EFTA00029100Set 8
2017-04-1334p8,943w
EFTA00029103
Table of Exhibits
EXHIBIT J: Notes of Feb. II, 2021 Call with AUSA (Sealed)
EXHIBIT K: Handwritten Notes by AUSA of Meeting and Contacts with Peter Skinner,
Stan Pottinger ... Brad Edwards
EXHIBIT L: Email String Between Peter Skinner and AUSA cc'ing Stan Pottinger, Brad
Edwards, and Sigrid McCawley (Feb. 29, 2016—Mar. 5, 2016) (Sealed)
EXHIBIT M: Emails ... between AUSA and Chief of the Criminal Division (Mar. 3, 2016)
(Sealed)
EXHIBIT I: Emails between AUSA and AUSA and other AUSAs (Nov. 30,
2018—Dec. 6, 2018) (Sealed)
EXHIBIT
https://www.justice.gov/epstein/files/DataSet%208/EFTA00029100.pdf
EFTA00028929Set 8
2017-04-1334p8,953w
EFTA00028932
Table of Exhibits
EXHIBIT J: Notes of Feb. II, 2021 Call with AUSA (Sealed)
EXHIBIT K: Handwritten Notes by AUSA of Meeting and Contacts with Peter Skinner,
Stan Pottinger ... Brad Edwards
EXHIBIT L: Email String Between Peter Skinner and AUSA cc'ing Stan Pottinger, Brad
Edwards, and Sigrid McCawley (Feb. 29, 2016—Mar. 5, 2016) (Sealed)
EXHIBIT M: Emails ... between AUSA and Chief of the Criminal Division (Mar. 3, 2016)
(Sealed)
EXHIBIT N: Emails between AUSA and AUSA and other AUSAs (Nov. 30,
2018—Dec. 6, 2018) (Sealed)
EXHIBIT
https://www.justice.gov/epstein/files/DataSet%208/EFTA00028929.pdf
EFTA00208037Set 9
2011-04-0754p17,943w
Entered on FLSD Docket 04/07/2011 Page 23 of
54
Petitioners urge would require AUSAs to meet and confer with each and every prisoner who
alleged that ... prosecution by the State of Florida.
Nonetheless, during its investigation, the agents and AUSA, in compliance with the Justice
Department's guidelines on working with victims and witnesses, went above ... wherein they were
advised of this right and given the phone numbers of AUSA FBI Special Agent
and the Justice Department's Office for Victims of Crime. The letters specifically
https://www.justice.gov/epstein/files/DataSet%209/EFTA00208037.pdf
EFTA00731146Set 9
2006-11-1611p4,983w
that the fact that the investigation exclusively concerned
illegal sexual conduct during massage sessions, AUSA issued irrelevant official
document requests seeking Mr. Epstein's 2004 and 2005 personal income ... Disregard of the United States Attorney's Manual are Used
9. In June 2007, AUSA subpoenaed the investigating agent of Epstein's attorney,
Roy Black, in a clear effort ... durin negotiations over a possible federal plea agreement, FAUSA
and AUSA demanded that Mr. Epstein agree to the imposition of civil
liability under 18 U.S.C. § 2255 as a pre-condition
https://www.justice.gov/epstein/files/DataSet%209/EFTA00731146.pdf
EFTA00210063Set 9
2006-11-1611p4,996w
that the fact that the investigation exclusively concerned
illegal sexual conduct during massage sessions, AUSA issued irrelevant official
document requests seeking Mr. Epstein's 2004 and 2005 personal income ... Disregard of the United States Attorney's Manual are Used
9. In June 2007, AUSA subpoenaed the investigating agent of Epstein's attorney,
Roy Black, in a clear effort ... during ne otiations over a possible federal plea agreement, FAUSA
and AUSA demanded that Mr. Epstein agree to the imposition of civil
liability under 18 U.S.C
https://www.justice.gov/epstein/files/DataSet%209/EFTA00210063.pdf
EFTA00224728Set 9
2008-06-0214p6,969w
house for sexual favors. In July 2006, the matter was presented to AUSA A. Marie Villafana
of our West Palm Beach branch office to pursue a formal criminal investigation. That ... victims.
Over the last several months, approximately six more minor victims have been identified.
AUSA Villafana has been ready to present an indictment to a West Palm Beach federal
grand ... Robert Senior,
08-80736-CV-MARR.A P-014942
EFTA00224729
By May 2007, AUSA Villafana began seeking approval from her supervisors to indict
Epstein. Her immediate supervisor was Andrew Laurie
https://www.justice.gov/epstein/files/DataSet%209/EFTA00224728.pdf
EFTA00191264Set 9
2007-06-07132p38,225w
Edwards Declaration at ¶¶20-22.
EFTA00191266
8. At the time of plea discussions, AUSA Villafana had drafted the-UnSrAttomeyls-Oirme-had
an 82-page prosecution memorandum outlining numerous federal sexual ... inmestigating
Eirsteinls-sen-offensesrU7SrAttemeyls-Cerrespondenee-M-497-587
7 The-eerrespondenee-alse-shows-that-AUSA-Wilatana-was-Mterested-in-finding-a-place-te
eonelude-a-plea-bargain-that-weuld-effeetively ... ChiefReiier-not4O-diselose
the-eufeente-fe-anyene
4-2, On about September 25, 2007, AUSA Villafafia sent an e-mail to Lefkowitz, a copy of
which is attached hereto
https://www.justice.gov/epstein/files/DataSet%209/EFTA00191264.pdf
EFTA00206764Set 9
2008-05-3029p8,407w
offenses. U.S. Attorney's Correspondence
at 4.
9. In September 2007, Assistant U.S. Attorney (AUSA) A. Marie in an effort to
avoid prosecuting Epstein for his numerous sexual offenses against ... Correspondence at 153 (emphases added).
6
EFTA00206769
12. On about September 25, 2007, AUSA sent an e-mail to Lefkowitz stating: "And
can we have a conference call to discuss ... agreement." U.S. Attorney's Correspondence at 156.
13. On about September 26, 2007, AUSA. sent an e-mail to Lefkowitz in which she
stated: "Hi Jay — Can you give
https://www.justice.gov/epstein/files/DataSet%209/EFTA00206764.pdf
EFTA00009229Set 7
2019-10-18100p22,286w
half years, as we understand it, from the time the line AUSA
11 first briefed you and then criminal chief
12 in July of 2006, and until you were formally ... valued the fact that he had
13 trained and, you know, so many AUSAs, and really spent a lot
14 of time reviewing -- the major crimes chief as opposed ... other chiefs spends a lot of time reviewing the work of
16 AUSAs, and so, he would be someone who is very experienced
17 and able
https://www.justice.gov/epstein/files/DataSet%207/EFTA00009229.pdf
EFTA00207822Set 9
2007-06-0715p4,072w
communications between
Epstein and the Justice Department.
8. At the time of plea discussions, AUSA Villafana had drafted an 82-page prosecution
memorandum outlining federal offenses committed by Epstein (including ... well as a 53-page draft indictment.
9. During the plea discussions, AUSA wrote in an e-mail to defense counsel: "On an
'avoid the press' note, I believe that ... Attorney's Correspondence at 153 (emphases added).
11. On about September 25, 2007, AUSA sent an e-mail to Lefkowitz stating: "And
can we have a conference call to discuss
https://www.justice.gov/epstein/files/DataSet%209/EFTA00207822.pdf
EFTA01186131Set 9
2016-02-1057p17,269w
federal agents.' Ultimately, however, none of those would work. Assistant
U.S. Attorney ("AUSA") (the "line prosecutor") informed Epstein's counsel that
she was getting pushback for creating a charge using ... Government had disproven or rejected Epstein's
various arguments against federal charges, as AUSA sent a letter to Epstein's
counsel stating, "[w]e would reiterate that the agreement ... would make it
hard for a judge to see what was happening:
Andy [i.e., AUSA ] recommended that some of the timing issues
be addressed only in the state agreement
https://www.justice.gov/epstein/files/DataSet%209/EFTA01186131.pdf
EFTA00103994Set 9
2020-02-0312p2,571w
Geoffrey S. Berman
U.S. Attorney, Southern District of New York
SUBJECT: Foreign Travel for AUSAs a and
DATE: January 23, 2020
This memo is intended to uest a royal ... planned foreign travel of
a a and
District of New York. AUSAs
Assistant United States Attorneys in the Southern
and will be traveling to Stockholm,
Sweden, to interview a potential ... with an investi ation into possible
violations of 18 U.S.C. § 2423, among other offenses. AUSAs , and
la
will travel between February 3 (overnight) and February 7, 2020. Ed Tyrrell
https://www.justice.gov/epstein/files/DataSet%209/EFTA00103994.pdf
EFTA00098000Set 9
2021-04-0716p7,340w
building. Whatever day you wish to have the review conducted at the warehouse, an AUSA and an agent will meet the
attorney, investigator, and paralegal at the warehouse to escort ... them into the building to the evidence review room. The
AUSA will remain present at the warehouse to answer any questions that may arise.
The FBI has informed me that ... Confidential," in which case they
may not be photographed, absent specific authorization from an AUSA. I note the possibility of authorization to
photograph this latter category because some Highly Confidential
https://www.justice.gov/epstein/files/DataSet%209/EFTA00098000.pdf
EFTA00799803Set 9
2007-08-0722p5,839w
6/2/2017 Villafafia Decl. at fl 10, 12, 19.
46. Admitted.
47. Denied. AUSA Villafana met with Jane Doe 1 and Jane Doe 2 and most of the other
victims when ... admits that paragraph 54 accurately quotes from an email dated
September 25, 2007 from AUSA Marie Villafafia to Jay Lefkowitz, but denies that the email ... Jane Doe 2 never asked to
confer or consult with the FBI or with AUSA Villafafia about the prosecution of Epstein despite
having been informed of a victim's right
https://www.justice.gov/epstein/files/DataSet%209/EFTA00799803.pdf
EFTA00799781Set 9
2007-08-0722p5,853w
6/2/2017 Villafafia Decl. at fl 10, 12, 19.
46. Admitted.
47. Denied. AUSA Villafana met with Jane Doe 1 and Jane Doe 2 and most of the other
victims when ... admits that paragraph 54 accurately quotes from an email dated
September 25, 2007 from AUSA Marie Villafafia to Jay Lefkowitz, but denies that the email ... Jane Doe 2 never asked to
confer or consult with the FBI or with AUSA Villafafia about the prosecution of Epstein despite
having been informed of a victim's right
https://www.justice.gov/epstein/files/DataSet%209/EFTA00799781.pdf
EFTA00015753Set 8
2021-04-0817p7,507w
building. Whatever day you wish to have the review conducted at the warehouse, an AUSA and an agent will meet the
attorney, investigator, and paralegal at the warehouse to escort ... them into the building to the evidence review room. The
AUSA will remain present at the warehouse to answer any questions that may arise.
The FBI has informed me that ... Confidential," in which case they
may not be photographed, absent specific authorization from an AUSA. I note the possibility of authorization to
photograph this latter category because some Highly Confidential
https://www.justice.gov/epstein/files/DataSet%208/EFTA00015753.pdf
EFTA00098016Set 9
2021-04-0717p7,201w
building. Whatever day you wish to have the review conducted at the warehouse, an AUSA and an agent will meet the
attorney, investigator, and paralegal at the warehouse to escort ... them into the building to the evidence review room. The
AUSA will remain present at the warehouse to answer any questions that may arise.
EFTA00098017
The FBI has informed ... Confidential," in which case they
may not be photographed, absent specific authorization from an AUSA. I note the possibility of authorization to
photograph this latter category because some Highly Confidential
https://www.justice.gov/epstein/files/DataSet%209/EFTA00098016.pdf