On June 19, 2008, I sent an email to State Attorney Krischer advising him that we had spoken with Roy Black about wrapping up both the state and federal /times (Exhibit 68). I reminded State Attorney Krischer that the signed NPA required a plea to the current state indictment and to an information charging an offense that requires sex offender registration, namely procuring minors to engage in prostitution, with a sentence of at least 18 months' imprisonment (id.). I attended the change of plea on June 30, 2008 but did not have any contact with any member of the SAO that day. Later, when the issue arose regarding whether or not Epstein was taking the position that the NPA included USA Acosta's December 2007 letter, I contacted Ms. Behlolavek and SA Krischer to obtain a copy of what Epstein's counsel had filed in state court. In September 2008, I had communications with Mr. Krischer about a suit filed in state court to unseal the NPA (Exhibit 70). At some point, Mr. Krischer sent me an email about wanting to buy me a cup of coffee. I was not able to find the email while preparing this response, but with additional time, I can probably locate it. I don't believe I ever answered Mr. Krischer. I know I never met him for coffee. I recall that in many of Epstein's letters to the Justice Department, there were complaints of a lack of coordination between the USAO and the SAO. That lack of coordination was not caused by the government agencies, but, rather, by the tactics of Epstein's counsel. For example, Epstein's counsel insisted that I should conduct a completely independent review of the evidence so that I would not be tainted by bias from the PBPD or the SAO. When I did so and reached a conclusion that they did not like, Epstein's attorneys insisted that Criminal Chief Senior and that CEOS conduct similarly sterile reviews free from the "taint" of me and the federal agents. If Ms. Atkinson and I or the agents and I reached out to the SAO to discuss how the NPA should be worded to insure that we were getting correct information from Epstein's attorneys, we were accused of "infringing on the SAO's discretion." Yet, that "lack of coordination" that Epstein's attorneys caused, was later held up to the DAAG, the AAG, and DAG, as violations of the Petite policy's state-federal coordination requirement. 8. Describe any research conducted by you, or anyone else within the USAO, into law or policy regarding any of the following issues: a. The propriety of permitting a person to plead guilty to state court charges in exchange for an agreement by the USAO to refrain from federal prosecution. In your response, you should identify any USAO or Department policies that were considered by the USAO, and any effort by the USAO to obtain guidance or approval from the Department to use a non-prosecution agreement to resolve this case. I did not do any research on this point. I do not know whether USA Acosta or Criminal Chief Menchel conducted any research or obtained any guidance or approval from the Department. Page 32 of 58 EFTA00225514

b. The propriety of including in a non-prosecution agreement with Mr. Epstein a provision that the federal government would forgo prosecution of any potential co-conspirators of Mr. Epstein, including unidentified co-conspirators. I do not recall doing any research on this particular point, other than discussing with MAUSA Lourie that we would not pursue an investigation into Epstein's subordinates after closing the investigation of Epstein. c. The propriety of including in the non-prosecution agreement a provision incorporating 18 U.S.C. § 2255. As noted above, I became familiar with § 2255 through my work as the PSC Coordinator. I also was aware, as set forth in the victim notification letters that I prepared, that, under the CVRA, I was obligated to use my "best efforts" to protect the victims' rights to "full and timely restitution as provided in law." 18 U.S.C. § 3771(a)(6). As I discussed above, restitution in child exploitation cases was an issue of growing concern, so I was mindful that this plea mechanism that Criminal Chief Menchel had devised with Lilly Ann Sanchez would extinguish, the victims' right to restitution. That was one of the reasons why, on July 4, 2007, I wrote to Mr. Menchel that I believed the plea proposal violated the victims' rights legislation. When Mr. Menchel announced in late July that USA Acosta was going forward with the two-year state plea offer despite those concerns, I undertook my best efforts to still afford those restitution rights to the victims identified through the federal investigation. Immediately after the meeting where Mr. Menchel announced to me and the investigative team that USA Acosta intended to offer a state plea, I delved further into the requirements for claims under § 2255 (Exhibit 37). While § 2255 is a civil damages statute, not a criminal restitution provision, the criminal restitution statutory scheme recognizes that there is some overlap. See 18 U.S.C. § 3664(j)(2)(A), (1). Section 2255 also provides for attorneys' fees, just as courts can use court funds to appoint guardians ad litem for minor victims in criminal cases who can advocate for restitution for the victims. My review of the legislative history led me to conclude that the inclusion of a provision under § 2255 would be the best way to protect the victims' right to restitution. CEOS Chief Oosterbaan described the agreement as "a very significant result that will serve the victims well" (Exhibit 71). I should note that a plea to one of the federal crimes under investigation — with a 24-month binding sentencing recommendation — would have achieved USA Acosta's desired outcomes (24 months' imprisonment" and sex offender registration); would have provided federally mandated restitution for the victims; and would have provided victims with court-funded representation via the guardian ad litem program for those who needed it. All of these contortions were brought about by the decision to use a state plea to resolve a federal investigation. 27 As noted above, I was never told the source of the 24-month figure. In my opinion, a straight § 371 plea, with a five-year statutory maximum, was a significant concession. Page 33 of 58 EFTA00225515

d. How the Florida state judicial system would address issues pertaining to the terms of Mr. Epstein's incarceration, including designation of an appropriate facility, the availability of work release (or any similar release condition), and the availability of other privileges. Identify whether such research was conducted before or after the non- prosecution agreement was signed, and whether it was conducted before or after Mr. Epstein entered his state court plea. Describe any communications you or other USAO personnel had with representatives of the Palm Beach County State Attorney's Office, other law enforcement, or local corrections officials regarding these matters. One of my concerns about using a state forum to resolve this case was that it left our Office with no control over the process. We also did not have any members of our team who had experience with the Palm Beach County state courts — Criminal Chief Menchel had been a state prosecutor in New York before joining the USAO; I had been in private practice. Similarly, no one else involved in the process had been an ASA or even a criminal defense attorney in Palm Beach County. The defense team, on the other hand, included Roy Black and Jack Goldberger, who had extensive state court criminal experience in Palm Beach County. Any litigator will tell you that knowing the Court is a key component of success, so we were placed at a distinct disadvantage. It was exacerbated by defense counsel's tactics of prohibiting coordination between the USAO and the SAO — which somehow was successful.28 It also required the USAO to place an inordinate amount of trust in the SAO, when one of the reasons for opening the federal investigation was the concerns that undue influence had been brought to bear on the State Attorney.29 The loss of control did not just end with the Court proceedings, it included how the sentence would be executed. Federal sentences are executed by the U.S. Marshals and the Bureau of Prisons. All are housed within the Department of Justice and have clearly written rules and regulations. BOP is used to housing wealthy, politically-connected offenders and would be less likely to be unduly influenced by Epstein. I attempted to build some certainty back into the agreement through several provisions. First, I selected the state statutes that Epstein would have to plead guilty to and conducted my own research to confirm that they required sex offender registration. Second, I included language that 28 Epstein's team was equally successful in DC, where they dictated who could and could not participate in the "independent review" at CEOS. For example, Myesha Braden, who had not yet joined the Leap Year team, was excluded from consideration because she had disagreed with Lilly Ann Sanchez about the handling of an obscenity case while Ms. Sanchez was an AUSA. 29 According to PBPD Chief Reiter, the State Attorney initially planned to file no charges against Epstein. Following complaints, the SAO planned to charge Epstein with a misdemeanor solicitation of adult prostitution charge. Then, after the police chief complained further, the State Attorney assertedly presented "multiple charges" to the grand jury, and they "elected" to return an indictment charging one felony count of soliciting adult prostitution. The State Attorney did not intend to charge an offense requiring sex offender registration and was only seeking a sentence of probation. Page 34 of 58 EFTA00225516

he would have to plead guilty, not nolo contendere. Third, I researched different terms that Florida courts would use that appeared to impose a term of incarceration, but really imposed something else, and prohibited those sentences ("Epstein shall be sentenced to consecutive terms of twelve (12) months and six (6) months in county jail for all charges, without any opportunity for withholding adjudication or sentencing, and without probation or community control is lieu of imprisonment" (Exhibit 52 at 3 (emphasis added)). Fourth, I included a waiver of the right to challenge the Information and an appeal waiver. Fifth, I included a requirement that Epstein would have to provide the USA° with a copy of his plea agreement with the SAO before he signed it. Sixth, I required Epstein to use his best efforts to enter his guilty plea within approximately 30 days and an agreement that that term (like all others) was material. Seventh, I included an agreement that Epstein would not be afforded any gain time benefits different from any other inmate, and that he would provide an accounting of gain time if asked. Finally, "breach of any one of these conditions allows the United States to elect to terminate the agreement and to investigate and prosecute Epstein and any other individual or entity for any and all federal offenses" (id. at 6). In addition to the terms of the NPA, the agents and I also did our best to make sure that Epstein would be serving jail time like anyone else. Prior to the September 12, 2007 meeting at the State Attorney's Office, I spoke with Andy Lourie and emailed Jeff Sloman about research I had conducted on Florida sentencing practices to avoid "trucks up the sleeves of the defense" (Exhibit 46 at I.) Normally a defendant who is sentenced to a term of prison in excess of 12 months must go to a state prison. The Office did not object to "splitting" Epstein's sentence into two pieces — 12 months followed by 6 months — so that he would be eligible to be housed at the Palm Beach County Jail. All of us were, however, insistent that Mr. Epstein would actually serve out his term at the jail like any other prisoner. At the September 12, 2007 meeting with the State Attorney's Office, this issue was specifically addressed, and State Attorney Krischer assured us that Epstein would be at the Palm Beach County Jail (it is referred to as "Gun Club" because it is located on Gun Club Road). I remember that they discussed that Epstein would be kept in solitary confinement "for his own safety." After that meeting, the case agents went to meet with the jail about the issue of work release. I do not recall the exact date. On November 14, 2007, I sought FAUSA Sloman's permission to meet with State Attorney Krischer after ASA Behlolavek stood up the agents a few times. The purpose of my meeting was "to clear up the issue regarding sex offender registration/work release and also should be able to tell us whether a plea and sentencing can be scheduled this month" (Exhibit 72). FAUSA Sloman and Acting MAUSA Rolando Garcia had conversations with the State Attorney and Jay Lefkowitz who both confirmed that Epstein would "be a sex offender and he'll be treated like any other sex offender" (Exhibit 76 at 2). On November 16, 2007, the case agents met with ASA Belohlavek who said that Epstein would be housed at the Palm Beach County Jail, so the Palm Beach Sheriff's Office would be in charge of whether Epstein would be eligible for work release (id. at I). Special Agent Richards confirmed on November 16, 2007 that Epstein would not qualify for work release as a sex offender unless the judge specially ordered it (id.). As noted above, when we learned that Epstein's attorneys were negotiating a new deal with the State Attorney's Office, Karen Atkinson and I firmly informed Epstein's attorneys and the State Attorney's Office that there was a signed agreement. While they were free to negotiate whatever they wanted, the terms they were discussing violated the NPA. Page 35 of 58 EFTA00225517

In June 2008, when Epstein had exhausted his appeals to the DAG, in accordance with the NPA, I asked to see the plea agreement that his attorneys had negotiated with the State Attorney's Office to insure that it was consistent with the NPA (Exhibit 77). After a number of requests to Roy Black and Jack Goldberger, I finally received the document (id.). After conferring with an AUSA who had previously worked at the Palm Beach County SAO, and with FAUSA Sloman, I informed Messrs. Goldberger and Black that the agreement was insufficient because it did not specify that the defendant was supposed to serve his sentence in a custodial setting (id.). After providing the written notice, Mr. Goldberger agreed to make the change (id) Goldberger also called me and "'swore' [his word] that Epstein would be in custody 24-hours-a-day during the community confinement portion of the sentence" (Exhibit 79). The agents also confirmed with local officers that the language in the state plea agreement suggested that Epstein would be at the Palm Beach County Detention Center, a/k/a the Palm Beach County Jail, and that, during their meeting with PBSO Col. Gauger several months before, he had assured them that Epstein would be ineligible for work release (Exhibit 80). Nonetheless, we decided that we would go meet with the Colonel together. Karen Atkinson joined us, and we learned that, despite the language in the agreement, Epstein was housed at the stockade rather than the jail (a lower security "camp-style" facility) (Exhibit 81). Gauger also told us that Epstein would be eligible for work release and will be placed on work release — directly contradicting what he had told the agents a few months before (id. ).30 We asked Col. Gauger to let us know if Epstein did, in fact, apply for work release. We never received any notice of Epstein's application. Instead, on November 20, 2008, when Gauger stopped by to see Karen Atkinson on another matter, he told her that Epstein had been on work release for the past few weeks (Exhibit 82). S/A Kuyrkendall spoke with the work release coordinator who told her that he was led to believe that the USAO and FBI knew that Epstein had applied for the program. He also said that he had been threatened with being sued if he didn't allow Epstein to participate (id) I reviewed my emails and notes of conversations with Black, Goldberger, and other defense counsel about Epstein being incarcerated for the MI 18 months (except for credit for "gain time"). Criminal Chief Senior advised me to determine if there was sufficient support to show a breach. After correspondence with Roy Black and a telephone conference with Mr. Black and Jay Lefkowitz, we were advised that USA Acosta had informed Mr. Leflcowitz3I that Epstein could be considered for any program that was available to other prisoners. At that point, I was unable to press forward with a breach, so I conducted an in-depth review of Epstein's application and found numerous false statements that, in my opinion, should have made the Sheriffs Office reverse its position regarding work release. I drafted a letter cataloguing all of the misstatements and conflicts of interest (e.g., Epstein's work release supervisor was one of his employees who lived in New Jersey) and submitted it to the Sheriff's Office (Exhibits 83 and 84). I never received a response from the Sheriff's Office. 30 Gauger also said that Jack Goldberger had threatened that "Ken Starr and the whole crew" would sue the jail if Epstein received less favorable treatment than others (id). 31 1 do not recall whether Alan Dershowitz or Ken Starr also was present for this meeting, but no one else from the USAO was present. Page 36 of 58 EFTA00225518

9. Describe all efforts made by you, or by anyone else within the USAO, to ensure that Mr. Epstein complied with the terms of the non-prosecution agreement (including its addendum) that he signed. Include in your response a discussion of all breaches of the agreement by Mr. Epstein of which the USAO was aware, and explain why the USAO decided not to rescind the agreement as a consequence of such non-compliance, who was involved in that decision, and how the decision was made. Many instances of notices of breach have been catalogued throughout this letter, as well as my efforts to force Epstein to abide by the terms of the NPA prior to declaring a breach (e.g., resisting efforts to change the state plea to one that did not require sex offender registration; requiring Epstein's counsel to provide us with copies of the state plea agreement before the plea; requiring the appointment of the attorney-representative who representative the victims; etc.). The attempt to declare a breach in connection with Epstein's application for work release is discussed above. In June 2009, Epstein and his lawyers tried to dismiss a lawsuit filed in the Southern District of Florida by the attorney-representative on behalf of one of the identified victims that raised a single claim under 18 U.S.C. § 2255. I prepared a lengthy memorandum analyzing why Epstein's actions were a breach and seeking permission to serve a breach letter (Exhibit 85). The Office approved the request to serve the breach letter. At the same time, the indictment package was re-reviewed and approved (Exhibit 86). The notice of breach letter was served on June 12, 2009 (Exhibit 87). Epstein promptly "cured" the breach, but I took the opportunity to catalogue his past breaches and advised that continuing on that course of conduct would no longer be tolerated (Exhibit 88). Perhaps sensing that the Office's patience had waned, perhaps having gained a greater understanding (through the civil litigation) of the strength of the potential criminal case, Epstein's counsel expressed a greater interest in avoiding problems. While I demurred on their request that I essentially offer "advisory opinions," I suggested that Mr. Epstein should "take all of his obligations seriously and elect to err on the side of caution in making decisions that relate to the performance of his duties" (Exhibit 89). In consideration of my warnings, Mr. Black contacted the USAO to advise us in advance that Mr. Epstein was seeking to transfer his community control to the Virgin Islands and wanted our position (Exhibit 90). Having the experience of all of the false statements on Epstein's application for work release, I immediately sought the application from Mr. Goldberger, but it was never provided. I became concerned that Epstein's attorneys would use the delay engendered by Mr. Goldberger's failure to provide me with the application as a bar to any objection, so I provided a letter with preliminary objections (Exhibit 91). I noted that: "Throughout the negotiation of the NPA, representations were repeatedly made by you and your colleagues that Mr. Epstein would serve his complete sentence, including community control, in Palm Beach County. During his change of plea and sentencing, Mr. Epstein told the Court that he intended to remain in Palm Beach County during his period of community control — a fact that was important to Judge Pucillo in making her decision whether or not to accept the plea agreement. Mr. Epstein's presence in Palm Beach County was important to the Court, our Office, and, presumably, the State Attorney's Office, because it allowed all of these entities to monitor Mr. Epstein's performance of his obligations. Relocating to the Virgin Islands, where Mr. Epstein lives on a private island without any independent law enforcement presence, would eliminate that ability" (id.). Following my letter, Mr. Epstein did not follow through on his application to transfer to the Virgin Islands. Page 37 of 58 EFTA00225519

10. Identify any cases in which you have been involved as an AUSA, or of which you were otherwise aware, that were resolved through a non-prosecution agreement. I have not been involved in, nor am I aware of, any other cases that have been resolved via a non-prosecution agreement. On one occasion, in my eighteen years with the Justice Department, I recommended a Pre-Trial Diversion agreement for a doctor who wrote and filled a small number of fraudulent opioid prescriptions that she took herself for her post-cancer pain. The recommendation was vetted and approved through the chain of command in accordance with Department policy (the USAM) and the USAO's Criminal Circular. B. CVRA Compliance 1. Describe your understanding of any USAO, Department, or FBI policy or practice regarding victim notification rights, obligations, or procedures that were in effect from the time the federal investigation of Mr. Epstein began to the time that he entered his state plea, including the applicability of the CVRA to cases resolved through non-prosecution agreements, and identify the source(s) of such understanding. Explain when and how you became aware of such policy or practice. Describe your prior experience notifying victims under the CVRA. Explain whether and how victim notifications in the Epstein case departed from the USAO's general practice. My understanding of USAO/DOJ victim notifications policies that were in effect in 2006- 2007 had come from my own work on PSC cases. I do not recall receiving any training from the USAO on the CVRA or the AG's Guidelines on Victims' Rights prior to the Epstein case. I was familiar with the CVRA, the Victims' Rights and Restitution Act, and other pieces r victims' rights legislation, primarily from two prior cases that I had handled. In United States O'Neil, I had litigated the Office's first case where a defendant objected to a victim impact statement. It was a case where a 41-year-old man gave a lethal overdose of heroin to his 23-year-old girlfriend. The victim's mother, other family members, and the owner of the rehab center where the defendant had recruited the victim all asked to address the Court. I cited the CVRA and other statutes to support the Court's authority to hear from them. The second case was United States' Oliver, which was the Office's first case seeking the appointment of a guardian ad litem (GAL). Through these cases, I researched statutes, cases, the USAM, and the AG Guidelines. I recall that the Guidelines were often described themselves as a floor, not a ceiling. See, e.g., Attorney General Guideline for Victim and Witness Assistance (May 2005) at 8 ("A strong presumption exists in favor of providing rather than withholding assistance and services to victims and witnesses of crime."). Like most PSC prosecutors and investigators, the agents and I treated the AG's Guidelines as a floor and tried to provide a higher standard of contact. That is why, during the Epstein investigation, victim rights notification letters were provided at the first meeting between the agents and victims encouraging victims to contact me directly with questions and concerns. Throughout the investigation, I tried to meet in person with as many victims as possible and talk through their concerns. Many were afraid of Mr. Epstein; many were afraid that their reputations would be ruined; almost all wanted to just put the episode(s) behind them. Some had not even told their parents about what had happened and did not want Page 38 of 58 EFTA00225520

their parents to know. Several girls needed counseling and at least one attempted suicide. S/As Kuyrkendall and Richards, Victim-Witness Specialist Smith, and I all worked to find counseling for those who wanted it through Palm Beach County Victim Services, and I reported the issues to Karen Atkinson, Andy Lourie (when he was still in West Palm Beach), and Jeff Sloman. I also recall sending and receiving emails regarding the emotional toll on the victims when agents and I enquired into the status of the indictment review. With regard to specific office procedures at the time of the Epstein investigation, there was no victim-witness coordinator in West Palm Beach and no standardized way to do any victim notifications prior to indictment. Our Office's procedure — which was still being developed at the time of the Epstein investigation — required a victim list to be submitted along with the indictment package. That victim list would be used to notify victims of upcoming court proceedings — to the extent that those upcoming court dates appeared in the case tracking system used at the time. Conferring with victims regarding plea negotiations could not happen through that victim notification system, so my practice, when possible, was to ask agents to work with me to contact victims about a potential plea. I also asked agents to work with me to notify victims of court dates because I knew there was a delay with the victim notification system. For example, often a defendant will decide the day before or the day of calendar call or trial to plead guilty. If it is a case with victims, like a bank robbery case, the agents and I will do our best to contact the victims to advise and confer, and to invite the victims to appear at the change of plea if they wish. The victims also are informed that they will have the opportunity to give a victim impact statement for purposes of sentencing. In child exploitations cases where there has been a lot of contact with the victims, these last-minute interactions are less likely. I usually discuss potential plea scenarios with the parents/victims/GALs in advance and the judges aren't as rushed. The exception is child pornography possession/distribution cases, where the victims often are not identified prior to the plea.32 Especially during the time of the Epstein investigation, the procedures for identifying victims in child pornography cases were in their infancy. Now, victims from many child pornography "series" have been identified and have attorney contact information for purposes of restitution. CEOS' Gelber is the national expert in this area. To summarize, my understanding of my obligation was: to do my best to notify victims of upcoming court proceedings and to make them feel welcome to — but not obligated to — participate (unless subpoenaed, of course); to guard their privacy and help them navigate the process to come out as unscathed as possible; to insure their safety from interference from the defendant; to listen to their desires in terms of prosecution, plea, and sentencing and balance that with the other factors that go into prosecutorial discretion33 in making decisions about the case; and to be mindful that decisions that I and the Office made would impact them. I understood that conferring with the victims did not mean that I had to agree with them or that they could override an Office decision. For example, in the Oliver case, we had a plea offer for a lengthy sentence. The victim's father believed that we should take the case to trial. The GAL and I did not believe that, given the age 32 These are cases where the defendant is not believed to be involved in the production of the child pornography. 33 Those other factors include the need to do justice, to deter the defendant and others, and to consider the impact of the prosecution on the local and national community. Page 39 of 58 EFTA00225521

of the defendant, it made sense to put the victim, who was, I believe, 9 years' old at the time, through the stress of a trial. After conferring with my supervisor, we decided to go forward with the change of plea. The victim's father and the GAL made victim-impact statements and, in the end, the judge imposed a sentence of 140 years' imprisonment followed by lifetime supervised release. With regard to the Epstein investigation in particular, the handling of victim notifications varied from my understanding and my practice in two significant ways. First, it never occurred to me that this was not a situation where conferring with the victims was required. I specifically informed the Office in writing on two occasions and orally on other occasions, that I thought the victims should be consulted before entering into the Non-Prosecution Agreement.34 The first of these written reminders was in July 2007 when I learned that Criminal Chief Menchel had engaged in plea discussions with Lilly Ann Sanchez. (Exhibit 3.) The second was in early September 2007 after my discussion with CEOS Chief Drew Oosterbaan regarding this subject. (Exhibit 44.) Later, I believe after the NPA was already signed, Jeff Sloman told me that the Office had taken the position in other cases that there is no obligation to confer in the absence of the filing of a federal case, but I don't recall discussing that at the time. 35 I had never before used a non-prosecution 34 As I noted in my filings in the Jane Doe' United States litigation, I had concerns about informing the victims that part of the negotiations involved securing for them the right to obtain damages from Epstein until we knew that Epstein would, in fact, enter into and perform his obligations under the NPA. As stated above, during the State investigation, Epstein's counsel had frequently accused the victims of faking or exaggerating their statements for purposes of civil damages claims. In a deposition for one of the civil suits, one of Epstein's lawyers later falsely accused Jeff Sloman and me of telling a victim that she could get damages from Epstein if she told the FBI that Epstein had assaulted her. (I can locate and redact this transcript.) I nevertheless believed that we could and should have discussed other aspects of the NPA with them — that is, the state guilty plea, sex offender registration, and the sentence. The AG Guidelines specifically take into account situations like this, so I could have discussed jail time, sex offender registration, avoiding trial, the right to address the court at sentencing, but, applying my discretion, decided not to tell them about the monetary portion of the agreement. See 2005 AG Guidelines at 30 ("In determining what is reasonable [in notifying identified victims about prospective plea negotiations] the responsible official should consider factors relevant to the wisdom and practicality of giving notice and considering views in the context of the particular case, including, but not limited to, . . . [w]hether the victim is a possible witness in the case and the effect that relating any information may have on the defendant's right to a fair trial."). 35 Regardless of that position, as noted earlier, the decision to resolve the case through a non-prosecution agreement was made by Chief Menchel, and his email of July 5, 2007 informed me that he was the person vested with the discretion to vary from any Department policy and that he had undertaken his actions with USA Acosta's knowledge. I relied upon their knowledge of the CVRA and exercise of discretion on this issue. (See Exhibit 3; see also 2005 AG Guidelines at 10-11 ("Pursuant to 42 U.S.C. § 10607(a), the Attorney General is request to designate persons in the Department of Justice who will be responsible for identifying the victims of crime and performing the services described in that section. These persons are referred to as 'responsible officials' in the statute and throughout these AG Guidelines. .. . Responsible officials may delegate their responsibilities under these AG Guidelines to subordinates in appropriate circumstances, but Page 40 of 58 EFTA00225522

agreement or deferred prosecution in favor of state prosecution in the way that the Epstein case was handled. I believed that the fairest course was to consult with the victims before the execution of any agreement. The second significant departure from my regular practice was the victim notification procedure. Never before or since have I shared "drafts" of victim notifications with counsel for the defendants. The CVRA places the entire burden of complying with the Act on the government and the court and provides that a "person accused of the crime may not obtain any form of relief under this Chapter." 18 U.S.C. § 3771(d)(1) (2004). But, in this case, I was required to provide draft victim notification letters, rewrite them due to objections from defense counsel, and refrain from sending them altogether. My protestations appear in my emails, and were shared with the agents, my legal assistant, and my supervisors. With regard to FBI policies and practices, I understood that the FBI had its own victim notification procedures. I had previously worked with Twiler Smith on other cases (and worked with her on other cases after the Epstein investigation). I did not know the details of what FBI included in its letters or when they were sent. I did not instruct FBI on what to send or when to send it. My general rule is to tell agencies to follow their regular procedures. I don't remember saying anything different in this case. I did not see any FBI letters in this case prior to collecting the FBI letters to Brad Edwards' clients in connection with the Jane Doe I United States litigation. I did not instruct the FBI to include the language about the case being under investigation and that they should be patient. 2. Identify all victims in this case to whom written or oral notifications were made, when and how each notification was made, and the contents of the notifications. Explain why notifications were made to some victims, and not to others, and who was responsible for those decisions. On the attached chart (Exhibit B-1), I listed all of the individuals identified as victims during the state investigation, the federal investigation, or after Epstein entered his state guilty plea, but who were brought to my attention by various attorneys. The chart lays out how and when each was contacted. Due to the passage of time, it is impossible for me to give exact dates and the exact content of each conversation. Also, there are some victims that I specifically remember meeting with. There are some that I know I did not meet with. There are others that I believe I met with, but I am not certain. I have qualified my answers on the chart accordingly. On August 4, 2006, I prepared 24 Victim Notification Letters for victims who had been identified during the state investigation. (Exhibit 12.) These were provided to Special Agent Kuyrkendall to hand-deliver to victims during interviews. I decided to prepare these letters and I decided on the content of those letters. On August 11, 2006, 18 amended letters were prepared. (Exhibit 13.) These letters clarified that the recipients were victims and/or witnesses, since we had not yet been able to confirm that they were minors during the time of their encounters with Epstein and we were still working to confirm federal jurisdiction. People who had already received the August 4, 2006 responsible officials remain obliged to ensure that all such delegated responsibilities are discharged. The Attorney General designates the following responsible officials: .. . For cases in which charges have been filed—the U.S. Attorney in whose district the prosecution is pending.")) Page 41 of 58 EFTA00225523

letters did not receive August 11, 2006 letters. If an August 11, 2006 letter was prepared, I believe that meant that the agents had not yet made contact with the person and the agents discarded the August 4, 2006 letter. We included letters for witnesses who we knew were over the age of 18 to advise them to contact us if they felt they were being harassed because the agents had learned of potential harassment during the early set of interviews. I decided to prepare these letters after discussing the issue with Special Agent Kuyrkendall and I decided on the content of those letters. Although I do not have a clear recollection of this, I believe that a new letter was issued for Individual #4 because the agents had difficulty interviewing her and did not want to provide her with a letter that was several months old. On June 7, 2007, I simply printed the same letter with a new date and signed it. (Exhibit 30.) I do not believe that the August 11, 2006 letter was ever provided to her. The same explanation applies for the June 7, 2007 letters for Individuals 9, 31, 38, and 43. (Exhibit 30.) Individuals 3 and 40 were not identified until several months into the federal investigation. Victim notification letters were prepared for them on June 7, 2007. (Exhibit 30.) I decided to prepare these letters after discussing the issue with Special Agent Kuyrkendall and I decided on the content of the letters. As discussed above, in July 2007 and September 2007, I raised in writing the need to confer with the victims regarding the proposed agreement with Epstein. I also raised the issue in internal conversations with supervisors, agents, and others. I was told that I could not discuss the matter with the victims. (See Exhibits 3 and 44.) After the Non-Prosecution Agreement was signed, I drafted a notification letter to inform the victims of the terms of the agreement and the date of the state court proceedings. After several delays, the state plea and sentencing date was set for December 9, 2007. On November 19, 2007, I prepared the draft notification that appears at Exhibit B-2 based upon my reading of the NPA and research I had conducted on state law. (See Exhibit B-7.) Several blanks appeared because we were still waiting for Epstein's counsel to confirm that Epstein would pay the fees of the attorney- representative selected by the Special Master. A second draft of the plea notification letter was prepared on November 27, 2007 at 7:11 p.m. for Jeff Sloman's review. (Exhibit B-3.96 On November 28, 2007 at 9:42 p.m. a third draft was prepared for Jeff Sloman's review. (Exhibit B-4). This version was shared with counsel for Epstein. (Exhibits B-8). On November 29, 2007, Jay Lefkowitz, counsel for Epstein, objected to the victim notification letter in a letter to USA Acosta. (Exhibit B-9). USA Acosta asked Mr. Lefkowitz to discuss the matter with Jeff Sloman and me. (Exhibit B-10). On December 5, 2007, Kenneth Starr and Jay Lefkowitz wrote a letter to USA Acosta requesting an updated victim notification letter incorporating their objections. (Exhibit B-11). On December 6, 2007, Jeff Sloman sent a letter to Jay Letkowitz, which attached another proposed victim notification letter. (Exhibit B-12). There was significant internal correspondence regarding my concerns that the Government needed to meet its obligation to inform the victims of the upcoming plea. (Exhibit B-13). After providing a final draft to the Miami office on December 7, 36 This document was converted from Word Perfect, which caused the formatting problems. Page 42 of 58 EFTA00225524

2007, (Exhibit B-63'), later that day, my legal assistant and I prepared 32 victim notification letters and envelopes to send. (Exhibit B-14). At 5:08 pm, I received an email from Jeff Sloman that said, "Hold the letter" (Exhibit B-54). On December 10 007, I contacted Jim Eisenberg, counsel for Individual # 28, who is Jane Doe #2 in the Jane Doe I United States suit. As noted on the attached chart, Mr. Eisenberg was paid for by Mr. Epstein. I told Mr. Eisenberg that I was preparing victim notification letters and needed to know if he was still representing Individual #28. He said that he was and instructed me to send the letter to him. My continued designation of Individual #28 as a victim, based upon the statements of other witnesses and the documentary evidence collected by federal and state agents, was one of the main bases that Epstein's counsel used to support their allegations of prosecutorial misconduct with officials at the Department of Justice. (See Exhibit B-20.) Based upon those attacks, which relied upon the videotaped statement given by Individual #28, I was instructed by either Jeff Sloman or Alex Acosta, not to consider Individual #28 as a victim for purposes of the NPA because she was not someone whom the Office was prepare to include in an indictment. On December 7, 2007, Lilly Ann Sanchez sent a letter to Jeff Sloman fmally providing the USAO with the date and time of the change of plea for Mr. Epstein. (Exhibit B-15). Based upon that information, on December 14, 2007, I prepared another version of the victim notification letter. (Exhibit B-I 638). I provided a copy via email to Alex Acosta, Jeff Sloman, Rolando Garcia, and Karen Atkinson. (Exhibit B-17). On December 17, 2007, I sent an email to Jeff Sloman inquiring about the status of the case and informing him that the agents also were expressing their concerns about the delays in victim notifications. (Exhibit B-18). Over my objection, my request to send the victim notification letter was not approved, and on December 19, 2007, USA Acosta sent a letter to Lilly Ann Sanchez stating, "I understand that the defense objects to the victims being given notice of [the] time and place of Mr. Epstein's state court sentencing hearing. I have reviewed the proposed victim notification letter and the statute. ... We will defer to the discretion of the State Attorney to determine if he wishes to provide victims with notice of the state proceedings, although we will provide him with the information necessary to do so if he wishes." (Exhibit B-19.) Although I did not know it at the time, in preparing this response, I noticed that, in FAUSA Sloman's June 3, 2008 letter to DAG Filip, he stated that the quoted language was proposed by USA Acosta "in consultation with DAAG Mandelker." (Exhibit B-123 at 7.) On December 21, 2007, attorney Jay Lefkowitz expounded on a new challenge — that Mr. Epstein had not been provided with a list of the victims and an opportunity to challenge the list prior to signing the NPA. I made clear verbally and in writing that I would not expose the victims to further harassment while Epstein was clearly trying to wheedle his way out of pleading guilty and going to prison. As I told Mr. Lefkowitz, I had devised a system to address this concern prior to the signing of the NPA; since Epstein's team of attorney's had not requested the right to see and challenge the list, I had not offered it. A few days later, Lefkowitz again wrote to the U.S. Attorney stating that he did not think our Office should provide any notifications; they should come only " This document was converted from Word Perfect, which caused the formatting problems. 38 This document was converted from Word Perfect, which caused the formatting problems. Page 43 of 58 EFTA00225525

from the State Attorney's Office. Lefkowitz insisted on the right to review the letters. (Exhibit B-22).39 The matter was tabled while Epstein was allowed time to raise his federal jurisdiction, sufficiency, and prosecutorial misconduct challenges with CEOS, the DAAG, and the AAG. While everything was supposed to be "on hold" pending those reviews, I learned that Epstein was trying to contact some of the victims — victims who would have been represented if Epstein had performed his obligations under the terms of the NPA. I then worked to find pro bono counsel for those victims (Exhibit B-23). On May 15, 2008, CEOS, DAAG Mandelker, and AAG Fisher completed their review, finding that our case against Epstein was neither improper nor inappropriate (Exhibit B-24). By that time, a revised indictment package had already been reviewed and approved (Exhibits B-25 through B-28). Additional victims also had been identified through the continued investigation (Exhibits B-29 through B-31). On May 19, 2008, FAUSA Sloman wrote to counsel for Epstein giving Epstein two weeks to enter his guilty plea in state court in accordance with the terms of the NPA (Exhibit B-32). Rather than performing, Epstein sought continued review, again alleging prosecutorial misconduct and challenging both the sufficiency of the evidence and the federal interest in the case. At this point, Epstein sought review from Deputy Attorney General Mark Filip (Exhibit B- 33), and he hired Joe Whitley to join his defense team. I was informed that Epstein's deadline to enter his guilty plea would be extended again, and we continued preparing for indictment (Exhibits B-34 through B-37). So, on May 27, 2008, Bob Senior, who took Matt Menchel's place as Criminal Chief, Jeff Sloman, who had taken over for USA Acosta due to his recusal from the Epstein matter, Karen Atkinson, and 1 all had an email exchange agreeing that there would be no further negotiations and that the case would be indicted (Exhibit B-38). At the same time, the agents heard that Epstein was trying to strike a new deal with the State Attorney's Office — one that would require less jail time (Exhibit B-39) (discussed below). While the DAG completed his review, I was told that the grand jury presentation would be delayed again (Exhibit B-40). I was then tasked with drafting the USAO's letter to DAG Filip in response to Epstein's challenges. While the case was being investigating and prepared for indictment, I did not prepare or send any victim notification letters — there simply was nothing to update. I did not receive any victim calls during this time. I did receive communications from two attorneys. In March 2008, I received a letter from attorney Richard Willits, advising me that he represented Individual #3 and that he had filed suit on her behalf against Epstein in Palm Beach County Circuit Court (Exhibit B-41). I responded, acknowledging his representation (Exhibit B-42). On June 18, 2008, I liv received a call from attorney Brad ards, who told me that he represented Individual #43, who is also Jane Doe #1 in the Jane Doe United States lawsuit. Mr. Edwards expressed an interest in assisting with the case. We were still waiting to hear about whether we would be moving " On the State side, Lefkowitz has consistently taken the position that there were only two victims related to the state offenses. Thus, if only the State provided notifications, only two victims would receive notices of the hearing and Epstein would avoid a full sentencing hearing. Page 44 of 58 EFTA00225526

forward to indictment. I invited him to send whatever information he could and expressed that time was of the essence (Exhibit B-43). Given the uncertainty of the situation — Epstein was still challenging our ability to prosecute him federally, pressing allegations of prosecutorial misconduct, and trying to negotiate better plea terms, while the agents, my supervisors, and I were all moving towards indictment — I did not feel comfortable sharing any information about the case. It also is my practice not to talk about status before the grand jury. For those reasons, and because I had never met Mr. Edwards, I listened more than I spoke. Early on June 23, 2008, FAUSA Sloman emailed Criminal Chief Senior saying that, if the USAO received the go-ahead from the DAG's Office, I should immediately notify Epstein's attorneys that Epstein would only have until June 3011' to comply with the September 246 agreement or be held in breach. Later that day, Mr. Senior responded, cc'ing me, instructing me to send out that notification (Exhibit B-49). On June 23, 2008, DAG Filip completed his review, and John Roth sent a letter to Attorneys Starr and Lefkowitz stating their finding that there was no abuse of discretion and no misconduct (Exhibit B-44). I immediately sent an email to Jay Lefkowitz in accordance with Mr. Senior's instructions (Ex. B-49). The following day, Roy Black and Jack Goldberger, as local counsel for Epstein, contacted me to wrap up the details of performing pursuant to the terms of the NPA (Exhibit B-45). On June 25 and 26, 2008, there were a series of internal communications regarding victim notification letters and providing Epstein with a final list of victims (Exhibits B-46, B-47, B-48). I provided my draft victim notification letter to FAUSA Sloman and USA Acosta (Exhibits B-47, B-48).4° Since Mr. Acosta had agreed in December 2007 that we would not provide written notice of the state change of plea, the written victim notifications were prepared to be sent immediately following Epstein's guilty plea. The FBI was working on finalizing the victim list to disclose to Epstein (Exhibit B-50). I requested permission to make oral notifications to the victims regarding the upcoming change of plea, but the Office decided that victim notifications could only come from a state investigator, and Jeff Sloman asked PBPD Chief Reiter to assist (Exhibit B-52). On Friday, June 27, 2008, we received notification that Epstein's change of plea and sentencing would occur the following Monday, June 30, 2008 (Exhibit B-51). I made two calls to try to spread the word about the state change of plea. Following up on FAUSA Sloman's call from the previous day, I called Chief Reiter and asked him to notify the victims (Exhibit B-53). I also called Brad Edwards as counsel for Individuals 35 and 43,41 and strongly encouraged him and his clients to attend. He said that someone would try to be there. I had not been authorized by the Office to disclose the terms of the NPA, so I could not be more explicit in my conversation with him (Exhibit B-54). After the change of plea on June 30, 2008, I made calls to the attorneys whom I knew represented identified victims in civil suits to confirm that they wanted me to send their clients' victim notification letters to the attorneys (Exhibit B-55). Also, as directed by my Office, I 40 Exhibits B-47 and 8-48 consist of emails with draft victim notification letters attached. Due to changes in word processing systems, some of the attachments, as well as other drafts, have formatting issues when they were printed. My original draft was prepared on 6/25/2008 at 3:57 pm. I revised it at 5:23 p.m. that same day. I received a revised version from USA Acosta and FAUSA Sloman at 6:00 p.m. on June 25111. 41 Mr. Edwards also was representing Individual #28 at the time, but I did not know that. Page 45 of 58 EFTA00225527

provided a draft of the proposed victim notification letter to counsel for Epstein (Exhibit B-56). I was concerned that Epstein and his counsel were again creating a potential problem. USA Acosta had taken the position that the final NPA consisted of three documents — the 9/24/2007 NPA, the 10/29/2007 Addendum, and the 12/19/07 letter from USA Acosta to Lilly Ann Sanchez. I prepared victim notifications (and, later, a Declaration in the Jane Doe litigation) based upon this understanding. When Epstein entered his guilty plea, Judge McSorley required him to file his federal Non-Prosecution Agreement with the Court since that formed part of the consideration for the state plea. I wanted to confirm that Epstein was taking a consistent position with the State Attorney's Office, Judge McSorley, and the USAO, so I asked for a copy of what was filed in the State Court. This led to multiple letters with counsel for Epstein before I could finalize the victim notification letters (Exhibits B-57 through B-65). On July 9, 2008, I finally sent the first two victim notification letters to two of Brad Edwards' clients, Individuals 35 and 43 (Exhibit B-66). Whenever I sent a victim notification letter, a redacted version of the letter also was sent to Jack Goldberger, counsel for Jeffrey Epstein. I was not authorized to send a victim notification letter to Individual # 28 or to include her on the list of persons provided to Epstein because she was not a person that the Office was prepared to name in an indictment.42 On July 10, 2008, I sent victim notification letters to a number of other represented victims, Individuals 3, 8, 17, 25, 26, 37, and 44 (Exhibit B-67). The FBI also asked for some assistance of language to use in its own victim notifications (Exhibit B-68), and I was waiting for contact information for the unrepresented victims (Exhibit B-69). On July 21, 2008, I sent victim notification letters to a group of unrepresented victims, Individuals 1, 2, 4, 9, 13, 14, 21, 23, 30, 32, and 38 (Exhibit B-70). There were some unrepresented victims who did not receive notification letters on July 21, 2008 because the FBI had not been able to confirm mailing addresses by that time — Individuals 10, 11, 16, 18, 20, 24, 31, 33, 36, 39, 40, and 42. In August 2008, the issue of "which version of the NPA controls" finally came to a head. On August 5, 2008, in the context of a Notice of Breach, I pressed my Office to clarify the issue (Exhibit B-71). The decision was made to require Epstein to elect either the 12/19/07 letter or not, but to make it clear in writing (Exhibits B-73 through B-82). On August 15, 2008, I wrote to Roy Black and Jay Lefkowitz confirming their position that the final agreement consisted only of the NPA and Addendum (Exhibit B-83). By discarding USA Acosta's December 2007 modification, the original terms providing for the attorney representative for the victims came back into effect, and the victim notification letters for the unrepresented victims were even more important. Mr. Lefkowitz responded on August 18, 2008 with "objections" in advance to the language of the victim notifications (Exhibit B-84). On August 21, 2008, I responded to Mr. Lefkowitz with a draft victim notification letter corresponding to the language contained in the NPA and Addendum and noted the importance of promptly providing corrected information to the victims (Exhibit B- 85). The following day, Mr. Lefkowitz sent a letter with indeterminate objections to the letter (Exhibit B-86). I responded by pointing out that the language in the victim notification letter was taken verbatim from the NPA and Addendum (Exhibit B-87). On September 2, 2008, Mr. Lefkowitz finally confirmed that Mr. Goldberger would be the designated recipient for victim notifications and that Mr. Epstein would pay the attorney representative's fees (Exhibit B-88). I immediately started distributing victim notification letters. 42 That decision was made by USA Acosta and/or FAUSA Sloman. I do not know which. Page 46 of 58 EFTA00225528

On that date, Notification Letters were sent directly to Individuals 1, 2, 4, 9, 10, 11,43 13, 14, 16, 20,44 21, 23, 24, 30, 31, 32,45 33, and 38, and via counsel to Individuals 3, 8, 17, 25, 26, 37, and 44 (Exhibit B-89). On September 3, 2008, Notification Letters were sent via counsel to Individuals 35 and 43, and via FBI Legal Attaches to Individuals 36 and 42 (Exhibit B-90). On September 12, 2008, I sent a Notification Letter to Individual 39 (Exhibit B-91). On September 15, 2008, I sent Notification Letters to Individuals 18 and 32 (Exhibit B-92). Soon thereafter, I received a letter from Jeffrey Herman, one of the civil attorneys who represented a number of victims, notifying me that he had complained to the Florida Bar that the Victim Notification Letters violated the Florida Bar rules against solicitation. He had filed complaints against myself and against Robert Josefsberg — the attorney-representative selected by the Special Master. On September 18, 2008, I wrote to the Florida Bar asking for an Ethics opinion (Exhibit B-93). I did not feel that I could send out any additional notifications until I received a response to that inquiry. The Florida Bar eventually issued a letter reviewing the relevant rules that (a) contacts with represented and unrepresented persons required by law are permitted and (b) business solicitation prohibitions are limited to those motivated by pecuniary gain. Thereafter, I issued notification letters to Individuals 20 and 40 on November 14, 2008 (Exhibit B-94). I only issued one other set of victim notifications: when I learned that Epstein had been allowed out on work release. While it technically was not required, I knew that the State Attorney's Office had not provided the notice, so I wanted to provide the victims with at least the option to take advantage of "exclusionary zones.i46 On December 4, 2008, I drafted a work release notice, which was approved by my office (Exhibit B-95). The following day, I sent work release notices to attorneys for Individuals 1, 2, 3, 8, 13, 14, 17, 20, 21, 25, 26, 28, 31, 32, 35, 35, 43, and 44 (Exhibit B-96). On December 8, 2008, I sent work release notices to attorneys for Individuals 7, 9, 17, and 37, and I sent notices directly to Individuals 11, 39, and 40 (Exhibit B-97). On December 9, 2008, I mailed work release notices directly to Individuals 4, 10, 16, 18, 23, 24, 30, 33, and 38 (Exhibit B-98). On December 11, 2008, I followed up with the attorneys about whether any of their clients wanted to take advantage of the "Exclusionary Zone" option in Epstein's GPS unit (Exhibit B-99). There was a bit of correspondence and telephone calls about this, but ultimately none of the victims elected to participate in this. On December 12, 2008, I send the work release notice to Individual #42 (Exhibit B-100). I am not aware of any other notices provided to victims in connection with this case. 43 The letter was returned on September 12, 2008, and Individual #11 was contacted by phone. She came to the office and picked up the letter in person on September 16, 2008. 44 The letter was returned on September 15, 2008. A new letter was sent on November 14, 2008 to a corrected address. 45 The letter was returned on September 11, 2008. A new letter was sent on September 15, 2008. At Individual #32's request, a copy was sent to her and with a copy to Jeffrey Herman, Esq. 46 "Exclusionary zones" can be programmed into a GPS tracking unit to send an alarm if a prisoner on work release enters into a prohibited area — e.g., a four-block radius of a victim's residence. Page 47 of 58 EFTA00225529

3. Identify all individuals within the USAO and FBI who had a role in determining whether, when, how, and to which victims to provide victim notifications in the Epstein case and explain what decisions were made and the basis for them. Greater detail is provided in the answer to Item B-2, above, and the exhibits referenced therein. Normally the line AUSA is the person who handles deciding who should receive victim notifications. Prior to indictment, the line AUSA has responsibility for those notifications, in conjunction with the case agents. Post-indictment, a victim list is provided to the victim-witness coordinator who is supposed to issue letters (again, I do not know how automated that was in 2006- 2008). In this matter, I made the decision to make contact with victims early and I decided on the content of the introductory letters as well as the recipients of those letters. At the time of plea negotiations, Criminal Chief Menchel made the decision that he had the authority to vary from the general policy of conferring with victims before entering into a plea. I do not know the basis for that decision (see Exhibit 3). His email to me said that the decision was made with USA Acosta's concurrence. I do not know the veracity of that statement. I know that, even after Chief Menchel left the USAO, as the plea negotiations continued, when I re-raised the issue of conferring with the victims after discussing it with CEOS Chief Drew Oosterbaan (see Exhibit 44), the Office still did not confer. I do not know the basis for this decision. Regarding providing notifications of the date of the change of plea, I drafted several iterations of a notification letter and also asked to provide oral notifications. USA Acosta decided that the USAO should not provide any notifications of a state court proceeding. From the correspondence that he drafted, the basis for doing so was that it was a state proceeding, not a federal one, so the notice should come from the State Attorney's Office. With regard to the FBI, my understanding is that Twiler Smith, the victim specialist, in conjunction with Nesbitt Kuyrkendall, the case agent, had primary responsibility for making victim notifications and the content of those. I do not know if anyone else within the FBI played any role in those decisions, and, with regard to their standard victim notification letters, I do not believe that anyone from the USAO played any role. I know that the FBI deferred to the USAO, and to USA Acosta's decision not to confer with the victims in advance of signing the NPA. I also know that the FBI also deferred to USA Acosta's decision not to inform the victims of the state court plea. 4. Identify any effort made by the government to notify the victims, either in writing or through other means, that it intended to enter into a non- prosecution agreement with Mr. Epstein, or had entered into such an agreement. For all such efforts, identify the victims notified, when, and by whom. If some or all of the victims were not notified about the non- prosecution agreement, explain why and identify the individuals responsible for the decision. Greater detail is provided in the answer to Item B-2, above, and the exhibits referenced therein. In short, while I requested permission to confer with the victims in advance of entering into the NPA, that permission was denied. So no one notified the victims that the government intended to enter into a non-prosecution agreement. Immediately after the government entered into the NPA, I prepared notification letters, but the U.S. Attorney decided that these letters also should not be sent out. The case agents made oral notifications to two identified victims in October Page 48 of 58 EFTA00225530

2007, but they became concerned that it appeared that Epstein was going to renege on the NPA. The agents suspected that, at trial, Epstein would allege that the agents had told the victims that they could get money from Epstein. So they decided to suspend the notifications until Epstein was indicted or his "challenges" to the NPA and the investigation were settled. 5. Explain why victims who received victim notification letters after the non- prosecution agreement was first signed in September 2007 were notified in the letters that the federal investigation of Jeffrey Epstein "is currently under investigation." Explain whether you, or other government personnel, considered whether the statement was accurate in light of the non-prosecution agreement; describe the process leading to the decision to so advise the victims; and describe any discussions among government personnel concerning the statement and its accuracy, occurring before or after it was made. The letters containing the quoted language were prepared by FBI victim-witness specialist Twit Smith and I was unaware of them until they were collected in connection with the Jane Doe United States litigation. I do not recall ever discussing the wording of the FBI's letters prior to their distribution. The decision to issue the letters and the wording of those letters were exclusively FBI decisions. Even though I was unaware of the language at the time, there is no doubt that from the perspective of the agents and myself the matter was, in fact, "currently under investigation." The NPA was signed on September 24, 2007. The letters that Judge Marra referred to in his order were dated January 10, 2008 and May 30, 2008. During the period that the letters were sent, Epstein was asserting that: (a) there was insufficient evidence to charge him with any offense; (b) there was no basis for federal prosecution and that federal prosecution violated the Petite policy; (c) I had engaged in prosecutorial misconduct during the investigation and resolution of the matter; (d) Jeff Sloman had engaged in prosecutorial misconduct during the investigation and resolution of the matter; (e) Special Agent Kuyrkendall had engaged in misconduct during the investigation of the matter; and (f) the NPA violated public policy because of its inclusion of the provision for § 2255 damages in lieu of mandatory restitution. Setting aside items (a) through (e), if the Department agreed with item (1) or if Epstein accepted USA Acosta's invitation to "unwind" the NPA and proceed to trial, we were faced with a target who had committed numerous identified crimes and had unlimited resources to flee the jurisdiction. The investigative team wanted to be prepared to arrest him as quickly as possible with the strongest criminal case at the ready. I also believed that either the U.S. Attorney or someone at DOJ would stop allowing Epstein to use the NPA as both a sword and a shield — attacking terms that Ken Starr had once thanked me for recommending while keeping the USAO from indicting Epstein. On December 12, 2007, Criminal Chief Senior and I finalized a revised indictment package to present to the grand jury (Exhibit B-101). On January 7, 2008, I sent an email to my entire advisory chain — up to the U.S. Attorney — laying out a series of steps in furtherance of the investigation (Exhibit B-102). Next, I secured the assignment of a CEOS attorney, Myesha Braden, as co-counsel, and she immediately traveled to West Palm Beach to participate in interviews to familiarize herself with the case and to re-connect with the victims to prepare them for potential trial testimony (Exhibits B-103, B-104). On January 14, 2008, Ms. Braden and I went over charging and investigative strategy, as well as her next trip to West Palm Beach (Exhibit B- 105). I also asked the agents to compile the evidence so that it would be more manageable for Page 49 of 58 EFTA00225531

Chief Senior's ongoing indictment review (Exhibit B-106). Ms. Braden, the agents, and I continued working on the best way to charge the case, and collecting evidence to corroborate witness statements (see Exhibit B-107). On January 31, 2008, another group of grand jury subpoenas was prepared and served (Exhibit B-108). On January 31 and February 1, 2008, Ms. Braden, the agents and I re-interviewed a series of victims (Exhibit B-109). As you can see from Exhibit B-109, it wasn't simply the agents and I who thought that the investigation was ongoing, the supervisory chain (up to and including the U.S. Attorney and the Chief of CEOS) was aware that: (1) victim and witness interviews were occurring; (2) grand jury subpoenas were being issued; and (3) an indictment package was being revised and reviewed. In February 2008, I was focused on working with the agents and Ms. Braden to finalize a revised indictment package and having it reviewed and signed by my supervisors (Exhibit B-110). On February 20, 2008, I sent an email to USA Acosta, FAUSA Sloman, CEOS Chief Oosterbaan, Criminal Chief Senior, and others in the supervisory chain letting them know that I had provided the final indictment package to my immediate supervisor the previous day (Exhibit B-I 11). I also informed Ms. Braden that I reserved time with the grand jury on March 11, 2008 and asked her to attend on that date (id). On February 25, 2008, I conferred with my immediate supervisor and with one of our Senior Litigation Counsel, who also was one of our Professional Responsibility Officers, about whether there was any reason to re-present the case to a different grand jury (Exhibit B-112). I provided the result of my inquiry to FAUSA Sloman, Criminal Chief Senior, the West Palm Beach supervisors, and Ms. Braden (Exhibit B-113). My supervisor completed her review the following day (see Exhibit B-114). Also on February 26, 2008, FAUSA Sloman informed me that he had told attorney Jay Lefkowitz that, if CEOS rejected Epstein's position, Epstein would be allowed "one week to abide by the terms and conditions of the September 24, 2007 Agreement" (Exhibit B-115). I wrote to FAUSA Sloman telling him that I could not understand why Epstein would be allowed to plead to the same terms in light of Epstein's false allegations and in light of the new evidence we had uncovered, including six confirmed additional victims and three potential new victims in New York (id.). I don't recall receiving any response. Despite that communication to Epstein's counsel, the Office continued towards indictment. On February 27 and 28, 2008, FAUSA Sloman, Criminal Chief Senior, Civil Rights Chief Weinstein, and I communicated about the USAM requirement that DOJ's Civil Rights Section be consulted when violations of 18 U.S.C. § 1591 are included in an indictment (Exhibit B-116). I continued reviewing records received in response to grand jury subpoenas and the agents continued working towards identifying additional witnesses and victims (Exhibit B-117). The following day, I advised the same gentlemen about identifying another New York witness/potential victim and her upcoming planned interview and inquired about the status of CEOS' review (Exhibit B-118). In March 2008, there were several developments in the investigation. The case agent and I decided to present search warrants for memory cards that the Palm Beach Police Department had collected. They had been reviewed by the PBPD near the time they were collected and no images of child pornography had been seen, but a forensic examiner had recently opined that forensic examination might result in the recovery of deleted images. I advised that a new forensic examination would require search warrants, so they were prepared and executed (Exhibits B-119, B-120). Page 50 of 58 EFTA00225532

On March 5, 2008, I updated the Office supervisory chain and CEOS Chief Oosterbaan on a number of case developments (Exhibit B-121). In that email, I noted that, if we were not going to proceed, we needed to be mindful of the state statute of limitations, to allow the PBPD to present charges to the Palm Beach State Attorney's Office (id). I also reported on the status of indictment review and my plan to start presenting to the grand jury on March 18, 2008, so that the grand jury would have sufficient time to hear all of the evidence and reflect on it before voting on an indictment (id.). On March 14, 2008, the head of the West Palm Beach office completed his review of the indictment package and it was forwarded to Criminal Chief Senior for final review and approval (Exhibits B-25, B-122). On March 18, 2008, I began my grand jury presentation (Exhibit B-26). The planned continued presentation to the grand jury was postponed while we awaited CEOS' review. I expressed my concerns about the impact on the ongoing investigation (Exhibit B-124). In mid-May, 2008, CEOS completed its review, finding that a federal prosecution of Epstein's conduct was factually and legally sound (Exhibit B-24). The agents and I immediately prepared to go back to the grand jury (Exhibit B-125). My supervisors also immediately prepared to review and finalize an indictment incorporating the results of the continued investigation (Exhibit B-38). The agents continued locating and interviewing more victims (see, e.g., Exhibit B-126). When DAG Filip agreed to consider Epstein's challenges, the planned grand jury presentation was canceled (Exhibit 8-40). Even after that delay, the agents and I pressed on. In June 2008, even as I was assisting with the USAO's submissions to DAG Filip (Exhibits B-123, B-127, and B-128), the agents and I were working on additional grand jury subpoenas and obtaining 6001 immunity for a witness (Exhibit B-129). On June 17, 2008, I applied for, and received permission to seek DOJ approval for 6001 immunity (Exhibit 8-130). On June 24, DAAG Mandelker's designee granted the application (Exhibit B-131). I also received permission to travel to New York with the agents to conduct additional witness interviews (B-132). Time with the grand jury was scheduled and the supervisory chain was informed of those plans as well as the status of the application for 6001 immunity (Exhibit B-133). I also was corresponding with counsel for the witness about her travel for the grand jury appearance, which was scheduled for July I, 2008 (Exhibit B-I 34). Even when the witness' attorney told me that Epstein would be pleading guilty on June 30, 2008, I would not release the witness (id). I formally withdrew the subpoena on June 30, 2008, following Jeffrey Epstein's entry of his guilty plea in state court (Exhibit B-135). These activities took us up to the time of Jeffrey Epstein's June 30, 2008 guilty plea. From September 2007 until the end of June 2008, the agents and I: collected additional evidence; reviewed that evidence; interviewed new victims and witnesses; re-interviewed previously identified victims and witnesses; identified new crimes and charges; developed new charging strategies; drafted supplemental pros memos; revised the indictment package; and presented new evidence and testimony to the grand jury. Although I did not know that Victim-Witness Specialist Smith's letters contained the language that the Epstein case was "currently under investigation," from my perspective, that language was absolutely true and, despite being fully advised of our ongoing investigative activities, no one in my supervisory chain ever told me that the case was not under investigation. Page 51 of 58 EFTA00225533

C. General 1. As to all of the foregoing matters, identify any disagreements or concerns expressed by government personnel as to these matters, the parties involved, how the disagreements were resolved, and any concerns you had about any such resolution and the individuals, if any, with whom you discussed your concerns. I raised a multitude of concerns during the investigation, negotiations, and enforcement periods. They ranged from the explicit — my July 2007 email exchange with Matt Menchel about his violations of the USAM, CVRA, and Ashcroft Memo (Exhibit 3) — to the subtle — repeated requests to just meet with the victims. Here is one especially poignant request from January 31, 2008: Hi Jeff and Alex - We just finished interviewing three of the girls. I wish you could have been there to see how much this has affected them. One girl broke down sobbing so that we had to stop the interview twice within a 20 minute span. She regained her composure enough to continue a short time, but she said that she was having nightmares about Epstein coming after her and she started to break down again, so we stopped the interview. The second girl, who has a baby girl of her own, told us that she was very upset about the 18 month deal she had read about in the paper. She said that 18 months was nothing and that she had heard that the girls could get restitution, but she would rather not get any money and have Epstein spend a significant time in jail. The FBI's victim-witness coordinator attended and she has arranged for counseling for several of the girls. Please reach out to Alice to make her decision. These girls deserve so much better than they have received so far, and I hate feeling that there is nothing I can do to help them. We have four more girls coming in tomorrow. Can I persuade you to attend? (Exhibit C-1.) Many of the disagreements have been catalogued above, but I will try to collect them into general categories in chronological order. a. I did not want to meet with counsel for Epstein (Lilly Ann Sanchez and Gerald Lefcourt) prior to completing my investigation. My co-counsel (John McMillan) agreed with me. Our supervisor, Andrew Lourie, overruled us. b. AUSA McMillan and I did not want to have a subsequent meeting with another set of attorneys for Epstein, including Lilly Ann Sanchez, Gerald Lefcourt, Alan Dershowitz, and Roy Black, that would also include Criminal Chief Matt Menchel. Over my objections, Mr. Menchel also instructed me to provide defense counsel with a list of the federal statutes that we had under consideration. Mr. Menchel asked me to provide all of my evidence to the defense and only withdrew that instruction when I reminded him that federal statutes Page 52 of 58 EFTA00225534

protected child victims' identities. I told my supervisor, Karen Atkinson, my concerns and that I thought I should ask to have the case reassigned, and she counseled against it (Exhibit C-4). c. Ms. Atkinson, the agents, and I all tried to impress upon the others that, due to the nature of the crimes under investigation, time was of the essence — Epstein was accused of committing sexual offenses against dozens of minor girls. Our expert witness, as well as our own experience, led us to believe that Epstein would not cease his criminal behavior voluntarily. We also knew that Epstein was continuing to travel extensively using his private airplanes, and that he would have the ability to flee to a jurisdiction that did not extradite if he knew that charges were coming. At one point in May 2007, after the indictment had been reviewed on several levels, we knew where Epstein would be and I asked to arrest him on a criminal complaint. Criminal Chief Menchel responded that he was "having trouble understanding — given how long this case has been pending — what the rush is." (Exhibit C-5). There was another instance a month or two later where we knew that Epstein was traveling to serve as a judge for a beauty contest and I again asked for permission to prepare a criminal complaint. Criminal Chief Menchel's denial of the request was even more emphatic. d. In July 2007, Mr. Menchel and I exchanged strong words when he reported that he had engaged in plea negotiations without the input or knowledge of the agents, victims, or myself (Exhibit 3). My objections included: i. The failure to meet and consult with the victims, agents, and me before deciding what plea offer to extend. ii. Offering a plea to a state offense. There was never any explanation of why a federal investigation would be resolved with a state plea, and I understood that a state plea would remove all control over the plea and sentencing procedure. iii. Starting the negotiations at only 24 months' imprisonment, which was unreasonably low and not in keeping with any of the federal crimes under investigation.07 iv. Sending the message to defense counsel that plea negotiations would be handled by the executive division rather than the line prosecutor and the West Palm Beach supervisory team. e. From the beginning of the federal investigation, the agents and I had pushed to get the computer equipment that Epstein had removed from his home prior to the execution of the state search warrant. When Epstein's counsel had stated that Epstein wanted to "cooperate" with the federal investigation, we asked that they turn it over voluntarily; they never did. We sought it via grand jury subpoena and they moved to quash the subpoena. Every time the matter was set for a hearing, Epstein's counsel would ask the Office to agree 47 Mr. Menchel's responsive email in July 2007, suggested that, in light of the statement by Ms. Sanchez that 24 months' imprisonment was a "non-starter," we would be able to re-set plea negotiations at a higher number, but that never happened. Page 53 of 58 EFTA00225535

g. to "continue" the hearing pending our "plea negotiations." I repeatedly recommended moving forward on the computer equipment because it was obvious that they did not want to turn it over and the equipment likely contained hard evidence of travel, contact with victims, obstruction of justice, and possibly child pornography offenses. Instead, the Office continuously agreed to put off the hearing and even when Epstein's attorneys tried to use the existence of the pending motion to quash as a basis to stay some of the victims' civil suits. f. Once I was informed that I had to devise a plea agreement with a sentencing cap of 24 months' imprisonment, I drafted a plea to a conspiracy to violate 18 U.S.C. § 2422, in violation of 18 U.S.C. § 371 — one of the crimes that had been the subject of the investigation and that was included in the indictment. That crime was a felony with a five- year statutory maximum, and the guidelines would have exceeded the five-year max, so the plea agreement would have had to be a binding plea pursuant to Fed. R. Crim. P. 11(c)(1)(C), which is what I drafted. I was informed by Mr. Lourie that USA Acosta did not want to do a (c)(1)(C) plea, so I had to find charges that would result in a two-year statutory maximum. This resulted in me having to research misdemeanors and find facts that would fit those misdemeanors. I thought it was totally inappropriate. Luckily, Andy Lourie finally stepped in and told Lefkowitz that we would not agree to a misdemeanor charge unrelated to the crimes that we had investigated. Throughout the drafting of the NPA, every time Jay Lefkowitz and I reached an impasse, he and/or Ken Starr would appeal to Andy Lourie, Jeff Sloman, or Alex Acosta, making it impossible to hold a firm line or keep a singular negotiating strategy. I tried to work from the Office's standard plea agreement language, but even after language was agreed to, it would be rewritten by Mr. Acosta. i. I strenuously objected to the reduction of the prison term from 24 months to 18 months. ii. I objected to the clear efforts at delay for no reason other than delay (for example, going back and forth from a federal plea to a state plea and back to a federal plea — all the while asking me to provide copious drafts). iii. At various points, it was apparent that Epstein was not engaging in good faith plea negotiations and I asked to terminate the negotiations and proceed to indictment. Every time, Mr. Acosta refused. For example, near the end of the negotiations, Mr. Lefkowitz tried to "slip in" a citation to a different state crime that did not require sex offender registration. When I brought this to Mr. Leflcowitz's attention, he admitted that, despite their explicit agreement that Mr. Epstein would plead guilty to a crime that required sex offender registration, they originally believed that the crimes listed in the NPA did not require registration. When they realized their error — and the Epstein would, indeed, have to register, they tried to replace the statute with a different one. This was the clearest example of bad faith amongst many, yet I was told that I had to continue working with Mr. Lefkowitz to finalize the agreement. USA Acosta told me that he did not want to punish Epstein for the bad behavior of his attorneys — even though Epstein clearly was directing every aspect of his defense. Page 54 of 58 EFTA00225536

J. iv. I told FAUSA Sloman and USA Acosta that I did not want to sign the NPA because I did not think that it was "my" agreement. USA Acosta asked me to sign it. h. After the NPA was signed, USA Acosta continued to concede points that had already been decided. For example, he agreed to the preparation of the Addendum. He then made a number of concessions regarding the letter to the Special Master, including a statement that we would not vouch for the veracity of the victims, despite the fact that these were victims that we intended to include in an indictment. These were all areas that were the subject of a signed, binding agreement. On October 5, 2007, and October 23, 2007, I against asked for permission to proceed to indictment (Exhibits C-6, C-7). i. After the Addendum was signed, USA Acosta wrote in the 12/19/2007 letter to Lilly Ann Sanchez that he had "considered defense counsel arguments regarding the Section 2255 portions of the Agreement. ... During the course of negotiations [our] intent was reduced to writing in Paragraphs 7 and 8, which as I wrote previously, appear far from simple to understand." (Exhibit B-19). I raised concerns about undermining an Agreement entered into by our Office and giving away one of the protections that had been negotiated for the victims — representation by an attorney selected by the Special Master. I raised concerns about delays in entering Epstein's guilty plea and sentencing. These were portrayed as "professional courtesies" but it quickly became obvious that the NPA was signed with no intention of actual performance — it was simply a way for Epstein to buy time to avoid indictment and intimidate victims. k. I raised objections to the multiple "appeals" to DC and the delays that those entailed. USA Acosta explained that "every defendant" has the right to appeal to DC and raise federalism concerns. I explained that the objections should have been raised prior to signing the NPA, not after, and, if they were legitimate "policy questions," Epstein should agree that he would not use the time to harass and intimidate victims. 1. As detailed above, after the NPA was signed, the agents and I repeatedly raised concerns about the Office's deference to the defense's objections to providing notification to the victims of the resolution of the investigation and the date and time of the Epstein's plea and sentencing. m. On February 26, 2008, I learned that, if CEOS conducted its review and concluded the federal prosecution of Epstein was appropriate, the Office was going to allow Epstein to plead guilty pursuant to the NPA with no additional terms or conditions, despite the fact that additional victims had been located during the ongoing investigation. I wrote to FAUSA Sloman and expressed my view that this was an unjust result (Exhibit B-115). I re-raised this objection every time the Office allowed Epstein another opportunity to maintain the benefits of the NPA even as he was attacking the NPA's legitimacy. n. On March 19, 2008, I informed the supervisory chain up to FAUSA Sloman of the toll that the delay was taking on the victims and the grand jury. In particular, one of the grand jurors had told another that he was concerned that we were going to "whitewash" the case and not charge it. Epstein was using the delay to harass the victims, and one of the victims tried to commit suicide. I wrote how the "FBI's victim-witness coordinator is doing her Page 55 of 58 EFTA00225537

best to get counseling for all of our needy victims, but I just can't stress enough how important it is for these girls to have a resolution in this case. The `please be patient' answer is really wearing thin, especially when Epstein's group is still on the attack while we are forced to wait on the sidelines. Your guidance is needed." (Exhibit C-2) I followed up on March 19 and 22, 2008 to let everyone know that Epstein was subpoenaing victims and was using particularly aggressive means of service — having the Sheriff's Office serve the subpoenas at the places of work, calling them into the Dean's Office at their colleges, etc. I explained that Epstein was issuing these subpoenas in the context of the state criminal case — even though these victims were not named victims in the state criminal case, and I asked FAUSA Sloman to try to have Epstein's attorneys stop this contact as it was inconsistent with Epstein's alleged interest in resolving the matter (Exhibit C-3). I do not believe that anyone contacted Epstein's attorneys about this. I worked to secure pro bono counsel for as many victims as possible so that Epstein would only be able to contact them through counsel (id.). My concerns about the victims' mental health were brought to the attention of management in emails and telephone calls throughout the entire period from 2006 through 2008 and probably into 2009. o. Even after Epstein enter his guilty plea and was sentenced, there were a number of material breaches. Every time I tried to enforce the agreement and enforce the Office's authority to proceed to indictment, the Office would accept Epstein's excuse that he received "bad advice" from his attorneys and then he would "cure" the breach. With regard to the work release, either Roy Black or Jay Lefkowitz informed me that USA Acosta had agreed, after the NPA was signed, that Epstein would be allowed to participate in work release like any other state prisoner — in direct contravention of discussions and communications that Karen Atkinson and I had with the defense. I was not allowed to invoke this as a breach. 2. Identify any occasion during which you were or felt pressured, intimidated, threatened, coerced, or in any other manner inappropriately influenced to take a position or action in the Epstein case with which you disagreed or which caused you concern, and the individuals, if any, with whom you discussed such concerns. Throughout this memo, I have listed a number of disagreements. In broad categories, I disagreed with: (1) meeting with defense counsel before the investigation was completed and disclosing to them our charging strategy; (2) members of the Executive Division engaging in plea and strategy discussions outside the presence of the prosecution team and encouraging defense counsel to avoid the prosecution team; (3) entering into pre-indictment plea negotiations; (4) agreeing to delay the litigation regarding Epstein's computer equipment while pursuing plea negotiations; (5) entering into an agreement deferring federal prosecution; (6) entering into any agreement that required a sentence of only 18 months' (or even 24 months') imprisonment; (7) agreeing to a length of a sentence and then trying to find a charge with a statutory max to match; (8) reaching an agreement without conferring with the victims, the agents, or even the prosecution team; (9) refusing to hear from/meet with the victims even after meeting repeatedly with Epstein's representatives; (10) during the drafting of the NPA, allowing Epstein's attorneys to complain directing to the First Assistant and U.S. Attorney when they were dissatisfied with answers from the line AUSA and West Palm Beach supervisors; (11) repeatedly overruling my efforts to hold Epstein to the original terms, including reducing the term of imprisonment from 24 months down to 18; (12) dismissing my repeated warnings that the attorneys were not negotiating in good faith Page 56 of 58 EFTA00225538

and were delaying for strategic reasons; (13) repeatedly ceding our discretion to the defense, for example, agreeing that they could review and comment on victim notification letters and decide whether or not we could provide notice; (14) even after the NPA was signed, continuing to water it down, with the Addendum, the 12/19/07 Acosta letter, and then later offering Epstein the option of not having to provide the attorney-representative for the victims; (15) refusing to allow the agents and Ito notify the victims about the terms of the NPA and about the change of plea; (16) allowing Epstein to continue to enjoy the benefits of the NPA even after he failed to promptly perform its terms and filed specious delays in order to try to negotiate better terms or win a battle of attrition; (17) refusing to defend me from the false allegations of prosecutorial misconduct; (18) refusing to step in and protect the victims from harassment from Epstein's attorneys when Epstein was "appealing" to DC; and (19) allowing Epstein to repeatedly breach the NPA and then claim that he just got bad advice from his lawyers and "cure" the breaches. At various times during the investigation, negotiations, etc., I spoke with a number of people about my disagreements with the Office, including my supervisor, Karen Atkinson, my co- counsel, John McMillan, Special Agents Kuyrkendall and Richards, AUSAs Lynn Kirkpatrick, Susan Roe, E.J. Yera, and DOJ Trial Attorneys Tammie Gregg and Myesha Braden. On several occasions, I drafted emails about re-assigning the case because the Office's handling of the matter was so contrary to my methods. I shared at least one of these with Ms. Atkinson (Exhibit C-4). She counseled against sending it. The agents asked me not to leave the case because they believed that, if I left, the case would simply disappear. I couldn't disagree with them. Criminal Chief Menchel's response to my email in July 2007 was, in my mind, inappropriate and meant to intimidate. It is, quite frankly, unheard of, for a Criminal Chief to engage in plea negotiations without the line AUSA's knowledge, much less blessing. And the offer that was made was inexplicable. To this day, I do not understand the NPA — 24 months/18 months — it is a completely random amount of time. Allowing a federal defendant to plead guilty to state charges also is completely unheard of. No one has ever explained to me where the idea originated from. For Mr. Menchel to suggest that my judgment was questionable or that I was unable to handle "major" cases was obviously meant to "put me in my place." In my July 13, 2007 response to Mr. Menchel, I wrote: With respect to your questions regarding my judgment, I will simply say that disagreements about strategy and raising concerns about the forgotten voices of the victims in this case should not be classified as a lapse in judgment. This Office should seek to foster spirited debate about the law and the use of prosecutorial discretion. I know of other instances where disagreements about the application of the law to different defendants and defense attorneys has resulted in a call for the resignation of the AUSA who dared to challenge the Executive Office's conclusions. I find that very disheartening. However, my first and only concern in this case (and my other child exploitation cases) 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. After my response to Mr. Menchel, I know that he spoke with Anne Ruth Schultz, who was Chief of Appeals at the time, about moving me to the Appellate Section. The results of the disagreements catalogued above were communicated to me (orally or via e-mail) as decisions of the Executive Division. They sometimes followed extensive debate. They Page 57 of 58 EFTA00225539

sometimes followed no debate. I was sometimes heard on the issue; other times I knew nothing about it until I received the directive. There were times that I learned of communications between defense counsel and the Executive Division where concessions were made only after the decision was made. Many of these decisions were incorrect, in my opinion, but I did not believe that they were illegal. As a line AUSA, I was duty bound to follow the directives of the U.S. Attorney, which I did. I do not know that following a direct order from the Executive Division would qualify as coercion — even if it follows very strong objections. I felt strongly that we should have conferred with the victims before entering into the NPA and that we should have informed them of the change of plea and sentencing. I felt strongly that Epstein's attorneys were given unprecedented access to members of the Executive Division, and that the victims were given no access -- I could not even talk with them about plea negotiations or notify them about the plea hearing. At one point, my assistant and I had letters and envelopes ready to be stuffed and put through the franking machine and we received notice from Miami that they could not go out. While I felt that conferring was the right thing to do, as noted above, the AG Guidelines vest discretion in the U.S. Attorney, so I could not say that USA Acosta's decision was illegal. I also believed that, because the resolution of the federal case rested on Epstein's state guilty plea, the federal victims were entitled to notice of the state hearing. But I could not say that USA Acosta's decision that the CVRA was limited to notice of federal proceedings was illegal. I think that pressure was brought in more subtle ways. For example, I believe that one of the reasons why USA Acosta did not take an aggressive stance against the prosecutorial misconduct claims against me was because he disliked my insistence on pushing the case forward. After the NPA was signed, USA Acosta recommended that I transfer to the Civil Division. I agreed to meet with them and talk about their work. Despite USA Acosta's recommendation, I decided not to follow his recommendation, and I stayed in the criminal division. Please advise if further information is needed. Sincerely, dal Marta rilliskrages. A. Marie Villafaila Page 58 of 58 EFTA00225540

BAKER,DONELSON 100 116111 STREET • BALTIMORE, MARYLAND 21202 • 410.685.1120. bakerdonelson.com JONATHAN BRAN Direct Dial: 410.862.1073 E-Mail [email protected] May 10, 2019 VIA EMAIL °N4" Laura Ingersoll Counsel, Office of Professional Responsibility U.S. Department of Justice 950 Pennsylvania Avenue, N.W. — Room 3266 Washington, D.C. 20530 Re: OPR Investigation Relating to Jeffrey Epstein Federal Criminal Investigation Dear Ms. Ingersoll: Attached please find the written response of Assistant United States Attorney A. Marie Villafafia to the letter of Jeffrey R. Ragsdale, dated April 2, 2019, regarding the criminal investigation of Jeffrey Epstein. AUSA Villafafia separately has sent you encrypted disks containing the exhibits referenced in her written response, and has emailed other exhibits that were not included on the disks. Mr. Ragsdale's letter also requested background information concerning AUSA Villafafia's professional background and experience. The remainder of this letter provides that information. A native of Minnesota, A. Marie Villafafia graduated from Cornell University and the University of California, Berkeley, School of Law. She was admitted to the California Bar in 1995, to the Minnesota Bar in 1997, and to the Florida Bar in 2005. She is currently an active member of the Florida Bar, and maintains inactive status in California and Minnesota. Ms. Villafafia began her legal career as a judicial law clerk to the Honorable David F. Levi, United States District Judge for the Eastern District of California, from 1993 to 1994. Ms. Villafafia then worked in private practice for seven years, including as a litigation associate at Morrison & Foerster in San Francisco and a trial associate with Dorsey & Whitney, LLP, in Minneapolis, Minnesota, and London, England. Ms. Villafafia remained in civil practice, specializing in intellectual property litigation until 2001, when she was hired by the United States Attorney's Office in Miami. While she enjoyed civil practice, Ms. Villafafia for many years had wanted to be an Assistant United States Attorney. Two early career mentors — Judge Levi and Portia Moore from Morrison & Foerster — had worked at U.S. Attorney's Offices and they, like many former 4822.5464-M66vI 2865555.000127 05/102019 ALABAMA • FLORIDA • GEORGiA • LOUISIANA • MARYLAND • M1SS!SSIPPI• SOUTH CAROLINA • TENNESSEE • TEXAS • VIRGINIA • WASHINGTON, D.C. EFTA00225541

Laura Ingersoll May 10, 2019 Page 2 of 7 AUSAs, described the job as the best of their careers. Ms. Villafafia also wanted to serve her community. She was in the first generation of her family to graduate from college. She is the only member of her family to get an advanced degree. Personal experiences left her deeply committed to wanting to create safer communities for victims of crime. After several years of waiting for an opening at the USAO in Minneapolis, when Ms. Villafafia's brother moved to the West Palm Beach area, she applied for a position at the U.S. Attorney's Office for the Southern District of Florida. On September 10, 2001, Ms. Villafafia began serving as an Assistant United States Attorney in the Southern District of Florida. She did a rotation through the Appellate Section and then joined the Major Crimes Section from late September 2001 until January 2004. While in that unit, she handled reactive cases and short-term investigations and cases, including narcotics, firearms, child exploitation offenses, immigration matters, credit card fraud, bank robbery, violent offenses, and supervised release violations. While serving in that unit, she was also selected as one of the Southern District of Florida's first Project Safe Neighborhood prosecutors. In January 2004, AUSA Villafafia transferred to the West Palm Beach Office. In 2006, the U.S. Department of Justice initiated Project Safe Childhood, and, in recognition of her expertise in child exploitation matters, AUSA Villafalia became the Southern District of Florida's first Project Safe Childhood coordinator. From 2004 through early 2009, AUSA Villafaha handled the bulk of the child exploitation cases in West Palm Beach, as well as other cases involving violent crime, gangs, narcotics, firearms, immigration, and white collar matters. In March 2009, AUSA Villafafia was selected as the first Chief of the Special Prosecutions North Section, which was a new section in the Fort Lauderdale Office that would work on Project Safe Childhood and Project Safe Neighborhood prosecutions. In late 2010, when a new U.S. Attorney was sworn in, AUSA Villafafia asked that she be transferred back to the West Palm Beach Office, because the daily commute to Fort Lauderdale was both taxing and time consuming and it was exacerbating a then undiscovered medical condition from which she was suffering. Since 2010, AUSA Villafafia has been assigned to the West Palm Beach Office and is now the liaison to the Greater Palm Beach County Health Care Fraud Task Force. Since returning to West Palm Beach, AUSA Villafafia's caseload has shifted more towards economic crimes, but she has worked on a wide array of cases including insurance fraud, varying types of health care fraud, human trafficking, drug diversion, and bank fraud. According to CourtLink, AUSA Villafafia was counsel of record in 445 criminal matters in the Southern District of Florida. This number does not include all of the 2255 petition and appeals AUSA Villafafia has handled, but does include search warrants and pen registers that she sought. Of these approximately 445 cases, a number of matters are noteworthy: 4822.5464.6166x1 2865555.000127 05/10,2019 EFTA00225542

Laura Ingersoll May 10, 2019 Page 3 of 7 As the Southern District of Florida's first Project Safe Childhood Coordinator, she personally handled dozens of child exploitation cases. It appears from a review of Westlaw and Courtlink research, that AUSA Villafafia was the first prosecutor in the Southern District of Florida to convince the court to recognize the rights of a victim's family to appear and speak to the Court about the proper sentence: • U.S.'. William Charles O'Neil, 04-Cr-80040 The victim's mother remains in touch with AUSA Villafafia to this day. From Westlaw and Courtlink research, it appears that AUSA Villafafia was the first prosecutor in the Southern District of Florida to advocate for the appointment of a guardian ad litem for minor victims in connection with a criminal prosecution. • U.S.'. Jimmy Oliver, 06-Cr-80023 • U.S.'. Marion Yarbrough, 07-Cr-80099 From Westlaw and Courtlink research, it appears that AUSA Villafafia was the first prosecutor in the Southern District of Florida to charge enticement of a minor based upon use of a cellular phone. U.S.'. McDaniel, 06-Cr-80058 From Westlaw and Courtlink research, it appears that AUSA Villafafia was the first prosecutor in the Southern District of Florida to charge a violation of the child pornography advertising statute. U.S.'. Frank Grasso, 05-Cr-80111 From Westlaw and Courtlink research, it appears that AUSA Villafafia was the first prosecutor in the Southern District of Florida to charge failure to register as a sex offender. AUSA Villafafia trained other prosecutors and agents on how to investigate and prosecute those cases. U.S.'. Alfonso Diaz Cardenas, 07-Cr-80108 AUSA Villafafia assisted in the drafting of Eleventh Circuit Pattern [Criminal] Jury Instructions related to child exploitation offenses, including clarifying that, in cases of actual contact with a child, there is no requirement of proving the defendant's knowledge of age. 4822-54644166v1 2865555-000127 05/10/2019 EFTA00225543

Laura Ingersoll May 10, 2019 Page 4 of 7 According to inquiries with DOJ's Health Care Fraud Section, Ms. Villafaila was the first prosecutor in the nation to charge sex trafficking in connection with a health care fraud case. U.S.'. 0 Kenneth Chatman, 17-Cr-80013 (subject of an American Greed episode, CNBC, Season 12, Episode 10 "Florida Rehab Gone " July 2, 2018) Chatman was the first of several cases to target fraud in connection with substance abuse treatment. To date, AUSA Villafafia has convicted 30 individuals, including six licensed medical or mental health professionals, for related offenses: II U.S. . Kenneth Chatman, et al., 17-Cr-80013 O U.S. . Barry Gregory, 17-Cr-80033 I fl U.S. . Richard Botero, et al., 17-Cr-80070 O U.S. . Tovah Lynn Jasperson, et al., 17-Cr-80194 U U.S.'. Jeffrey Williams, 17-Cr-80195 U U.S. . Albert Jones Saye, l7-Cr-80229 O U.S. . John Skeffington, et al., 18-Cr-80018 O U.S. . Anthony Jackson, 18-Cr-80040 U U.S. . Lanny Fried, 18-Cr-80100 O U.S.'. 13osco Vega, 18-Cr-80101 fl U.S.'. Mark Hollander, 18-Cr-80102 O U.S.'. Larry Weisberg, 18-Cr-80108 U U.S. I. Kenneth MI -Kolb, 18-Cr-80121 I O U.S. . Arman Abovyan, et al., 18-Cr-80122 fl U.S.'. Hamilton Wayne, et al., 18-Cr-80165 O U.S.'. Ethan Wayne, 18-Cr-80168 The Chatman case resulted in AUSA Villafafia being awarded the 2018 Council of the Inspectors General on Integrity and Efficiency Award and the 2017 National Healthcare Anti- Fraud Association Investigation of the Year Award. This series of investigations has been nominated for this year's FBI Director's Award and the Florida Insurance Fraud Education Committee's Award. At the request of DOJ's Office of Legislative Affairs, AUSA Villafafia has provided advice on Congress' recent legislation on fraud involving sober homes and treatment facilities. 4822-5464-6166%1 2865555-000127 05/10/2019 EFTA00225544

Laura Ingersoll May 10, 2019 Page 5 of 7 AUSA Villafafia's prosecution of a member of Guatemala's Kaibil military branch led to war crimes investigations and prosecutions of numerous high-ranking military and political figures in Guatemalan and international courts, and resulted in her receipt of the Justice Department's 2011 National Crime Victims' Rights Service Award. The case was the subject of an award-wining documentary entitled "Finding Oscar" and numerous television shows and podcasts. U.S.'. Gilberto Jordan, 10-Cr-80069 AUSA Villafafia prosecuted the leader and numerous members of the Krazy Locos street gang in Palm Beach County (an MS-13 affiliate) for two murders in connection with racketeering activity and numerous firearms, drug, and sex trafficking offenses. U.S.'. Jonathan a, et al., 09-Cr-80091 U.S.'. Ivan Santiago, 09-Cr-80135 U.S.'. Itzel Candela-Campos, 10-Cr-80042 AUSA Villafafia prosecuted 57 individuals, including 21 medical professionals, for charges related to staged accidents and chiropractic clinic fraud. According to information received from victim insurance companies, the prosecutions resulted in a 50% decrease in fraudulent auto insurance claims in Palm Beach County as well as changes to state legislation. AUSA Villafafia received the Attorney General's Award for Fraud Prevention and the [EOUSA] Director's Award for this series of cases. She also received Prosecutor of the Year awards from the Coalition Against Insurance Fraud and the Florida Insurance Fraud Education Committee for her work in these cases. • U.S.'. Vladimir Lopez, et al., 11-Cr-80106 • U.S.'. Ketty a, et al., 11-Cr-80211 • U.S.'. Obelio Rodriguez, et al., 12-Cr-80107 • U.S.'. Yuliet Tapanes, et al., 12-Cr-80108 • U.S.'. M Adams, 12-Cr-80112 • U.S.'. Iris Roca, 13-Cr-80109 • U.S.'. Olinda Rodriguez, 13-Cr-80110 AUSA Villafafia successfully handled the appeal in the matter of U.S.'. Damian Baston (14-14444 (11th Circuit)), arguing for full restitution for victims of sex trafficking and for the right of the United States to prosecute sex trafficking that occurred outside the United States but originated in the United States. 4822-5464.6166v1 2865555-000127 05/10/2019 EFTA00225545

Laura Ingersoll May 10, 2019 Page 6 of 7 From Westlaw and Courtlink research, it appears that AUSA Villafaha was the first prosecutor in the Southern District of Florida to charge violations of the federal money transmitting statute. • U.S. 1 Nolaco-Argueta, 02-Cr-20465 Significant Sentences: 130 years' imprisonment for Jimmy Oliver, who had molested numerous female family members over several decades. (06-Cr-80023) • Life plus 135 years for Jonathan , head of the Krazy Locos gang, for ordering two murders and an attempted murder in aid of racketeering and other offenses (09-Cr-80091) Life imprisonment plus 35 years for Manuel Medina for murder in aid of racketeering and other offenses (09-Cr-80091) 40 years' imprisonment for Marion Yarbrough, who had enticed a Florida girl to board a bus to Kentucky where he repeatedly abused her sexually (07-Cr-80099) 40 years' imprisonment for Mark Joseph Harvey, who was found in possession of over 1 million images of child pornography, organized in files by age and subject matter, and who had previously sexually abused family members (09-Cr-80023) • 30 years' imprisonment for Ivan Isidro Santiago, co-head of the Krazy Locos gang, for his role in two murders and an attempted murder in aid of racketeering and other offenses (09-Cr-80091 and 09-Cr-80135) 27.5 years for Kenneth Chatman, who had forced female patients of his substance abuse treatment program into prostitution (17-Cr-80013) • 25 years for Frank Grasso, who used social media to advertise for child pornography (05-Cr-80111) • 20 years for Jonathan Earl Clark on charges of enticement of a minor and child pornography (08-Cr-80067) • 20 years for Eric Runyan on charges of distribution of obscenity to a minor and enticement (12-Cr-80115) • 19 years for Alejandro Tomas for aiding and abetting murder in aid of racketeering (09-Cr-80091) • 15 years for Christopher -Chamberlain on a charge of aggravated assault in connection with the Krazy ocos case (09-Cr-80091) • 14 years for Lucas Phelps on charges of enticement of a minor and transmission of obscene material to a child. Phelps had previously been adjudicated delinquent on three counts of sexual battery. (05-Cr-80020) 4822-54644166A 2865555-000127 O5/102019 EFTA00225546

Laura Ingersoll May 10, 2019 Page 7 of 7 • 12 years for John Walsh on charges of distribution of child pornography (05-Cr- 80185) • 11 years for Silverio Macedonio-Gregorio for aiding and abetting murder in aid of racketeering and other offenses (09-Cr-80091) • 10 years for Thomas Bohannon on charges of enticement of a minor (05-Cr- 80023) • 10 years for Gilberto Jordan on charges of false statements on immigration application for failing to disclose his involvement in war crimes in Guatemala (10-Cr-80069) • 8 years for Christopher Prindle for possession of child pornography (04-Cr- 80156) If you have any questions about any of the above information and the information included AUSA Villafafia's attached letter, please contact me at your convenience. Very truly yours, BAKER, DONELSON, BEARMAN, CALDWELL & BERKOWITZ, PC /s/ Jonathan Biran JB/smr Enclosures/Attachment cc: AUSA A. Marie Villafafia 4822.5464-0166x1 2865555-000127 05/10/2019 EFTA00225547

U.S. Department of Justice United States Attorney Southern District of Florida 500 South Australian Ave., Suite 400 West Palm Beach, FL 33401 (561) 820-8711 Facsimile: (56!) 820-8777 July 10, 2008 NOTIFICATION OF IDENTIFIED VICTIM NOTICE: IN ACCORDANCE WITH TITLE 18, UNITED STATES CODE, SECTION 3509(d) AND FLORIDA LAW, THE ATTACHED DOCUMENT IS TO BE TREATED AS CONFIDENTIAL AND SHALL NOT BE DISCLOSED EXCEPT IN CONNECTION WITH A LEGAL PROCEEDING. EFTA00225548

THEODORE J. LEOPOLD, ESQ. NOTIFICATION OF IDENTIFIED VICTIM Jutx 10, 2008 PAGE 2 OF 2 had been tried federally and convicted of an enumerated offense. For purposes of implementing this paragraph, the United States shall provide Mr. Epstein's attorneys with a list of individuals whom it was prepared to name in an Indictment as victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this provision, including any authority determining which evidentiary burdens if any a plaintiff must meet, shall consider thatit is the intent of the parties to place these identified victims in the same position as they would have been had Mr. Epstein been convicted at trial. No more; no less." St ough this letter, this Office hereby provides Notice that your client, is an individual whom the United States was prepared to name as a victim o. an enumerated offense. Should your client decide to file a claim against Jeffrey Epstein, his attorney, Jack Goldberger, asks that you contact him at Atterbury Goldberger and Weiss, 250 Australian Avenue South, Suite 1400, West Palm Beach, FL 33401. Please understand that neither the U.S. Attorney's Office nor the Federal Bureau of Investigation can take part in or otherwise assist in civil litigation; however, if you do file a claim under 18 U.S.C. § 2255 and Mr. Epstein denies that your client is a victim of an enumerated offense, please provide written documentation of that denial to the undersigned. Please thank your client for all of her assistance during the course of this investigation and express the heartfelt regards of m self and Special Agents Kuyrkendall and Richards for the health and well-being of Ms. R. ALEXANDER ACOSTA UNITED STATES ATTORNEY By: cc: Jack Goldberger, Esq. ...•••••••• . MARIE VELLAFARA ASSISTANT U.S. ATTORNEY EFTA00225549

U.S. Department of Justice United States Attorney Southern District of Florida 500 South Australian Ave., Suite 400 West Palm Beach, FL 33401 (561)8204711 Facsimile: (56!) 8204777 July 10, 2008 VIA FACSIMILE AND U.S. MAIL Theodore J. Leopold, Esq. Ricci—Leopold, P.A. 2925 PGA Boulevard, Suite 200 Palm Beach Gardens, FL 33410 Re: Jeffrey Epstein/Saige Gonzalez: NOTIFICATION OF IDENTIFIED VICTIM. Dear Mr. Leopold: • By virtue of this letter, the United States Attorney's Office for the Southern District of Florida asks that you provide the following notice to your client, On June 30, 2008, Jeffrey Epstein (hereinafter referred to as "Epstein) entered a plea of guilty to violations of Florida Statutes Sections 796.07 (felony solicitation of prostitution) and 796.03 (procurement of minors to engage in prostitution), in the 15th Judicial Circuit in and for Palm Beach CoUnty (Case Nos. 2006-d-009454/OOOOAB and 2008-cf- 009381AXXXMB) and was sentenced to a term of twelve months' imprisonment to be followed by an additional six months' imprisonment, followed by twelve months of Community Control 1, with conditions of community confinement imposed by the Court. In light of the entry of the guilty plea and sentence, the United States has agreed to defer federal prosecution in favor of this state plea and sentence, subject to certain conditions. One such condition to which Epstein has agreed is the following: "Any person, who while a minor, was a victim of a violation of an offense enumerated in Title 18, United States Code, Section 2255, will have the same rights to proceed under Section 2255 as she would have had, if Mr. Epstein EFTA00225550

U.S. Department of Justice FILE COPY i United States Attorney Southern District of Florida .14.•411 Mr. 500 South Australian Ave., Suite 400 West Palm Beach, FL 33401 (561) 820-8711 Facsimile: (561) 820-8777 July 10, 2008 NOTIFICATION OF IDENTIFIED VICTIM NOTICE: IN ACCORDANCE WITH TITLE 18, UNITED STATES CODE, SECTION 3509(d) AND FLORIDA LAW, THE ATTACHED DOCUMENT IS TO BE TREATED AS CONFIDENTIAL AND SHALL NOT BE DISCLOSED EXCEPT IN CONNECTION WITH A LEGAL PROCEEDING. EFTA00225551

JEFFREY HERMAN, ESQ. NOTIFICATION OF IDENTIFIED VICTIM ANGELIQUE GARCIA (NEE CAVALLARO) JULY 10, 2008 PAGE 2 OF 2 rights to proceed under Section 2255 as she would have had, if Mr. Epstein had been tried federally and convicted of an enumerated offense. For purposes of implementing this paragraph, the United States shall provide Mr. Epstein's attorneys with a list of individuals whom it was prepared to name in an Indictment as victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this provision, including any authority determining which evidentiary burdens if any a plaintiff must meet, shall consider that it is the intent of the parties to place these identified victims in the same position as they would have been had Mr. Epstein been convicted at trial. No more; no less." Through this letter, this Office hereby provides Notice that your client, ), is an individual whom the United States was prepared to name as a victim of an enumerated offense. Should your client decide to file a claim against Jeffrey Epstein, his attorney, Jack Goldberger, asks that you contact him at Atterbury Goldberger and Weiss, 250 Australian Avenue South, Suite 1400, West Palm Beach, FL 33401. Please understand that neither the U.S. Attorney's Office nor the Federal Bureau of Investigation can take part in or otherwise assist in civil litigation; however, if you do file a claim under 18 U.S.C. § 2255 and Mr. Epstein denies that your client is a victim of an enumerated offense, please provide written documentation of that denial to the undersigned. Please thank your client for all of her assistance during the course of this investigation and express the heartfelt regards of myself and Special Agents Kuyrkendall and Richards for the health and well-being of Ms. Garcia. R. ALEXANDER ACOSTA UNITED STATES ATTORNEY By: C/ "Z. A. MARIE VILLAFANA ASSISTANT U.S. ATTORNEY cc: Jack Goldberger, Esq. EFTA00225552

U.S. Department of Justice United States Attorney Southern District of Florida 500 South Australian Ave.. Suite 400 West Palm Beach, FL 33401 (561)820-8711 Facsimile: (561) 820-8777 July 10, 2008 VIA FACSIMILE AND U.S. MAIL Jeffrey Herman, Esq. Herman & Mermelstein, P.A. 18205 Biscayne Boulevard Suite 2218 Miami, Florida 33160 Re: Jeffrey Epstein/Angelique Garcia (née Cavatiara): NOTIFICATION OF IDENTIFIED VICTIM Dear Mr. Herman: By virtue of this letter, the United States Attorney's Office for the Southern District of Florida asks that you provide the following notice to your client, Garcia. On June 30, 2008, Jeffrey Epstein (hereinafter referred to as "Epstein) entered a plea of guilty to violations of Florida Statutes Sections 796.07 (felony solicitation of prostitution) and 796.03 (procurement of minors to engage in prostitution), in the 15th Judicial Circuit in and for Palm Beach County (Case Nos. 2006-cf-009454AXXXMB and 2008-cf- 009381AXX3CMB) and was sentenced to a term of twelve months' imprisonment to be followed by an additional six months' imprisonment, followed by twelve months of Community Control 1, with conditions of community confinement imposed by the Court. In light of the entry of the guilty plea and sentence, the United States has agreed to defer federal prosecution in favor of this state plea and sentence, subject to certain conditions. One such condition to which Epstein has agreed is the following: "Any person, who while a minor, was a victim of a violation of an offense enumerated in Title 18, United States Code, Section 2255, will have the same EFTA00225553

U.S. Department of Justice United States Attorney Southern District of Florida 500 South Australian Ave., Suite 400 West Bohn Beach, FL 33401 (561)820-8711 Facsimile: (561) 820-8777 July 10, 2008 NOTIFICATION OF IDENTIFIED VICTIM NOTICE: IN ACCORDANCE WITH TITLE 18, UNITED STATES CODE, SECTION 3509(d) AND FLORIDA LAW, THE ATTACHED DOCUMENT IS TO BE TREATED AS CONFIDENTIAL AND SHALL NOT BE DISCLOSED EXCEPT IN CONNECTION WITH A LEGAL PROCEEDING. EFTA00225554

RICHARD WILLITS, ESQ. NCYFIFICATION OF IDENTIFIED VICTIM ANDRIANO JULY 10, 2008 PAGE 2 OF 2 of implementing this paragraph, the United States shall provide Mr. Epstein's attorneys with a list of individuals whom it was prepared to name in an Indictment as victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this provision, including any authority determining which evidentiary burdens if any a plaintiff must meet, shall consider that it is the intent of the parties to place these identified victims in the same position as they would have been had Mr. Epstein been convicted at trial. No more; no less." Through this letter, this Office hereby provides Notice that your client, is an individual whom the United States was prepared to name as a victim of an enumerated offense. Should your client decide to file a claim against Jeffrey Epstein, his attorney, Jack Goldberger, asks that you contact him at Atterbury Goldberger and Weiss, 250 Australian Avenue South, Suite 1400, West Palm Beach, FL 33401. Please understand that neither the U.S. Attorney's Office nor the Federal Bureau of Investigation can take part in or otherwise assist in civil litigation; however, if you do file a claim under 18 U.S.C. § 2255 and Mr. Epstein denies that your client is a victim of an enumerated offense, please provide written documentation of that denial to the undersigned. Please thank your client for all of her assistance during the course of this investigation and express the heartfelt regards of m self and Special Agents Kuyrkendall and Richards for the health and well-being of Ms. R. ALEXANDER ACOSTA UNITED STATES ATTORNEY By: A. MARIE V1LLAFAN- A ASSISTANT U.S. ATTORNEY cc: Jack Goldberger, Esq. EFTA00225555

U.S. Department of Justice United States Attorney' Southern District of Florida .500 South Australian Ave., Suite 400 West Palm Beach, FL 33401 (561)820-8711 Facsimile: (561) 820-8777 July 10, 2008 VIA FACSIMILE AND U.S. MAIL Richard H. Willits, P.A. 2290 10th Avenue North, Suite 404 Lake Worth, FL 33461 Re: Jeffrey Epstein/Carolyn NOTIFICATION OF IDENTIFIED VICTIM Dear Mr. Willits: By virtue of this letter, the United States Attorney's Office for the Southern District of Florida asks that you provide the following notice to your client, On June 30, 2008, Jeffrey Epstein (hereinafter referred to as "Epstein) entered a plea of guilty to violations of Florida Statutes Sections 796.07 (felony solicitation of prostitution) and 796.03 (procurement of minors to engage in prostitution), in the 15th Judicial Circuit in and for Palm Beach County (Case Nos. 2006-cf-009454/OOaMB and 2008-cf- 009381AXXXMB) and was sentenced to a term of twelve months' imprisonment to be followed by an additional six months' imprisonment, followed by twelve months of Community Control 1, with conditions of community confinement imposed by the Court. In light of the entry of the guilty plea and sentence, the United States has agreed to defer federal prosecution in favor of this state plea and sentence, subject to certain conditions. One such condition to which Epstein has agreed is the following: "Any person, who while a minor, was a victim of a violation of an offense enumerated in Title 18, United States Code, Section 2255, will have the same rights to proceed under Section 2255 as she would have had, if Mr. Epstein had been tried federally and convicted of an enumerated offense. For purposes EFTA00225556

U.S. Department of Justice United States Attorney Southern District of Florida • 500 South Australian Ave., Suite 400 West Palm Beach, FL 33401 (561) 820-8711 Facsimile: (561) 820-8777 Jply.10, 2008 NOTIFICATION OF IDENTIFIED VICTIM NOTICE: IN ACCORDANCE WITH TITLE 18, UNITED STATES CODE, SECTION 3509(d) AND FLORIDA LAW, THE ATTACHED DOCUMENT IS TO BE TREATED AS CONFIDENTIAL AND SHALL NOT BE DISCLOSED EXCEPT IN CONNECTION WITH A LEGAL PROCEEDING. EXHIBIT B-67 EFTA00225557

BRAD EDWARD$, ESQ. NOTIFICATION OF IDENTIFIED VICTIM JULY 9, 2008 PAGE 2 OF 2 had been tried federally and convicted of an enumerated offense. For purposes of implementing this paragraph, the United States shall provide Mr. Epstein's attorneys with a list of individuals whom it was prepared to name in an Indictment as victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this provision, including any authority determining which evidentiary burdens if any a plaintiff must meet, shall consider that it is the intent of the parties to place these identified victims in the same position as they would have been had Mr. Epstein been convicted at trial. No more; no less." • Through this letter, this Office hereby provides Notice that your client, is an individual whom the United States was prepared to name as a victim of an enumerated offense. Should your client decide to file a claim against Jeffrey Epstein, his attorney, Jack Goldberger, asks that you contact him at Atterbury Goldberger and Weiss, 250 Australian Avenue South, Suite 1400, West Palm Beach, FL 33401, (561) 659-8300. Please understand that neither the U.S. Attorney's Office nor the Federal Bureau of Investigation can take part in or otherwise assist in civil litigation; however, if you do file a claim under 18 U.S.C. § 2255 and Mr. Epstein denies that your client is a victim of an enumerated offense, please provide notice of that denial to the undersigned. Please thank your client for all of her assistance during the course of this examination and express the heartfelt regards ofAlself and Special Agents Kuyrkendall and Richards for the health and well-being of Ms. M. R. ALEXANDER ACOSTA UNITED STATES ATTORNEY By: A. MARIE VILLAFARA ASSISTANT U.S. ATTORNEY cc: Jack Goldberger, Esq. EFTA00225558

U.S. Department of Justice United States Attorney Southern District of Florida 500 South Australian Ave., Suite 400 West Palm Beach, FL 33401 (561) 820-8711 Facsimile: (561) 820-8777 July 9, 2008 . VIA FACSIMILE Brad Edwards, Esq. The Law Offices of Brad Edwards & Associates, LLC 2028 Harrison Street, Suite 202 Hollywood, Florida 33020. Re: Jeffrey Epstein/Courtney NOTIFICATION OF IDENTIFIED VICTIM Dear Mr. Edwards: By virtue of this letter, the United States Attorney's Office for the Southern District of Florida asks that you provide the following notice to your client, On June 30, 2008, Jeffrey Epstein (hereinafter referred to as "Epstein) entered a plea of guilty to violations of Florida Statutes Sections 796.07 (felony solicitation of prostitution) and 796.03 (procurement of minors to engage in prostitution), in the 15th Judicial Circuit in and for Palm Beach County (Case Nos. 2006-cf-009454A=MB and 2008-cf- 009381AXXXMB) and was sentenced to a term of twelve months' imprisonment to be followed by an additional six months' imprisonment, followed by twelve months of Community Control 1, with conditions of community confinement imposed by the Court. In light of the entry of the guilty plea and sentence, the United States has agreed to defer federal prosecution in favor of this state plea and sentence, subject to certain conditions. One such condition to which Epstein has agreed is the following: "Any person, who while a minor, was a victim of a violation of an offense enumerated in Title 18, United States Code, Section 2255, will have the same rights to proceed under Section 2255 as she would have had, if Mr. Epstein EFTA00225559

U.S. Department of Justice FILE COPY United States Attorney Southern District of Florida 500 South Australian Ave., Suite 400 West Palm Beach, FL 33401 (561) 820-8711 Facsimile: (561) 820-8777 July 9, 2008 NOTIFICATION OF IDENTIFIED VICTIM NOTICE: IN ACCORDANCE WITH TITLE 18, UNITED STATES CODE, SECTION 3509(d) AND FLORIDA LAW, THE ATTACHED DOCUMENT IS TO BE TREATED AS CONFIDENTIAL AND SHALL NOT BE DISCLOSED EXCEPT IN CONNECTION WITH A LEGAL PROCEEDING. EFTA00225560

BRAD EDWARDS, ESQ. NOTIFICATION OF IDENTIFIED VICTIM a RIVERA JULY 9, 2008 PAGE 2 OF 2 had been tried federally and convicted of an enumerated offense. For purposes of implementing this paragraph, the United States shall provide Mr. Epstein's attorneys with a list of individuals whom it was prepared to name in an Indictment as victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this provision, including any authority determining which evidentiary burdens if any a plaintiff must meet, shall consider that it is the intent of the parties to place these identified victims in the same position as they would have been had Mr. Epstein been convicted at trial. No more; no less." Through this letter, this Office hereby provides Notice that your client, M , is an individual whom the United States was prepared to name as a victim of an enumerated offense. Should your client decide to file a claim against Jeffrey Epstein, his attorney, Jack Goldberger, asks that you contact him at Atterbury Goldberger and Weiss, 250 Australian Avenue South, Suite 1400, West Palm Beach, FL 33401, (561) 659-8300. Please understand that neither the U.S. Attorney's Office nor the Federal Bureau of Investigation can take part in or otherwise assist in civil litigation; however, if you do file a claim under 18 U.S.C. § 2255 and Mr. Epstein denies that your client is a victim of an enumerated offense, please provide notice of that denial to the undersigned. Please thank your client for all of her assistance during the course of this examination and express the heartfelt regards of m self and Special Agents Kuyrkendall and Richards for the health and well-being of Ms. R. ALEXANDER ACOSTA UNITED STATES ATTORNEY By: cc: Jack Goldberger, Esq. A. MARIE VILLAFARA ASSISTANT U.S. ATTORNEY EFTA00225561

U.S. Department of Justice United States Attorney Southern District of Florida 500 South Australian Ave., Suite 400 West Palm Beach, FL 33401 (561)820-8711 Facsimile: (561)820-8777 July 9, 2008 VIA FACSIMILE Brad Edwards, Esq. The Law Offices of Brad Edwards & Associates, LLC 2028 Harrison Street, Suite 202 Hollywood, Florida 33020. Re: Jeffrey EpsteinMIM NOTIFICATION OF IDENTIFIED VICTIM Dear Mr. Edwards: By virtue of this letter, the United States Attorney's Office for the Southern District of Florida asks that you provide the following notice to your client, On June 30, 2008, Jeffrey Epstein (hereinafter referred to as "Epstein) entered a plea of guilty to violations of Florida Statutes Sections 796.07 (felony solicitation ofprostitution) and 796.03 (procurement of minors to engage in prostitution), in the 15th Judicial Circuit in and for Palm Beach County (Case Nos. 2006-ef-009454AXXXMB and 2008-cf- 00938 1 AXXXMB) and was sentenced to a term of twelve months' imprisonment to be followed by an additional six months' imprisonment, followed by twelve months of Community Control 1, with conditions of community confinement imposed by the Court. In light of the entry of the guilty plea and sentence, the United States has agreed to defer federal prosecution in favor of this state plea and sentence, subject to certain conditions. One such condition to whichEpstein has agreed is the following: "Any person, who while a minor, was a victim of a violation of an offense enumerated in Title 18, United States Code, Section 2255, will have the same rights to proceed under Section 2255 as she would have had, if Mr. Epstein EFTA00225562

U.S. Department of Justice United States Attorney Southern District of Florida 500 South Australian Ave., Suite 400 West Palm Beach, FL 33401 (561) 820-8711 Facsimile: (561) 820-8777 July 9, 2008 NOTIFICATION OF IDENTIFIED VICTIM NOTICE: IN ACCORDANCE WITH TITLE 18, UNITED STATES CODE, SECTION 3509(d) AND FLORIDA LAW, THE ATTACHED DOCUMENT IS TO BE TREATED AS CONFIDENTIAL AND SHALL NOT BE DISCLOSED EXCEPT IN CONNECTION WITH A LEGAL PROCEEDING. EXHIBIT B-66 EFTA00225563