vinovCase 9:08-cv-80736-Kfichillatiksunetltrc2445010enteteticOirefal_Sevemketa01300N2014 Page 13 of we get some new eyes on the case and the circumstance are different, things will change." In this Section Palm Beach County Sheriffs Office otters salute lo 16 fallen in the line of duly over the decades Free movie al Boynton's Dewey Park on Friday Boynton Beach officers stop to investigate Camaro. witness theft of BMW: pursuit ends In crash Greenacres single-family home development moving forward Our Economy. Gardens complex lands 3 sizeable businesses Morning commute on 195, turnpike clear of crashes from Boca to Vero Find out how to work on the Riviera Beach marina development Royal Palm Beach Publix sells Fantasy S ticket now worth more than 5111K Sun. rain today and mostly rain Saturday in Palm Beach County. TCoast 3 NYPD officers arrested in separate gun incidents PREVIOUS: LOCAL Teti uesta crash sends seven people to hospitals Popular on MyPalmBeachPost.com All Comments (o) COMMENTS Post comment NEXT: OPINION Commentary: !las GM pulled a Pinto? Post a Comment hIlp/Ay.wornweln-beachposlorYnens/newstappellale•rullna-could-lore&lecIS1O-rfteRsHW-Seinfflimlicidspbp_internaltink mnpimilationbox feb2014 99cda 3/6 EFTA00191364

PRIVILEGE LOG Bates Range Description Privilege(s) Asserted Box #1 P-000001 thru P-000039 File folder entitled "CORR RE GJ SUBPOENAS" containing correspondence related to various grand jury subpoenas and attorney (Villafafia) handwritten notes 6(e) Work Product Box #1 P-000040 thru P-000549 Operation Leap Year Grand Jury Log containing subpoenas OLY-01 through OLY-81, correspondence and research related to enforcement of same, documents produced in response to some subpoenas; and attorney (Villafafia) handwritten notes 6(e) Work Product Contains documents subject to investigative privilege Also contains documents subject to privacy rights of victims who are not parties to this litigation Box #1 P-000550 thru P-000621 File folder entitled "Ritz Compact Flash SW" containing copies of a sealed search warrant application, warrant, and supporting documents 6(e) Contains information subject to investigative privilege Also contains information subject to privacy rights of victims who are not parties to this litigation Box #1 P-000622 thru P-000693 File folder entitled "PNY Technologies Compact Flash SW" containing copies of a sealed search warrant application, warrant, and supporting documents 6(e) Contains information subject to investigative privilege Also contains information subject to privacy rights of victims who are not parties to this litigation Box #1 P-000694 thru P-000781 File folder entitled "JE Corporations" containing attorney research on Epstein-owned corporations and prior litigation Work Product Contains information subject to investigative privilege Box #1 P-000782 thru P-000803 File folder entitled "Capital One" containing subpoena and correspondence 6(e) Box #1 P-000804 thru P-000854 File folder entitled "DTG Operations/Dollar Rent-a-Car" containing subpoena and responsive documents 6(e) Contains documents and information subject to investigative privilege Also contains documents and information subject to privacy rights of victims who are not parties to this litigation Page 1 of 23 EFTA00191365

Bates Range Description Privilege(s) Asserted Box #1 P-000855 thru P-000937 File folder entitled "JP Morgan Chase" containing subpoena, correspondence, and responsive documents 6(e) Contains documents and information subject to investigative privilege Box #1 P-000938 thru P-000947 File folder entitled "Washington Mutual" containing subpoena, correspondence, and responsive documents 6(e) Contains documents and information subject to investigative privilege Box #1 P-000948 tiny P-000982 File folder entitled "Computer Search &" containing legal research on computer search and handwritten notes on indictment preparation Work Product Attorney-Client Contains information subject to investigative privilege. Also contains information subject to privacy rights of victims who are not parties to this litigation Box #1 P-000983 thru P-001007 File folder entitled "Attorney Notes from Document Review" containing typed and handwritten attorney (Villafafia) notes, target letters, correspondence re grand jury subpoena Work product 6(e) Contains information subject to investigative privilege. Also contains information subject to privacy rights of victims who are not parties to this litigation Box #1 P-001008 thru P-001056 File folder entitled "Notes from Fed Ex Records" containing handwritten and typed attorney (Villafana) notes and screen shots of FedEx subpoena response electronic file Work Product 6(e) Contains information subject to investigative privilege. Also contains information subject to privacy rights of victims who are not parties to this litigation Box #1 P-001057 thru P-001959 File folder entitled "Colonial Bank Records" containing records received in response to grand jury subpoena 6(e) Contains information subject to investigative privilege Box #1 P-001960 Thru P-002089 File folder entitled "OLY Grand Jury Log Vol 2: OLY-5I THROUGH" containing subpoenas numbered OLY-51 through OLY-81 with related correspondence 6(e) Contains information subject to investigative privilege. Also contains information subject to privacy rights of victims who are not parties to this litigation Page 2 of 23 EFTA00191366

Bates Range Description Privilege(s) Asserted Box #1 P-002090 Thru P-002169 File folder entitled "Epstein Corporate Records: OLY-51, OLY-52, OLY-53, OLY-54" containing subpoenas, records received in response to subpoenas, and related correspondence 6(e) Contains information and documents subject to investigative privilege Box #1 P-002170 Thru P-002246 File folder entitled "Colonial Bank" containing subpoenas, correspondence related to subpoenas, records received in response to subpoenas 6(e) Contains information and documents subject to investigative privilege Box #1 P-002247 Thru P-002265 File folder entitled "JEGE & Hyperion from Goldberger OLY-46 & OLY-47" containing documents received in response to subpoenas 6(e) Contains information and documents subject to investigative privilege Box #1 P-002266 Thru P-002386 Indictment preparation binder containing: Grand jury subpoena log, evidence/activity summary chart, wimess/victim names and contact list, attorney (Villafada) handwritten notes, 302s, portions of state investigative file, attorney (Villafada) typed notes, of individuals listed as "Additional victims" Work product 6(e) Contains information and documents subject to investigative privilege. Also contains information and documents subject to privacy rights of victims who are not parties to this litigation Box #1 P-002387 Thru P-002769 Indictment preparation binder containing: Grand jury subpoena log, evidence/activity summary chart, witness/victim names and contact list, attorney (Villafaila) handwritten notes, 302s, portions of state investigative file, attorney (Villafaila) typed notes, relevant pieces of grand jury materials, telephone records/flight records analysis charts, victim/witness photographs, DAVID records, NCICs, and related materials for persons identified as Jane Does #15, 16, 17, 18, 19, Past Employees, Misc. Witnesses Work product 6(e) Contains information and documents subject to investigative privilege. Also contains information and documents subject to privacy rights of victims who are not parties to this litigation Box #1 P-002770 Thru P-003211 Indictment preparation binder containing: witness/victim list with identifying information, sexual activity summary, telephone call summary chart, attorney (Villafaila) handwritten notes, 302s, portions of state investigative file, attorney (Villafalia) typed notes, relevant pieces of grand jury materials, telephone records/flight records analysis charts, victim/witness photographs, DAVID records, NCICs, and related materials for persons identified as Jane Does #1, 2, 3, 4, 5, 6, 7, 8 Work product 6(e) Contains information and documents subject to investigative privilege. Also contains information and documents subject to privacy rights of victims who are not parties to this litigation Page .3 of 2.3 EFTA00191367

Bates Range Description Privilege(s) Asserted Box #1 P-003212 Thru P-003545 Indictment preparation binder containing meta- analysis charts of telephone/flight/grand jury information for a number of victim/witnesses, Nadia Marcinkova, and Adriana Mucinska Work product 6(e) Contains information and documents subject to investigative privilege. Also contains information and documents subject to privacy rights of victims who are not parties to this litigation Box #1 P-003546 Thru P-003552 FBI Reports of March 2008 interviews of additional witness/victim located in New York Work product 6(e) Contains information and documents subject to investigative privilege. Also contains information and documents subject to privacy rights of victims who are not parties to this litigation Box #1 P-003553 Thm P-003555B Printout of filenames from Federal Express subpoena response with Attorney notations Work product 6(e) Box #1 P-003556 Thru P-003562 Document entitled "Identified Numbers" with accompanying handwritten attorney list compiled from grand jury materials and attorney analysis of records Work product 6(e) Contains information subject to investigative privilege Box #1 P-003563 Thru P-003629 Folder entitled "Flight Manifests" containing manifests received pursuant to grand jury subpoena 6(e) Contains information and documents subject to investigative privilege Box #1 P-003630 Thru P-003633 File folder entitled "Recent Attorney Notes" containing handwritten attorney (Villafafia) notes regarding document review and case strategy Work product 6(e) Investigative privilege Deliberative process Box #1 P-003634 Thru P-003646 File folder bearing victim name containing FBI interview report from May 2008, telephone activity report with attorney (Villafanafia) handwritten notes, related grand jury material Work product Attorney-client privilege 6(e) Investigative privilege Also contains information and documents subject to privacy rights of victims who are not parties to this litigation Page 4 of 23 EFTA00191368

Bates Range Description Privilege(s) Asserted Box #1 P-003647 Thru P-003651 File folder entitled "Summary of Sexual Activity" containing chart bearing handwritten title "Sexual Activity — Summary" with meta-analysis of information, sorted by name of each victim/witness, including name and identifying information of each victim/witness Work product 6(e) Investigative privilege Deliberative process Also contains information and documents subject to privacy rights of victims who are not parties to this litigation Box #1 P-003652 Thru P-003663 File folder entitled "Victim Civil Suits" Not privileged. Produced to counsel for Petitioners Box #1 P-003664 Thru P-003678 File folder entitled "Research re JE Websites" containing attorney research Work product Box #1 P-003679 Thru P-003680 File folder entitled "Serene Cano (N.Y. AUSA)" containing attorney (Villafana) handwritten notes Work product Box #1 P-003681 Thru P-003687 File folder entitled "Dr. Anna Salter" containing attorney (Villafana) memo to expert witness and handwritten attorney notes Work product Investigative privilege Box #1 P-003688 Thru P-003693 File folder entitled "I[] G[] Interview" containing attorney handwritten notes of interview, and attorney handwritten notes regarding potential charges Work product Investigative privilege Also contains information subject to privacy rights of victims who are not parties to this litigation Box #1 P-003694 Thru P-0037 1 1 File folder entitled "Research re Travel for Prostitution" containing attorney (Villafana) handwritten notes regarding grand jury presentation, chart entitled "Brought to Epstein's House" with handwritten notes, Message Pad meta-analysis chart, summary of evidence related to one victim/witness, and relevant grand jury information Work product 6(e) Investigative privilege Also contains information and documents subject to privacy rights of victims who are not parties to this litigation Box #1 P-003712 Empty file folder bearing name of victim/witness Investigative privilege Also contains information subject to privacy rights of victim who is not a party to this litigation Page 5 of 23 EFTA00191369

Bates Range Description Privilege(s) Asserted Box #1 P-003713 Thru P-003746 File folder entitled "T[j MO" containing grand jury subpoenas, motion and order to compel testimony, and correspondence regarding same 6(e) Documents under seal pursuant to court order Box #1 P-003747 Thru P-003751 File folder entitled "Adriana Ross" containing subpoena and correspondence regarding same 6(e) Box #1 P-003752 Thru P-004295 File folder entitled "PBPD Investigative File" obtained via subpoena 6(e) Investigative privilege Also contains information and documents subject to privacy rights of victims who are not parties to this litigation Box NI P-004296 Thm P-004350 File folder bearing name of victim/witness containing meta-analysis chart showing telephone calls, travel, and grand jury materials relevant to possible charges Work product 6(e) Investigative privilege Also contains information and documents subject to privacy rights of victims who are not parties to this liti ation Box #1 P-004351 Thru P-004381 File folder entitled "Daniel Documents Work product 53909-004" containing attorney research related to bias issue Box #1 P-004382 Thru P-004478 File Folder entitled "FEDEX" containing documents obtained via subpoena 6(e) Investigative privilege Box #1 P-004479 Thru P-004551 File Folder entitled "State of Delaware Records" containing documents obtained in preparation for indictment 6(e) Investigative privilege Work product Box #1 P-004552 Thru P-004555 File folder entitled "Jet Blue Records" containing documents obtained via subpoena 6(e) Work product Investigative privilege Also contains information and documents subject to privacy rights of victims who are not parties to this litigation Box #1 P-004556 Thru P-004560 File folder entitled "FL EMPLOYMENT RECORDS" containing FDLE records on targets and witnesses obtained at attorney request Investigative privilege Work product Page 6 of 23 EFTA00191370

Bates Range Description Privilege(s) Asserted Box #1 P-004561 Thru P-004565 Filed folder entitled "JANUSZ BANASIAK" containing attorney (Villafafta) handwritten notes of interview Work product Investigative privilege Box #1 P-004566 Thru P-004716 File folder entitled "JANUSZ BANASIAK RECORDS 23-0001 THROUGH 23-" containing documents obtained via subpoena 6(e) Work product Investigative privilege Also contains information and documents subject to privacy rights of victims who are not parties to this litigation Box #1 P-004717 Thru P-004722 File folder entitled "IGOR ZINOVIEV" containing attorney research regarding witness Work product Investigative privilege Box #1 P-004723 Thru P-004725 File folder entitled "BEAR STEARNS RESEARCH" containing attorney research regarding potential witness and subpoena recipient Work Product Investigative privilege Box #1 P-004726 Thru P-004819 File folder entitled "LAWSUITS INVOLVING EPSTEIN CORP'S" containing attorney research regarding Epstein's past personal and business litigative practices Work Product Investigative privilege Box #1 P-004820 Thru P-004959 Filed folder entitled "SEC RECORDS" containing attorney research regarding Epstein financial relationships Work Product Investigative privilege Box #1 P-004960 Thru P-005059 File folder entitled "Message Pads" containing selected items from evidence obtained via subpoena Work Product 6(e) Investigative privilege Also contains information and documents subject to privacy rights of victims who are not parties to this litigation Box #1 P-005060 Thru P-005081 File folder bearing name of victim/witness containing correspondence with counsel for victim/witness, attorney witness outline with attorney handwritten notes, attorney handwritten notes regarding witness reports and case preparation Work Product 6(e) Investigative privilege Also contains information and documents subject to privacy rights of victims who are not parties to this litigation Box #1 P-005082 Thru P-005083 File folder entitled "New York Trip" containing attorney notes re witness interview Work product Investigative privilege Page 7 of 23 EFTA00191371

Bates Range Description Privilege(s) Asserted P-005084 thru P-005107 are non responsive documents and have been removed Box #1 P-005108 Thru P-005193 File folder entitled "ANNA SALTER" containing attorney research on select expert, use of experts at trials in child exploitation cases, and additional research materials on offenders and victims Work product Investigative privilege Box #1 P-005194 Thru P-005300 File folder entitled "Extra Copies" containing meta-analysis chart and 302's of victim/witnesses used in preparing indictment package Work product 6(e) Investigative privilege Also contains information and documents subject to privacy rights of victims who are not parties to this litigation Box NI P-005301 Thru P-005331 File folder entitled "JUAN ALESSI STATEMENT" containing transcript obtained via subpoena 6(e) Investigative privilege Box #1 P-005332 Thru P-005341 File folder entitled "KEN LANNING" containing attorney research on select expert, including attorney handwritten notes Work product Investigative privilege Box #1 P-005342 Thar P-005387 File folder entitled "Info re Planes" containing correspondence regarding subpoenas and documents received in response to subpoenas 6(e) Investigative privilege Box #1 P-005388 Thru P-005442 File folder entitled "Police Reports & PC Affidavit" containing portions of police reports with attorney notes, related phone records, a list entitled "Victims" with identifying information and attorney handwritten notes, photographs and DAVID information, and additional attorney research regarding Epstein sexual activity Work product 6(e) Investigative privilege Also contains information and documents subject to privacy rights of victims who are not parties to this litigation Box #1 P-005443 Thru P-005496 File folder entitled "[Victim name] Transcript of Interview & GJ Transcript" 6(e) Investigative privilege Also contains information and documents subject to privacy rights of victims who are not parties to this litigation Box #1 P-005497 Thru P-005556 File folder entitled "Bear Stearns Subpoena Resp." containing material received in response to subpoena 6(e) Investigative privilege Page 8 of 23 EFTA00191372

Bates Range Description Privilege(s) Asserted Box #1 P-005557 Thru P-005576 U.S. Attorney's Office Criminal Case File Jacket containing file opening documents, expert witness payment documents Work product Deliberative process Box #1 P-005578 Thru P-005583 U.S. Attorney's Office Asset Forfeiture Case File Jacket containing file opening and file closing documents Work product Deliberative process Box #1 P-005584 Thru P-005606 File folder entitled "6001 Immunity Request" containing internal memoranda seeking witness immunity and correspondence with counsel for witness regarding same 6(e) Work product and deliberative process (as to internal memoranda) Investigative privilege Also contains information and documents subject to privacy rights of victims who are not parties to this litigation Box #2 P-005607 Thru P-005914 File folder entitled "MASTER PHONE RECORDS" containing meta-analysis of all phone, travel, and grand jury data for all victim/witnesses for indictment preparation Work product 6(e) Investigative privilege Also contains information and documents subject to privacy rights of victims who are not parties to this litigation Box #2 P-0059 I5 Thru P-005977 File folder bearing name of victim/witness containing meta-analysis of all phone, travel, and grand jury data related to that victim/witness for indictment preparation Work product 6(e) Investigative privilege Also contains information and documents subject to privacy rights of victims who are not parties to this litigation Box #2 P-005978 Thru P-006050 File folder bearing name of victim/witness containing meta-analysis of all phone, travel, and grand jury data related to that victim/witness for indictment preparation Work product 6(e) Investigative privilege Also contains information and documents subject to privacy rights of victims who are not parties to this litigation Box #2 P-006051 Thru P-006065 File folder bearing name of victim/witness containing meta-analysis of all phone, travel, and grand jury data related to that victim/witness for indictment preparation Work product 6(e) Investigative privilege Also contains information and documents subject to privacy rights of victims who are not parties to this litigation Page 9 of 23 EFTA00191373

Bates Range Description Privilege(s) Asserted Box #2 P-006066 Thru P-006220 File folder entitled "JANE DOE #4" containing meta-analysis of all phone, travel, and grand jury data related to that victim/witness for indictment preparation Work product 6(e) Investigative privilege Also contains information and documents subject to privacy rights of victims who are not parties to this litigation Box #2 P-006221 Thru P-006222 File folder entitled ""JANE DOE #12" containing meta-analysis of all phone, travel, and grand jury data related to that victim/witness for indictment preparation Work product 6(e) Investigative privilege Also contains information and documents subject to privacy rights of victims who are not parties to this litigation Box #2 P-006223 Thru P-006522 File folder entitled "CORRECTED PHONE RECORDS 5/31/07" containing meta-analysis of all phone, travel, and grand jury data related to all victims/witnesses for indictment preparation Work product 6(e) Investigative privilege Also contains information and documents subject to privacy rights of victims who are not parties to this litigation Box #2 P-006523 Thru P-006802 File folder entitled "[Victim Name] Phone Records" containing telephone records received in response to subpoena Work product 6(e) Investigative privilege Also contains information and documents subject to privacy rights of victims who are not parties to this litigation Box #2 P-006803 Thru P-006860 File folder entitled "Lists of Identified Phone Numbers" containing charts of information culled from grand jury materials, interviews, and other investigation, with attorney handwritten notes, and information to issue follow-up grand jury subpoena Work product 6(e) Investigative privilege Also contains information and documents subject to privacy rights of victims who are not parties to this litigation Box #2 P-006861 Thru P-007785 File folder entitled "EPSTEIN/KELLEN CELL PHONE RECORDS" containing documents received via subpoena with attorney handwritten notes and highlighting Work product 6(e) Investigative privilege Also contains information and documents subject to privacy rights of victims who are not parties to this litigation Page 10 of 23 EFTA00191374

Bates Range Description Privilege(s) Asserted Box #2 P-007786 Thru P-008120 Folder entitled "OLY GRAND JURY LOG: OLY-01 THROUGH OLY-50" containing subpoenas, correspondence regarding same, 6(e) letters, attorney handwritten notes regarding records received in response to subpoenas Work product 6(e) Investigative privilege Also contains information and documents subject to privacy rights of victims who are not parties to this litigation Box #2 P-008121 Thru P-008139 Handwritten flight logs received in response to subpoena 6(e) Investigative privilege Box #2 P-008140 Thru P-008298 Grand jury presentation folder containing attorney handwritten notes, typed outline with additional handwritten notes, complete indictment package dated 2/19/2008, victim list with identifying information, photographs, and summary of activity Work product 6(e) Investigative privilege Also contains information and documents subject to privacy rights of victims who are not parties to this litigation Box #2 P-008299 Thru P-008363 File folder entitled "FINAL AGREEMENTS" containing subfolder entitled "Agrmts Filed in State Court" (P-008300-P-008327 [not being withheld as privileged — have been produced to opposing counsel]); signed Non-Prosecution Agreement, Addendum, and operative portion of 12/19/2007 Sanchez-Acosta letter (P-008328-P- 008343 [not being withheld as privileged — have been produced to opposing counsel]); subfolder entitled "12/19/07 Acosta-Sanchez Ltr" containing unredacted copies of that letter (P- 008344-P-008363 [pursuant to Court's Order, not being withheld as privileged — will be produced to opposing counsel upon lift of stay by 1 I1h Circuit]) Box #2 P-008364 Thru P-008382 File folder entitled "Lacerda Immunity Request" containing internal memoranda, Justice Department documentation, and subpoena regarding immunity request 6(e) Work Product Deliberative Process Investigative privilege Box #2 P-008383 Thru P-008516 File folder containing March 18, 2008 grand jury presentation materials, including "Operation Leap Year Revised Indictment Summary Chart (by victim)," grand jury materials, draft indictments, victim reference list, grand jury subpoena log Work product 6(e) Investigative privilege Deliberative process Also contains information and documents subject to privacy rights of victims who are not parties to this litigation Page 11 of 23 EFTA00191375

Bates Range Description Privilege(s) Asserted Box #2 P-008517 Thru P-008535 6/25/2007 Letter from Gerald Lefcourt to Jeffrey Sloman and Andrew Lourie [pursuant to Court's Order, not being withheld as privileged — will be produced to opposing counsel upon lift of stay by I Id' Circuit] Box #2 P-008536 Thru P-008542 Handwritten attorney notes to prepare for interview of Jane Doe #2 Work product Investigative Privilege Contains information subject to privacy rights of victims who are not parties to this suit Box #2 P-008543 Thru P-008549 Handwritten attorney notes regarding May 8, 2007 grand jury presentation Work product 6(e) Investigative privilege Contains information subject to privacy rights of victims who are not parties to this suit Box #2 P-008550 Thru P-008615 File folder entitled "Most Recent Indictment & Good Cases" containing draft indictment and legal research Work product 6(e) Investigative privilege Deliberative process Contains information subject to privacy rights of victims who are not parties to this suit Box #2 P-008616 Thru P-008686 File folder entitled "FBI Summary Charts" containing chart prepared at direction of AUSA, containing victim names, identifying information, summary of activity, and other information relevant to indictment Work product Attorney-Client Privilege 6(e) Investigative privilege Contains information subject to privacy rights of victims who are not parties to this suit Box #2 P-008687 Thru P-008776 File folder entitled "[Victim name]/Jane Doe #4" containing phone records and meta-analysis of all phone, travel, and grand jury data related to that victim/witness for indictment preparation Work product 6(e) Investigative privilege Contains information and documents subject to privacy rights of victims who are not parties to this suit Box #2 P-008777 Thru P-008808 File folder entitled "[Victim name]/Jane Doe #5" containing handwritten notes and meta-analysis of all phone, travel, and grand jury data related to that victim/witness for indictment preparation Work product 6(e) Investigative privilege Contains information subject to privacy rights of victims who are not parties to this suit Page 12 of 23 EFTA00191376

Bates Range Description Privilege(s) Asserted Box #2 P-008809 Thai P-008847 File folder entitled "[Victim name]/Jane Doe #6" containing meta-analysis of all phone, travel, and grand jury data related to that victim/witness for indictment preparation Work product 6(e) Investigative privilege Contains information subject to privacy rights of victims who are not parties to this suit Box #2 P-008848 Thru P-008862 File folder entitled "[Victim name]/Jane Doe #7" containing meta-analysis of all phone, travel, and grand jury data related to that victim/witness for indictment preparation Work product 6(e) Investigative privilege Contains information subject to privacy rights of victims who are not parties to this suit Box #2 P-008863 Thru P-008890 File folder entitled "[Victim name]/Jane Doe #8" containing meta-analysis of all phone, travel, and grand jury data related to that victim/witness for indictment preparation Work product 6(e) Investigative privilege Contains information subject to privacy rights of victims who are not parties to this suit Box #2 P-008891 Thru P-009103 File folder entitled "Certified Copy of State Case" containing certified copy of Epstein state criminal cases and change of plea transcript [not being withheld as privileged — copy provided to opposing counsel Box #2 P-009104 Thru P-009111 File folder entitled "Meeting Timeline" containing Villafafia typed notes summarizing meetings with opposing counsel prepared at request of R. Alexander Acosta, with handwritten correction and typed guideline estimate Work product Deliberative process Box #2 P-009112 Thru P-009113 11/26/2008 Email from Roy Black to A. Marie Villafafia and Karen Atkinson re Jeffrey Epstein (work release) [pursuant to Court's Order, not being withheld as privileged — will be produced to opposing counsel upon lift of stay by 11'" Circuit] Box #2 P-009114 Thru P-009115 7/3/2008 Email from A. Marie Villafafia to Col. M. Gauger at PBSO re Epstein work release with attachment [not being withheld as privileged — produced to opposing counsel] Box #2 P-009116 Thru P-009125 12/6/2007 Letter from Jeffrey Sloman to Jay P. Lefkowitz re Jeffrey Epstein (victim notification) [pursuant to Court's Order, not being withheld as privileged — will be produced to opposing counsel upon lift of stay by 11'" Circuit]) Page 13 of 23 EFTA00191377

Bates Range Description Privilege(s) Asserted Box #2 P-009126 Thru P-009134 File folder entitled "[Victim name]/Jane Doe #9" containing meta-analysis of all phone, travel, and grand jury data related to that victim/witness for indictment preparation Work product 6(e) Investigative privilege Contains information subject to privacy rights of victims who are not parties to this suit Box #2 P-009135 Thru P-009141 File folder entitled "[Victim name]/Jane Doe #13" containing meta-analysis of all phone, travel, and grand jury data related to that victim/witness for indictment preparation Work product 6(e) Investigative privilege Contains information subject to privacy rights of victims who are not parties to this suit Box #2 P-00914 IA Thru P-00914 IC File folder entitled "[Victim name]/Jane Doe #12" containing meta-analysis of all phone, travel, and grand jury data related to that victim/witness for indictment preparation Work product 6(e) Investigative privilege Contains information subject to privacy rights of victims who are not parties to this suit Box #2 P-009142 Thru P-009152 File folder entitled "Adrian `Mucinka' Ross" containing meta-analysis of all phone, travel, and grand jury data related to that individual for indictment preparation Work product 6(e) Investigative privilege Contains information subject to privacy rights of victims who are not parties to this suit Box #2 P-009153 Thru P-009156 File folder entitled "Nadia Marcinkova" containing meta-analysis of all phone, travel, and grand jury data related to that individual for indictment preparation Work product 6(e) Investigative privilege Contains information subject to privacy rights of victims who are not parties to this suit Box #2 P-009157 Thru P-009208 File folder entitled "[Victim name]/Jane Doe #1" containing meta-analysis of all phone, travel, and grand jury data related to that victim/witness for indictment preparation Work product 6(e) Investigative privilege Contains information subject to privacy rights of victims who are not parties to this suit Box #2 P-009209 Thru P-009213 File folder entitled "[Victim name]/Jane Doe #2" containing meta-analysis of all phone, travel, and grand jury data related to that victim/witness for indictment preparation Work product 6(e) Investigative privilege Contains information subject to privacy rights of victims who are not parties to this suit Page 14 of 23 EFTA00191378

Bates Range Description Privilege(s) Asserted Box #2 P-009214 Thru P-009271 File folder entitled "[Victim name]/Jane Doe #3" containing meta-analysis of all phone, travel, and grand jury data related to that victim/wimess for indictment preparation Work product 6(e) Investigative privilege Contains information subject to privacy rights of victims who are not parties to this suit Box #2 P-009272 Thru P-009354 File folder entitled "Purpose of Travel Cases" containing attorney research and handwritten notes Work product Box #2 P-009355 Thru P-009403 File folder entitled "Interstate Commerce Cases" containing attorney research and handwritten notes Work product Box #2 P-009404 Thru P-009536 File folder entitled "Attorney Conflict Research" containing attorney research and handwritten notes Work product Box #2 P-009537 Thru P-009574 File folder entitled "Mann Act/Travel to Have Sex w/Minor" containing attorney research and handwritten notes Work product Box #2 P-009575 Thru P-009603 File folder entitled "Travel Act" containing attorney research and handwritten notes Work Product Box #2 P-009604 Thru P-009711 File folder entitled "Florida Prostitution/Lewdness Statutes" containing attorney research and handwritten notes Work Product Box #2 P-009712 Thru P-009819 Booklet entitled "Attorney General Guidelines for Victim and Witness Assistance" [not being withheld as privileged — produced to opposing counsel] Box #2 P-009820 Thru P-009965 File folder entitled "Corporate Liability Rsrch" containing attorney research and handwritten notes Work Product Box #2 P-009966 Thru P-010096 File folder entitled "Research re Knowledge of Age Unnecessary" containing attorney research and handwritten notes and copy of grand jury subpoena Work Product 6(e) Page 15 of 23 EFTA00191379

Bates Range Description Privilege(s) Asserted Box #2 P-010097 Thru P-010276 File folder entitled "Money Laundering" containing attorney research and handwritten notes Work Product Box #2 P-010277 Thru P-010394 File folder entitled "1960 & Aiding/Abetting" containing attorney research and handwritten notes Work Product Box #2 P-010395 Thru P-010488 File folder entitled "18 USC § 2255 Cases" containing attorney research and handwritten notes Work Product Box #2 P-010489 Thru P410509 File folder entitled "Research re Overt Acts & Witness Testimony" containing attorney research and handwritten notes Work Product Box #2 P-010510 Thru P-010525 File folder entitled "Extradition" containing attorney research and handwritten notes Work Product Box #2 P-010526 Thru P-010641 File folder entitled "Rsrch re Crime Victims Rights" containing attorney research, handwritten notes, draft victim notification letter, and draft correspondence to Jay Lefkowitz (Also contains a November 28, 2007 letter from Kenneth Starr to Alice S. Fisher; and a November 29, 2007 letter from Jay Lefkowitz to R. Alexander Acosta (P-010528 thru P-010530 and P-010556 thru P-010559). Pursuant to the Court's Order, these will be produced to opposing counsel upon lift of stay by 11th Circuit) Work Product Deliberative Process Box #2 P-010642 Thru P-01650 File folder entitled "Immunity" containing attorney research on granting immunity to witnesses Work Product Box #2 P-010651 Thru P-010659 File folder entitled "Research re G.J. Transcript" containing attorney research and draft pleadings re compelling production of grand jury transcript with subpoena Work Product 6(e) Deliberative process Box #2 P-010660 Thru P-010757 File folder entitled "Research re GJ Transcript" containing grand jury subpoena, 6(e) letters, attorney research and correspondence related to subpoena Work Product 6(e) Page 16 of 23 EFTA00191380

Bates Range Description Privilege(s) Asserted Box #2 P-010758 Thru P-010793 File folder entitled "Original Proposed Ind." containing draft indictment Work Product 6(e) Deliberative process Box #2 P-010794 Thru P-010829 File folder entitled "Epstein" containing sample indictments and attorney research re potential charges with attorney notes Work Product Box #2 P-010830 Thru P-010853 File folder entitled "1591 & Money Laundering" containing attorney research and handwritten notes Work Product Box #2 P-010854 Thru P-010876 File folder entitled "18 USC 2425" containing attorney research and handwritten notes Work Product Box #2 P-010877 Thru P-010920 File folder entitled "Knowledge of Age" containing attorney research and handwritten notes Work Product Box #2 P-010921 Thm P-011049 File folder entitled "2423(b) Constitutionality and Purpose of Travel" containing attorney research and handwritten notes Work Product Box #2 P-011050 Thru P-011212 File folder entitled "Mistake not a Defense" containing attorney research and handwritten notes Work Product Box #2 P-011213 Thru P-011237 File folder entitled "Research re 'Pandering' containing attorney research and handwritten notes Work Product Box #2 P-011238 Thru P-011319 File folder entitled "Research re Grand Any Instructions" containing attorney research and handwritten notes Work Product 6(e) Box #2 P-011320 Thru P-011361 File folder entitled "Telephone = Facility of Commerce" containing attorney research and handwritten notes Work Product Box #2 P-011362 Thru P-011374 File folder entitled "Def of Prostitution" containing attorney research and handwritten notes Work Product Page 17 of 23 EFTA00191381

Bates Range Description Privilege(s) Asserted Box #2 P-011375 Thru P-011456 File folder entitled "Relevant Florida Statutes" containing attorney research and handwritten notes Work Product Box #2 P-011457 Thru P-011626 File folder entitled "Unit of Prosecution Research" containing attorney research and handwritten notes Work Product Box #3 P-011627 Thru P-011662 File folder entitled "Attorney Notes" containing attorney handwritten and typed notes Work Product Box #3 P-011663 Thru P-011698 and P-012189 thru P-012361 (gap was scanning error) File folder entitled "Drafts" containing draft indictments with attorney handwritten notes, draft internal memoranda, relevant witness interview reports and grand jury material and attorney handwritten notes 6(e) Work Product Deliberative Process Investigative Privilege Contains information subject to privacy rights of victims who are not parties to this Box #3 P-011699 Thru P-011777 File folder entitled "6/9/09 Signed Indictment" containing signed indictment package dated 6/9/2009 with corrections 6(e) Work product Deliberative process Box #3 P-011778 Thru P-011788 File folder entitled "6/12/09 Victim Noti£ Log" containing chart with victim contact information and attorney notes regarding dates and type of contacts Work product Box #3 P-011789 Thru P-011879 File folder entitled "Breach Memo" containing memorandum analyzing breach of Non- Prosecution Agreement with attachments Work product Deliberative process Box #3 P-011880 Thru P-011922 File folder entitled "Overt Act Lists" containing handwritten notes cross-checking all overt acts alleged in draft indictment by victim and typed overt act summary charts for indictment preparation Work product Attorney-client privilege Deliberative process 6(e) Page 18 of 23 EFTA00191382

Bates Range Description Privilege(s) Asserted Box #3 P-011923 Thru P-011966 Folder entitled "Responses to Arguments from JE Counsel" containing: ■ 7/13/2007 letter from Lilly Ann Sanchez to Andrew Lourie with handwritten attorney (Lourie) notes; ■ 6/25/2007 letter from Gerald Lefcourt to Jeffrey Sloman, Matt Menchal, Andrew Lourie, and Marie Villafafla with handwritten attorney (Villafttfla) notes; ■ 6/25/2007 email from Andrew Lourie to Matt Menchel and Marie Villafana entitled "Thoughts on Lefcourt's letter" Handwritten and typed attorney (Villafafia) notes regarding main themes raised by Epstein counsel Work product Deliberative process 6(e) Attorney-Client Privilege Box #3 P-011967 Thru P-012016 Composition book entitled "Operation Leap Year" containing attorney handwritten notes regarding investigation and case strategy Work product Investigative privilege 6(e) Contains information subject to privacy rights of victims who are not parties to this litigation Box #3 P-012017 Thru P-012055 Motion of Jeffrey Epstein to Intervene and to Quash Grand Jury Subpoenas and Incorporated Memorandum of Law 6(e) Box #3 P-012056 Thru P-012088 Affidavit of Roy Black, Esq. in Support of Motion of Jeffrey Epstein to Intervene and to Quash Grand Jury Subpoenas 6(e) Box #3 P-012089 Thru P-012129 United States' Response to Motion of Jeffrey Epstein to Intervene and to Quash Grand Jury Subpoenas and Cross-Motion to Compel 6(e) Box #3 P-012130 "Him P-012150 Declaration of Joseph Recarey 6(e) Box #3 P-012151 Thru P-012167 Ex Pane Declaration Number One in Support of United States' Response to Motion to Quash Subpoenas 6(e) Investigative Privilege Also contains information subject to privacy rights of victims who are not parties to this litigation Page 19 of 23 EFTA00191383

Bates Range Description Privilege(s) Asserted Box #3 P-012168 Thru P-012170 Ex Parte Declaration Number Two in Support of United States' Response to Motion to Quash Subpoenas 6(e) Investigative Privilege Box #3 P-012171 Thru P-012173 Supplement to Ex Parte Declaration Number One in Support of United States' Response to Motion to Quash Subpoenas 6(e) Investigative Privilege Also contains information subject to privacy rights of victims who are not parties to this litigation Box #3 P-012174 Thru P-012176 Draft of September 2009 letter from Marie Villafafia to Roy Black regarding breach of Non Prosecution Agreement with handwritten attorney (Villafafia) notes Work Product Attorney-Client Privilege Deliberative Process Box #3 P-012177 Thru P-012178 Undated handwritten attorney (Villafafia) notes regarding negotiations and allegations Work Product Attorney-Client Privilege Deliberative Process Box #3 P-012179 Thru P-012188 File Folder entitled "FBI G.J. Log" containing copy of FBI grand jury subpoena log with attorney (Villafafia) handwritten notes 6(e) Work Product Investigative Privilege Also contains information subject to privacy rights of victims who are not parties to this litigation Box #3 P-012362 Thru P-012451 File folder entitled "Key Documents" containing correspondence between AUSA and case agent regarding indictment prep questions, victim identification information, corrections to draft indictment, indictment preparation timeline, key grand jury material 6(e) Work Product Attorney-Client privilege Investigative Privilege Also contains information subject to privacy rights of victims who are not parties to this litigation Box #3 P-012451 Thru P-012452 File folder entitled "Victim List" containing list of victims with dates of birth and age information Work Product Investigative Privilege Also contains information subject to privacy rights of victims who are not parties to this litigation Page 20 of 23 EFTA00191384

Bates Range Description Privilege(s) Asserted Box #3 P-012453 Thru P-0 I 2623 Complete indictment package marked "Originals 12112/07" Work-product Deliberative process 6(e) Also contains documents subject to investigative privilege Also contains documents subject to privacy rights of victims who are not parties to this litigation Box #3 P-012624 Thru P-012653 Folder entitled "(Victims) Additional 302's" containing reports of interviews conducted in June 2007, October 2007, and March 2008. Investigative Privilege Also contains documents subject to privacy rights of victims who are not parties to this litigation Box #3 P-012654 Thru P-012864 3-ring binder entitled "Child Molesters: A Behavioral Analysis" with attorney (Villafa0a) handwritten notes Work-product Box #3 P-012865 Thru P-013226 Indictment preparation binder containing: witness/victim list with identifying information, sexual activity summary, telephone call summary chart, attorney (Villafafia) handwritten notes, 302s, portions of state investigative file, attorney (Villafafia) typed notes, relevant pieces of grand jury materials, telephone records/flight records analysis charts, victim/witness photographs, DAVID records, NCICs, and related materials for persons identified as Jane Does #9, 10, 11, 12, 13, 14 Work Product Deliberative Process 6(e) Also contains documents subject to investigative privilege Also contains documents subject to privacy rights of victims who are not parties to this litigation Box #3 P-013227 April 23, 2008 Memo from Jeffrey Sloman to Office of Professional Responsibility re Self Reporting, Corrected Version of the previously submitted April 21, 2008 Letter to OPR Privacy Act Box #3 P-013226 Thru P-013230 April 21, 2008 Letter from Jeffrey Sloman to Office of Professional Responsibility re Self Reporting Privacy Act Box #3 P-013231 Thru P-013239 April 22, 2008 Letter from A. Marie Villafafia to Office of Professional Responsibility re Self- Report of Allegation of Conflict of Interest Privacy Act Page 21 of 23 EFTA00191385

Bates Range Description Privilege(s) Asserted Box #3 P-013240 Thru P-013247 April 21, 2008 Letter from Jeffrey Sloman to Office of Professional Responsibility re Self Reporting with attachments Privacy Act Box #3 P-013248 Thru P-013251 Emails between Richard Sudder, Assistant General Counsel, Executive Office for United States Attorneys, and Benjamin Greenberg, First Assistant U.S. Attorney, Southern District of Florida, regarding Formal Notice of Office-wide Recusal of Southern District of Florida dated August 24 and August 29, 2011 Attorney-Client Privilege Box #3 P-013252 Thru P-013253 Emails between Richard Sudder, Assistant General Counsel, Executive Office for United States Attorneys, and Benjamin Greenberg, First Assistant U.S. Attorney, Southern District of Florida, regarding Recusal matter, dated July 28, August 3, and August 24, 2011 Attorney-Client Privilege Box #3 P-013254 Thru P-013257 Emails between Richard Sudder, Assistant General Counsel, Executive Office for United States Attorneys, and Benjamin Greenberg, First Assistant U.S. Attorney, Southern District of Florida, regarding Formal Notice of Office-wide Recusal of Southern District of Florida dated August 24 and August 29, 2011 Attorney-Client Privilege Box #3 P-013258 Thru P-013259 Emails between Richard Sudder, Assistant General Counsel, Executive Office for United States Attorneys, and Benjamin Greenberg, First Assistant U.S. Attorney, Southern District of Florida, regarding Formal Notice of Office-wide Recusal of Southern District of Florida dated July 28 and August 3, 2011 Attorney-Client Privilege Box #3 P-013260 Thru P-013262 Email from Richard Sudder, Assistant General Counsel, Executive Office for United States Attorneys, to Wifredo Ferrer (U.S. Attorney, SDFL), Robert O'Neill (U.S. Attorney, MDFL), Benjamin Greenberg, (FAUSA, SDFL), and Lee Bentley (FAUSA, MDFL) regarding Formal Notice of Office-wide Recusal of Southern District of Florida dated August 24, 2011. CC's David Margolis (ODAG), Jay MadaSAEO), Thomas Anderson (USAEO), Tapken (USAEO), James Read (USAEO) Attorney-Client Privilege Page 22 of 23 EFTA00191386

Bates Range Description Privilege(s) Asserted Box #3 Emails between Richard Sudder, Assistant Attorney-Client Privilege P413263 General Counsel, Executive Office for United Deliberative Process Thru States Attorneys, and Benjamin Greenberg, First Work Product P-013271 Assistant U.S. Attorney, Southern District of Florida, regarding recusal of Southern District of Florida, dated July 29, 2011, with attached memorandum from A. Marie Villafafla to Benjamin Greenberg summarizing Jeffrey Epstein Investigation Box #3 Emails between Peter Mason, Executive Office Attorney-Client Privilege P-013272 Thru for United States Attorneys, and Dexter Lee, Southern District of Florida, seeking advice P-013278 regarding office-wide recusal, dated December 16 and 17, 2010, with attached letter from Paul Cassell to Wifredo A. Ferrer, dated December 10, 2010 Page 23 of 23 EFTA00191387

• ...... .• •:z666:66 To: [email protected] Bi imaaol.comj; Subject: RE: Sent: Tue 4 2006 5:51:08 PM From: Villafena, Ann Marie C. (USAFLS) Hi Jim -- Thank you for the e-mail, and I will even forgive the football reference. I was just set for trial, so the earliest I will be able to reschedule the testimony will be after Thanksgiving. I will give you a call to discuss theibrity Issue but I am concerned about other things we have talked about -- if Ms. is given immunity, will she be forthcoming and answer the questions? Or am I going to jump through hoops to get her immunity and then have to worry about filing motions to compel, motions for orders to show cause why she shouldn't be held in contempt, etc., etc.? As always, thank you for your assistance. Regards, Marie A. Marie Villafana Assistant U.S. Attorney 561 209-1047 Fax 581 820-8777 ann. ma [email protected] From: [email protected] (mailto:[email protected]] Sent: Tuesday, October 24, 2006 12:00 PM To: Villafana, (USAFLS) Subject: Re: Sorry I t get back to you sooner. I have been out of town for several weeks. As to Miss she still does not wish to testify in this case and has a Fifth Amendment basis for er position. She wishes not to accept the "proffer letter " cover of Immunity, which again is her right. I think it Is a waste of time to have her appear Friday to just take. the Fifth. I suggest that you huddle with your people. (It is football season). If you want to push the issue you will have to get formal immati. I will accept service now and In the future for you so you don't have to chase down. Jim Eisenberg 08-80736-CV-MARRA P-013875 EFTA00191388

Memorandum Subject Re: Jeffrey Epstein Investigation Date July 26, 2011 To From Benjamin Greenberg, First Assistant U.S. Attorney A. Marie Villafafia I. Introduction This memorandum summarizes the conflict of interest related to the investigation by the Federal Bureau of Investigation ("FBI") of additional crimes committed by Jeffrey Epstein ("Epstein"). The memo begins with a brief overview of the original investigation of Epstein, dubbed "Operation Leap Year"; summarizes the resolution of Operation Leap Year by the Southern District of Florida; and addresses the events following the resolution of Operation Leap Year, including the basis for the conflict. Lastly, the memo briefly addresses the additional crimes that the FBI wants to investigate. II. 'Operation Lean Year' The investigation of Jeffrey Epstein initially was undertaken by the City of Palm Beach Police D artment in response to a complaint received from the parents of a 14-year-old girl, from Royal Palm Beach. When and another girl began fighting at school because the other girl accused of being a prostitute, one of the school principals intervened. The principal searched urse and found $300 cash. The principal asked where the money came from. initialiiimed that she earned the money working at "Chik-Fil-A," which no one believed. then claimed that she made the money selling drugs; no one believed that either. finally admitted that she had been paid $300 to give a massage to a man on Palm Beach island. parents approached the Palm Beach Police Department ("PBPD") about pressing charges. PBPD began investigating the recipient of the massage, Jeffrey Epstein, and two of his assistants, Sarah Kellen and Nadia Marcinkova. PBPD identified 27 girls who went to EFTA00191389

Epstein's house to perform "massage service? (not including one licensed massage therapist). The girls' ages ranged from 14 years' old to 23 years' old. Some girls saw Epstein only once and some saw him dozens of times. The "massage services" performed also varied. Some girls were fully clothed while they massaged Epstein; some wore only their underwear; and some were fully nude. During all of these massages, Epstein masturbated himself and he would touch the girl performing the massage, usually fondling their breasts and touching their vaginas — either over their clothing or on their bare skin. Epstein often used a vibrator to masturbate the girls and digitally penetrated a number of them. For the girls who saw him more often, Epstein graduated to oral sex and vaginal sex. Epstein sometimes brought his assistant/girlfriend, Nadia Marcinkova, into the sexual activity. One of the girls described Marcinkova as Epstein's "sex slave". On October 18, 2005, PBPD obtained a search warrant with the assistance of the Palm Beach County State Attorney's Office ("PBSAO"). By this time, PBSAO had already been contacted by Epstein's cadre of lawyers. When PBPD arrived at Epstein's home two days later (10/20/05) to execute the search warrant, they found several items conspicuously missing. For example, computer monitors and keyboards were found, but the CPUs were gone. I Similarly, surveillance cameras were found, but they were disconnected and the videotapes were gone. Nonetheless, the search did recover some evidence of value, including message pads showing messages from many girls over a two year span. The messages show girls returning phone calls to confirm appointments to "work." Messages were taken by three of Epstein's "personal assistants." Photographs taken inside the home showed that the girls' descriptions of the layout of the home and master bedroom/bathroom area were accurate. PBPD also found massage tables and oils, the high school transcript of one of the girls, and sex toys. 'During a meeting, two of Epstein's attorneys, Gerald Lefcourt and Lilly Ann Sanchez, admitted that attorney Roy Black instructed Epstein to have the CPUs removed although they insisted that those instruction were given well in advance of the execution of the search warrant - not in response to a "leak." 2 EFTA00191390

In sum, the PBPD investigation showed that girls from Royal Palm Beach High School would be contacted by one of Epstein's assistants to make an appointment to "work." Up to three appointments each day would be made. The girls would travel to Epstein's home in Palm Beach where they would meet Epstein's chef and Epstein's assistant-usually Sarah Kellen-in the kitchen. The assistant would escort the girls upstairs to the master bedroom/bathroom area and set up the massage table and massage oils. The girl sometimes was instructed to remove her clothing. The assistant would leave and Epstein would enter the room wearing a robe. He would remove the robe and lie face down and nude on the massage table. Epstein would then instruct the girl on what to do and would ask her to remove her clothing. After some time, Epstein would turn over, so that he was lying face up. Epstein would masturbate himself and fondle the girl performing the massage. When Epstein climaxed, the massage was over, and the girl was instructed to get dressed and to go downstairs to the kitchen while Epstein showered. Epstein's assistant would be in the kitchen and the girl would be paid-usually $200-and if it was a "new" girl, the assistant would ask for the girl's phone number to contact her in the future.2 Girls were encouraged to find other girls to bring with them. If a girl brought another girl to perform a "massage," each girl would receive $200. Each time a girl returned to the house, Epstein would pressure the girl to go further sexually, advancing to oral sex and sexual intercourse. Epstein would pay more for these acts - in the words of one girl, "the more you do, the more you make." The PBPD investigation consisted primarily of sworn taped statements from the girls. When PBPD began having problems with PBSAO, they approached the FBI. The investigation was formally presented to the FBI and to the U.S. Attorney's Office after PBSAO "presented" the case to a state grand jury and the state grand jury returned an indictment charging Epstein only with one felony count of solicitation of [adult] prostitution. After the matter was presented to the U.S. Attorney's Office and there was a determination that federal statutes had been violated, FBI, ICE, and the U.S. Attorney's Office opened files. The federal investigation focused on the interstate nexus required for all of the federal violations, so a number of grand jury subpoenas were issued for telephone records, flight manifests, and credit card records. The federal agents also re-interviewed some of the girls. The agents delved into Epstein's history and interviewed other girls and obtained records to corroborate the girls' stories. FBI also interviewed 2Sometimes Epstein made the payment and asked for the phone number, sometimes it was the assistant. 3 EFTA00191391

girls who came forward after the PBSAO indictment was reported in the papers and the additional girls identified through those interviews. The attempt to handle secretly the federal case was doomed from the start when the Chief of the Palm Beach Police Department gave a letter to each of the victims identified through his investigation telling them that, because of his disappointment in the way that the PBSAO had handled the case, the matter had been referred to the FBI. Almost immediately, Epstein's attorneys began calling to request a meeting with the U.S. Attorney's Office. When one attorney was unable to schedule a meeting, Epstein hired another attorney who called up the chain of command until someone agreed to a meeting. Between January and May 2007, an indictment package was prepared, charging Epstein and three of his personal assistants with a number of child exploitation offenses. The case agent made several appearances before the grand jury. Attorneys for Epstein made several presentations to the U.S. Attorney's Office to convince the Office not to prosecute, and made allegations of prosecutorial misconduct against the line Assistant and the First Assistant U.S. Attorney. Epstein also challenged the legal analysis behind the prosecution, both within the U.S. Attorney's Office (up to the U.S. Attorney) and to the Child Exploitation and Obscenity Section at the Justice Department. All of Epstein's challenges were considered and rejected. III. The Resolution of "Operation Leap Year' On September 24, 2007, Epstein signed a Non-Prosecution Agreement wherein the U.S. Attorney's Office for the Southern District of Florida promised not to prosecute Epstein for the crimes that were the subject of the grand jury investigation if: (1) he pled guilty to two crimes in state court - the state felony prostitution charge and a state charge of procuring minors into prostitution, which would require Epstein to register as a sex offender; (2) he were sentenced to at least 18 months' imprisonment, and (3) he agreed to pay damages to the victims of his offenses. After signing this Agreement, Epstein and his counsel decided that they were dissatisfied with its terms, and again complained to the Justice Department, seeking review to the Deputy Assistant Attorney General and the Deputy Attorney General. After those attempts also failed, on June 30, 2008, Epstein entered his guilty plea in state court and began serving his sentence. IV. Post-Resolution Events A few days before the plea and sentencing (in state court those occur on the same 4 EFTA00191392

day), the Assistant U.S. Attorney handling the matter contacted counsel for three of Epstein's identified victims and informed him of the upcoming court date, encouraging his clients to attend and be heard. They did not appear. On July 7, 2008, two of those victims filed suit against the United States in federal court claiming that their rights had been violated under the Crime Victims' Rights Act because they had not been consulted before the Office entered into the Non-Prosecution Agreement. (This will be referred to as the "CVRA Action.") After an initial flurry of activity, the Petitioners obtained a copy of the confidential Non-Prosecution Agreement, and the Court ordered that it be shared with all of the identified victims. After it was provided, the Petitioners and most of Epstein's victims focused on their civil suits against him. In 2009, the U.S. Attorney's Office in Fort Lauderdale initiated an investigation into a Ponzi scheme operated by Scott Rothstein through his law firm. As part of his Ponzi scheme, Rothstein told investors that his law firm represented several of Epstein's victims and that Epstein was willing to pay huge sums of money to avoid exposing his criminal activities. The attorney representing the victims in the CVRA Action, Brad Edwards ("Edwards"), worked at the Rothstein firm. Epstein sued Edwards, alleging that Edwards was part of the Ponzi scheme, and alleging that Edwards' attempts to subpoena some of Epstein's high-powered friends were done to increase the value of the Ponzi scheme, rather than for legitimate discovery purposes. In the summer of 2010, most of the civil suits against Epstein were settled, including the suits filed by the two victims in the CVRA Action. All of the settlements were confidential, so it is unknown how much each of the victims received. In September 2010, U.S. District Judge Kenneth Marra, who handled most of the civil cases and the CVRA Action, issued an Order closing the CVRA Action. Almost immediately thereafter, the Petitioners filed a Motion to Reopen, stating that they had obtained discovery through their civil suits against Epstein that showed that the U.S. Attorney's Office had violated their rights as victims. For several months, attempts were made to resolve the matter. In short, the victims have asked that the U.S. Attorney's Office disavow the Non-Prosecution Agreement, on the basis that the CVRA was violated, and bring charges against Epstein. Edwards has said that one of his clients repeatedly calls and asks him when Epstein is going to jail. One of the other attorneys on the case has suggested that emails he 5 EFTA00191393

considers to be embarrassing to the Office will not be disclosed if we re-open our investigation of Epstein and prosecute him. Herein lies the conflict. If the U.S. Attorney's Office for the Southern District of Florida re-initiates a grand jury investigation of Jeffrey Epstein, it will be perceived - correctly or incorrectly - as having been done at the insistence of the victims in the CVRA Action. And Epstein will allege that any prosecution arising therefrom will have been undertaken in an effort to resolve the CVRA Action, not based upon the merits of the investigation itself. I. The FBI's Current Investigation The main focus of the FBI's current investigation is a victim, M, who refused to speak with agents during the "Operation Leap Year" investigation. Based upon her debriefing, Epstein engaged in several additional crimes in the Southern District of Florida and, more important) in several other Districts, with and other minor females. Epstein transported in his private airplanes to engage in sexual activity with him. Epstein also "pimped" to several of his other important friends, and transported her to those sexual encounters. This activity was not part of the initial investigation. also reported that, during the "Operation Leap Year" investigation, she was contacted by Epstein's investigators, lawyers, and Epstein himself, and offered payment to remain silent when contacted by the police. FBI agents are seeking grand jury subpoenas at this time to corroborate statement. They also are asking for permission to approach one of Epstein's "personal assistants," who was served with a target letter during the "Operation Leap Year" investigation, to give her a "de-target" letter and interview her. There are several other Districts that may have jurisdiction over the additional crimes under investigation. Epstein lived and still lives in the Southern District of New York; he engaged in sexual activity with in the S.D.N.Y.; and it is believed that he made the calls from the S.D.N.Y. to wherein he offered to pay her to keep her from speaking to law enforcement. When Epstein would fly into and out of New York, however, he used the airport in Teterboro, New Jersey, so the District of New Jersey also has jurisdiction over charges related to traveling in interstate commerce to engage in illicit sexual conduct and transporting minors in interstate commerce. reported 6 EFTA00191394

that Epstein engaged in sexual activity with her on his private island in the U.S. Virgin Islands and also had her engage in sexual activity with one of his friends on that island, so the District of the Virgin Islands also would have jurisdiction. also reported frequent sexual activity with Epstein in the District of New Mexico and the Central District of California. In both of those Districts there is evidence (from or other witnesses) of Epstein engaging in illegal sexual activity with other underage victims, as well. 7 EFTA00191395