EFTA00191199

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 08-80736-CIV-Marra/Matthewman JANE DOE # I and JANE DOE #2, Petitioners, I UNITED STATES OF AMERICA, Respondent. UNITED STATES' RESPONSE TO PETITIONERS' FIRST REOUEST FOR ADMISSIONS TO THE GOVERNMENT The United States (hereinafter the "government") hereby responds to Jane Doe #1 and Jane Doe #2's First Requestfor Admissions to the Government Regarding Questions Relevant to Their Pending Action Concerning the Crime Victims Rights Act (hereinafter the "Request for Admissions"), and states as follows:' I. The government admits that the FBI and the U.S. Attorney's Office for the Southern District of Florida ("USAO") conducted an investigation into Jeffrey Epstein ("Epstein") and developed evidence and information in contemplation of a potential federal prosecution against Epstein for many federal sex offenses. Except as otherwise admitted above, the government denies Request No. I. The government's response is confined to Request No. I through Request No. 26 in the "Discovery Requested" section of the Request for Admissions and does not intend to respond to assertions in any other section of the Request for Admissions (including the "Background" section), none of which appear to separately state any matter calling for an admission. Nonetheless, the government denies the assertion that the government has declined the request of Jane Doe #1 and Jane Doe #2 to stipulate to undisputed facts in this case. EFTA00191199 2. (a) The government admits that, after Epstein's attorneys learned of the notification that the government planned to provide to Jane Doe #2, who claimed that she was not a victim, Epstein's attorneys contacted the USAO and objected to the procedures for notification and the legal bases therefor. The government further admits that the USAO considered those objections when evaluating what notification to provide to victims. Except as otherwise admitted above, the government denies Request No. 2(a). (b) Admitted. (c) The government admits that, as a result of objections lodged by Epstein's attorneys, the government reevaluated the notifications that it had intended to provide to victims and, as a result of that reevaluation, the USAO altered the scope, nature, and timing of notifications that it had contemplated providing to victims. With regard to Jane Doe #2, the government further admits that, as a result of representations made by Jane Doe #2 that she was not a victim and objections lodged by Epstein's attorneys, the USAO stopped making notifications to Jane Doe #2. Except as otherwise admitted above, the government denies Request No. 2(c). (d) The government admits that, after the USAO received objections to victim notifications from Epstein's counsel and reevaluated its victim notification obligations, the USAO altered the language that was ultimately contained in the July 9, 2008 notification letter to Jane Doe #1 in care of Bradley Edwards. Except as otherwise admitted above, the government denies Request No. 2(d). 2 EFTA00191200 (e) The government admits that, at least in part as a result of objections lodged by Epstein's lawyers to victim notifications, the USAO reevaluated its obligations to provide notifications to victims, and Jane Doe #1 was thus not told that the USA(?) had entered into a non-prosecution agreement with Epstein until after the agreement was signed. The government further admits that Jane Doe #2 was not told that the USAO had entered into a non-prosecution agreement with Epstein until after the agreement was signed, but denies that the USA() did not inform Jane Doe #2 as a result of any negotiations involving Epstein or any objections lodged by Epstein's lawyers; the USAO did not consider Jane Doe #2 a victim after she informed the USAO and the FBI that she was not a victim of any offense committed by Epstein, and, as a result, the USAO did not consider informing Jane Doe #2 about the non-prosecution agreement. Except as otherwise admitted above, the government denies Request No. 2(e). 3. Denied. 4. Denied. 5. The government admits that, during the negotiations with Jeffrey Epstein regarding the non-prosecution agreement, at least one experienced attorney within the USAO subscribed to the position that the CVRA required notifications to the victims in this case and that position was communicated to Epstein's counsel. To the extent that Request No. 5 seeks admissions regarding the positions held by attorneys within the USAO that were not communicated to non-government personnel regarding whether or not the CVRA ultimately required notifications to the victims in this case, the government objects to Request No. 5 as violative of the deliberative process privilege. 3 EFTA00191201 6. (a) Denied. (b) Denied. (c) Admitted. (d) Admitted. (e) Admitted to the extent that the reference to "Lillian Sanchez" was meant to refer to Lilly Ann Sanchez. (0 Admitted. (g) Admitted. 7. The government admits that, on about January 10, 2008, when Jane Doe # I and Jane Doe #2 were sent letters advising them that "this case is currently under investigation," the U.S. Attorney's Office had already signed a non-prosecution agreement with Jeffrey Epstein, but that, on that date, the non-prosecution agreement nonetheless remained in a state of some flux and was subject to being set aside as Epstein was challenging the propriety of the non-prosecution agreement and seeking further review from the Department of Justice. 8. Denied. 9. (a) The government admits that, at Epstein's insistence, the USAO agreed to a provision in the non-prosecution agreement that provided as follows: "The parties anticipate that this agreement will not be made part of any public record. If the United States receives a freedom of Information Act request or any compulsory process commanding the disclosure of the agreement, it will provide notice to Epstein before making that disclosure." Except as otherwise admitted above, the government denies Request No. 9(a). 4 EFTA00191202 (b) Admitted. (c) Denied. (d) Denied. (e) The government admits that, during the period from September 24, 2007 through June 2008, the USAO did not notify Jane Doe #2 of the existence of the non- prosecution agreement. The government further admits that, although FBI agents notified Jane Doe #1 of the existence and substance of the agreement at the request of the USAO on or about October 27, 2007, no employee of the USAO personally notified Jane Doe #1 of the existence of the non-prosecution agreement during the period from September 24, 2007 through June 2008. Except as otherwise admitted above, the government denies Request No. 9(c). 10. (a) Admitted. Because Request No. 10 appears directed solely to the communica- tions between FBI agents and Jane Doe #1 during their meeting on or about October 26, 2007, the government responses to Requests No. 10(b) through 10(g) address only that meeting. (b) The government admits that, on or about October 26, 2007, FBI agents explained to Jane Doe #1 that Epstein would plead guilty to state charges for procuring minors to engage in prostitution; that Epstein would be required to register as a sex offender; that Jane Doe #1 would be entitled to seek damages from Epstein; and that, if she desired, Jane Doc //I would be entitled to use the services of an attorney at no expense to her in seeking those damages from Epstein. The government denies that the FBI agents explained that the state charges "involv[ed] another victim." 5 EFTA00191203 (c) The government denies that the FBI agents did not explain to Jane Doc #1 that an agreement had already been signed; denies that the FBI agents did not explain to Jane Doe #1 that the agreement resolved the investigation of the federal case involving Jane Doe #1; and denies that the FBI agents did not explain to Jane Doe other terms of that agreement Except as otherwise admitted above, the government denies Request No. 10(c). (d) Denied. (e) Denied. (f) Denied. (g) Denied. I I. The government admits that, on or about November 28, 2007, A. Marie Villafalia of the USAO sent a draft of a crime victim notification letter to Jay Lefkowitz, counsel for Jeffrey Epstein, and that the draft notification letter stated, in part: "I am writing to inform you that the federal investigation of Jeffrey Epstein has been completed, and Mr. Epstein and the U.S. Attorney's Office have reached an agreement containing the following terms . . . ." The government further admits that, in part as a result of objections lodged by Epstein's lawyers, the USAO reevaluated its obligations to provide notifications to victims, and, as a result of that reevaluation and other considerations and developments, the USAO never sent victims the draft notification letter that was sent to Jay Lefkowitz on or about November 28, 2007. Except as otherwise admitted above, the government denies Request No. I I. 12. The government admits that, prior to July 3, 2008, the USAO had already entered a binding non-prosecution agreement with Jeffrey Epstein. The government is without 6 EFTA00191204 knowledge of precisely when "Bradley J. Edwards was working on a letter to the U.S. Attorney's Office concerning the need to federally prosecute Epstein for sex offenses committed against Jane Doe #1 and Jane Doe #2," and, accordingly, the government denies the assertion that Edwards worked on that letter on July 3, 2008. Except as otherwise admitted above, the government denies Request No. 12. 13. (a) The government admits that, when Epstein pled guilty to state charges on June 30, 2008, Jane Doe #2 had not been informed by the USAO of the existence of the non-prosecution agreement. The government further admits that, although the USAO, through FBI agents, had notified Jane Doe ill of the existence of the non- prosecution agreement prior to Epstein's June 30, 2008 guilty plea, no employee of the USAO had personally notified Jane Doe #1 at that time of the existence of the non-prosecution agreement. Except as otherwise admitted above, the government denies Request No. I3(a). (b) The government denies that, by the time of Epstein's June 30, 2008 guilty plea, an attorney for the government working at the USAO had not already conferred with Jane Doe #1 and Jane Doe #2 about their opinions regarding how the federal investigation and potential prosecution of Epstein should proceed. The government admits that the USAO had not conferred with Jane Doe #2 about the non-prosecution agreement prior to Epstein's June 30, 2008 guilty plea. The government further admits that, although the USAO had communicated with Jane Doe #1 about the non-prosecution agreement through FBI agents prior to Epstein's June 30, 2008 guilty plea, no employee of the USAO had personally conferred with Jane Doe #1 about the non-prosecution agreement prior to 7 EFTA00191205 Epstein's guilty plea. Except as otherwise admitted above, the government denies Request No. I3(b). (c) Although the government was aware that Jane Doe #2 had been represented by counsel paid for by Epstein, the government is unaware of the extent of Epstein's defense attorneys' awareness of the USAO's communications with Jane Doe #1 and Jane Doe #2 about the agreement, as described in the responses to Requests No. 13(a) and 13(b), and therefore can neither deny nor admit Request No. 13(c). Except as otherwise admitted above and in the responses to Requests No. 13(a) and 13(b), the government denies Request No. I3(c). (d) The government admits that Epstein's attorneys negotiated with the USAO for a provision in the non-prosecution agreement that ultimately provided as follows: "The parties anticipate that this agreement will not be made part of any public record. If the United States receives a Freedom of Information Act request or any compulsory process commanding the disclosure of the agreement, it will provide notice to Epstein before making that disclosure." Except as otherwise admitted above, the government denies Request No. 13(d). 14. The government admits that, when Epstein was pleading guilty to the state charges discussed in the non-prosecution agreement, the USAO and Epstein's defense attorneys sought to keep the document memorializing the non-prosecution agreement confidential, but denies that they sought at that time to keep the existence of the non- prosecution agreement confidential. Except as otherwise admitted above, the government denies Request No. 14. 8 EFTA00191206 IS. (a) The government admits that, while Bruce E. Reinhart was an Assistant U.S. Attorney, he learned confidential, non-public information about the Epstein matter. (b) The government admits that, while Bruce E. Reinhart was an Assistant U.S. Attorney, he discussed the Epstein matter with another Assistant U.S. Attorney working on the Epstein matter. (c) Denied. 16. Admitted. 17. Admitted. 18. (a) Denied. (b) Denied. 19. To the extent that Request No. 19 is directed to the business or personal relationships of the 93 U.S. Attorneys and over 5,400 Assistant U.S. Attorneys serving across this country, or the countless individuals who have formerly served as U.S. Attorneys and Assistant U.S. Attorneys throughout this nation, the government objects to Request No. 19 as overly broad and burdensome and not calculated to lead to or involve information relevant to the instant matter. The government denies possessing or having any knowledge or information about a personal or business relationship between Jeffrey Epstein and either the U.S. Attorney or any Assistant U.S. Attorney serving in the Southern District of Florida. Except as otherwise admitted above, the government denies Request No. 19. 20. Admitted. 21. Denied. 9 EFTA00191207 22. (a) Admitted. (b) Admitted. (c) Admitted. 23. The government admits that the non-prosecution agreement signed by the USAO and Jeffrey Epstein currently blocks the USA() from prosecuting sex offenses committed by Epstein against Jane Doe #1 and Jane Doe #2 in the Southern District of Florida from in or around 2001 through in or around September 2007, provided that those offenses are set out on pages I and 2 of the non-prosecution agreement, were the subject of the joint investigation by the FBI and the USAO, or arose from the federal grand jury investigation. Except as otherwise admitted above, the government denies Request No. 23. 24. Admitted; Jeffrey Epstein provided valuable consideration to the federal government through the non-prosecution agreement he entered with the USAO. 25. Denied. 26. The government objects to Request No. 26 because it seeks information protected from disclosure by the law enforcement investigative privilege. /II I0 EFTA00191208 Respectfully submitted, WIFREDO A. FERRER UNITED STATES ATTORNEY By: Is Dexter A. Lee Dexter A. Lee Assistant United States Attorney Florida Bar No. 0936693 99 N.E. 4th Street Miami, Florida 33132 Tel: (305) 961-9320; Fax: (305) 530-7139 Email: dexter.lee®usdoj.gov A. Marie Villafana Assistant United States Attorney Florida Bar No. 0018255 500 S. Australian Avenue, Suite 400 West Palm Beach, FL 33401 Tel: (561) 820-8711; Fax: (561) 820-8777 Email: ann.marie.c.villafana®usdoj.gov Eduardo I. Sanchez Assistant United States Attorney Florida Bar No. 877875 99 N.E. 4th Street Miami, Florida 33132 Tel: (305) 961-9057; Fax: (305) 536-4676 Email: eduardo.i.sanchez@usdoj.gov Attorneys for United States CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the foregoing United States' Response to Petitioners' First Request for Admissions to the Government was served via CM/ECF on this 19th day of July, 2013, on the parties and counsel appearing on the attached service list. /s Dexter A. Lee Assistant United States Attorney II EFTA00191209 SERVICE LIST Jane Does 1and 4 United States, Case No. 08-80736-CIV-MARRA/MATTHEWMAN United States District Court, Southern District of Florida Brad Edwards, Esq., Roy Black, Esq. Farmer, Jaffe, Weissing, Jackie Perczek, Esq. Edwards, Fistos & Lehrman, P.L. Black, Srebnick, Kornspan & Stumpf, P.A. 425 North Andrews Avenue, Suite 2 201 South Biscayne Boulevard, Suite 1300 Fort Lauderdale, Florida 33301 Miami, FL 33131 (954)524-2820 (305) 371-6421 Fax: (954) 524-2822 Fax: (305)358-2006 E-mail: brad@pathtojustice.com E-mail: pleading@iroyblack.com Paul G. Cassell Martin G. Weinberg S.J. Quinney College of Law at the MARTIN G. WEINBERG, P.C. University ofUtah 20 Park Plaza 332 S. 1400 E. Suite 1000 Salt Lake City, Utah 84112 Boston, MA 02116 (801) 585-5202 Office: (617) 227-3700 Fax: (801) 585-6833 Fax: (617) 338-9538 E-mail: casselp®law.utah.edu Email: owlmgw@attnet Attorneys for Jane Doe # 1 and Jane Doe # 2 Jay P. Letkowitz Kirkland &Ellis, LLP 601 Lexington Avenue New York. NY 10022 Fax: Email: lefkowitz@kirkland.com 12 EFTA00191210 Page I of 1 Nom (541)020-11111 Ongli P814 Shp Dale 23,11/1415 USA° 'Aerosol, reUr124. Ac6Vgl 0 5 LEI Departneal of Just* CAD B69/(146( NE13610 500 S A4004144 Avenu• Suite 400 )elvecy AA I( ( ode III1111II 11I1111111111111 110 111111 West Pale (load% Ft 33401 I II II SHIP 10: M4)524-2120 MI I Sf H Ref N Brad Edwards, Esq. rev(' N Farmer Jaffe Weissing Edwards PON Dept N 425 N. Andrews Avenue Suite 2 FORT LAUDERDALE, FL 33301 WED - 24 JUN AA STANDARD OVERNIGHT TR" 7738 9191 3028 0201 . 33301 32 HWOA 11 US FLL 11 https://www.fedex.com/shipping/shipAction.handle?method=doContinue 6/23/2015 EFTA00191211 Page I of I Fr= (55802043111 Oapn PEPA Shp Dais: 23JUN15 USAO .11Crossen • sas ,...n sa AcNigt 05 L8 Dopartment of Justsda CAD 8097846N€T3610 500 S Aushalan Avenues Suits 400 Delvary Ad s a Cade IIIIINIIIIII HI' I III Wes1Paln Beach. FL 33401 it,i2lUCenC)tor SFS 70: ANTIS:64212 BILL SENDER RON Paul G. Cassell Invoice PO N University of Utah Days SJ Quinney College of Law 332 S. 1400 E. SALT LAKE CITY, UT 84112 WED - 24 JUN AA STANDARD OVERNIGHT TR" 7738 9192 3670 84112 XH NPHA UT US SLC !:.7.!..y. I (I, https://www.fedex.com/shipping/shipAction.handlemethod=doContinue 6/23/2015 EFTA00191212 Brad Edwards, Esq., Farmer Jaffe Weissing Edwards Fistos Lehrman 425 N AndreWs Ave Ste 2 Fort Lauderdale, FL 33301-3268 brad©pathtojustice.com 954-524-2820 Fax: 954-524-2822 Paul G. Cassell S.J. Quinney College of Law at the University of Utah 332 S. 1400 E. Salt Lake City, Utah 84112 (801) 585-5202 Fax: (801) 585-6833 E-mail: casselpialaw.utah.edu t>") CA.)-recd EFTA00191213 PRIVILEGE LOG Bates Range Description Privilege(s) Asserted Box #1 File folder entitled "CORR RE GJ 6(e) P-000001 SUBPOENAS" containing correspondence Work Product thru related to various grand jury subpoenas and P-000039 attorney (Villafada) handwritten notes Box #1 Operation Leap Year Grand Jury Log 6(e) P-000040 containing subpoenas OLY-01 through OLY-81, Work Product thru correspondence and research related to Contains documents subject P-000549 enforcement of same, documents produced in to investigative privilege response to some subpoenas; and attorney Also contains documents (Villafafla) handwritten notes subject to privacy rights of victims who are not parties to this litigation Box #1 File folder entitled "Ritz Compact Flash SW" 6(e) P-000550 containing copies of a sealed search warrant Contains information subject thru application, warrant, and supporting documents to investigative privilege P-000621 Also contains information subject to privacy rights of victims who are not parties to this litigation Box #1 File folder entitled "PNY Technologies Compact 6(e) P-000622 Flash SW" containing copies of a sealed search Contains information subject thru warrant application, warrant, and supporting to investigative privilege P-000693 documents Also contains information subject to privacy rights of victims who are not parties to this litigation Box #1 File folder entitled "JE Corporations" containing Work Product P-000694 attorney research on Epstein-owned corporations Contains information subject thru and prior litigation to investigative privilege P-000781 Box #1 File folder entitled "Capital One" 6(e) P-000782 containing subpoena and correspondence thru P-000803 Box #1 File folder entitled "DTG Operations/Dollar 6(e) P-000804 Rent-a-Car" containing subpoena and responsive Contains documents and thru documents information subject to P-000854 investigative privilege Also contains documents and information subject to privacy rights of victims who are not parties to this litigation Page 1 of 23 EFTA00191214 Bates Range Description Privilege(s) Asserted Box #1 File folder entitled "JP Morgan Chase" 6(e) P-000855 containing subpoena, correspondence, and Contains documents and thru responsive documents information subject to P-000937 investigative privilege Box #1 File folder entitled "Washington Mutual" 6(e) P-000938 containing subpoena, correspondence, and Contains documents and thru responsive documents information subject to P-000947 investigative privilege Box #1 File folder entitled "Computer Search &" Work Product P-000948 containing legal research on computer search and Attorney-Client thru handwritten notes on indictment preparation Contains information subject P-000982 to investigative privilege. Also contains information subject to privacy rights of victims who are not parties to this litigation Box #1 File folder entitled "Attorney Notes from Work product P-000983 Document Review" containing typed and 6(e) thru handwritten attorney (Villafada) notes, target Contains information subject P-001007 letters, correspondence re grand jury subpoena to investigative privilege. Also contains information subject to privacy rights of victims who are not parties to this litigation Box #1 File folder entitled "Notes from Fed Ex Records" Work Product P-001008 containing handwritten and typed attorney 6(e) thru (Villafafia) notes and screen shots of FedEx Contains information subject P-001056 subpoena response electronic file to investigative privilege. Also contains information subject to privacy rights of victims who are not parties to this litigation Box #1 File folder entitled "Colonial Bank Records" 6(e) P-001057 containing records received in response to grand Contains information subject thru jury subpoena to investigative privilege P-001959 Box #1 File folder entitled "OLY Grand Jury Log Vol 2: 6(e) P-001960 OLY-51 THROUGH" containing subpoenas Contains information subject Thru numbered OLY-51 through OLY-81 with related to investigative privilege. P-002089 correspondence Also contains information subject to privacy rights of victims who are not parties to this litigation Page 2 of 23 EFTA00191215 Bates Range Description Privilege(s) Asserted Box #1 File folder entitled "Epstein Corporate Records: 6(e) P-002090 OLY-51, OLY-52, OLY-53, OLY-54" containing Contains information and Thru subpoenas, records received in response to documents subject to P-002169 subpoenas, and related correspondence investigative privilege Box #1 File folder entitled "Colonial Bank" containing 6(e) P-002170 subpoenas, correspondence related to subpoenas, Contains information and Thru records received in response to subpoenas documents subject to P-002246 investigative privilege Box #1 File folder entitled "JEGE & Hyperion from 6(e) P-002247 Goldberger OLY-46 & OLY-47" containing Contains information and Thru documents received in response to subpoenas documents subject to P-002265 investigative privilege Box #1 Indictment preparation binder containing: Work product P-002266 Grand jury subpoena log, evidence/activity 6(e) Thru summary chart, witness/victim names and contact Contains information and P-002386 list, attorney (Villafafia) handwritten notes, 302s, documents subject to portions of state investigative file, attorney investigative privilege. Also (Villafafia) typed notes, of individuals listed as contains information and "Additional victims" documents subject to privacy rights of victims who are not parties to this litigation Box #1 Indictment preparation binder containing: Work product P-002387 Grand jury subpoena log, evidence/activity 6(e) Thru summary chart, witness/victim names and contact Contains information and P402769 list, attorney (Villafafia) handwritten notes, 302s, documents subject to portions of state investigative file, attorney investigative privilege. Also (Villafafia) typed notes, relevant pieces of grand contains information and jury materials, telephone records/flight records documents subject to privacy analysis charts, victim/witness photographs, rights of victims who are not DAVID records, NCICs, and related materials for parties to this litigation persons identified as Jane Does #15, 16, 17, 18, 19, Past Employees, Misc. Witnesses Box #1 Indictment preparation binder containing: Work product P-002770 witness/victim list with identifying information, 6(e) Thrti sexual activity summary, telephone call summary Contains information and P-00321 I chart, attorney (Villafafia) handwritten notes, documents subject to 302s, portions of state investigative file, attorney investigative privilege. Also (Villafafia) typed notes, relevant pieces of grand contains information and jury materials, telephone records/flight records documents subject to privacy analysis charts, victim/witness photographs, rights of victims who are not DAVID records, NCICs, and related materials for parties to this litigation persons identified as Jane Does #1, 2, 3, 4, 5, 6, 7, 8 Page 3 of 23 EFTA00191216 Bates Range Description Privilege(s) Asserted Box #1 Indictment preparation binder containing meta- Work product P-003212 analysis charts of telephone/flight/grand jury 6(e) Thru information for a number of victim/witnesses, Contains information and P-003545 Nadia Marcinkova, an. 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 FBI Reports of March 2008 interviews of Work product P-003546 additional witness/victim located in New York 6(e) . Thru Contains information and P-003552 documents subject to investigative privilege. Also contains information and documents subject to privacy rights of victims who are not parties to this litigation Box 141 Printout of filenames from Federal Express Work product P-003553 subpoena response with Attorney notations 6(e) Thru P-003555B Box #1 Document entitled "Identified Numbers" with Work product P-003556 accompanying handwritten attorney list compiled 6(e) Thru from grand jury materials and attorney analysis of Contains information subject P-003562 records to investigative privilege Box #1 Folder entitled "Flight Manifests" containing 6(e) P-003563 manifests received pursuant to grand jury Contains information and Thru subpoena documents subject to P-003629 investigative privilege Box #1 File folder entitled "Recent Attorney Notes" Work product P-003630 containing handwritten attorney (Villafada) notes 6(e) Thru regarding document review and case strategy Investigative privilege P-003633 Deliberative process Box #1 File folder bearing victim name containing FBI Work product P-003634 interview report from May 2008, telephone Attorney-client privilege Thru activity report with attorney (Villafanana) 6(e) P-003646 handwritten notes, related grand jury material Investigative privilege Also contains information and documents subject to privacy rights of victims who are not parties to this litigation Page 4 of 23 EFTA00191217 Bates Range Description Privilege(s) Asserted Box #1 File folder entitled "Summary of Sexual Activity" Work product P-003647 containing chart bearing handwritten title "Sexual 6(e) Thru Activity — Summary" with meta-analysis of Investigative privilege P-003651 information, sorted by name of each Deliberative process victim/witness, including name and identifying Also contains information and information of each victim/witness documents subject to privacy rights of victims who are not parties to this litigation Box #1 File folder entitled "Victim Civil Suits" Not privileged. P-003652 Produced to counsel for Thru Petitioners P-003663 Box #1 File folder entitled "Research re JE Websites" Work product P-003664 containing attorney research Thru P-003678 Box #1 File folder entitled "Serene Cano (N.Y. AUSA)" Work product P-003679 containing attorney (Villafafla) handwritten notes Thru P-003680 Box #1 File folder entitled "Dr. Anna Salter" containing Work product P-003681 attorney (Villafafia) memo to expert witness and Investigative privilege Thru handwritten attorney notes P-003687 Box #1 la File folder entitled GO Interview" containing Work product P-003688 attorney handwritten notes of interview, and Investigative privilege Thru attorney handwritten notes regarding potential Also contains information P-003693 charges subject to privacy rights of victims who are not parties to this litigation Box #I File folder entitled "Research re Travel for Work product P-003694 Prostitution" containing attorney (Villafafia) 6(e) Thru handwritten notes regarding grand jury Investigative privilege P-003711 presentation, chart entitled "Brought to Epstein's Also contains information and House" with handwritten notes, Message Pad documents subject to privacy meta-analysis chart, summary of evidence related rights of victims who are not to one victim/witness, and relevant grand jury parties to this litigation information Box #1 Empty file folder bearing name of victim/witness Investigative privilege P-003712 Also contains information subject to privacy rights of victim who is not a party to this litigation Page 5 of 23 EFTA00191218 Bates Range Description Privilege(s) Asserted Box #1 File folder entitled "T(] M(]" containing grand 6(e) P-003713 jury subpoenas, motion and order to compel Documents under seal Thru testimony, and correspondence regarding same pursuant to court order P-003746 Box #1 File folder entitled containing 6(e) P-003747 subpoena and correspondence regarding same Thru P-003751 Box #1 File folder entitled "PBPD Investigative File" 6(e) P-003752 obtained via subpoena Investigative privilege Thru Also contains information and P-004295 documents subject to privacy rights of victims who are not parties to this litigation Box #1 File folder bearing name of victim/witness Work product P-004296 containing meta-analysis chart showing telephone 6(e) Thru calls, travel, and grand jury materials relevant to Investigative privilege P-004350 possible charges Also contains information and documents subject to privacy rights of victims who are not parties to this liti tion Box #1 File folder entitled "Daniel Documents Work product P-004351 53909-004" containing attorney research related Thru to bias issue P-004381 Box #1 File Folder entitled "FEDEX" containing 6(e) P-004382 documents obtained via subpoena Investigative privilege Thru P-004478 Box #1 File Folder entitled "State of Delaware Records" 6(e) P-004479 containing documents obtained in preparation for Investigative privilege Thru indictment Work product P-004551 Box #1 File folder entitled "Jet Blue Records" containing 6(e) P-004552 documents obtained via subpoena Work product Thru Investigative privilege P-004555 Also contains information and documents subject to privacy rights of victims who are not parties to this litigation Box #1 File folder entitled "FL EMPLOYMENT Investigative privilege P-004556 RECORDS" containing FDLE records on targets Work product Thni and witnesses obtained at attorney request P-004560 Pagc 6 of 23 EFTA00191219 Bates Range Description Privilege(s) Asserted Box # I Filed folder entitled "JANUSZ BANASIAK" Work product P-004561 containing attorney (Villafana) handwritten notes Investigative privilege Thru of interview P-004565 Box #1 File folder entitled "JANUSZ BANASIAK 6(e) P-004566 RECORDS 23-0001 THROUGH 23-" containing Work product Thm documents obtained via subpoena Investigative privilege P-004716 Also contains information and documents subject to privacy rights of victims who are not parties to this litigation Box #1 File folder entitled "IGOR ZINOVIEV" Work product P-004717 containing attorney research regarding witness Investigative privilege Thru P-004722 Box #1 File folder entitled "BEAR STEARNS Work Product P-004723 RESEARCH" containing attorney research Investigative privilege Thru regarding potential witness and subpoena P-004725 recipient Box #1 File folder entitled "LAWSUITS INVOLVING Work Product P-004726 EPSTEIN CORP'S" containing attorney research Investigative privilege Thru regarding Epstein's past personal and business P-004819 litigative practices Box #1 Filed folder entitled "SEC RECORDS" Work Product P-004820 containing attorney research regarding Epstein Investigative privilege Thru financial relationships P-004959 Box #1 File folder entitled "Message Pads" containing Work Product P-004960 selected items from evidence obtained via 6(e) Thru subpoena Investigative privilege P-005059 Also contains information and documents subject to privacy rights of victims who are not parties to this litigation Box #1 File folder bearing name of victim/witness Work Product P-005060 containing correspondence with counsel for 6(e) Thru victim/witness, attorney witness outline with Investigative privilege P-005081 attorney handwritten notes, attorney handwritten Also contains information and notes regarding witness reports and case documents subject to privacy preparation rights of victims who are not parties to this litigation Box #1 File folder entitled "New York Trip" containing Work product P-005082 attorney notes re witness interview Investigative privilege Thru P-005083 Page 7 of 23 EFTA00191220 Bates Range Description Privilege(s) Asserted P-005084 duu P-005107 are non responsive documents and have been removed Box #1 File folder entitled "ANNA SALTER" containing Work product P-005108 attorney research on select expert, use of experts Investigative privilege Thru at trials in child exploitation cases, and additional P-005193 research materials on offenders and victims Box #1 File folder entitled "Extra Copies" containing Work product P-005194 meta-analysis chart and 302's of victim/witnesses 6(e) Thru used in preparing indictment package Investigative privilege P-005300 Also contains information and documents subject to privacy rights of victims who are not parties to this litigation Box #1 File folder entitled "JUAN ALESSI 6(e) P-005301 STATEMENT" containing transcript obtained via Investigative privilege Thru subpoena P-005331 Box #1 File folder entitled "KEN LANNING" containing Work product P-005332 attorney research on select expert, including Investigative privilege Thru attorney handwritten notes P-005341 Box #1 File folder entitled "Info re Planes" containing 6(e) P-005342 correspondence regarding subpoenas and Investigative privilege Thru documents received in response to subpoenas P-005387 Box #1 File folder entitled "Police Reports & PC Work product P-005388 Affidavit" containing portions of police reports 6(e) Thru with attorney notes, related phone records, a list Investigative privilege P-005442 entitled "Victims" with identifying information Also contains information and and attorney handwritten notes, photographs and documents subject to privacy DAVID information, and additional attorney rights of victims who are not research regarding Epstein sexual activity parties to this litigation Box # I File folder entitled "[Victim name] Transcript of 6(e) P-005443 Interview & GJ Transcript" Investigative privilege Thru Also contains information and P-005496 documents subject to privacy rights of victims who are not parties to this litigation Box #1 File folder entitled "Bear Stearns Subpoena 6(e) P-005497 Resp." containing material received in response Investigative privilege Thru to subpoena P-005556 Page 8 of 23 EFTA00191221 Bates Range Description Privilege(s) Asserted Box #1 U.S. Attorney's Office Criminal Case File Jacket Work product P-005557 containing file opening documents, expert Deliberative process Thru witness payment documents P-005576 Box #1 U.S. Attorney's Office Asset Forfeiture Case File Work product P-005578 Jacket containing file opening and file closing Deliberative process Thru documents P-005583 Box #1 File folder entitled "6001 Immunity Request" 6(e) P-005584 containing internal memoranda seeking witness Work product and Thru immunity and correspondence with counsel for deliberative process (as to P-005606 witness regarding same internal memoranda) Investigative privilege Also contains information and documents subject to privacy rights of victims who are not parties to this litigation Box #2 File folder entitled "MASTER PHONE Work product P-005607 RECORDS" containing meta-analysis of all 6(e) Thru phone, travel, and grand jury data for all Investigative privilege P-005914 victim/witnesses for indictment preparation Also contains information and documents subject to privacy rights of victims who are not parties to this litigation Box #2 File folder bearing name of victim/witness Work product P-005915 containing meta-analysis of all phone, travel, and 6(e) Thru grand jury data related to that victim/witness for Investigative privilege P-005977 indictment preparation Also contains information and documents subject to privacy rights of victims who are not parties to this litigation Box #2 File folder bearing name of victim/witness Work product P-005978 containing meta-analysis of all phone, travel, and 6(e) Thru grand jury data related to that victim/witness for Investigative privilege P-006050 indictment preparation Also contains information and documents subject to privacy rights of victims who are not parties to this litigation Box #2 File folder bearing name of victim/witness Work product P-006051 containing meta-analysis of all phone, travel, and 6(e) Thru grand jury data related to that victim/witness for Investigative privilege P-006065 indictment preparation Also contains information and documents subject to privacy rights of victims who are not parties to this litigation Page 9 of 23 EFTA00191222 Bates Range Description Privilege(s) Asserted Box #2 File folder entitled "JANE DOE #4" containing Work product P-006066 meta-analysis of all phone, travel, and grand jury 6(e) Thru data related to that victim/witness for indictment Investigative privilege P-006220 preparation Also contains information and documents subject to privacy rights of victims who are not parties to this litigation Box #2 File folder entitled ""JANE DOE #12" containing Work product P-006221 meta-analysis of all phone, travel, and grand jury 6(e) Thru data related to that victim/witness for indictment Investigative privilege P-006222 preparation Also contains information and documents subject to privacy rights of victims who are not parties to this litigation Box #2 File folder entitled "CORRECTED PHONE Work product P-006223 RECORDS 5/31/07" containing meta-analysis of 6(e) Thru all phone, travel, and grand jury data related to all Investigative privilege P-006522 victims/witnesses for indictment preparation Also contains information and documents subject to privacy rights of victims who are not parties to this litigation Box #2 File folder entitled "[Victim Name] Phone Work product P-006523 Records" containing telephone records received 6(e) Thni in response to subpoena Investigative privilege P-006802 Also contains information and documents subject to privacy rights of victims who are not parties to this litigation Box #2 File folder entitled "Lists of Identified Phone Work product P-006803 Numbers" containing charts of information culled 6(e) Thru from grand jury materials, interviews, and other Investigative privilege P-006860 investigation, with attorney handwritten notes, Also contains information and and information to issue follow-up grand jury documents subject to privacy subpoena rights of victims who are not parties to this litigation Box #2 File folder entitled "EPSTEIN/KELLEN CELL Work product P-006861 PHONE RECORDS" containing documents 6(e) Thru received via subpoena with attorney handwritten Investigative privilege P-007785 notes and highlighting Also contains information and documents subject to privacy rights of victims who are not parties to this litigation Page 10 of 23 EFTA00191223 Bates Range Description Privilege(s) Asserted Box #2 Folder entitled "OLY GRAND JURY LOG: Work product P-007786 OLY-01 THROUGH OLY-50" containing 6(e) Thru subpoenas, correspondence regarding same, 6(e) Investigative privilege P-008120 letters, attorney handwritten notes regarding Also contains information and records received in response to subpoenas documents subject to privacy rights of victims who are not parties to this litigation Box #2 Handwritten flight logs received in response to 6(e) P-008121 subpoena Investigative privilege Thru P-008139 Box #2 Grand jury presentation folder containing Work product P-008140 attorney handwritten notes, typed outline with 6(e) Thru additional handwritten notes, complete indictment Investigative privilege P-008298 package dated 2/19/2008, victim list with Also contains information and identifying information, photographs, and documents subject to privacy summary of activity rights of victims who are not parties to this litigation Box #2 File folder entitled "FINAL AGREEMENTS" P-008299 containing subfolder entitled "Agrmts Filed in Thru State Court" (P-008300-P-008327 [not being P-008363 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 11th Circuit]) Box #2 File folder entitled "Lacerda Immunity Request" 6(e) P-008364 containing internal memoranda, Justice Work Product Thru Department documentation, and subpoena Deliberative Process P-008382 regarding immunity request Investigative privilege Box #2 File folder containing March IS, 2008 grand jury Work product P-008383 presentation materials, including "Operation Leap 6(e) Thru Year Revised Indictment Summary Chart (by Investigative privilege P-008516 victim)," grand jury materials, draft indictments, Deliberative process victim reference list, grand jury subpoena log Also contains information and documents subject to privacy rights of victims who are not parties to this litigation Page 11 of 23 EFTA00191224 Bates Range Description I'll% ilege(s) Asserted Box #2 6/25/2007 Letter from Gerald Lefcourt to Jeffrey P-008517 Sloman and Andrew Lourie Thru [pursuant to Court's Order, not being withheld as P-008535 privileged — will be produced to opposing counsel upon lift of stay by 11's Circuit] Box #2 Handwritten attorney notes to prepare for Work product P-008536 interview of Jane Doe #2 Investigative Privilege Thru Contains information subject P-008542 to privacy rights of victims who are not parties to this suit Box #2 Handwritten attorney notes regarding May 8, Work product P-008543 2007 grand jury presentation 6(e) Thru Investigative privilege P-008549 Contains information subject to privacy rights of victims who are not parties to this suit Box #2 File folder entitled "Most Recent Indictment & Work product P-008550 Good Cases" containing draft indictment and 6(e) Thru legal research Investigative privilege P-008615 Deliberative process Contains information subject to privacy rights of victims who are not parties to this suit Box #2 File folder entitled "FBI Summary Charts" Work product P-008616 containing chart prepared at direction of AUSA, Attorney-Client Privilege Thru containing victim names, identifying information, 6(e) P-008686 summary of activity, and other information Investigative privilege relevant to indictment Contains information subject to privacy rights of victims who are not parties to this suit Box #2 File folder entitled "[Victim name]/Jane Doe #4" Work product P-008687 containing phone records and meta-analysis of all 6(e) Thru phone, travel, and grand jury data related to that Investigative privilege P-008776 victim/witness for indictment preparation Contains information and documents subject to privacy rights of victims who are not parties to this suit Box #2 File folder entitled "[Victim name]/Jane Doe #5" Work product P-008777 containing handwritten notes and meta-analysis 6(e) Thi u of all phone, travel, and grand jury data related to Investigative privilege P-00SSOS that victim/witness for indictment preparation Contains information subject to privacy rights of victims who are not parties to this suit Page 12 of 23 EFTA00191225 Bates Range Description Privilege(s) Asserted Box #2 File folder entitled "[Victim name]/Jane Doe #6" Work product P-008809 containing meta-analysis of all phone, travel, and 6(e) Thru grand jury data related to that victim/witness for Investigative privilege P-008847 indictment preparation Contains information subject to privacy rights of victims who are not parties to this suit Box #2 File folder entitled "[Victim name]/Jane Doe #7" Work product P-008848 containing meta-analysis of all phone, travel, and 6(e) Thru grand jury data related to that victim/witness for Investigative privilege P-008862 indictment preparation Contains information subject to privacy rights of victims who are not parties to this suit Box #2 File folder entitled "[Victim name]/Jane Doe #8" Work product P-008863 containing meta-analysis of all phone, travel, and 6(e) Thru grand jury data related to that victim/witness for Investigative privilege P-008890 indictment preparation Contains information subject to privacy rights of victims who are not parties to this suit Box #2 File folder entitled "Certified Copy of State Case" P-008891 containing certified copy of Epstein state criminal Thru cases and change of plea transcript (not being P-009103 withheld as privileged — copy provided to opposing counsel] Box #2 File folder entitled "Meeting Timeline" Work product P-009104 containing Villafafia typed notes summarizing Deliberative process Thru meetings with opposing counsel prepared at P-009111 request of R. Alexander Acosta, with handwritten correction and typed guideline estimate Box #2 11/26/2008 Email from Roy Black to A. Marie P-009112 Villafafia and Karen Atkinson re Jeffrey Epstein Thru (work release) P-009113 [pursuant to Court's Order, not being withheld as privileged — will be produced to opposing counsel upon lift of stay by 1 l'h Circuit] Box #2 7/3/2008 Email from A. Marie Villafafia to Col. P-009114 M. Gauger at PBSO re Epstein work release with Thru attachment [not being withheld as privileged — P-009115 produced to opposing counsel] Box #2 12/6/2007 Letter from Jeffrey Sloman to Jay P. P-009116 Lefkowitz re Jeffrey Epstein (victim notification) Thru [pursuant to Court's Order, not being withheld as P-009125 privileged — will be produced to opposing counsel upon lift of stay by 11's Circuit]) Page 13 of 23 EFTA00191226 Bates Range Description Privilege(s) Asserted Box #2 File folder entitled "[Victim name]/Jane Doe #9" Work product P-009126 containing meta-analysis of all phone, travel, and 6(e) Tbru grand jury data related to that victim/witness for Investigative privilege P-009134 indictment preparation Contains information subject to privacy rights of victims who are not parties to this suit Box #2 File folder entitled "[Victim name]/Jane Doe Work product P-009135 #13" containing meta-analysis of all phone, 6(e) Thru travel, and grand jury data related to that Investigative privilege P-009141 victim/witness for indictment preparation Contains information subject to privacy rights of victims who are not parties to this suit Box #2 File folder entitled "[Victim name]/Jane Doe Work product P-009141A #12" containing meta-analysis of all phone, 6(e) Thru travel, and grand jury data related to that Investigative privilege P-00914IC victim/witness for indictment preparation Contains information subject to privacy rights of victims who are not parties to this suit Box #2 File folder entitled' Work product P-009142 containing meta-analysis o a p one, trave , and 6(e) Thru grand jury data related to that individual for Investigative privilege P-009152 indictment preparation Contains information subject to privacy rights of victims who are not parties to this suit Box #2 File folder entitled "Nadia Marcinkova" Work product P-009153 containing meta-analysis of all phone, travel, and 6(e) Thru grand jury data related to that individual for Investigative privilege P-009156 indictment preparation Contains information subject to privacy rights of victims who are not parties to this suit Box #2 File folder entitled "[Victim name]/Jane Doe #1" Work product P-009157 containing meta-analysis of all phone, travel, and 6(e) Thru grand jury data related to that victim/witness for Investigative privilege P-009208 indictment preparation Contains information subject to privacy rights of victims who are not parties to this suit Box #2 File folder entitled "[Victim name]/Jane Doe #2" Work product P-009209 containing meta-analysis of all phone, travel, and 6(e) Thru grand jury data related to that victim/witness for Investigative privilege P-009213 indictment preparation Contains information subject to privacy rights of victims who are not parties to this suit Page 14 of 23 EFTA00191227 Bates Range Description Privilege(s) Asserted Box #2 File folder entitled "[Victim name]/Jane Doe #3" Work product P-009214 containing meta-analysis of all phone, travel, and 6(e) Thru grand jury data related to that victim/witness for Investigative privilege P-009271 indictment preparation Contains information subject to privacy rights of victims who are not parties to this suit Box #2 File folder entitled 'Purpose of Travel Cases" Work product P-009272 containing attorney research and handwritten Thru notes P-009354 Box #2 File folder entitled "Interstate Commerce Cases" Work product P-009355 containing attorney research and handwritten Thru notes P-009403 Box #2 File folder entitled "Attorney Conflict Research" Work product P-009404 containing attorney research and handwritten Thru notes P-009536 Box #2 File folder entitled "Mann Act/Travel to Have Work product P-009537 Sex w/Minor" containing attorney research and Thru handwritten notes P-009574 Box #2 File folder entitled "Travel Act" containing Work Product P-009575 attorney research and handwritten notes Thru P-009603 Box #2 File folder entitled "Florida Work Product P-009604 Prostitution/Lewdness Statutes" containing Thru attorney research and handwritten notes P-009711 Box #2 Booklet entitled "Attorney General Guidelines for P-009712 Victim and Witness Assistance" [not being Thru withheld as privileged — produced to opposing P-009819 counsel] Box #2 File folder entitled "Corporate Liability Rsrch" Work Product P-009820 containing attorney research and handwritten Thru notes P-009965 Box #2 File folder entitled "Research re Knowledge of Work Product P-009966 Age Unnecessary" containing attorney research 6(e) Thru and handwritten notes and copy of grand jury P-010096 subpoena Page 15 of 23 EFTA00191228 Bates Range Description Privilege(s) Asserted Box #2 File folder entitled "Money Laundering" Work Product P-010097 containing attorney research and handwritten Thru notes P-010276 Box #2 File folder entitled "1960 & Aiding/Abetting" Work Product P-010277 containing attorney research and handwritten Thru notes P-010394 Box #2 File folder entitled "18 USC § 2255 Cases" Work Product P-010395 containing attorney research and handwritten Thru notes P-010488 Box #2 File folder entitled "Research re Overt Acts & Work Product P-010489 Witness Testimony" containing attorney research Thru and handwritten notes P-010509 Box #2 File folder entitled "Extradition" containing Work Product P-010510 attorney research and handwritten notes Thru P-010525 Box #2 File folder entitled "Rsrch re Crime Victims Work Product P-010526 Rights" containing attorney research, handwritten Deliberative Process Thru notes, draft victim notification letter, and draft P-010641 correspondence to Jay Leflcowitz (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 11'" Circuit) Box #2 File folder entitled "Immunity" containing Work Product P-010642 attorney research on granting immunity to Thru witnesses P-01650 Box #2 File folder entitled "Research re G.J. Transcript" Work Product P-010651 containing attorney research and draft pleadings 6(e) Thru re compelling production of grand jury transcript Deliberative process P-010659 with subpoena Box #2 File folder entitled "Research re GJ Transcript" Work Product P-010660 containing grand jury subpoena, 6(e) letters, 6(e) Thru attorney research and correspondence related to P-010757 subpoena Page 16 of 23 EFTA00191229 Bates Range Description Privilege(s) Asserted Box #2 File folder entitled "Original Proposed Ind." Work Product P-010758 containing draft indictment 6(e) Thru Deliberative process P-010793 Box #2 File folder entitled "Epstein" containing sample Work Product P-010794 indictments and attorney research re potential Thru charges with attorney notes P-010829 Box #2 File folder entitled "1591 & Money Laundering" Work Product P-010830 containing attorney research and handwritten Thru notes P-010853 Box #2 File folder entitled "18 USC 2425" containing Work Product P-010854 attorney research and handwritten notes Thru P-010876 Box #2 File folder entitled "Knowledge of Age" Work Product P-010877 containing attorney research and handwritten Thru notes P-010920 Box #2 File folder entitled "2423(b) Constitutionality and Work Product P-010921 Purpose of Travel" containing attorney research Thru and handwritten notes P-011049 Box #2 File folder entitled "Mistake not a Work Product P-011050 Defense" containing attorney research and Thru handwritten notes P-011212 Box #2 File folder entitled "Research re `Pandering— Work Product P-011213 containing attorney research and handwritten Thru notes P-011237 Box #2 File folder entitled "Research re Grand Jury Work Product P-011238 Instructions" containing attorney research and 6(e) Thru handwritten notes P-011319 Box #2 File folder entitled "Telephone = Facility of Work Product P-011320 Commerce" containing attorney research and Thru handwritten notes P-011361 Box #2 File folder entitled "Def of Prostitution" Work Product P-011362 containing attorney research and handwritten Thru notes P-011374 Page 17 of 23 EFTA00191230 Bates Range Description Privilege(s) Asserted Box #2 File folder entitled "Relevant Florida Statutes" Work Product P-011375 containing attorney research and handwritten Thru notes P-011456 Box #2 File folder entitled "Unit of Prosecution Work Product P-011457 Research" containing attorney research and Thru handwritten notes P-011626 Box #3 File folder entitled "Attorney Notes" containing Work Product P-011627 attorney handwritten and typed notes Thru P-011662 Box #3 File folder entitled "Drafts" containing draft 6(e) P-011663 indictments with attorney handwritten notes, draft Work Product Thru internal memoranda, relevant witness interview Deliberative Process P-011698 and reports and grand jury material and attorney Investigative Privilege P-012189 thru handwritten notes Contains information subject P-012361 to privacy rights of victims (gap was who are not parties to this scanning error) Box #3 File folder entitled "6/9/09 Signed Indictment" 6(e) P-011699 containing signed indictment package dated Work product Thru 6/9/2009 with corrections Deliberative process P-011777 Box #3 File folder entitled "6/12/09 Victim Notif. Log" Work product P-011778 containing chart with victim contact information Thru and attorney notes regarding dates and type of P-011788 contacts Box #3 File folder entitled "Breach Memo" containing Work product P-011789 memorandum analyzing breach of Non- Deliberative process Thru Prosecution Agreement with attachments P-011879 Box #3 File folder entitled "Overt Act Lists" containing Work product P-011880 handwritten notes cross-checking all overt acts Attorney-client privilege Thru alleged in draft indictment by victim and typed Deliberative process P-011922 overt act summary charts for indictment 6(e) preparation Page 18 of 23 EFTA00191231 Bates Range Description Privilege(s) Asserted Box #3 Folder entitled "Responses to Arguments from JE Work product P-011923 Counsel" containing: Deliberative process Thru ■ 7/13/2007 letter from Lilly Ann Sanchez 6(e) P-011966 to Andrew Lourie with handwritten Attorney-Client Privilege attorney (Lourie) notes; ■ 6/25/2007 letter from Gerald Lefcourt to Jeffrey Sloman, Matt Menchal, Andrew Lourie, and Marie Villaftuia with handwritten attorney (Villafafia) notes; ■ 6/25/2007 email from Andrew Lourie to Man Menchel and Marie Villafafia entitled "Thoughts on Lefcourt's letter" Handwritten and typed attorney (Villafafia) notes regarding math themes raised by Epstein counsel Box #3 Composition book entitled "Operation Leap Work product P-011967 Year" containing attorney handwritten notes Investigative privilege Thru regarding investigation and case strategy 6(e) P-012016 Contains information subject to privacy rights of victims who are not parties to this litigation Box #3 Motion of Jeffrey Epstein to Intervene and to 6(e) P-012017 Quash Grand Jury Subpoenas and Incorporated Thru Memorandum of Law P-012055 Box #3 Affidavit of Roy Black, Esq. in Support of 6(e) P-012056 Motion of Jeffrey Epstein to Intervene and to Thru Quash Grand Jury Subpoenas P-012088 Box #3 United States' Response to Motion of Jeffrey 6(e) P-012089 Epstein to Intervene and to Quash Grand Jury Thru Subpoenas and Cross-Motion to Compel P-012129 Box #3 Declaration of Joseph Recarey 6(e) P-012130 Thru P-012150 Box #3 Ex Parte Declaration Number One in Support of 6(e) P-012151 United States' Response to Motion to Quash Investigative Privilege Thru Subpoenas Also contains information P-012167 subject to privacy rights of victims who are not parties to this litigation Page 19 of 23 EFTA00191232 Bates Range Description Privilege(s) Asserted Box #3 Ex Parte Declaration Number Two in Support of 6(e) P-012168 United States' Response to Motion to Quash Investigative Privilege Thru Subpoenas P-012170 Box #3 Supplement to Ex Parte Declaration Number One 6(e) P-012171 in Support of United States' Response to Motion Investigative Privilege Thru to Quash Subpoenas Also contains information P-012173 subject to privacy rights of victims who are not parties to this litigation Box #3 Draft of September 2009 letter from Marie Work Product P-012174 Villafana to Roy Black regarding breach of Non Attorney-Client Privilege Thru Prosecution Agreement with handwritten attorney Deliberative Process P-012176 (Villafafia) notes Box #3 Undated handwritten attorney (Villaftula) notes Work Product P-012177 regarding negotiations and allegations Attorney-Client Privilege Thru Deliberative Process P-012178 Box #3 File Folder entitled "FBI G.J. Log" containing 6(e) P-012179 copy of FBI grand jury subpoena log with Work Product Thru attorney (Villafafla) handwritten notes Investigative Privilege P-012188 Also contains information subject to privacy rights of victims who are not parties to this litigation Box #3 File folder entitled "Key Documents" containing 6(e) P-012362 correspondence between AUSA and case agent Work Product Thru regarding indictment prep questions, victim Attorney-Client privilege P-012451 identification information, corrections to draft Investigative Privilege indictment, indictment preparation timeline, key Also contains information grand jury material subject to privacy rights of victims who are not parties to this litigation Box #3 File folder entitled "Victim List" containing list Work Product P-012451 of victims with dates of birth and age information Investigative Privilege Thru Also contains information P-012452 subject to privacy rights of victims who are not parties to this litigation Page 20 of 23 EFTA00191233 Bates Range Description Privilege(s) Asserted Box #3 Complete indictment package marked "Originals Work-product P-012453 12/12/07" Deliberative process Thru 6(e) P-012623 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 Folder entitled "(Victims) Additional 302's" Investigative Privilege P-012624 containing reports of interviews conducted in Also contains documents Thru June 2007, October 2007, and March 2008. subject to privacy rights of P-012653 victims who are not parties to this litigation Box #3 3-ring binder entitled "Child Molesters: A Work-product P-012654 Behavioral Analysis" with attorney (Villafafia) Thru handwritten notes P-012864 Box #3 Indictment preparation binder containing: Work Product P-012865 witness/victim list with identifying information, Deliberative Process Thru sexual activity summary, telephone call summary 6(e) P-013226 chart, attorney (Villafafia) handwritten notes, Also contains documents 302s, portions of state investigative file, attorney subject to investigative (Villafafia) typed notes, relevant pieces of grand privilege July materials, telephone records/flight records Also contains documents analysis charts, victim/witness photographs, subject to privacy rights of DAVID records, NCICs, and related materials for victims who are not parties to persons identified as Jane Does #9, 10, 11, 12, 13, this litigation 14 Box #3 April 23, 2008 Memo from Jeffrey Sloman to Privacy Act P-013227 Office of Professional Responsibility re Self Reporting, Corrected Version of the previously submitted April 21, 2008 Letter to OPR Box #3 April 21, 2008 Letter from Jeffrey Sloman to Privacy Act P-013226 Office of Professional Responsibility re Self Thru Reporting P-013230 Box #3 April 22, 2008 Letter from A. Marie Villafafia to Privacy Act P-013231 Office of Professional Responsibility re Self- Thru Report of Allegation of Conflict ofInterest P-013239 Page 21 of 23 EFTA00191234 Bates Range Description Privilege(s) Asserted Box #3 April 21, 2008 Letter from Jeffrey Sloman to Privacy Act P-013240 Office of Professional Responsibility re Self Thru Reporting with attachments P-013247 Box #3 Emails between Richard Sudder, Assistant Attorney-Client Privilege P-013248 General Counsel, Executive Office for United Thru States Attorneys, and Benjamin Greenberg, First P-013251 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 Box #3 Emails between Richard Sudder, Assistant Attorney-Client Privilege P-013252 General Counsel, Executive Office for United Thru States Attorneys, and Benjamin Greenberg, First P-013253 Assistant U.S. Attorney, Southern District of Florida, regarding Recusal matter, dated July 28, August 3, and August 24, 2011 Box #3 Emails between Richard Sudder, Assistant Attorney-Client Privilege P-013254 General Counsel, Executive Office for United Thru States Attorneys, and Benjamin Greenberg, First P-013257 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 Box #3 Emails between Richard Sudder, Assistant Attorney-Client Privilege P-013258 General Counsel, Executive Office for United Thru States Attorneys, and Benjamin Greenberg, First P-013259 Assistant U.S. Attorney, Southern District of Florida, regarding Format Notice of Office-wide Recusal of Southern District of Florida dated July 28 and August 3, 2011 Box #3 Email from Richard Sudder, Assistant General Attorney-Client Privilege P-013260 Counsel, Executive Office for United States Thru Attorneys, to Wifredo Ferrer (U.S. Attorney, P-013262 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 MackSJSAEO), Thomas Anderson (USAEO), Tapken (USAEO), James Read (USAEO) Page 22 of 23 EFTA00191235 Bates Range Description Privilege(s) Asserted Box #3 Emails between Richard Sudder, Assistant Attorney-Client Privilege P-013263 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 Villafafia to Benjamin Greenberg summarizing Jeffrey Epstein Investigation Box #3 Emails between Peter Mason, Executive Office Attorney-Client Privilege P-013272 for United States Attorneys, and Dexter Lee, Thru 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 EFTA00191236 U.S. Department of Justice United States Attorney Southern District of Florida 500 S. Ausfrallan Ave, Ste 400 West Palm Beach, FL 33401 (561)820-8711 Facsimile: (561)820-8777 July 19, 2013 DELIVERY BY FEDERAL EXPRESS Brad Edwards, Esq., Farmer Jaffe Weissing Edwards Fistos Lehrman 425 N Andrews Ave Ste 2 Fort Lauderdale, FL 33301-3268 Re: Jane Doe #1 and Jane Doe #2'. United States Dear Brad: Enclosed please find: (1) One DVD containing documents Bates Stamped 000001 thru 000979; (2) Documents bearing Bates Nos. P-003652 thru P-003663; (3) Documents bearing Bates Nos. P-008300 thru P-008343; (4) Documents bearing Bates Nos. P-008891 thru P-009103; (5) Documents bearing Bates Nos. P-009114 thru P-009115; (6) Documents bearing Bates Nos. P-009712 thru P-009819; (7) A copy of the Privilege Log that was filed with the Court; and (8) A copy of the Responses to your Requests for Admissions that were filed with the Court. Please let me know if you have any difficulties with any of the copies. Sincerely, Wifredo A. Ferrer Ui iM4 Sues Atto • ey By: A. Mane Vi afafia Assistant United States Attorney cc: Dexter Lee, Esq. EFTA00191237 SECOND SUPPLEMENTAL PRIVILEGE LOG Bates Range Description Privilege(s) Asserted Box #4 P-013970 thru P- 1 5/18/2007 email from Marie Villafafia to Work Product Matt Menchel informing him of intent to 6(e) subpoena Roy Black's private investigator Deliberative Process and steps taken to obtain DOJ authorization Investigative Privilege 2 5/21/2007 email from Marie Villafafta to Work Product Myesha Braden (CEOS) re 2423(b) charging 6(e) question Deliberative Process Investigative Privilege 3 5/21/2007 email from Marie Villafafia to Work Product Matt Menchel and Jeff &man regarding 6(e) guidance on grand jury presentation Deliberative Process 4 6/12/2007-7/6/2007 series of emails between Work Product Marie Villafafia and AU SAs Serene Nakano Investigative Privilege and James Cott re an earlier unrelated Privacy Act investigation of Epstein 5 7/3/2007-7/13/2007 email chain between 6(e) Matt Menchel and Marie Villafafia regarding Work Product disagreement on Menchel's plea negotiations Deliberative Process and written request for meeting between Investigative Privilege USAO management and victims 6 7/16/2007 email from Marie Villafafia to 6(e) Matt Menchel and Andrew Lourie regarding Work Product correspondence from Roy Black and Motion Deliberative Process to Quash Investigative Privilege 7 7/18/2007 emails from Marie Villafafia to 6(e) Andrew Lourie and Matt Menchel regarding Work Product Motion to Quash grand jury subpoena and Deliberative Process supporting affidavit filed by Roy Black Investigative Privilege 8 7/19/2007 email chain between Marie 6(e) Villafafta, Andrew Lourie, Matt Menchel, Work Product S/A Jason Richards and S/A Eliasib Ortiz Deliberative Process regarding potential service of target letters Investigative Privilege Attorney-Client Privilege 9 7/26/2007 email from Marie Villafafia to 6(e) Matt Menchel and Andrew Lourie regarding Work Product proposed changes to the indictment Deliberative Process Investigative Privilege Page 1 of 12 EFTA00191238 Bates Range Description Privilege(s) Asserted 10 8/2/2007 email drom Marie Villafafia to Jeff Work Product Sloman, Matt Menchel, and Andrew Lourie Deliberative Process with draft response to Epstein counsel Investigative Privilege regarding agreement 11 7/31/2007-8/2/2007 email chain between Jeff Work Product Sloman, Matt Menchel, Andrew Lourie, and Deliberative Process Marie Villafafia regarding plea negotiations Investigative Privilege 12 8/3/2007 Email from Marie Villafafia to Matt Work Product Menchel, Andrew Lourie, Jeff Sloman, and Deliberative Process Karen Atkinson regarding draft response to Investigative Privilege correspondence from Epstein counsel and planned investigative steps if agreement cannot be reached. 13 Emails dated 8/6/2007 from Marie Villafafia Work Product to Cyndee Campos/Frederica Devlin and Jeff Deliberative Process Sloman regarding Matt Menchel's correspondence prior to his departure. 14 8/7/2007 email chain between Marie Work Product Villafafia, Cyndee Campos, and Alex Acosta Deliberative Process regarding meeting to discuss Epstein matter Investigative Privilege 15 8/7/2007 email from Marie Villafafia to Work Product Andy Lourie regarding deadline set for Deliberative Process Epstein plea and Epstein's plan to demand a Investigative Privilege meeting with CEOS. 16 8/7/2007 email from Marie Villafafia to Work Product Andrew Oosterbaan regarding Epstein Deliberative Process meeting Investigative Privilege 17 8/7/2007 email chain from Jeff Sloman to Work Product Andrew Oosterbaan, Mark Villafafia, and Deliberative Process Alex Acosta regarding Epstein meeting Investigative Privilege 18 8/8/2007 emails between Marie Villafafia Work Product and Andrew Oosterbaan (CEOS) regarding Deliberative Process case staffing and plea negotiations Investigative Privilege 19 8/8/2007 email chain between Andrew Work Product Oosterbaan, Alex Acosta, Marie Villafafia, Deliberative Process Cyndee Campos, Jeff Sloman, and Andrew Investigative Privilege Lourie regarding "The meeting on Epstein" 20 8/10/2007 Electronic correspondence from Work Product Marie Villafafia to expert witness regarding topics for expert testimony 21 9/21/2007 emails between Marie Villafafia Work Product and Andrew Lourie, Rolando Garcia, Karen Deliberative Process Atkinson, and John McMillan regarding revisions to the non-prosecution agreement Page 2 of 12 EFTA00191239 Bates Range Description Privilege(s) Asserted 22 9/24/2007 series of emails between Marie Work Production Villafafia, Alex Acosta, and Andrew Lourie Deliberative Process regarding plea negotiations and revisions to non-prosecution agreement 23 9/23/2007-9/24/2007 series of emails Work Product between Alex Acosta, Marie Villafafia, Deliberative Process Andrew Lourie, Rolando Garcia, and Jeff Sloman regarding proposed revisions to non- prosecution agreement 24 4/29/2008 email from Marie Villafafia to Work Product Robert Senior, Jeff Sloman, Karen Atkins, 6(e) on Rolando Garcia re grand jury presentation Deliberative Process Investigative Privilege 25 5/23/2008-5/27/2008 emails between Marie Work Product Villafafia, Robert Senior, J,11Sloman, Karen 6(e) Atkinson, Nesbitt Kuyrketidall (FBI), and Deliberative Process Jason Richards (FBI) re status of Investigative Privilege investigation, indictment review, grand jury preparation, and Epstein's attempt to revisit plea negotiations 26 5/22/2007 email from Andy Lourie to Matt Work Product Menchel and Jeff Sloman (cc: Marie Deliberative Process Villafaita) re letter received from Gerald Lefcourt discussing a meeting to discuss Epstein investigation 27 5/23/2007 email from Jason Richards to Work Product Marie Villafafia re extradition research A/C privilege Investigative Privilege 28 5/23/2007 emails between Karen Atkinson Work Product and Marie Villafafia regarding decision to Deliberative Process meet with counsel for Epstein 29 4/2/2008 emails between Marie Villafafia, Deliberative Process Alex Acosta, Jeff Sloman, Karen Atkinson, Work Product Robert Senior, Rolando Garcia, and Nesbitt Attorney-Client Privilege Kuyrkendall regarding efforts by Jay Lefkowitz and Ken Starr to speak with Alex Acosta and instructions to direct question to Marie Villafalla and Karen Atkinson 30 3/19/2008-3/21/2008 emails between Marie Work Product Villafafia, Drew Oosterbaan (CEOS), 6(e) Gelber (CEOS), Jeff Sloman, and Deliberative Process Robert Senior about meeting between Investigative Privilege Esptein counsel and CEOS and follow-up questions Page 3 of 12 EFTA00191240 Bates Range Description Privilege(s) Asserted 31 4/4/20084/7/2008 emails between Marie Work Product Villafafta, Robert Senior, Andrew 6(e) Oosterbaan, and Jeff Sloman regarding status Deliberative Process of CEOS review of Epstein matter 32 4/11/2008-4/23/2008 emails between Marie Work Product Villafafla, Jeff Sloman, and Dexter Lee Deliberative Process regarding self-reporting to OPR false Privacy Act allegations of ethics violations 33 5/15/2008-5/16/2008 emails between Jeff Work Product Sloman, Marie Villafafia, and Robert Senior Deliberative Process regarding receiving final approval from DC 34 5/7/2008-5/9/2008 emails between Marie Work Product Villafafia, Robert Senior, Jeff Sloman, 6(e) Nesbitt Kuyrkendall, and Jason Richards Deliberative Process regarding awaiting approval from DC and Attorney-Client Privilege status of ongoing investigation Investigative Privilege 35 5/2/2008 emails between Robert Senior, 6(e) Marie Villafafta, Karen Atkinson, Nesbitt Work Product Kuyrkendall, and Jason Richards regarding Attorney-Client Privilege developments in Epstein investigation and Investigative Privilege impact on grand jury presentation Deliberative Process 36 4/29/2008-5/2/2008 emails between Marie 6(e) Villafafia and Jeff Sloman regarding contact Work Product by Epstein counsel and victims and draft Deliberative Process letter to counsel for Epstein Investigative Privilege 37 11/29/2006-12/1/2006 emails between Marie Work Product Villafafia and prison employee regarding Investigative Privilege attempted contact with potential witness Privacy Act 38 7/19/2007 email from Marie Villafafia to Work Product Andrew Lourie and Matt Menchel regarding 6(e) planned service of target letters Investigative Privilege Deliberative Process 39 5/18/2007 emails between Marie Villafafia Work Product and expert witness regarding securing pre- 6(e) indictment consultation contract Investigative Privilege 40 7/3/2007-7/4/2007 emails between Marie 6(e) Villafafla and Andrew Lourie regarding Work Product extension of time to respond to subpoenas Investigative Privilege requested by Lilly Ann Sanchez and possible Deliberative Process resolution of case 41 9/19/2007-9/20/2007 emails between Marie Work Product Villafafta, Andrew Lourie, and Rolando Deliberative Process Garcia regarding plea negotiations with counsel for Epstein Page 4 of 12 EFTA00191241 Bates Range Description Privilege(s) Asserted 42 6/26/2007 email from Marie Villafafia to Jeff Work Product Sloman, Matt Menchel, and Andrew Lourie Deliberative Process addressing arguments regarding interstate nexus for 2422(b) charges 43 3/28/2008 emails between Marie Villafafia, Work Product Nesbitt Kuyrkendall, Jeff Sloman, Robert 6(e) Senior, and Karen Atkinson regarding status Investigative Privilege of DC review of case and preparing for grand Deliberative Process jury presentation 44 7/31/2007 email from Marie Villafafia to Jeff Work Product Sloman, Matt Menchel, and Andrew Lourie Deliberative Process summarizing proposed plea terms as per Menchel recommendation 45 8/8/2007 email from Marie Villafafia to Work Product Drew Oosterbaan regarding plea Investigative Privilege negotiations, guideline calculations, and Deliberative Process assistance in preparing case for trial 46 8/8/2007 email from Marie Villafafia to Alex Work Product Acosta, Cyndee Campos, Jeff Slonum, 6(e) Andrew Lourie, and Drew Oosterbaan Investigative Privilege regarding planning meeting with Epstein Deliberative Process counsel and service of target letters 47 6/14/2007-6/21/2007 emails between Marie 6(e) Viilafalla, Karen Atkinson, Andrew Lourie, Work Product Matt Menchel, and Jeff Sloman regarding Deliberative Process addendum to Pros Memo, grand jury Investigative Privilege presentation and changes to indictment, and meeting with counsel for Epstein 48 8/2/2007 emails between Matt Menchel, Jeff Work Product Sloman, Andy Lourie, and Marie Villafafia Deliberative Process regarding letter received from Lilly Ann Sanchez 49 3/19/2008-3/27/2008 emails between Jeff Work Product Sloman, Bob Senior, Karen Atkinson, Deliberative Process Rolando Garcia, Nesbitt Kurykendall, and Investigative Privilege Jason Richards regarding waiting for DC's 6(e) decision regarding Epstein's challenges to NPA; status of ongoing investigation; problems with Epstein's counsel contacting victims in the guise of deposing them for the state criminal action; and securing pro bono counsel for those victims to represent them in connection with the depositions Page 5 of 12 EFTA00191242 Bates Range Description Privilege(s) Asserted 50 3/31/2008 emails between Marie Villafafia, 6(e) Jeff Sloman, Robert Senior, and Nesbitt Work Product Kuyrkendall regarding status of ongoing Deliberative Process investigation, planned presentation to grand Investigative Privilege jury, continued delay in awaiting decision from Washington, DC, and problems with victims being harassed 51 4/10/20084/18/2008 emails between Marie 6(e) Villafafia, Robert Senior, Karen Atkinson, Work Product Nesbitt Kuyrkendall, and Jeff Sloman about Deliberative Process continued delay in presenting case to grand Investigative Privilege jury due to failure to receive decision from DC, status of grand jury presentation and ongoing investigation 52 4/21/2008-5/1/2008 emails between Marie 6(e) Villafaila, Robert Senior, Jeff Sloman, Karen Work Product Atkinson, Nesbitt Kuyrkendall, and Drew Deliberative Process Oosterbaan about continued delay in Investigative Privilege presenting case to grand jury due to failure to receive decision from DC, status of grand jury presentation and ongoing investigation, staffing of case for purposes of trial, and meeting to prepare for grand jury presentation 53 5/19/2008-5/22/2008 emails between Marie 6(e) Villafafia, Karen Atkinson, Robert Senior, Work Product and Jeff Sloman regarding preparation for Deliberative Process grand jury presentation; communication with Investigative Privilege S/A Kuyrkendall regarding plea negotiations; and status of ongoing investigation 54 8/15/2008 email from Marie Villafafia to Work Product Alex Acosta, Jeff Sloman, Robert Senior, Deliberative Process Karen Atkinson, and Dexter Lee containing draft response to 8/15/2008 email from Jay Lefkowitz regarding implementation of the NPA. (Redacted version produced to opposing counsel) 55 12/3/2007-12/5/2007 correspondence Work Product between Alex Acosta, Jeff Sloman, Marie Deliberative Process Villafafta, Nesbitt Kuyrkendall, Cyndee 6(e) Campos, and Annette Castillo about drafting Attorney-Client Privilege and sending the 12/4/2007 Acosta letter to Ken Starr Page 6 of 12 EFTA00191243 Bates Range Description Privilege(s) Asserted 56 12/18/2007 emails from other AUSAs to Work Product Marie Villaftula regarding other instances of 6(e) charging 2422(b) based only on the use of a telephone 57 11/28/2007 correspondence between Marie Work Product Villafafta, Andrew Lourie, Drew Oosterbaan, Deliberative Process and Rolando Garcia regarding Lefkowitz 11/27/2007 email discussing presentation to DAAG 58 11/19/2007-11/28/2007 emails between Work Product Marie Villafafla, Nesbitt Kuyrkendall, Jason Deliberative Process Richards, and Jeff Sloman regarding drafting Attorney-Client Privilege victim notification letter of upcoming plea 6(e) Also contains information subject to privacy rights of victims who are not parties to this litigation 59 12/11/2007 email from Marie Villafafia to Work Product Jeff Sloman and Alex Acosta regarding call Deliberative Process with lawyer for Jane Doe #2 (T.M.) 60 12/3/2007 emails between Marie Villafatta, Work Product Alex Acosta, and Jeff Sloman regarding Deliberative Process history of plea negotiations and drafting response to correspondence from Jay Lekowitz and Ken Starr 61 8/10/2007 email from Marie Villafafia to Work Product Andrew Lourie regarding target letters and staying motion to compel production of computers 62 8/30/2007 email from Marie Villafafta to Jeff Work Product Sloman, Andrew Lourie, Drew Oosterbaan, John McMillan, and Karen Atkinson regarding press coverage of meeting with Ken Starr 63 9/4/2007-9/6/2007 emails between Marie Work Product Villafafia and Jeff Sloman regarding planned Deliberative Process participation of FBI ASAIC at 9/7/2007 meeting with Epstein defense team 64 9/6/2007 emails between Marie Villafafia, Work Product Jeff Sloman, Andrew Lourie Drew Deliberative Process Oosterbaan, and Rolando Garcia regarding status of plea negotiations, draft agreements, and need to confer with victims Page 7 of 12 EFTA00191244 Bates Range Description Privilege(s) Asserted 65 9/11/2007 emails between Marie Villafafia, Work Product John McMillan, Drew Oosterbaan, Nesbitt Deliberative Process Kuyrkendall, and Jason Richards regarding Investigative Privilege changes to the draft indictment and status of Attorney-Client Privilege plea negotiations 66 9/10/2007-9/11/2007 emails between Marie Work Product Villafafta, Alex Acosta, and Jeff Sloman Deliberative Process regarding modifications to the proposed Non-Prosecution Agreement 67 9/13/2007 emails from Marie Villafafta to Work Product Andrew Lourie, Alex Acosta, Jeff Sloman, Deliberative Process Rolando Garcia, and Karen Atkinson regarding plea to federal charges recommending 18 USC 403 or 1512(d), or 47 USC 223(a)(1)(B); response that Epstein was only willing to plead to assault on the plane; and rejection of facts supporting assault on the plane charge 68 9/13/2007-9/14/2007 emails regardingMarie Work Product Villafafla research regarding victim trust fund set up in Alaska child exploitation case 69 9/17/2007-9/19/2007 emails between Marie Work Product Villafafia, Rolando Garcia, Andrew Lourie, Deliberative Process Alex Acosta, Karen Atkinson, and John McMillan regarding negotiations of a federal plea and a non-prosecution agreement 70 9/20/2007 emails between Marie Villafafta Work Product and Andrew Lourie regarding plea Deliberative Process agreement to federal charges and factual proffer 71 9/20/2007-9/24/2007 emails between Alex Work Product Acosta, Marie Villafafia, and Andrew Lourie Deliberative Process regarding revisions to the non-prosecution agreement 72 9/21/2007 email from Marie Villafafia to Work Product Alex Acosta, Rolando Garcia, Karen Deliberative Process Atkinson, and Andrew Lourie regarding review ofEpstein indictment package 73 9/24/2007 emails between Marie Villafafia Work Product and Rolando Garcia regarding notifying Deliberative Process Palm Beach Police Chief and victims about agreement Page 8 of 12 EFTA00191245 Bates Range Description Privilege(s) Asserted 74 9/24/2007-9/25/2007 emails between Alex Work Product Acosta, Marie Villafafia, Andrew Lourie, and Deliberative Process Rolanda Garcia regarding Letkowitz email about keeping agreement from becoming public and confidentiality provision in agreement 75 10/5/2007-10/16/2007 emails between Marie Work Product Villafafia, Jeff Sloman, and Alex Acosta re Deliberative Process selection of Special Master and negotiation of revision/addendum to Non-Prosecution Agreement 76 11/14/2007-11/19/2007 emails between WP AMCV, Jason Richards, Jeff Sloman, DP Rolando Garcia, Alex Acosta, and Karen Attorney-Client Privilege Atkinson regarding communications with State Attorney's Office and Sheriff's Office in an attempt to insure that Epstein was ineligible for work release 77 11/19/2007 emails between AMCV, Jeff WP Sloman, and Rolando Garcia about efforts by DP Epstein's counsel to change date for change of plea 78 11/8/2007-11/14/2007 emails between WP AMCV, Jeff Sloman, Karen Atkinson, and DP Jason Richards regarding response to Attorney-Client Privilege objections raised by Epstein counsel and efforts to change date for guilty plea 79 10/31/2007 email from Nesbitt Kurykendall WP to AMCV regarding attempts to interview Attorney-Client Privilege additional witnesses/victims IP 6(e) Also contains information subject to privacy rights of victims who are not parties to this litigation 80 10/22/2007-10/31/2007 emails between Jeff WP Sloman, Alex Acosta, and AMCV regarding DP negotiation of Addendum to Non- Prosecution Agreement and drafting of correspondence regarding scope of Special Master's duties and selection criteria 81 10/19/2007 emails between Jeff Sloman and WP AMCV regarding Special Master's Selection DP of Attorney Representative Page 9 of 12 EFTA00191246 Bates Range Description Privilege(s) Asserted 82 10/18/2007 emails between AMCV and Jeff WP Sloman regarding Epstein's request to delay DP his change of plea 83 11/2/2007-11/5/2007 emails between AMCV WP and Jeff Sloman regarding drafting DP 11/5/2007 letter from Sloman to Lefkowitz 84 11/5/2007-11/7/2007 emails from AMCV to WP Jeff Sloman inquiring about status of matter DP and contact by Epstein investigators with victims 85 12/6/2007 emails between AMCV, Andrew WP Lourie, Cyndee Campos, Jeff Sloman, Alex DP Acosta, Karen Atkinston, and Nesbitt Kuyrkendall regarding correspondence from Ken Starr, request for a meeting from Epstein counsel, and need to notify victims of upcoming plea 86 12/6/2007-12/7/2007 emails between WP AMCV, Cyndee Campos, Karen Atkinson, DP Jeff Sloman, and Alex Acosta regarding draft victim notification letter 87 9/10/2007-/I4/2007 emails between AMCV, WP Andrew Lourie, Jeff Sloman, Karen DP Atkinson, Rolando Garcia, Shawn Ball, and 6(e) Alex Acosta regarding final plea III negotiations, finalizing details with State Attorney's Office and final revisions to indictment package 88 9/10/2007 email from AMCV to Jeff Sloman WP and John McMillan regarding Acosta inquiry 6(e) about FBI investigation into State grand jury IP proceeding 89 11/29/2007-12/1/2007 emails between WP AMCV, Alex Acosta, Jeff Sloman, Cyndee DP Campos, and Andrew Lourie regarding draft response to Jay Lefkowitz and victim notification letters 90 12/6/2007-12/7/2007 emails between WP AMCV, Nesbitt Kuyrkendall, Jason DP Richards, Jeff Sloman, Cyndee Campos, 6(e) Annette Castillo, Karen Atkinson, and Attorney-Client Privilege Shawn Ball regarding request from State IP Attorney's Office for draft plea proffer Page 10 of 12 EFTA00191247 Bates Range Description Privilege(s) Asserted 91 12/14/2007 email from AMCV to Jeff WP Sloman, Alex Acosta, and Janice LeClainche DP regarding state cases mentioned by Epstein's counsel 92 12/14/2007 email from AMCV to Alex WP Acosta, Jeff Sloman, Rolando Garcia, and DP Karen Atkinson with draft letters to State Attorney's Office and victims 93 12/9/2007-12/12/2007 emails between WP AMCV, Jeff Sloman, Jason Richards, Nesbitt DP Kuyrkendall, Annette Castillo, Karen Atkinson, and Rolando Garcia regarding drafting response to personal attacks and upcoming meeting with Ken Starr 94 12/12/2007 emails between AMCV, WP Frederica Devlin, and Bob Senior regarding DP planning indictment review 6(e) 95 12/17/2007 email from AMCV to Jeff WP Sloman inquiring about case status and DP informing Sloman regarding agent concern about victim notifications 96 3/10/2008-3/12/2008 emails between WP AMCV, Robert Senior, Myesha Braden, DP Krishna Patel, Nesbitt Kuyrkendall, E.J. Attorney-client privilege Yera, and Karen Atkinson about Epstein attempts to contact victims and finding counsel for victims 97 3/12/2008-3/17/2008 emails between WP AMCV, Nesbitt Kuyrkendall and E.J. Yera Attorney client privilege regarding search warrant application and IP execution of search warrant Also contains information subject to privacy rights of victims who are not parties to this litigation 98 3/14/2008-3/17/2008 emails between WP AMCV, Nesbitt Kuyrkendall, Jason DP Richards, and Robert Senior regarding 6(e) corrections to indictment package and Attorney-Client Privilege proposed grand jury presentation Also contains information subject to privacy rights of victims who are not parties to this litigation Page 11 of 12 EFTA00191248 Bates Range Description Privilege(s) Asserted 99 3/14/2008-3/19/2008 emails between WP AMCV, Nesibtt Kuyrkendall, Jason DP Richards, Robert Senior, Jeff Sloman, Karen Attorney-client privilege Atkinson, and Rolando Garcia about Epstein Also contains information attempts to contact victims and finding subject to privacy rights of counsel for victims victims who are not parties to this litigation 100 3/14/2008 emails between AMCV, Rolando WP Garcia, Karen Atkinson, Frederica Devlin, DP and Shawn Ball regarding complete 6(e) indictment package for Robert Senior final review 101 3/12/2008 emails between AMCV, Drew WP Oosterbaan, and Myesha Braden regarding CEOS meeting with Epstein counsel 102 3/5/2008-3/6/2008 emails between AMCV, WP Alex Acosta, Jeff Sloman, Drew Oosterbaan, DP Robert Senior, Myesha Braden, Rolando 6(e) Garcia, and Karen Atkinson regarding lP meeting in DC, additional information to prepare for meeting, and new information from ongoing investigation 103 Page 12 of 12 EFTA00191249 SUPPLEMENTAL PRIVILEGE LOG Bates Range Description Privilege(s) Asserted Suppl. Box #3 8/15/08 Emails between A. Acosta and A. Marie Attorney-Client Privilege P-013279 Villafa0a, R. Senior, D. Lee and K. Atkinson re Work Product Thru proposed correspondence to Jay Lefkowitz P-013280 Suppl. Box #3 Handwritten note re Epstein investigation Attorney-Client Privilege P-013281 Work Product Investigative privilege Also contains information subject to privacy rights of victims who are not parties to this litigation Suppl. Box #3 7/9/08 Email from A. Marie Villafafia to A. Attorney-Client Privilege P-013282 Acosta, J. Sloman, K. Atkinson, and FBI re Work product Thru proposed response to Goldberger letter re victim Deliberative Process P-013283 notification Suppl. Box #3 7/10/08 Emails between J. Sloman and A. Marie Attorney-Client Privilege P-013284 Villafafia, K. Atkinson, and FBI re proposed Work Product response to Goldberger's letter re victim Deliberative Process notification Suppl. Box #3 File folder entitled "8/5/08 AMCV c-mail re Attorney-Client Privilege P-013285 correct agrmt" containing 8/5/08 email from A. Work Product Thru Marie Villafafia to A. Acosta, J. Sloman, R. Deliberative Process P-013289 Senior, K. Atkinson re "Jeffrey Epstein Agreement" discussing 6/24/08 email from A. Marie Villafafia to R. Black and J. Goldberger concerning the binding nature of the Agreement Suppl. Box #3 File folder entitled "8/14/08 E-mail from Lefk to Attorney-Client Privilege P-013290 AMCV" containing (undated) emails from A. Work Product Thru Marie Villafafia to R. Senior, J. Sloman, A. P-013292 Acosta, K. Atkinson, D. Lce re draft response to 8/14/08 email from J. Lefkowitz regarding "the December 2007 proposal" Page 1 of 14 EFTA00191250 Bates Range Description Privilege(s) Asserted Suppl. Box #3 File folder entitled "8/15/08 AMCV e-mail re Attorney-Client Privilege P-013293 Agrmt" containing 8/15/08 e-mails from A. Marie Work Product Thru Villafafta to A. Acosta, J. Sloman, R. Senior, K. Deliberative Process P-013299 Atkinson, D. Lee it follow up on Agreement and from A. Acosta to Ann Marie Villafana on issue of Special Master with attached 8/15/08 cmails from A. Marie Villafafta to A. Acosta, J. Sloman, R. Senior, K. Atkinson, D. Lee re Agreement; 8/15/08 email from J. Lefkowitz to A. Marie Villafana, K. Atkinson, R. Black, M. Weinberg re Agreement; 8/14/08 emails from A. Marie Villafana to J. Lefkowitz, K. Atkinson, R. Black m interpretation of Agreement; email from J. Lefkowitz to A. Marie Villafana, K. Atkinson re questions it Agreement; email from A. Marie Villafana to J. Lefkowitz, K. Atkinson re production of Agreement to victims Suppl. Box #3 File folder entitled "8/18/08 Lefkowitz Ltr to Attorney-Client Privilege P-013300 AMCV" containing A. Marie Villafafta's Work Product Thru handwritten draft notes for proposed letter to J. P-0133303 Lefkowitz; 5/22/07 e-mail from A. Lourie to M. Menchel, J. Sloman, A. Marie VilVana re meeting with G. Lefcourt with attached email from G. Lefcourt re solicitation for meetings Suppl. Box #3 File folder entitled "6/25/07 Lefcourt to Sloman Attorney-Client Privilege P-013304 & Lourie containing 6/25/07 letter (with Work Product Thru handwritten notes by A. Marie Villafafta) from G. P-013325 Lefcourt to J. Sloman, M. Menchel, A. Louric, A. Marie Villafafta addressing reasons for not prosecuting Epstein; handwritten outline by A. Marie Villafana of possible response to letter Suppl. Box #3 File folder entitled "9/17/07 Villafafia to Attorney-Client Privilege P-013326 Lefkowitz containing 9/17/07 e-mail from A. Work Product Thru Marie Villafafta to R. Garcia, A. Lourie and from P-013329 R. Garcia to A. Marie Villafana concerning status of plea negotiations Suppl. Box #3 File folder entitled "11/8/07 Lefkowitz to Attorney-Client Privilege P-013330 Sloman" containing 11/8/07 letter from J. Work Product Thru Lefkowitz it issues arising during pendency of P-013333 matter with attorney handwritten notes Suppl. Box #3 File folder entitled "I 1/13/07 Sloman to Attorney-Client Privilege P-013334 Lefkowitz (was this sent?)" containing draft Work Product Thru 11/13/07 letter from J. Sloman responding to J. P-013337 Lefkowitz's letter Page 2 of 14 EFTA00191251 Bates Range Description Privilege(s) Asserted Suppl. Box #3 File folder entitled "12/6/07 Sloman to [Not considered P-013338 Lefkowitz" containing 12/5/07 faxed letter w/ privileged. Will be Thm cover sheet from K. Starr and J. Lefkowitz to A. produced to opposing 013341 Acosta counsel upon lifting of stay) Suppl. Box #3 File folder entitled "12/05/07 Starr to Acosta" Attorney-Client Privilege P-013342 containing drafts of 11/30/07 letters from A. Work Product Thru Acosta to K. Starr and from J. Sloman to J. Deliberative Process P-013350 Lefkowitz re performance and victim notification with handwritten notes and edits by A. Marie Villafafia Suppl. Box #3 File folder entitled "12/21/07 Lefkowitz to Attorney-Client Privilege P-13351 Acosta" containing handwritten notes by A. Work Product Thru Marie Villafafia, 12/21/07 letter from J. P-013361 Lefkowitz to A. Acosta re performance of NPA and appeal to Washington with attorney handwritten notes Suppl. Box #3 File folder labeled "12/26/07 Lefkowitz to Attorney-Client Privilege P-013362 Acosta" containing 2 copies of draft letter from Work Product Thru A. Acosta to J. Lefkowitz (with 12/28/07 fax Deliberative Process P-013366 header) Suppl. Box #3 File folder labeled "Draft Itr from Sloman to Attorney-Client Privilege P-013367 Lefkowitz re termination" containing draft letter Work Product Thru dated "April , 2008" from J. Sloman to J. P-013372 Letkowitz concerning the compliance with the Agreement Suppl. Box #3 File folder labeled "6/3/08 Sloman Submission to Attorney-Client Privilege P-013373 the DAG" containing 6/3/08 letter from J. Sloman Deliberative Process Thru to Mark Filip, Office of the DAG, cc'd to R. Work Product P-013503 Senior, A. Marie Villafafia, K. Atkinson, re investigative privilege Jeffrey Epstein, detailing events concerning the Agreement and thereafter and with relevant attachments Suppl. Box #3 File folder labeled "Mtg w/ Ken Starr, RAA, JS, Attorney-Client Privilege P-013504 Drew" containing handwritten notes by A. Marie Work Product Thru Villafafia P-013507 Suppl. Box #3 File folder labeled "Internal Corr." containing Attorney-Client Privilege P-013508 11/28/07 c-mails from J. Sloman to A. Marie Work Product Thru Villafafia re responding to 11/28/07 e-mail from P-013514 J. Lefkowitz to J. Sloman regarding victim notification with attachments Page 3 of 14 EFTA00191252 Bates Range Description Privilege(s) Asserted Suppl. Box #3 Draft 11/30/07 letter from A. Acosta to K. Stan• Attorney-Client Privilege P-013515 cc'd to J. Sloman and A. Marie Villafafta re Work Product Thru compliance with Agreement and internal emails Deliberative Process P-013525 from J. Sloman, A. Acosta, and A. Louric re items to address in letter Suppl. Box #3 5/23/07 e-mail from A. Marie Villafafia to K. Attorney-Client Privilege P-013526 Atkinson re draft proposed internal e-mail about Work Product Thru handling of case and attached email Deliberative Process P-013527 correspondence between Andrew Lourie and G. Lefcourt Suppl. Box #3 Handwritten notes by A. Marie Villafana dated Work Product P-013528 9/21 re telephone conference with possible victim Thm representative, conflict check with names and P-013530 email listed, list of names of potential victim representatives, payment discussion, and P-013532 guideline calculation, email containing contact Thru info for potential victim representative, draft Non P-013537 Prosecution Agreement dated 9/10/07 4:17 pm Suppl. Box #3 Typed note addressed to "Dear David" re 6(e) P-013531 response to grand jury subpoena Investigative privilege Suppl. Box #3 File folder labeled "Notes Re Post-Agreement Work Product P-013538 Communications" containing handwritten notes Deliberative Process Thru by A. Marie Villafafia P-013553 Suppl. Box #3 File folder labeled "E-mails Re Plea Attorney-Client Privilege P-013554 Negotiations" containing: Work Product Thai ■ 11/28/07 e-mail from A. Lourie to A. Deliberative Process Marie Villafafta, A. Oosterbaan, R. Garcia Investigative Privilege re non-prosecution agreement, with attached correspondence; ■ 9/19/07 e-mail from A. Marie Villafafia to A. Louric, R. Garcia, K. Atkinson re negotiating strategy, with attached correspondence; ■ 9/18/07 e-mail from A. Marie Villafaila to A. Acosta, A. Louric, R. Garcia, K. Atkinson, J. McMillan re negotiating strategy; ■ 9/17/07 e-mail from A. Marie Villafafta to A. Acosta re negotiation; ■ 9/17/07 e-mail from A. Marie Villafafia to R. Garcia, A. Acosta, A. Louric, K. Atkinson, J. McMillan re negotiations; ■ 9/17/07 e-mail from A. Marie Villafafia to Page 4 of 14 EFTA00191253 Bates Range Description Privilege(s) Asserted R. Garcia, A. Lourie re negotiation strategy; ■ 9/14/07 e-mail from A. Marie Villafafia to J. Sloman, A. Acosta, R. Garcia, A. Lourie, K. Atkinson, S. Ball re proposed plea agreement and Information; ■ 9/14/07 e-mail from A. Marie Villafafia to J. Sloman, A. Acosta, A. Lourie, R. Garcia, K. Atkinson, J. McMillan, S. Ball rc plea negotiations; ■ 9/13/07 e-mail from A. Marie Villafafia to K. Atkinson, S. Ball, J. McMillan re indictment package; ■ 9/13/07 e-mail from A. Marie Villafafia to A. Oosterbaan re trust agreement with attached correspondence; ■ 9/13/07 c-mail from A. Marie Villafafia to A. Oosterbaan re trust agreement; ■ 9/13/07 e-mail from A. Marie Villafafia to R. Garcia, J. Sloman rc conference call with J. Lefkowilz; ■ 9/13/07 e-mail from A. Marie Villafafia to A. Lourie re plea negotiations with attached correspondence; ■ 9/13/07 e-mail from A. Marie Villafafia to A. Lourie re charging strategy with attached correspondence; ■ 9/13/07 e-mail from A. Marie Villafafia to K. Atkinson, S. Ball, J. McMillan re indictment package; ■ 9/13/07 e-mail from A. Marie Villafafia to A. Acosta, J. Sloman, R. Garcia, K. Atkinson, A. Lourie re plea negotiations; ■ 9/11/07 e-mail from A. Marie Villafafia to A. Lourie re meeting w/ G. Lefcourt with attached correspondence; ■ 9/11/07 e-mail from A. Marie Villafafia to A. Lourie re revised Agreement with attached correspondence; ■ 9/11/07 e-mail from A. Marie Villafafia to J. Sloman re non-prosecution agreement edits with attached correspondence; ■ 9/11/07 e-mail from A. Marie Villafafia to A. Oostcrbaan rc status of negotiations with attached correspondence; Page 5 of 14 EFTA00191254 Bates Range Description Privilege(s) Asserted ■ 9/10/07 e-mail from A. Marie Villafafia to J. Sloman re negotiations; 9/10/07 e-mail from A. Marie Villafafia to J. Sloman, J. McMillan re state grand jury proceedings; ■ 9/17/07 c-mail from A. Acosta to A. Marie Villafafia, R. Garcia, A. Lourie, K. Atkinson, J. McMillan re draft Agreement with attached correspondence; ■ 9/14/07 e-mail from J. Sloman to A. Marie Villafafia, A. Acosta, R. Garcia, A. Lourie, K. Atkinson, S. Ball, re finalizing documents; ■ 9/14/07 e-mail from A. Lourie to A. Marie Villafafia re charging strategy with attached correspondence; ■ 9/13/07 e-mail from A. Oosterbaan to A. Marie Villafafia re setting up trust fund; ■ 9/13/07 e-mail from A. Lourie to A. Marie Villafafia re final negotiations with attached correspondence; ■ 9/11/07 e-mail from A. Lourie to A. Marie Villafafia re scheduling a meeting regarding finalizing the agreement with attached correspondence; ■ 9/11/07 e-mail from J. Sloman to A. Marie Villafafia re non-prosecution agreement edits with attached correspondence; ■ 9/11/07 e-mail from J. Sloman to A. Marie Villafafia re non-prosecution agreement edits with attached correspondence; ■ 9/11/07 e-mail from A. Oosterbaan to A. Marie Villafafia re negotiations with attached correspondence; ■ 9/17/07 e-mail from A. Marie Villafafia to R. Garcia, A. Lourie re negotiation strategy Suppl. Box #3 File folder entitled "[] Target Letter" containing 6(e) P-013609 copy of signed letter and contact info for counsel Investigative Privilege Thru for target P-013615 Page 6 of 14 EFTA00191255 Bates Range Description Privilege(s) Asserted Suppl. Box #3 File folder entitled "Ally Notes re Revised Attorney-Client Privilege P-013616 Indictment" containing handwritten notes by A.Deliberative Process Thru Marie Villafafia Work Product P-013621 Investigative Privilege Also contains information subject to privacy rights of victims who are not parties to this litigation Suppl. Box #3 File folder entitled "Research Re Possible Work product P-013622 Misdemeanors" containing attorney research Thru P-013643 Suppl. Box #3 File folder entitled "Notes Re Plea Negotiations" Attorney-Client Privilege P-013644 containing 9/17/07 c-mail from A. Mark Work Product Thru Villafafla to J. Richards, N. Kuyrkendall re status Deliberative Process P-013653 update; undated and typed handwritten notes by Investigative privilege A. Marie Villafafia re items to be completed on Also contains information case, strength of case, victim interviews, subject to privacy rights of summary of evidence, guidelines calculations victims who are not parties to this litigation Suppl. Box #3 File folder entitled "Plea Agreement Drafts" Attorney-Client Privilege P-013654 containing several draft plea agreements some Work Product Thru with handwritten notes by A. Marie Villafafia; Deliberative Process P-013745 copies of draft non-prosecution agreement some with handwritten notes by A. Marie Villafafia; copy of a draft Information Suppl. Box #3 File folder entitled "Draft Non-Prosecution Attorney-Client Privilege P-0013747 Agreements" containing several draft non- Work Product Thru prosecution agreements some with handwritten Deliberative Process P-013810 notes by A. Marie Villafafia; plea sheet State Circuit Court; copies of draft Information; draft plea proffer; draft motion and order to seal; draft penalty sheet; draft plea agreement Suppl. Box 3 File folder entitled "Information Packet Drafts" Attorney-Client Privilege P-013811 containing several drafts of Informations, and Work Product Thru complete draft Information packet Deliberative Process P-013833 Suppl. Box 3 Two pages of filed document, D.E. 62, page 2 of atty work-product P-013834 54 and page 6 of 54, containing handwritten Through attorney notes P-013835 Page 7 of 14 EFTA00191256 Bates Range Description Privilege(s) Asserted Suppl. Box 3 Palm Beach Daily News Article, "Attorneys want Ally work-product P-013836 Jeffrey Epstein Agreement Thrown Out," with Thru attorney's notes written on margin P-013837 Suppl. Box 3 Letter from Paul Cassell to Wifrcdo A. Ferrer, Atty work-product P-013838 December 10, 2010, Subject: Request for Thru Investigation of Jeffrey Epstein Prosecution, with P-013841 underlines, written notes, and comments by DOJ attorney Suppl. Box 3 Email from Dexterr Lee to Ruth Plagenhoef Atty work-product P-013842 (OPR), February 25, 2011, 4:31 p.m., Re: Atty-client privilege Request for OPR Investigation — Jeffrey Epstein Non-Prosecution Agreement Suppl. Box 3 E-mail, Marie Villafana to Andrew Lourie, Atty work-product P-013843 Rolando Garcia, and Karen Atkinson, September atty-client privilege Thru 19, 2007, 4:33 p.m., RE: Plea Agreement P-013844 Suppl. Box 3 E-mail, Andrew Lourie to Marie Villafana, Atty work-product P-013845 September 19, 2007, 4:21 p.m., RE: Epstein, Thm with internal U.S. Attorney's Office e-mails P-013846 attached Suppl. Box 3 E-mail, Marie Villafana to Andrew Londe, Atty work-product P-013847 Rolando Garcia, and Karen Atkinson, September Thru 18, 2007, 11:43 a.m., RE: Draft Agreements?, P-013849 with e-mail from Jay Lefkowitz (September 18, 2007, 11:09 a.m.) attached Suppl. Box 3 E-mail, Marie Villafana to Alex Acosta, Andrew Atty work-product P-013850 Lourie, Rolando Garcia, Karen Atkinson, and John McMillan, September 18, 2007, 9:31 a.m., RE: Epstein Negotiations . Suppl. Box 3 E-mail, Marie Villafana to Rolando Garcia and Atty work-product P-013851 Andrew Louric, September 17, 2007, 10:35 a.m., Thru RE: Epstein [providing update re plea P-013853 negotiations] Suppl. Box 3 E-mail, Marie Villafana to Andrew Oosterbaan, Atty work-product P-013854 September 13, 2007, 8:10 p.m., RE: Epstein, with e-mail from Andrew Oosterbaan (September 13, 2007, 7:54 p.m.), attached Suppl. Box 3 E-mail, Marie Villafana to Jeff Sloman and Atty work-product P-013855 Andrew Louric, September 10, 2007, 5:24 p.m., Atty-client privilege RE: FBI Suppl. Box 3 E-mail, Marie Villafana to Jeff Sloman, Atty work-product P-013856 September 6, 2007, 5:47 p.m., RE: Epstein, with Atty-client privilege Thru e-mail from Jeff Sloman (September 6, 2007, P-013857 5:35 p.m.), attached Page 8 of 14 EFTA00191257 Bates Range Description Privilege(s) Asserted Suppl. Box 3 Email, Marie Villafana to Jeff Sloman, arty work-product P-013858 September 6, 2007, 9:29 a.m., Re: Meeting on Friday Suppl. Box 3 Email, Gerald Lefcourt to Marie Villafana, Lilly [Not considered P-013859 Ann Sanchez, Roy Black, re: Jeffrey Epstein privileged. Will be Through produced to opposing P-013860 counsel upon lifting of stay] Suppl. Box 3 E-mail, Marie Villafana to Matthew Menchel, Atty work-product P-013861 July 13, 2007, 3:14 p.m., RE: Epstein, with c- atty-client privilege Thru mail from Menchel (July 5, 2007, 3:30 p.m.), P-013865 Villafana to Menchel (July 4, 2007, 5:16 p.m.), and Sloman to Villafana (July 3, 2007, 1:47 p.m.), attached Suppl. Box 3 E-mail, Marie Villafana to Jeff Sloman, Matthew Atty work-product P-013866 Menchel, Andrew Lourie, Karen Atkinson, and Shawn Ball, July 3, 2007, 6:26 a.m., RE: Epstein Suppl. Box 3 E-mail, Marie Villafana to Matthew Menchel, Atty work-product P-013867 June 21, 2007, 3:24 p.m., RE: Meeting Next Thai Week, with e-mails from Menchel to Villafana P-013868 (June 21, 2007, 2:58 p.m.), and Villafana to Mcnchcl (June 21, 2007, 1:37 p.m.), attached Suppl. Box 3 E-mail, Marie Villafana to Matthew Mcnchcl, Any work-product P-013869 Jeff Sloman, Andrew Lourie, and Karen Atkinson, June 18, 2007, 5:04 p.m., RE: Epstein Suppl. Box 3 E-mail, Andrew Lourie to Marie Villafana, May Atty work-product P-013870 24, 2007, 9:25 a.m., FW: Jeffrey Epstein, with e- Thai mail from Gerald Lefcourt to Andrew Lourie P-013871 (May 23, 2007, 5:00 p.m.), Andrew Lourie to Gerald Lefcourt (May 22, 2007, 6:32 p.m.), and Gerald Lefcourt to Andrew Lourie Marie Villafana, and Lilly Ann Sanchez (May 22, 2007, 2:05 p.m.), attached Suppl. Box 3 E-mail, Andrew Lourie to Matthew Menchel, Jeff Atty work-product P-013872 Sloman, and Marie Villafana, May 22, 2007, 3:11 p.m., FW: Jeffrey Epstein, with e-mail from Lefeourt to Lourie, Villafana, and Lilly Ann Sanchez (May 22, 2007, 2:05 p.m.), attached Suppl. Box 3 E-mail Menchel to Villafana and Lourie, May 14, Atty work-product P-013873 2007, 10:52 a.m., RE: Operation Leap Year, with c-mail from Villafana to Louric and Menchcl (May 14, 2007, 10:38 a.m.), attached Page 9 of 14 EFTA00191258 Bates Range Description Privilege(s) Asserted Suppl. Box 3 Inadvertently marked as privileged, will be P-013874 produced Through P-013875 Suppl. Box 3 E-mail, Villafana to Louric, Garcia, and Atty work-product P-013876 Atkinson, September 19, 2007, 4:33 p.m., RE: Thru Draft Plea Agreement, with e-mail from P-013877 Lefkowitz to Villafana (September 19, 2007, 3:44 p.m.), and Lefkowitz to Villafana (September 19, 2007, 3:35 p.m.) attached Suppl. Box 3 E-mail, Lourie to Villafana, September 19, 2007, Atty work-product P-013878 4:21 p.m., RE: Epstcin, with e-mails from Thru Villafana to Lourie and Garcia (September 19, P-013879 2007, 4:13 p.m.), Villafana to Lourie and Garcia (September 19, 2007, 4:05 p.m.), and Louric to Villafana and Garcia (September 19, 2007, 3:50 p.m.), Villafana to Lourie (September 19 2007, 2:36 p.m.), Louric to Villafana (September 19, 2007, 2:33 p.m.), and Villafana to Lourie and Garcia (September 19, 2007, 2:31 p.m.), attached Suppl. Box 3 E-mail, Villafana to Lourie, Garcia, and Atty work-product P-013880 Atkinson, September 18, 2007, 11:43 a.m., RE: Thru Dratt Agreemcnts?, with e-mails from Villafana P-013882 to Lourie, Garcia and Atkinson (September 18, 2007, 11:18 a.m.), Leficowitz to Villafana (September 18, 2007, 11:09 a.m.), and Villafana to Lefkowitz (September 18, 2007, 9:14 a.m.), ande Lcfkowitz to Villafana (September 18, 2007, 8:59 a.m.), attached Suppl. Box 3 E-mail, Villafana to Acosta, Louric, Garcia, Atty work-product P-013883 Atkinson, and McMillan, September 18, 2007, 9:31 a.m., RE: Epstein Negotiations Suppl. Box 3 E-mail, Villafana to Garcia and Louric, Atty work-product P-013884 September 17, 2007 10:35 a.m., RE: Epstein, Thru with e-mail from Garcia (September 17, 2007, P-013886 10:26 a.m.), attached Suppl. Box 3 E-mail, Marie Villafana to Andrew Oosterbaan, Atty work-product P-013887 September 13, 2007, 8:10 p.m., RE: Epstcin, with e-mail from Andrew Oosterbaan (September 13, 2007, 7:54 p.m.), attached Suppl. Box 3 E-mail, Marie Villafana to kfr Sloman and Atty work-product P-013888 Andrew Lourie, September 10, 2007, 5:24 p.m., Atty-client privilege RE: FBI Page 10 of 14 EFTA00191259 Bates Range Description Privilege(s) Asserted Suppl. Box 3 E-mail, Marie Villafana to Jeff Sloman, Atty work-product P-013889 September 6, 2007, 5:47 p.m., RE: Epstein, with Atty-client privilege Thru e-mail from Jeff Sloman (September 6, 2007, P-013890 5:35 p.m.), attached Suppl. Box 3 Email, Marie Villafana to Jeff Sloman, atty work-product P-013891 September 6, 2007, 9:29 a.m., Re: Meeting on Friday Suppl. Box 3 Email, Gerald Lefcourt to Marie Villafana, Lilly [Not considered P-013892 Ann Sanchez, Roy Black, re: Jeffrey Epstein privileged. Will be Through produced to opposing P-013893 counsel upon lifting of stay] Suppl. Box 3 E-mail, Marie Villafana to Matthew Menchel, Atty work-product P-013894 July 13, 2007, 3:14 p.m., RE: Epstein, with e- atty-client privilege Thru mail from Menchel (July 5, 2007, 3:30 p.m.), P-013898 Villafana to Menchel (July 4, 2007, 5:16 p.m.), and Sloman to Villafana (July 3, 2007, 1:47 p.m.), attached Suppl. Box 3 E-mail, Marie Villafana to Jeff Sloman, Matthew Atty work-product P-013899 Menchel, Andrew Lourie, Karen Atkinson, and Shawn Ball, July 3, 2007, 6:26 a.m., RE: Epstein Suppl. Box 3 E-mail, Marie Villafana to Matthew Menchel, Atty work-product P-013900 June 21, 2007, 3:24 p.m., RE: Meeting Next Thru Week, with e-mails from Menchel to Villafana P-013901 (June 21, 2007, 2:58 p.m.), and Villafana to Menchel (June 21, 2007, 1:37 p.m.), attached Suppl. Box 3 E-mail, Marie Villafana to Matthew Menchel, Atty work-product P-013902 Jeff Sloman, Andrew Lourie, and Karen Atkinson, June 18, 2007, 5:04 p.m., RE: Epstein Suppl. Box 3 E-mail, Andrew Lourie to Marie Villafana, May Atty work-product P-013903 24, 2007, 9:25 a.m., FW: Jeffrey Epstein, with e- Thru mail from Gerald Lefcourt to Andrew Lourie P-013904 (May 23, 2007, 5:00 p.m.), Andrew Lourie to Gerald Lefcourt (May 22, 2007, 6:32 p.m.), and Gerald Lcfcourt to Andrew Lourie Marie Villafana, and Lilly Ann Sanchez (May 22, 2007, 2:05 p.m.), attached Suppl. Box 3 E-mail, Andrew Lourie to Matthew Menchel, Jeff Atty work-product P-013905 Sloman, and Marie Villafana, May 22, 2007, 3:11 p.m., FW: Jeffrey Epstein, with c-mail from Lcfcourt to Lourie, Villafana, and Lilly Ann Sanchez (May 22, 2007, 2:05 p.m.), attached Page 11 of 14 EFTA00191260 Bates Range Description Privilege(s) Asserted Stipp]. Box 3 E-mail Menchel to Villafana and Lourie, May 14, Atty work-product P-013906 2007, 10:52 a.m., RE: Operation Leap Ycar, with e-mail from Villafana to Lourie and Menchel (May 14, 2007, 10:38 a.m.), attached Suppl. Box 3 Inadvertently marked as privileged, will be P-013907 produced Through P-013908 Suppl. Box 3 Memorandum, Lisa Howard, Assistant Counsel, Deliberative Process P-013909 U.S. Department of Justice, Office of Privilege; atty work- Thru Professional Responsibility (OPR), to Ruth product P-013911 Plagenhoef, Acting Associate Counsel, OPR, undated, Subject: Recommendation Suppi. Box 3 Memorandum, Lisa Howard, Assistant Counsel, Deliberative Process P-013912 OPR, to Ruth Plagenhoef, Acting Associate Privilege, atty work- Thru Counsel, OPR, Subject: Recommendation, with product P-013914 handwritten note dated 5/4/1 I Suppi. Box 3 Memorandum, Lisa Howard, Assistant Counsel, Deliberative Process P-013915 OPR, to Ruth Plagenhoef, Acting Associate Privilege; atty work- Thru Counsel, OPR, Subject: Recommendation, with product P-013918 two post-it notes attached with handwritten attorney notations, and handwritten notations, underlines, and circled text throughout the body of the two page memorandum Suppl. Box 3 Draft letter, marked "Confidential", from Robin Deliberative Process P-013919 C. Ashton, Counsel, Office of Professional Privilege Thru Responsibility to Wifredo A. Ferrer, United Attorney Work Product P-013921 States Attorney, with handwritten corrections, strikethroughs, and added text Suppl. Box 3 Draft Letter, marked 'Confidential", from Robin Deliberative Process P-013922 C. Ashton, to Wifredo A. Ferrer, with Privilege Thru handwritten corrections Attorney Work Product P-013924 Suppi. Box 3 Draft Letter, from Robin C. Ashton to Professor Deliberative Process P-013925 Paul G. Cassell, with handwritten correction Privilege Thru Attorney Work Product P-013927 Suppl. Box 3 Draft Letter, from Robin C. Ashton to Professor Deliberative Process P-013928 Paul G. Cassell, with handwritten corrections Privilege Thru Attorney Work Product P-013930 Suppl. Box 3 Draft Letter, from Robin C. Ashton to Professor Deliberative Process P-013931 Paul G. Cassell, with handwritten corrections, Privilege Thru circled text, strikethroughs, and additional text Attorney Work Product P-013933 Page 12 of 14 EFTA00191261 Bates Range Description Privilege(s) Asserted Suppl. Box 3 Draft Letter, marked "Confidential," from Robin Deliberative Process P-013934 C. Ashton to Wifredo A. Ferrer, with handwritten Privilege Thru corrections Attorney Work Product P-013936 Suppl. Box 3 Draft Letter, Robin C. Ashton to Professor Paul Deliberative Proccss P-013937 G. Cassell, with handwritten corrections Privilege Thru Attorney Work Product P-013939 Suppl. Box 3 Draft Letter, marked "Confidential: To Be Deliberative Process P-013940 Opened by Addressee Only," Robin C. Ashton to Privilege Thru Wifredo A. Ferrer, with handwritten corrections Attorney Work Product P-013942 Suppl. Box 3 E-mail, Ruth Plagenhoef to Lisa Howard, May 5, Deliberative Process P-013943 2011, 11:19 a.m., RE: Re-write of Epstein letters Privilege for your review, with c-mail from Lisa Howard to Attorney Work Product Ruth Plagenhoef (May 5, 2011, 11:08 a.m.), and Plagenhoef to Howard (May 5, 2011, 11:10 a.m.), and Howard to Plagenhoef (May 5, 2011, 10:41 a.m.), attached Suppl. Box 3 E-mail, Plagenhoef to Howard, May 5, 2011, Deliberative Process P-013944 11:17 a.m., RE: Re-write of Epstein letters for Privilege your review, with e-mail from Howard to Plagenhoef (May 5, 2011, 11:08 a.m.), Plagenhoef to Howard (May 5, 2011, I 1:01 a.m.), and Howard to Plagenhoef (May 5, 2011, 10:41), attached Suppl. Box 3 E-mail, Plagenhoef to Howard, May 4, 2011, 5:01 Deliberative Process P-013945 p.m., RE: draft letters in Epstein matter, with e- Privilege mail from Howard to Plagenhoef (May 4, 2011, 4:57 p.m.), attached Suppl. Box 3 E-mail, Plagenhoef to Robin C. Ashton, May 4, Law Enforcement P-013946 2011, 4:08 p.m., RE: FYI on the Florida matter investigatory record, atty work product; deliberative process privilege Suppl. Box 3 E-mail, Paul Cassell to Plagenhoef, May 3, 2011, atty work product; law P-013947 12:23 p.m., RE: OPR Inquiry — request for enforcement investigatiory infonnation, with post-it note attached with record handwritten attorney notes on telephone call between Plagenhoef and Howard with Dexter Lee and Marie Villafana Suppl. Box 3 E-mail, Plagenhoef to Howard and Robin C. atty work-product P-013948 Ashton, May 3, 2011, 12:30 p.m., FW: OPR Thru Inquiry — request for information, with attached P-013951 e-mails. Handwritten attorney notes on margin Page 13 of 14 EFTA00191262 Bates Range Description Privilege(s) Asserted Suppl. Box 3 E-mail, Dexter Lee to Ruth Plagenhoef, March atty work-product; any- P-013952 16, 2011, 10:52 a.m., RE: Referral of Cassell client privilege Thru Request for Investigation, with e-mail from Paul P-013953 Cassell to Dexter Lee and Marie Villafana (March 15, 2011, 7:21 p.m.), attached Suppl. Box 3 E-mail, Plagenhoef to Neil Hurley, OPR, atty work-product, atty- P-013954 December 16, 2010, 10:59 a.m., FW: OPR client privilege Thru Referral — Allegation of Misconduct — U.S. P-013955 Attorney's Office, S.D.Fla., with e-mail from Dexter Lee to Plagenhoef (December 16, 2010, 10:22 a.m.), attached. Handwritten attorney notations. Suppl. Box 3 Fourteen (14) pages of handwritten attorney notes ally work-product P-013956 on case, telephone interviews with DOJ attorneys r_a Thru pimajee Pot39 69 Page 14 of 14 EFTA00191263