreed to add these two terms. On July 31, 2007, I finalized a term sheet, entitled "CONFIDENTIAL PLEA NEGOTIATIONS: TERMS OF EPSTEIN NON-PROSECUTION AGREEMENT." (Exhibit 4.) On the same date, it was provided to counsel for Epstein. Present at the meeting for the government were FAUSA Jeff Sloman, Criminal Chief Matt Menchel, MAUSA Andy Lourie, S/A Nesbitt Kuyrkendall, S/A Jason Richards, and myself, and for Epstein were Roy Black, Gerald Lefcourt, and Lilly Ann Sanchez. (See Exhibit 5.) At the meeting, counsel for Epstein stated that their client would not consider a plea that required state jail time. During the meeting, Matt Menchel suggested a plea to a federal charge that would allow Epstein the opportunity to serve his sentence in a federal facility. I was told that USA Acosta did not want to do a federal plea that bound the court to a two- year prison term, so I would have to find a charge or charges that resulted in a two-year statutory maximum. On August 1, 2007, Mr. Menchel advised that the counter-offer that Epstein's attorneys had promised did not arrive, and I told him that I had found a federal charge that could result in a 2-1/2 year statutory maximum (Exhibit 65). On August 2, 2007, Lilly Ann Sanchez sent a counter-proposal directly to Criminal Chief Matt Menchel and, in her email, stated that a copy would also be hand-delivered to USA Acosta (Exhibit 8.) The counter-proposal essentially called for home confinement, no sex offender registration, and an agreement to pay damages via 18 U.S.C. § 2255 (Exhibit 40). Ms. Sanchez also asked for a meeting with the U.S. Attorney (id.). On August 3, 2007, Mr. Menchel sent a letter rejecting the counter-proposal, advising that a minimum of two years' imprisonment was needed to vindicate the federal interest, and that USA Acosta was not inclined to have a meeting (Exhibit 41). Mr. Menchel provided a deadline for August 17, 2007 to accept the plea offer (id). That was Mr. Menchel's last day of employment with the USAO before he entered private practice in New York. Mr. Epstein's attorneys were incensed that USA Acosta had set a deadline of August 17, 2007 and would not meet with them, so they demanded a meeting with CEOS Chief Drew Oosterbaan (Exhibit 43). Mr. Oosterbaan agreed to travel to Florida to meet with USA Acosta and Epstein's attorneys (id.). Mr. Oosterbaan also traveled to West Palm Beach to meet with the agents and myself to go through the evidence and our analysis of the statutes (Exhibit 5). Before he came Page 22 of 58 EFTA00225504

to West Palm Beach, I advised Mr. Oosterbaan that I had worked with CEOS Trial Attorney Myesha Braden on some of the legal issues and that, if there were a trial, I was hoping she might be able to assist (Exhibit 43). In preparation for the planned meeting on September 7, 2007, FAUSA Sloman emailed me to ask what the status of the plea negotiations were. I wrote: Here is the term sheet and guidelines calculation that we provided at the last meeting. You and Matt and I had also discussed a possible federal plea to an Information charging a 371 conspiracy, with a Rule 11 plea with a two-year cap, but I think Matt must have asked Alex about it and it was nixed. Just to be prepared for tomorrow, I was just starting to draft a Rule 11 Plea agreement in case Alex changes his mind and a formal non-prosecution agreement containing the state plea terms. . . . There are three concerns that I hope we can address tomorrow. . . . [including] that the agents and I have not reached out to the victims to get their approval, which as Drew politely reminded me, is required under the law. (Exhibit 44). On September 7, 2007, USA Acosta, FAUSA Sloman, CEOS Chief Oosterbaan, AUSA McMillan, and I met with Kenneth Starr, Jay Lefkowitz, and Lilly Ann Sanchez (Exhibit 5). At the meeting, Mr. Starr focused primarily on federalism/policy arguments, and Mr. Epstein's background. I remember Mr. Starr thanking me for bringing § 2255 to their attention and that it would allow a state resolution that still provided the equivalent of federal restitution. Following the meeting, there were communications between Gerald Lefcourt, USA Acosta, and MAUSA Lourie that I was not privy to. The fact of the conversations was mentioned in later emails. Based upon those communications, on September 10, 2007, I was asked to send Mr. Lefcourt an office response to Lefcourt's counterproposal (see Exhibit 47 ("Gerry: As per your discussion with U.S. Attorney Acosta, I have attached the Office's written counterproposal.")). I sent Mr. Lefcourt a Non-Prosecution Agreement that required Epstein, inter alia, to: (1) plead guilty to three state felony offenses, including lewd and lascivious battery on a child; solicitation of minors to engage in prostitution; and engaging in sexual activity with minors at least sixteen years of age; (2) make a binding recommendation (with the State Attorney's Office) for the Court to impose a thirty-month sentence consisting of 20 months in prison followed by 10 months of community control; (3) waive his right to appeal his conviction and sentence; (4) concede that victims identified by the United States were victims for purposes of 18 U.S.C. § 2255; and (5) plead guilty by September 28, 2007 and be sentenced by October 15, 2007. (Exhibit 66). The following day, FAUSA Sloman forwarded to me USA Acosta's email with USA Acosta's revisions to the NPA (Exhibit 46). At FAUSA Sloman's request, I incorporated the changes and sent the new version to Mr. Lefcourt (Exhibits 47 and 67). On September 12, 2007, MAUSA Lourie, Rolando Garcia, and I met at the State Attorney's Office with State Attorney Page 23 of 58 EFTA00225505

Krischer, ASA Belohlavek, Jay Lefkowitz, Gerry Lefcourt, and Jack Goldberger (Exhibit 5). The purpose of the meeting was to finalize and coordinate the terms of the state and federal agreements. Mr. Lefkowitz still expressed some interest in having Epstein serve his time in a federal facility, rather than a state one, and I remember Mr. Goldberger saying that because Mr. Epstein's home was on Palm Beach Island and touching the Intracoastal Waterway, it was somehow in "international waters" and federal jurisdiction. Other items that were discussed were: (1) that the state crime that Epstein agreed to plead guilty to was one requiring sex offender registration; and (2) that Epstein would be incarcerated 24-7 during the 20-month period of imprisonment. We left the meeting with an understanding that Epstein's counsel would contact us about whether Epstein wanted to plead to federal charges pursuant to a plea agreement or proceed with the Non- Prosecution Agreement. With that in mind, on September 13, 2007, I sent an email to USA Acosta, FAUSA Sloman, MAUSA Lourie, Rolando Garcia, and Karen Atkinson advising them that I had researched three potential federal charges that could be used for Epstein, but they would all result in a 24-month maximum. If Epstein's counsel rejected those charges because of the 24-month exposure, I recommended reconsidering a binding Rule 11 plea "rather than try to create violations out of whole cloth" (Exhibit 46 at 19). I provided a proposed plea agreement and information containing two counts of violations of 18 U.S.C. § 403. Mr. Lourie wrote to me later on September 13, 2007, "He is going to give us an assault on the plane or we can do conspiracy"20 (Exhibit 46 at 21). I responded, "It would still have to be a conspiracy to commit an assault on a plane. I just want to make sure that we have something that is factually accurate. Just trying to plan ahead" (id). At Jay Lefkowitz's request, MAUSA Lourie and I scheduled a conference call with him for early on the morning of September 14, 2007 (id. at 25). Mr. Lourie did not attend the conference call, and on the call, Jay Lefkowitz asked me to consider allowing Epstein to plead to charges that required only 12 months' imprisonment. I recommended 24 months' imprisonment. Lefkowitz said his client would plead to obstruction of a witness and one count of assault on an airplane (id. at 29). Despite Mr. Lourie's earlier agreement to the assault on an airplane charge, he then decided that the "assault sounds like a stretch and factually sort of silly" (id. at 31). I then went back to Mr. Lefkowitz with four options: (1) a plea only to state charges with 18 months' imprisonment; (2) federal and state pleas with a recommendation for concurrent time so that Epstein could serve his time in a federal facility; (3) a § 371 plea with a binding recommendation of 20 months' imprisonment (if USA Acosta approved it); or (4) an agreement that had a plea to one federal charge followed by one state charge (id. at 33). We continued to negotiate issues about how to provide restitution to the victims, and each iteration of the agreements seemed to move us further apart. As shown in Exhibit 46, each time Mr. Lefkowitz tried to reduce the period of incarceration; he tried to replace the state charge with one that did not require sex offender registration; and he kept changing the damages/restitution provisions to make it more difficult for the victims to obtain compensation; he removed the appeal waiver; he included an agreement that we would recommend an incorrect calculation of the guidelines. It was simply bad faith negotiations. I would point out how terms that were specifically rejected were re- inserted, and the Office would just send me back to the table. 2° This somehow resulted in 18 months' imprisonment. I do not recall how the prison term was decreased from 20 months on September 11, 2007 to 18 months on September 13, 2007. Page 24 of 58 EFTA00225506

The agreement was finally completed and signed on September 24, 2007. 4. Explain fully the process and circumstances leading to the development of the following terms of the non-prosecution agreement: a. an 18-month period of incarceration in a state facility, including the basis for the determination that it sufficiently satisfied the federal interest in the case; As noted above, the only information that I received was from Mr. Menchel's announcement that USA Acosta had decided to offer a two-year state deal. I do not know how Messrs. Menchel and Acosta determined that two years' incarceration sufficiently satisfied the federal interest in the case. During one meeting, Epstein's attorneys raised the possibility of a state-court plea with home confinement. USA Acosta specifically rejected the suggestion, noting that confinement in Mr. Epstein's home was not equivalent to incarceration. As discussed above, the 24-month term was reduced to 20 months and then, finally, to 18 months. b. victim restitution, including why and how to address victims' rights through 18 U.S.C. § 2255; The federal crimes that were under investigation all called for mandatory or discretionary restitution under 18 U.S.C. §§ 3663 and 3663A.2' Gelber and Drew Oosterbaan from CEOS are experts in this area, but as PSC Coordinator, ew that restitution in child exploitation cases was a hot-button issue at the time. The District of Alaska USAO had a multi-victim child exploitation case with a wealthy defendant (Boehm) where they had set up a trust fund with a bank and a trustee. With Drew Oosterbaan's help, I explored setting up a similar situation in the Epstein case (Exhibit 48), in connection with using a guardian ad litem ("GAL") for the victims,22 if there had been a plea to federal charges. In cases like the Epstein cases, using a GAL seemed the most prudent course because, to the extent that the victims' interests ever diverged from the government's, the GAL could advocate on behalf of the victims. Thus, there are several emails between myself and Jay Lefkowitz about the appointment of a GAL and the possibility of a restitution trust fund similar to the Boehm case out of Alaska. I obtained the trust fund agreement and spoke with the AUSA in 21 Mandatory restitution under § 3663A requires a conviction for a "crime of violence, as defined in [18 U.S.C. §1 16." At the time, these cases would have been considered crimes of violence because sex trafficking, even via fraud or coercion, would likely be considered to "involve() a substantial risk that physical force against the person . . . or another may be used in t the course of committing the offense." 18 U.S.C. § 16(b). Post-Johnson v. United Sta , U.S. 135 S. Ct. 2551 (2015), a court might decide differently. See, e.g., Menendez Whitaker, 908 F.3d 467 (9'b Cir. 2018). Even if not a crime of violence, a Court has the author; to impose an order of restitution when sentencing a defendant convicted of any offense under title 18 for any losses sustained by a victim as a result of the offense. 18 U.S.C. § 3663(aX1)(A), (B)(i)(I). And the court also can order restitution to persons other than the victim of the charged offense if the parties so agree. 18 U.S.C. § 3663(a)(1)(A). 22 I had been the first prosecutor in the S.D. Fla. to apply to the court for guardians ad litem for victims in child exploitation cases, so I was familiar with the procedure. Page 25 of 58 EFTA00225507

Alaska. The trust fund agreement was very complex and required a bank to agree to serve as the holder of the corpus and a trustee to oversee the administration of the trust, as well as the Court to enter an order setting up the trust and a mechanism for resolving disputes amongst beneficiaries or between a beneficiary and the trustee. In light of the amount of details and the number of victims involved, and the simple fact that, if there was only a state plea, there would be no federal judge to undertake the process, I knew that there was no way to accomplish a trust fund like Boehm within the confines of the NPA. In the Boehm case, there was a much smaller number of victims and, if I remember correctly, the victims were younger. The Alaska AUSA was able to confer with Boehm's victims and obtain their consent to the trust agreement procedure in advance of entering into the plea agreement. The Alaska AUSA also obtained the defendant's agreement to proceed ex pane. Our situation was quite different. There were more victims with disparate interests. In my emails, I made it clear that I could not bind the victims to such a procedure because I did not represent them. For example, how would the USAO decide on the size of the corpus of the trust? Would the USAO hire expert psychologists to evaluate the victims and economists to quantify their losses? If the USAO picked a number, would that preclude a victim from bringing a state tort claim? Would every victim receive the same amount? This is not how criminal restitution works — normally after a guilty plea, the Court's Probation Office works with victims to calculate losses, and issues are litigated at sentencing or within 90 days after sentencing. Lefkowitz was asking the USAO to pick a number virtually out of thin air to use as the corpus of the trust for a group of victims who were not clients of the USAO. We also would have to locate an independent bank to serve as the hold of the corpus. Given how difficult negotiating simple plea terms had been, I believed that creating an agreement of this sort was legally and logistically impossible. When Epstein's attorneys approached USA Acosta in December 2007 and suggested that I rejected the Trust proposal for nefarious reasons, I outlined all of the concerns that I had previously expressed to Mr. Lefkowitz (Exhibit 55). Once I was instructed that Epstein would be allowed to plead to state charges, I wanted to do what I could to place the victims and the community in the same position where they would have been in Epstein had pled to a federal offense. If Epstein had pled to one of the federal offenses under investigation, he would have been required to register as a sex offender and pay restitution to all victims of the federal offense. With regard to the restitution piece, I knew that the state investigation had not included all of the girls and young women whom we had identified and I was concerned that Epstein would avoid his restitution obligations if not forced to pay.23 As part of my duties as PSC Coordinator, on September 26, 2006, I had prepared a memo to management summarizing the Adam Walsh Child Protection and Safety Act of 2006 (the "Adam Walsh Act") (Exhibit 16). One of the provisions of the Adam Walsh Act that I noted was an amendment to 18 U.S.C. § 2255: "Section 2255 has been expanded to allow a person who, while a minor, was a victim of various child exploitation offenses, to pursue a civil action for personal injury damages — regardless of when the personal injury occurred. It also raises the presumptive damage amount to $150,000." (Id. at 7.) Although this was an amendment, I was unaware of § 2255 prior to preparing this September 2006 memo. The first few times I brought it 23 In fact, the State Attorney's Office did not seek or obtain restitution for any victims in the state case, not even the two victims that were the basis of the state charges. Page 26 of 58 EFTA00225508

to the attention of others, they thought I was mis-citing 28 U.S.C. § 2255 and I had to explain that there actually was an 18 U.S.C. § 2255, which was a civil provision within the criminal code. I do not know when I first discussed the possibility of using § 2255 as a replacement for the victims' lost restitution benefits, but I know that I conducted research on § 2255 cases on July 27, 2007 (Exhibit 37). That was the day after the meeting where Criminal Chief Menchel had announced that USA Acosta had decided to offer Epstein a two-year state plea (Exhibit 5). Language regarding § 2255 was included in the plea agreement term sheet provided to Epstein's counsel on July 31, 2007 (Exhibit 38). The issue must have been raised in advance of the meeting, because that was the first meeting attended by Ken Starr, and he specifically thanked me for bringing § 2255 to their attention. On August 2, 2007, Lilly Ann Sanchez sent a letter to Criminal Chief Menchel making a series of counterproposals including: "Application of 18 U.S.C. § 2255" (Exhibit 40 at 2). Ms. Sanchez went on to explain: 18 U.S.C. 2255 provides that any minor who suffers injury as a result of the commission of certain offenses shall recover actual damages and the cost of any suit. It is important to note that Mr. Epstein is prepared to fully fund the identified group of victims which are the focus of the Office — that is, the 12 individuals noted at the meeting on July 31, 2007. This would allow the victims to be able to promptly put this behind them and go forward with their lives. If given the opportunity to opine as to the appropriateness of Mr. Epstein's proposal, in my extensive experience in these types of cases, the victims prefer a quick resolution with compensation for damages and will always support any disposition that eliminates the need for trial (id. at n.1). Thus, the use of § 2255 as a replacement for restitution was not controversial — it was promoted by Epstein's own attorneys, including Mr. Starr. At one point during negotiations, Mr. Lefkowitz started advocating for a trust fluid like the one used in Boehm, mostly, I believe, to try to place a cap on his damages exposure. I offered some potential solutions, including asking the federal court to appoint a guardian ad litem who could work with Epstein's counsel to see if the victims would be willing to agree to a Trust Fund, and I would facilitate those efforts, but I simply would not agree to something that I legally could not promise — a binding resolution for victims whom I did not represent. Eventually, Mr. Lefkowitz made some changes to the § 2255 language but it remained quite close to the original proposal contained in the July 31, 2007 term sheet. c. immunity for co-conspirators, including unidentified co-conspirators; and In looking through the drafts of the agreements, the immunity provision does not appear in any of the federal plea agreements that I drafted. Its first appearance is in a version of the NPA proposed by Jay Lefkowitz along with a proposed promise that the government would not seek immigration sanctions against any of the co-conspirators. It was initially rejected, and then after several iterations, Lefkowitz revised it to the language that appeared in the final NPA. The final language was: "In consideration of Epstein's agreement to plead guilty and to provide compensation in the manner described above, if Epstein successfully fulfills all of the terms and conditions of this agreement, the United States also agrees that it will not institute any Page 27 of 58 EFTA00225509

ges against an co , em, including but not limited to Adriana Ross, or " (Exhibit 52 at 5). To the extent that there was a "criminal organization," the Office and the investigators considered Epstein to be the head of that organization. He was certainly the most culpable individual, and we did not foresee any scenario where we would defer prosecution against Epstein but proceed to prosecute his subordinates. Also, while the agreement included the language "including but not limited to," at the time that the NPA was signed, with the possible exception of Ghislaine Maxwell, the investigation had not disclosed any co-conspirators other than those listed. I recall that there was extensive discussion of Lefkowitz's proposed immigration language, but I do not recall much discussion of this language for the reasons stated above. d. the October 2007 addendum, including its purpose. During the negotiation of the NPA, I had been admitted to the hospital for surgery. After the surgery, I returned to the office almost immediately to try to complete the negotiations. When the NPA was signed, I sought permission to take a leave of absence to address my health concerns. While I was away, the Addendum was negotiated. While I conducted some of the drafting, I believe that FAUSA Sloman handled the bulk of the negotiations and drafting. My understanding was that the USAO wanted to formally assign its right to select the attorney representative for the victims to a Special Master. The NPA stated that the USAO would select the attorney representative in consultation with and subject to the good faith approval of Epstein's counsel. I had provided Epstein's counsel with a list of attorneys, none of whom I had ever met, that I had culled from consulting with one of the district judges24 and some AUSAs, including Mr. Yen, who I was dating at the time. After getting that list of names, I did my own research to determine who would be good fits for the type of litigation that I expected they would face — both in terms of the tactics of Epstein's lawyers and the special challenges of dealing with emotionally fragile victims. I provided that culled list to Jay Lefkowitz and disclosed that, although I had no financial interest, the list included a friend of a good friend of mine (I did not describe Mr. Yera as my "boyfriend"). Even with that disclosure, Mr. Lefkowitz selected Mr. Yera's friend. Before the matter went any further, FAUSA Sloman decided that the Office should use a Special Master to make the selection, rather than pick anyone — even a panel of attorneys leaving the final selection to Epstein's counsel. Despite that, Mr. Lefkowitz and Guy Lewis — who knew both Mr. Yera and his friend — claimed that there was a financial interest and that I had tried to create the procedure for financial gain.25 24 Epstein's lawyers suggested that I had ex parte communications with a judge. I simply asked for recommendations from a judge that I was friendly with; I did not disclose anything about the background of the case. 25 Mr. Lewis knew that Mr. Yera also was an AUSA and, therefore, was not partners with another lawyer. When that was patently obvious, Epstein's lawyers falsely claimed that they were "law school roommates." Both had graduated from law school more than fifteen years before, and had not been roommates. Ironically, one of the reasons why Epstein's legal team approved the selection of Robert Josefsberg was that Josefsberg and Alan Dershowitz were law school classmates — somehow there was no "financial interest" attributed to them. Page 28 of 58 EFTA00225510

Rather than simply elect to use a Special Master to exercise its right to make the attorney representative selection, the USA() believed that it should formalize the assignment in writing. 5. To the extent not evidenced in e-mails or other correspondence, identify and describe all interactions with defense counsel — such as phone conversations, meetings, or communications by private e-mail — that you or any other member of the government had regarding the investigation, potential prosecution, or negotiation of a resolution of this case. If at any point you became concerned about the nature of any member of the government's interaction with defense counsel, describe the interaction and explain when and why you became concerned. My communications with opposing counsel occurred primarily via email. Most of those communications were via office email, and some were from my home email. All of my home emails were collected and produced as part of the Jane Doe litigation. Negotiations were occurring at nights, on weekend, and while I was recuperating from surgery, and this occurred during a time when out of office access to email was very limited. I believe that only supervisors had Blackberry devices at that time. The meetings that I attended are catalogued on the meeting timeline (Exhibit 5). I believe there was one other meeting soon after Epstein entered his guilty plea, when I went to Jack Goldberger's office and met with him and Mike Tein (Guy Lewis' law partner) about the victim list. Other than that, I do not recall any in-person meetings. I had a couple of telephone conversations with Lilly Ann Sanchez and Guy Lewis at the start of the investigation that were very brief. Jeff Sloman and/or Andy Lourie was on some of these. I had telephone conversations later during the investigation with Lilly Ann Sanchez, Gerry Lefcourt, Roy Black, and Nate Dershowitz about subpoena responses. Karen Atkinson and Andy Lourie were on some of those calls. I had telephone conversations with Jay Lefkowitz about plea negotiations and scheduling meetings. Andy Lourie, Rolando Garcia, and Jeff Sloman were on some of those calls. I had numerous calls with Roy Black and Jack Goldberger about breaches of the NPA. Karen Atkinson was on most of those telephone calls. From emails and conversations, I know that Messrs. Acosta, Sloman, Menchel, and Lourie had numerous emails and conversations (mostly via telephone and possibly some in person) with members of the defense team. USA Acosta had contact with Ken Starr, Jay Lefkowitz, Gerry Lefcourt, and Alan Dershowitz. FAUSA Sloman had contact with Alan Dershowitz, Gerry Lefcourt, and Lilly Ann Sanchez. Criminal Chief Menchel had contact with Lilly Ann Sanchez and Gerry Lefcourt. There may have been other meetings that I was unaware of. I was concerned about the level of contact and the lack of consideration of the sanctity of the investigation. It was imperative to keep the investigation confidential to protect not just the victims' privacy rights, but to keep them from the harassment of overly aggressive lawyers. I felt that there were leaks of case-related facts and strategy, as well as personal matters that undermined my ability to deal with the defense and that ultimately was used by the defense to defame me and Mr. Sloman with senior members of the Department of Justice. Page 29 of 58 EFTA00225511

6. Provide a detailed description of all settlement negotiations conducted in this matter in which you took part or of which you were otherwise aware, including all terms of settlement that were discussed, considered, and rejected during the negotiations. Identify all individuals who participated in those negotiations, including government personnel and defense counsel. In each case, identify all participants and describe the discussions that occurred. Please see my response to Question A.3. 7. Describe the interactions by you, or anyone else within the USAO, with any employees of the Palm Beach County State Attorney's Office concerning the federal or state investigation of Mr. Epstein, the terms of a proposed resolution of the case, and the terms of the federal non-prosecution agreement, including the terms of Mr. Epstein's incarceration. As noted above, my first interaction with anyone from the Palm Beach County State Attorney's Office about the Epstein case was at the Project Safe Childhood Conference in Washington, DC, when State Attorney Barry Krischer introduced himself to USA Acosta and me and started railing against the victims and the case. My next interaction was with ASA Lanna Belohlavek at some later date. I was in her office, I believe on another matter, and I mentioned the case. She said that she "hated" the case and that she "hated" prostitution cases. She stated that some of the girls were not really victims because they had been paid "thousands of dollars." I was a bit taken aback because Ms. Belohlavek was the supervisor of the division charged with prosecuting child sex offenses, including child prostitution cases and, by definition, child prostitutes receive money. Although not personal interactions, I also had collected and reviewed the state grand jury transcript, indictment, and the state investigative materials. I had conferred with former ASAs about the use of the grand jury in the case, which was very unusual. In Florida, only capital cases need to be presented to a grand jury — all other cases can proceed by Information — and one ASA in Palm Beach County handles the presentation of all of the cases to the grand jury. This case was unusual because it was presented to a grand jury unnecessarily and it was not presented by the regular grand jury ASA. The State Attorney also had told the press that a variety of charges had been presented to the grand jury and the jurors had selected the lowest charge of solicitation of prostitution (with no designation of age). The transcript gave no indication that multiple charging options were presented, and the jurors were only provided with evidence about one victim, not all of the victims who had been the subjects of the investigation. I believe that the next interaction was on September 12, 2007, when I attended a meeting at the State Attorney's Office with Andy Lourie and Rolando Garcia. Jay Lefkowitz, Gerald Lefcourt, and Jack Goldberger attended on behalf of Mr. Epstein, and State Attorney Krischer and ASA Lanna Behlolavek were present. At some point in the past, one of Epstein's attorneys had falsely told State Attorney Krischer that a person from the USAO had referred to the SAO as "a joke." Messrs. Lourie and Garcia and I had to spend the first several minutes of the meeting convincing State Attorney Krischer that no one had ever said such a thing. After crossing that hurdle, we got to the core of the meeting, which was whether the SAO was in agreement with filing charges and seeking a sentence consisting with the terms of the NPA — that is, a plea to an Page 30 of 58 EFTA00225512

offense that required sex offender registration — namely, procuring a minor for prostitution in violation of Fl. Stat. 796.03; and a sentence totaling 18 or 20 months' imprisonment.26 I recall that either Mr. Lourie or I asked Ms. Behlolavek to confirm that § 796.03 required sex offender registration, and she said that it did. Epstein's attorneys also said that it did. We also specifically discussed that Epstein would be confined for the term of imprisonment. State Attorney Krischer said that a term of imprisonment of longer than one year usually required placement in a state penitentiary, but there was a way to structure the sentence as a split sentence so that Epstein would be housed at the Palm Beach County Jail. And we again confirmed that Epstein would remain in custody at the jail, not home confinement or any other type of release and we were told that he would be in jail. We also discussed wrapping the matter up quickly because of the extensive delays. On September 23, 2007, Jay Lefkowitz sent an email to Alex Acosta essentially admitting that, during the meeting on September 12, 2007, Epstein's attorneys and Ms. Behlolavek all believed that a conviction for Fl. Stat. 796.03, procurement of minors for prostitution, did not require sex offender registration — despite our specific inquiries (see Exhibit 51 ("I write to follow up on our conversation on Friday and to ask you to reconsider your decision to require that Mr. Epstein plead guilty to a registerable state charge. It appears that there was a misunderstanding at the meeting I had with Messrs. Laurie, Krischer, Goldberger, Lefcourt, Ms. Villafana and Ms. Belohlavek. . . . Before the meeting, Mr. Krischer, and Ms. Belohlavek, a sex prosecutor for 13 years, told us that solicitation of a minor, under 796.03, is not a registerable offense. However, as it turned out, 796.03 is a registerable offense and our discussion at the meeting was based on a mistaken assumption." (emphasis added)). On December 6, 2007, ASA Behlolavek contacted me to draft a factual proffer and advised that Epstein would be entering a guilty plea on December 21, 2007 (Exhibit 73). I did some research on 796.03 and prepared a draft that I shared with FAUSA Sloman, but he decided not to share the information with Ms. Behlolavek (see id). While drafting this response, I searched my electronic files for Mr. ICrischer's name and discovered a document entitled "071214 Acosta Ltr to Krischer.wpd" (Exhibit 69). I do not recall drafting this letter, although I located a cover email stating that I drafted this and two other letters for USA Acosta's signature that were directed to the State Attorney's Office (Exhibit 75). I do not know if any of the letters were ever sent to Mr. Krischer. In May 2008, Rolando Garcia had a discussion with State Attorney Krischer and Krischer advised that he and Jack Goldberger had reached a new agreement for Epstein of 90 days in jail (Exhibit B-39). On June 17, 2008, Karen Atkinson and I spoke with State Attorney Krischer. He complained that we had not been communicating with him, and we told him that Epstein's counsel had blocked the channels of communication (Exhibit 78). Krischer said that he and Jack Goldberger had reached a new agreement where Epstein would plead guilty to "attempted lewd conduct" and be sentenced to 60 days in the County Jail followed by two years of community confinement (id.). 26 As noted above, I do not recall the exact date when USA Acosta agreed that 18 months' imprisonment was sufficient. Page 31 of 58 EFTA00225513