UNITED STATES DISTRICT COURT

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 08-80736-CI V-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 Request for 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 1 and 4 United States, Case No. 08-80736-CIV-MARRA/MATTHEWMAN United States District Court, Southern District of Florida Brad Edwards, Esq., Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, P.L. 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 (954)524-2820 Fax: (954) 524-2822 E-mail: brad@pathtojustice.com 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: casselp®law.utah.edu Attorneys for Jane Doe # 1 and Jane Doe # 2 12 Roy Black, Esq. Jackie Perczek, Esq. Black, Srebnick, Kornspan & Stumpf, P.A. 201 South Biscayne Boulevard, Suite 1300 Miami, FL 33131 (305) 371-6421 Fax: (305)358-2006 E-mail: pleading@iroyblack.com Martin G. Weinberg MARTIN G. WEINBERG, P.C. 20 Park Plaza Suite 1000 Boston, MA 02116 Office: (617) 227-3700 Fax: (617) 338-9538 Email: owlmgw@attnet Jay P. Letkowitz Kirkland &Ellis, LLP 601 Lexington Avenue New York. NY 10022 Fax: Email: lefkowitz@kirkland.com EFTA00191210 Page I of 1 Nom (541)020-11111 Ongli P814 USA° 'Aerosol, reUr124. Departneal of Just* 500 S A4004144 Avenu• Suite 400 West Pale (load% Ft 33401 MI I Sf H SHIP 10: M4)524-2120 Brad Edwards, Esq. Farmer Jaffe Weissing Edwards 425 N. Andrews Avenue Suite 2 FORT LAUDERDALE, FL 33301 Shp Dale 23,11/1415 Ac6Vgl 0 5 LEI CAD B69/(146( NE13610 )elvecy AA I( ( ode I II II II I I 1111 Ref N rev(' N PON Dept N TR" 7738 9191 3028 0201 . II 11 I 1111111111111 111111 110 WED - 24 JUN AA STANDARD OVERNIGHT 32 HWOA 11 33301 11 US FLL https://www.fedex.com/shipping/shipAction.handle?method=doContinue 6/23/2015 EFTA00191211 Page I of I Fr= (55802043111 Oapn PEPA USAO .11Crossen • sas sa ,...n Dopartment of Justsda 500 S Aushalan Avenues Suits 400 Wes1Paln Beach. FL 33401 it,i2lUCenC)tor SFS 70: ANTIS:64212 BILL SENDER Paul G. Cassell University of Utah SJ Quinney College of Law 332 S. 1400 E. SALT LAKE CITY, UT 84112 Shp Dais: 23JUN15 AcNigt 05 L8 CAD 8097846N€T3610 Delvary Ad s a Cade IIIIINIIIIIIIII RON Invoice PO N Days II HI' I III TR" 7738 9192 3670 WED - 24 JUN AA STANDARD OVERNIGHT XH NPHA !:.7.!..y. I (I, 84112 UT US SLC 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 P-000001 thru P-000039 File folder entitled "CORR RE GJ SUBPOENAS" containing correspondence related to various grand jury subpoenas and attorney (Villafada) handwritten notes 6(e) Work Product Box #1 P-000040 thru P-000549 Operation Leap Year Grand Jury Log containing subpoenas OLY-01 through OLY-81, correspondence and research related to enforcement of same, documents produced in response to some subpoenas; and attorney (Villafafla) handwritten notes 6(e) Work Product Contains documents subject to investigative privilege Also contains documents subject to privacy rights of victims who are not parties to this litigation Box #1 P-000550 thru P-000621 File folder entitled "Ritz Compact Flash SW" containing copies of a sealed search warrant application, warrant, and supporting documents 6(e) Contains information subject to investigative privilege Also contains information subject to privacy rights of victims who are not parties to this litigation Box #1 P-000622 thru P-000693 File folder entitled "PNY Technologies Compact Flash SW" containing copies of a sealed search warrant application, warrant, and supporting documents 6(e) Contains information subject to investigative privilege Also contains information subject to privacy rights of victims who are not parties to this litigation Box #1 P-000694 thru P-000781 File folder entitled "JE Corporations" containing attorney research on Epstein-owned corporations and prior litigation Work Product Contains information subject to investigative privilege Box #1 P-000782 thru P-000803 File folder entitled "Capital One" containing subpoena and correspondence 6(e) Box #1 P-000804 thru P-000854 File folder entitled "DTG Operations/Dollar Rent-a-Car" containing subpoena and responsive documents 6(e) Contains documents and information subject to investigative privilege Also contains documents and information subject to privacy rights of victims who are not parties to this litigation Page 1 of 23 EFTA00191214 Bates Range Description Privilege(s) Asserted Box #1 P-000855 thru P-000937 File folder entitled "JP Morgan Chase" containing subpoena, correspondence, and responsive documents 6(e) Contains documents and information subject to investigative privilege Box #1 P-000938 thru P-000947 File folder entitled "Washington Mutual" containing subpoena, correspondence, and responsive documents 6(e) Contains documents and information subject to investigative privilege Box #1 P-000948 thru P-000982 File folder entitled "Computer Search &" containing legal research on computer search and handwritten notes on indictment preparation Work Product Attorney-Client Contains information subject to investigative privilege. Also contains information subject to privacy rights of victims who are not parties to this litigation Box #1 P-000983 thru P-001007 File folder entitled "Attorney Notes from Document Review" containing typed and handwritten attorney (Villafada) notes, target letters, correspondence re grand jury subpoena Work product 6(e) Contains information subject to investigative privilege. Also contains information subject to privacy rights of victims who are not parties to this litigation Box #1 P-001008 thru P-001056 File folder entitled "Notes from Fed Ex Records" containing handwritten and typed attorney (Villafafia) notes and screen shots of FedEx subpoena response electronic file Work Product 6(e) Contains information subject to investigative privilege. Also contains information subject to privacy rights of victims who are not parties to this litigation Box #1 P-001057 thru P-001959 File folder entitled "Colonial Bank Records" containing records received in response to grand jury subpoena 6(e) Contains information subject to investigative privilege Box #1 P-001960 Thru P-002089 File folder entitled "OLY Grand Jury Log Vol 2: OLY-51 THROUGH" containing subpoenas numbered OLY-51 through OLY-81 with related correspondence 6(e) Contains information subject to investigative privilege. Also contains information subject to privacy rights of victims who are not parties to this litigation Page 2 of 23 EFTA00191215 Bates Range Description Privilege(s) Asserted Box #1 P-002090 Thru P-002169 File folder entitled "Epstein Corporate Records: OLY-51, OLY-52, OLY-53, OLY-54" containing subpoenas, records received in response to subpoenas, and related correspondence 6(e) Contains information and documents subject to investigative privilege Box #1 P-002170 Thru P-002246 File folder entitled "Colonial Bank" containing subpoenas, correspondence related to subpoenas, records received in response to subpoenas 6(e) Contains information and documents subject to investigative privilege Box #1 P-002247 Thru P-002265 File folder entitled "JEGE & Hyperion from Goldberger OLY-46 & OLY-47" containing documents received in response to subpoenas 6(e) Contains information and documents subject to investigative privilege Box #1 P-002266 Thru P-002386 Indictment preparation binder containing: Grand jury subpoena log, evidence/activity summary chart, witness/victim names and contact list, attorney (Villafafia) handwritten notes, 302s, portions of state investigative file, attorney (Villafafia) typed notes, of individuals listed as "Additional victims" Work product 6(e) Contains information and documents subject to investigative privilege. Also contains information and documents subject to privacy rights of victims who are not parties to this litigation Box #1 P-002387 Thru P402769 Indictment preparation binder containing: Grand jury subpoena log, evidence/activity summary chart, witness/victim names and contact list, attorney (Villafafia) handwritten notes, 302s, portions of state investigative file, attorney (Villafafia) typed notes, relevant pieces of grand jury materials, telephone records/flight records analysis charts, victim/witness photographs, DAVID records, NCICs, and related materials for persons identified as Jane Does #15, 16, 17, 18, 19, Past Employees, Misc. Witnesses Work product 6(e) Contains information and documents subject to investigative privilege. Also contains information and documents subject to privacy rights of victims who are not parties to this litigation Box #1 P-002770 Thrti P-00321 I Indictment preparation binder containing: witness/victim list with identifying information, sexual activity summary, telephone call summary chart, attorney (Villafafia) handwritten notes, 302s, portions of state investigative file, attorney (Villafafia) typed notes, relevant pieces of grand jury materials, telephone records/flight records analysis charts, victim/witness photographs, DAVID records, NCICs, and related materials for persons identified as Jane Does #1, 2, 3, 4, 5, 6, 7, 8 Work product 6(e) Contains information and documents subject to investigative privilege. Also contains information and documents subject to privacy rights of victims who are not parties to this litigation Page 3 of 23 EFTA00191216 Bates Range Description Privilege(s) Asserted Box #1 P-003212 Thru P-003545 Indictment preparation binder containing meta- analysis charts of telephone/flight/grand jury information for a number of victim/witnesses, Nadia Marcinkova, and Adriana Mucinska Work product 6(e) Contains information and documents subject to investigative privilege. Also contains information and documents subject to privacy rights of victims who are not parties to this litigation Box #1 P-003546 Thru P-003552 FBI Reports of March 2008 interviews of additional witness/victim located in New York Work product 6(e) . Contains information and documents subject to investigative privilege. Also contains information and documents subject to privacy rights of victims who are not parties to this litigation Box 141 P-003553 Thru P-003555B Printout of filenames from Federal Express subpoena response with Attorney notations Work product 6(e) Box #1 P-003556 Thru P-003562 Document entitled "Identified Numbers" with accompanying handwritten attorney list compiled from grand jury materials and attorney analysis of records Work product 6(e) Contains information subject to investigative privilege Box #1 P-003563 Thru P-003629 Folder entitled "Flight Manifests" containing manifests received pursuant to grand jury subpoena 6(e) Contains information and documents subject to investigative privilege Box #1 P-003630 Thru P-003633 File folder entitled "Recent Attorney Notes" containing handwritten attorney (Villafada) notes regarding document review and case strategy Work product 6(e) Investigative privilege Deliberative process Box #1 P-003634 Thru P-003646 File folder bearing victim name containing FBI interview report from May 2008, telephone activity report with attorney (Villafanana) handwritten notes, related grand jury material Work product Attorney-client privilege 6(e) Investigative privilege Also contains information and documents subject to privacy rights of victims who are not parties to this litigation Page 4 of 23 EFTA00191217 Bates Range Description Privilege(s) Asserted Box #1 P-003647 Thru P-003651 File folder entitled "Summary of Sexual Activity" containing chart bearing handwritten title "Sexual Activity — Summary" with meta-analysis of information, sorted by name of each victim/witness, including name and identifying information of each victim/witness Work product 6(e) Investigative privilege Deliberative process Also contains information and documents subject to privacy rights of victims who are not parties to this litigation Box #1 P-003652 Thru P-003663 File folder entitled "Victim Civil Suits" Not privileged. Produced to counsel for Petitioners Box #1 P-003664 Thru P-003678 File folder entitled "Research re JE Websites" containing attorney research Work product Box #1 P-003679 Thru P-003680 File folder entitled "Serene Cano (N.Y. AUSA)" containing attorney (Villafafla) handwritten notes Work product Box #1 P-003681 Thru P-003687 File folder entitled "Dr. Anna Salter" containing attorney (Villafafia) memo to expert witness and handwritten attorney notes Work product Investigative privilege Box #1 P-003688 Thru P-003693 File folder entitled la GO Interview" containing attorney handwritten notes of interview, and attorney handwritten notes regarding potential charges Work product Investigative privilege Also contains information subject to privacy rights of victims who are not parties to this litigation Box #I P-003694 Thru P-003711 File folder entitled "Research re Travel for Prostitution" containing attorney (Villafafia) handwritten notes regarding grand jury presentation, chart entitled "Brought to Epstein's House" with handwritten notes, Message Pad meta-analysis chart, summary of evidence related to one victim/witness, and relevant grand jury information Work product 6(e) Investigative privilege Also contains information and documents subject to privacy rights of victims who are not parties to this litigation Box #1 P-003712 Empty file folder bearing name of victim/witness Investigative privilege Also contains information subject to privacy rights of victim who is not a party to this litigation Page 5 of 23 EFTA00191218 Bates Range Description Privilege(s) Asserted Box #1 P-003713 Thru P-003746 File folder entitled "T(] M(]" containing grand jury subpoenas, motion and order to compel testimony, and correspondence regarding same 6(e) Documents under seal pursuant to court order Box #1 P-003747 Thru P-003751 File folder entitled "Adrian Ross" containing subpoena and correspondence regarding same 6(e) Box #1 P-003752 Thru P-004295 File folder entitled "PBPD Investigative File" obtained via subpoena 6(e) Investigative privilege Also contains information and documents subject to privacy rights of victims who are not parties to this litigation Box #1 P-004296 Thru P-004350 File folder bearing name of victim/witness containing meta-analysis chart showing telephone calls, travel, and grand jury materials relevant to possible charges Work product 6(e) Investigative privilege Also contains information and documents subject to privacy rights of victims who are not parties to this liti tion Box #1 P-004351 Thru P-004381 File folder entitled "Daniel Documents Work product 53909-004" containing attorney research related to bias issue Box #1 P-004382 Thru P-004478 File Folder entitled "FEDEX" containing documents obtained via subpoena 6(e) Investigative privilege Box #1 P-004479 Thru P-004551 File Folder entitled "State of Delaware Records" containing documents obtained in preparation for indictment 6(e) Investigative privilege Work product Box #1 P-004552 Thru P-004555 File folder entitled "Jet Blue Records" containing documents obtained via subpoena 6(e) Work product Investigative privilege Also contains information and documents subject to privacy rights of victims who are not parties to this litigation Box #1 P-004556 Thru P-004560 File folder entitled "FL EMPLOYMENT RECORDS" containing FDLE records on targets and witnesses obtained at attorney request Investigative privilege Work product Pagc 6 of 23 EFTA00191219 Bates Range Description Privilege(s) Asserted Box # I P-004561 Thru P-004565 Filed folder entitled "JANUSZ BANASIAK" containing attorney (Villafana) handwritten notes of interview Work product Investigative privilege Box #1 P-004566 Thm P-004716 File folder entitled "JANUSZ BANASIAK RECORDS 23-0001 THROUGH 23-" containing documents obtained via subpoena 6(e) Work product Investigative privilege Also contains information and documents subject to privacy rights of victims who are not parties to this litigation Box #1 P-004717 Thru P-004722 File folder entitled "IGOR ZINOVIEV" containing attorney research regarding witness Work product Investigative privilege Box #1 P-004723 Thru P-004725 File folder entitled "BEAR STEARNS RESEARCH" containing attorney research regarding potential witness and subpoena recipient Work Product Investigative privilege Box #1 P-004726 Thru P-004819 File folder entitled "LAWSUITS INVOLVING EPSTEIN CORP'S" containing attorney research regarding Epstein's past personal and business litigative practices Work Product Investigative privilege Box #1 P-004820 Thru P-004959 Filed folder entitled "SEC RECORDS" containing attorney research regarding Epstein financial relationships Work Product Investigative privilege Box #1 P-004960 Thru P-005059 File folder entitled "Message Pads" containing selected items from evidence obtained via subpoena Work Product 6(e) Investigative privilege Also contains information and documents subject to privacy rights of victims who are not parties to this litigation Box #1 P-005060 Thru P-005081 File folder bearing name of victim/witness containing correspondence with counsel for victim/witness, attorney witness outline with attorney handwritten notes, attorney handwritten notes regarding witness reports and case preparation Work Product 6(e) Investigative privilege Also contains information and documents subject to privacy rights of victims who are not parties to this litigation Box #1 P-005082 Thru P-005083 File folder entitled "New York Trip" containing attorney notes re witness interview Work product Investigative privilege Page 7 of 23 EFTA00191220 Bates Range Description Privilege(s) Asserted P-005084 duu P-005107 are non responsive documents and have been removed Box #1 P-005108 Thru P-005193 File folder entitled "ANNA SALTER" containing attorney research on select expert, use of experts at trials in child exploitation cases, and additional research materials on offenders and victims Work product Investigative privilege Box #1 P-005194 Thru P-005300 File folder entitled "Extra Copies" containing meta-analysis chart and 302's of victim/witnesses used in preparing indictment package Work product 6(e) Investigative privilege Also contains information and documents subject to privacy rights of victims who are not parties to this litigation Box #1 P-005301 Thru P-005331 File folder entitled "JUAN ALESSI STATEMENT" containing transcript obtained via subpoena 6(e) Investigative privilege Box #1 P-005332 Thru P-005341 File folder entitled "KEN LANNING" containing attorney research on select expert, including attorney handwritten notes Work product Investigative privilege Box #1 P-005342 Thru P-005387 File folder entitled "Info re Planes" containing correspondence regarding subpoenas and documents received in response to subpoenas 6(e) Investigative privilege Box #1 P-005388 Thru P-005442 File folder entitled "Police Reports & PC Affidavit" containing portions of police reports with attorney notes, related phone records, a list entitled "Victims" with identifying information and attorney handwritten notes, photographs and DAVID information, and additional attorney research regarding Epstein sexual activity Work product 6(e) Investigative privilege Also contains information and documents subject to privacy rights of victims who are not parties to this litigation Box # I P-005443 Thru P-005496 File folder entitled "[Victim name] Transcript of Interview & GJ Transcript" 6(e) Investigative privilege Also contains information and documents subject to privacy rights of victims who are not parties to this litigation Box #1 P-005497 Thru P-005556 File folder entitled "Bear Stearns Subpoena Resp." containing material received in response to subpoena 6(e) Investigative privilege Page 8 of 23 EFTA00191221 Bates Range Description Privilege(s) Asserted Box #1 P-005557 Thru P-005576 U.S. Attorney's Office Criminal Case File Jacket containing file opening documents, expert witness payment documents Work product Deliberative process Box #1 P-005578 Thru P-005583 U.S. Attorney's Office Asset Forfeiture Case File Jacket containing file opening and file closing documents Work product Deliberative process Box #1 P-005584 Thru P-005606 File folder entitled "6001 Immunity Request" containing internal memoranda seeking witness immunity and correspondence with counsel for witness regarding same 6(e) Work product and deliberative process (as to internal memoranda) Investigative privilege Also contains information and documents subject to privacy rights of victims who are not parties to this litigation Box #2 P-005607 Thru P-005914 File folder entitled "MASTER PHONE RECORDS" containing meta-analysis of all phone, travel, and grand jury data for all victim/witnesses for indictment preparation Work product 6(e) Investigative privilege Also contains information and documents subject to privacy rights of victims who are not parties to this litigation Box #2 P-005915 Thru P-005977 File folder bearing name of victim/witness containing meta-analysis of all phone, travel, and grand jury data related to that victim/witness for indictment preparation Work product 6(e) Investigative privilege Also contains information and documents subject to privacy rights of victims who are not parties to this litigation Box #2 P-005978 Thru P-006050 File folder bearing name of victim/witness containing meta-analysis of all phone, travel, and grand jury data related to that victim/witness for indictment preparation Work product 6(e) Investigative privilege Also contains information and documents subject to privacy rights of victims who are not parties to this litigation Box #2 P-006051 Thru P-006065 File folder bearing name of victim/witness containing meta-analysis of all phone, travel, and grand jury data related to that victim/witness for indictment preparation Work product 6(e) Investigative privilege Also contains information and documents subject to privacy rights of victims who are not parties to this litigation Page 9 of 23 EFTA00191222 Bates Range Description Privilege(s) Asserted Box #2 P-006066 Thru P-006220 File folder entitled "JANE DOE #4" containing meta-analysis of all phone, travel, and grand jury data related to that victim/witness for indictment preparation Work product 6(e) Investigative privilege Also contains information and documents subject to privacy rights of victims who are not parties to this litigation Box #2 P-006221 Thru P-006222 File folder entitled ""JANE DOE #12" containing meta-analysis of all phone, travel, and grand jury data related to that victim/witness for indictment preparation Work product 6(e) Investigative privilege Also contains information and documents subject to privacy rights of victims who are not parties to this litigation Box #2 P-006223 Thru P-006522 File folder entitled "CORRECTED PHONE RECORDS 5/31/07" containing meta-analysis of all phone, travel, and grand jury data related to all victims/witnesses for indictment preparation Work product 6(e) Investigative privilege Also contains information and documents subject to privacy rights of victims who are not parties to this litigation Box #2 P-006523 Thni P-006802 File folder entitled "[Victim Name] Phone Records" containing telephone records received in response to subpoena Work product 6(e) Investigative privilege Also contains information and documents subject to privacy rights of victims who are not parties to this litigation Box #2 P-006803 Thru P-006860 File folder entitled "Lists of Identified Phone Numbers" containing charts of information culled from grand jury materials, interviews, and other investigation, with attorney handwritten notes, and information to issue follow-up grand jury subpoena Work product 6(e) Investigative privilege Also contains information and documents subject to privacy rights of victims who are not parties to this litigation Box #2 P-006861 Thru P-007785 File folder entitled "EPSTEIN/KELLEN CELL PHONE RECORDS" containing documents received via subpoena with attorney handwritten notes and highlighting Work product 6(e) Investigative privilege Also contains information and documents subject to privacy rights of victims who are not parties to this litigation Page 10 of 23 EFTA00191223 Bates Range Description Privilege(s) Asserted Box #2 P-007786 Thru P-008120 Folder entitled "OLY GRAND JURY LOG: OLY-01 THROUGH OLY-50" containing subpoenas, correspondence regarding same, 6(e) letters, attorney handwritten notes regarding records received in response to subpoenas Work product 6(e) Investigative privilege Also contains information and documents subject to privacy rights of victims who are not parties to this litigation Box #2 P-008121 Thru P-008139 Handwritten flight logs received in response to subpoena 6(e) Investigative privilege Box #2 P-008140 Thru P-008298 Grand jury presentation folder containing attorney handwritten notes, typed outline with additional handwritten notes, complete indictment package dated 2/19/2008, victim list with identifying information, photographs, and summary of activity Work product 6(e) Investigative privilege Also contains information and documents subject to privacy rights of victims who are not parties to this litigation Box #2 P-008299 Thru P-008363 File folder entitled "FINAL AGREEMENTS" containing subfolder entitled "Agrmts Filed in State Court" (P-008300-P-008327 [not being withheld as privileged — have been produced to opposing counsel]); signed Non-Prosecution Agreement, Addendum, and operative portion of 12/19/2007 Sanchez-Acosta letter (P-008328-P- 008343 [not being withheld as privileged — have been produced to opposing counsel]); subfolder entitled "12/19/07 Acosta-Sanchez Ltr" containing unredacted copies of that letter (P- 008344-P-008363 [pursuant to Court's Order, not being withheld as privileged — will be produced to opposing counsel upon lift of stay by 11 th Circuit]) Box #2 P-008364 Thru P-008382 File folder entitled "Lacerda Immunity Request" containing internal memoranda, Justice Department documentation, and subpoena regarding immunity request 6(e) Work Product Deliberative Process Investigative privilege Box #2 P-008383 Thru P-008516 File folder containing March IS, 2008 grand jury presentation materials, including "Operation Leap Year Revised Indictment Summary Chart (by victim)," grand jury materials, draft indictments, victim reference list, grand jury subpoena log Work product 6(e) Investigative privilege Deliberative process Also contains information and documents subject to privacy rights of victims who are not parties to this litigation Page 11 of 23 EFTA00191224 Bates Range Description I'll% ilege(s) Asserted Box #2 P-008517 Thru P-008535 6/25/2007 Letter from Gerald Lefcourt to Jeffrey Sloman and Andrew Lourie [pursuant to Court's Order, not being withheld as privileged — will be produced to opposing counsel upon lift of stay by 11's Circuit] Box #2 P-008536 Thru P-008542 Handwritten attorney notes to prepare for interview of Jane Doe #2 Work product Investigative Privilege Contains information subject to privacy rights of victims who are not parties to this suit Box #2 P-008543 Thru P-008549 Handwritten attorney notes regarding May 8, 2007 grand jury presentation Work product 6(e) Investigative privilege Contains information subject to privacy rights of victims who are not parties to this suit Box #2 P-008550 Thru P-008615 File folder entitled "Most Recent Indictment & Good Cases" containing draft indictment and legal research Work product 6(e) Investigative privilege Deliberative process Contains information subject to privacy rights of victims who are not parties to this suit Box #2 P-008616 Thru P-008686 File folder entitled "FBI Summary Charts" containing chart prepared at direction of AUSA, containing victim names, identifying information, summary of activity, and other information relevant to indictment Work product Attorney-Client Privilege 6(e) Investigative privilege Contains information subject to privacy rights of victims who are not parties to this suit Box #2 P-008687 Thru P-008776 File folder entitled "[Victim name]/Jane Doe #4" containing phone records and meta-analysis of all phone, travel, and grand jury data related to that victim/witness for indictment preparation Work product 6(e) Investigative privilege Contains information and documents subject to privacy rights of victims who are not parties to this suit Box #2 P-008777 Thi u P-00SSOS File folder entitled "[Victim name]/Jane Doe #5" containing handwritten notes and meta-analysis of all phone, travel, and grand jury data related to that victim/witness for indictment preparation Work product 6(e) Investigative privilege Contains information subject to privacy rights of victims who are not parties to this suit Page 12 of 23 EFTA00191225 Bates Range Description Privilege(s) Asserted Box #2 P-008809 Thru P-008847 File folder entitled "[Victim name]/Jane Doe #6" containing meta-analysis of all phone, travel, and grand jury data related to that victim/witness for indictment preparation Work product 6(e) Investigative privilege Contains information subject to privacy rights of victims who are not parties to this suit Box #2 P-008848 Thru P-008862 File folder entitled "[Victim name]/Jane Doe #7" containing meta-analysis of all phone, travel, and grand jury data related to that victim/witness for indictment preparation Work product 6(e) Investigative privilege Contains information subject to privacy rights of victims who are not parties to this suit Box #2 P-008863 Thru P-008890 File folder entitled "[Victim name]/Jane Doe #8" containing meta-analysis of all phone, travel, and grand jury data related to that victim/witness for indictment preparation Work product 6(e) Investigative privilege Contains information subject to privacy rights of victims who are not parties to this suit Box #2 P-008891 Thru P-009103 File folder entitled "Certified Copy of State Case" containing certified copy of Epstein state criminal cases and change of plea transcript (not being withheld as privileged — copy provided to opposing counsel] Box #2 P-009104 Thru P-009111 File folder entitled "Meeting Timeline" containing Villafafia typed notes summarizing meetings with opposing counsel prepared at request of R. Alexander Acosta, with handwritten correction and typed guideline estimate Work product Deliberative process Box #2 P-009112 Thru P-009113 11/26/2008 Email from Roy Black to A. Marie Villafafia and Karen Atkinson re Jeffrey Epstein (work release) [pursuant to Court's Order, not being withheld as privileged — will be produced to opposing counsel upon lift of stay by 1 l'h Circuit] Box #2 P-009114 Thru P-009115 7/3/2008 Email from A. Marie Villafafia to Col. M. Gauger at PBSO re Epstein work release with attachment [not being withheld as privileged — produced to opposing counsel] Box #2 P-009116 Thru P-009125 12/6/2007 Letter from Jeffrey Sloman to Jay P. Lefkowitz re Jeffrey Epstein (victim notification) [pursuant to Court's Order, not being withheld as privileged — will be produced to opposing counsel upon lift of stay by 11's Circuit]) Page 13 of 23 EFTA00191226 Bates Range Description Privilege(s) Asserted Box #2 P-009126 Tbru P-009134 File folder entitled "[Victim name]/Jane Doe #9" containing meta-analysis of all phone, travel, and grand jury data related to that victim/witness for indictment preparation Work product 6(e) Investigative privilege Contains information subject to privacy rights of victims who are not parties to this suit Box #2 P-009135 Thru P-009141 File folder entitled "[Victim name]/Jane Doe #13" containing meta-analysis of all phone, travel, and grand jury data related to that victim/witness for indictment preparation Work product 6(e) Investigative privilege Contains information subject to privacy rights of victims who are not parties to this suit Box #2 P-009141A Thru P-00914IC File folder entitled "[Victim name]/Jane Doe #12" containing meta-analysis of all phone, travel, and grand jury data related to that victim/witness for indictment preparation Work product 6(e) Investigative privilege Contains information subject to privacy rights of victims who are not parties to this suit Box #2 P-009142 Thru P-009152 File folder entitled "Adriana 'Mucinka' Ross" containing meta-analysis of all phone, travel, and grand jury data related to that individual for indictment preparation Work product 6(e) Investigative privilege Contains information subject to privacy rights of victims who are not parties to this suit Box #2 P-009153 Thru P-009156 File folder entitled "Nadia Marcinkova" containing meta-analysis of all phone, travel, and grand jury data related to that individual for indictment preparation Work product 6(e) Investigative privilege Contains information subject to privacy rights of victims who are not parties to this suit Box #2 P-009157 Thru P-009208 File folder entitled "[Victim name]/Jane Doe #1" containing meta-analysis of all phone, travel, and grand jury data related to that victim/witness for indictment preparation Work product 6(e) Investigative privilege Contains information subject to privacy rights of victims who are not parties to this suit Box #2 P-009209 Thru P-009213 File folder entitled "[Victim name]/Jane Doe #2" containing meta-analysis of all phone, travel, and grand jury data related to that victim/witness for indictment preparation Work product 6(e) Investigative privilege Contains information subject to privacy rights of victims who are not parties to this suit Page 14 of 23 EFTA00191227 Bates Range Description Privilege(s) Asserted Box #2 P-009214 Thru P-009271 File folder entitled "[Victim name]/Jane Doe #3" containing meta-analysis of all phone, travel, and grand jury data related to that victim/witness for indictment preparation Work product 6(e) Investigative privilege Contains information subject to privacy rights of victims who are not parties to this suit Box #2 P-009272 Thru P-009354 File folder entitled 'Purpose of Travel Cases" containing attorney research and handwritten notes Work product Box #2 P-009355 Thru P-009403 File folder entitled "Interstate Commerce Cases" containing attorney research and handwritten notes Work product Box #2 P-009404 Thru P-009536 File folder entitled "Attorney Conflict Research" containing attorney research and handwritten notes Work product Box #2 P-009537 Thru P-009574 File folder entitled "Mann Act/Travel to Have Sex w/Minor" containing attorney research and handwritten notes Work product Box #2 P-009575 Thru P-009603 File folder entitled "Travel Act" containing attorney research and handwritten notes Work Product Box #2 P-009604 Thru P-009711 File folder entitled "Florida Prostitution/Lewdness Statutes" containing attorney research and handwritten notes Work Product Box #2 P-009712 Thru P-009819 Booklet entitled "Attorney General Guidelines for Victim and Witness Assistance" [not being withheld as privileged — produced to opposing counsel] Box #2 P-009820 Thru P-009965 File folder entitled "Corporate Liability Rsrch" containing attorney research and handwritten notes Work Product Box #2 P-009966 Thru P-010096 File folder entitled "Research re Knowledge of Age Unnecessary" containing attorney research and handwritten notes and copy of grand jury subpoena Work Product 6(e) Page 15 of 23 EFTA00191228 Bates Range Description Privilege(s) Asserted Box #2 P-010097 Thru P-010276 File folder entitled "Money Laundering" containing attorney research and handwritten notes Work Product Box #2 P-010277 Thru P-010394 File folder entitled "1960 & Aiding/Abetting" containing attorney research and handwritten notes Work Product Box #2 P-010395 Thru P-010488 File folder entitled "18 USC § 2255 Cases" containing attorney research and handwritten notes Work Product Box #2 P-010489 Thru P-010509 File folder entitled "Research re Overt Acts & Witness Testimony" containing attorney research and handwritten notes Work Product Box #2 P-010510 Thru P-010525 File folder entitled "Extradition" containing attorney research and handwritten notes Work Product Box #2 P-010526 Thru P-010641 File folder entitled "Rsrch re Crime Victims Rights" containing attorney research, handwritten notes, draft victim notification letter, and draft correspondence to Jay 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) Work Product Deliberative Process Box #2 P-010642 Thru P-01650 File folder entitled "Immunity" containing attorney research on granting immunity to witnesses Work Product Box #2 P-010651 Thru P-010659 File folder entitled "Research re G.J. Transcript" containing attorney research and draft pleadings re compelling production of grand jury transcript with subpoena Work Product 6(e) Deliberative process Box #2 P-010660 Thru P-010757 File folder entitled "Research re GJ Transcript" containing grand jury subpoena, 6(e) letters, attorney research and correspondence related to subpoena Work Product 6(e) Page 16 of 23 EFTA00191229 Bates Range Description Privilege(s) Asserted Box #2 P-010758 Thru P-010793 File folder entitled "Original Proposed Ind." containing draft indictment Work Product 6(e) Deliberative process Box #2 P-010794 Thru P-010829 File folder entitled "Epstein" containing sample indictments and attorney research re potential charges with attorney notes Work Product Box #2 P-010830 Thru P-010853 File folder entitled "1591 & Money Laundering" containing attorney research and handwritten notes Work Product Box #2 P-010854 Thru P-010876 File folder entitled "18 USC 2425" containing attorney research and handwritten notes Work Product Box #2 P-010877 Thru P-010920 File folder entitled "Knowledge of Age" containing attorney research and handwritten notes Work Product Box #2 P-010921 Thru P-011049 File folder entitled "2423(b) Constitutionality and Purpose of Travel" containing attorney research and handwritten notes Work Product Box #2 P-011050 Thru P-011212 File folder entitled "Mistake not a Defense" containing attorney research and handwritten notes Work Product Box #2 P-011213 Thru P-011237 File folder entitled "Research re `Pandering— containing attorney research and handwritten notes Work Product Box #2 P-011238 Thru P-011319 File folder entitled "Research re Grand Jury Instructions" containing attorney research and handwritten notes Work Product 6(e) Box #2 P-011320 Thru P-011361 File folder entitled "Telephone = Facility of Commerce" containing attorney research and handwritten notes Work Product Box #2 P-011362 Thru P-011374 File folder entitled "Def of Prostitution" containing attorney research and handwritten notes Work Product Page 17 of 23 EFTA00191230 Bates Range Description Privilege(s) Asserted Box #2 P-011375 Thru P-011456 File folder entitled "Relevant Florida Statutes" containing attorney research and handwritten notes Work Product Box #2 P-011457 Thru P-011626 File folder entitled "Unit of Prosecution Research" containing attorney research and handwritten notes Work Product Box #3 P-011627 Thru P-011662 File folder entitled "Attorney Notes" containing attorney handwritten and typed notes Work Product Box #3 P-011663 Thru P-011698 and P-012189 thru P-012361 (gap was scanning error) File folder entitled "Drafts" containing draft indictments with attorney handwritten notes, draft internal memoranda, relevant witness interview reports and grand jury material and attorney handwritten notes 6(e) Work Product Deliberative Process Investigative Privilege Contains information subject to privacy rights of victims who are not parties to this Box #3 P-011699 Thru P-011777 File folder entitled "6/9/09 Signed Indictment" containing signed indictment package dated 6/9/2009 with corrections 6(e) Work product Deliberative process Box #3 P-011778 Thru P-011788 File folder entitled "6/12/09 Victim Notif. Log" containing chart with victim contact information and attorney notes regarding dates and type of contacts Work product Box #3 P-011789 Thru P-011879 File folder entitled "Breach Memo" containing memorandum analyzing breach of Non- Prosecution Agreement with attachments Work product Deliberative process Box #3 P-011880 Thru P-011922 File folder entitled "Overt Act Lists" containing handwritten notes cross-checking all overt acts alleged in draft indictment by victim and typed overt act summary charts for indictment preparation Work product Attorney-client privilege Deliberative process 6(e) Page 18 of 23 EFTA00191231 Bates Range Description Privilege(s) Asserted Box #3 P-011923 Thru P-011966 Folder entitled "Responses to Arguments from JE Counsel" containing: ■ 7/13/2007 letter from Lilly Ann Sanchez to Andrew Lourie with handwritten attorney (Lourie) notes; ■ 6/25/2007 letter from Gerald Lefcourt to Jeffrey Sloman, Matt Menchal, Andrew Lourie, and Marie 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 Work product Deliberative process 6(e) Attorney-Client Privilege Box #3 P-011967 Thru P-012016 Composition book entitled "Operation Leap Year" containing attorney handwritten notes regarding investigation and case strategy Work product Investigative privilege 6(e) Contains information subject to privacy rights of victims who are not parties to this litigation Box #3 P-012017 Thru P-012055 Motion of Jeffrey Epstein to Intervene and to Quash Grand Jury Subpoenas and Incorporated Memorandum of Law 6(e) Box #3 P-012056 Thru P-012088 Affidavit of Roy Black, Esq. in Support of Motion of Jeffrey Epstein to Intervene and to Quash Grand Jury Subpoenas 6(e) Box #3 P-012089 Thru P-012129 United States' Response to Motion of Jeffrey Epstein to Intervene and to Quash Grand Jury Subpoenas and Cross-Motion to Compel 6(e) Box #3 P-012130 Thru P-012150 Declaration of Joseph Recarey 6(e) Box #3 P-012151 Thru P-012167 Ex Parte Declaration Number One in Support of United States' Response to Motion to Quash Subpoenas 6(e) Investigative Privilege Also contains information subject to privacy rights of victims who are not parties to this litigation Page 19 of 23 EFTA00191232 Bates Range Description Privilege(s) Asserted Box #3 P-012168 Thru P-012170 Ex Parte Declaration Number Two in Support of United States' Response to Motion to Quash Subpoenas 6(e) Investigative Privilege Box #3 P-012171 Thru P-012173 Supplement to Ex Parte Declaration Number One in Support of United States' Response to Motion to Quash Subpoenas 6(e) Investigative Privilege Also contains information subject to privacy rights of victims who are not parties to this litigation Box #3 P-012174 Thru P-012176 Draft of September 2009 letter from Marie Villafana to Roy Black regarding breach of Non Prosecution Agreement with handwritten attorney (Villafafia) notes Work Product Attorney-Client Privilege Deliberative Process Box #3 P-012177 Thru P-012178 Undated handwritten attorney (Villaftula) notes regarding negotiations and allegations Work Product Attorney-Client Privilege Deliberative Process Box #3 P-012179 Thru P-012188 File Folder entitled "FBI G.J. Log" containing copy of FBI grand jury subpoena log with attorney (Villafafla) handwritten notes 6(e) Work Product Investigative Privilege Also contains information subject to privacy rights of victims who are not parties to this litigation Box #3 P-012362 Thru P-012451 File folder entitled "Key Documents" containing correspondence between AUSA and case agent regarding indictment prep questions, victim identification information, corrections to draft indictment, indictment preparation timeline, key grand jury material 6(e) Work Product Attorney-Client privilege Investigative Privilege Also contains information subject to privacy rights of victims who are not parties to this litigation Box #3 P-012451 Thru P-012452 File folder entitled "Victim List" containing list of victims with dates of birth and age information Work Product Investigative Privilege Also contains information subject to privacy rights of victims who are not parties to this litigation Page 20 of 23 EFTA00191233 Bates Range Description Privilege(s) Asserted Box #3 P-012453 Thru P-012623 Complete indictment package marked "Originals 12/12/07" Work-product Deliberative process 6(e) Also contains documents subject to investigative privilege Also contains documents subject to privacy rights of victims who are not parties to this litigation Box #3 P-012624 Thru P-012653 Folder entitled "(Victims) Additional 302's" containing reports of interviews conducted in June 2007, October 2007, and March 2008. Investigative Privilege Also contains documents subject to privacy rights of victims who are not parties to this litigation Box #3 P-012654 Thru P-012864 3-ring binder entitled "Child Molesters: A Behavioral Analysis" with attorney (Villafafia) handwritten notes Work-product Box #3 P-012865 Thru P-013226 Indictment preparation binder containing: witness/victim list with identifying information, sexual activity summary, telephone call summary chart, attorney (Villafafia) handwritten notes, 302s, portions of state investigative file, attorney (Villafafia) typed notes, relevant pieces of grand July materials, telephone records/flight records analysis charts, victim/witness photographs, DAVID records, NCICs, and related materials for persons identified as Jane Does #9, 10, 11, 12, 13, 14 Work Product Deliberative Process 6(e) Also contains documents subject to investigative privilege Also contains documents subject to privacy rights of victims who are not parties to this litigation Box #3 P-013227 April 23, 2008 Memo from Jeffrey Sloman to Office of Professional Responsibility re Self Reporting, Corrected Version of the previously submitted April 21, 2008 Letter to OPR Privacy Act Box #3 P-013226 Thru P-013230 April 21, 2008 Letter from Jeffrey Sloman to Office of Professional Responsibility re Self Reporting Privacy Act Box #3 P-013231 Thru P-013239 April 22, 2008 Letter from A. Marie Villafafia to Office of Professional Responsibility re Self- Report of Allegation of Conflict of Interest Privacy Act Page 21 of 23 EFTA00191234 Bates Range Description Privilege(s) Asserted Box #3 P-013240 Thru P-013247 April 21, 2008 Letter from Jeffrey Sloman to Office of Professional Responsibility re Self Reporting with attachments Privacy Act Box #3 P-013248 Thru P-013251 Emails between Richard Sudder, Assistant General Counsel, Executive Office for United States Attorneys, and Benjamin Greenberg, First Assistant U.S. Attorney, Southern District of Florida, regarding Formal Notice of Office-wide Recusal of Southern District of Florida dated August 24 and August 29, 2011 Attorney-Client Privilege Box #3 P-013252 Thru P-013253 Emails between Richard Sudder, Assistant General Counsel, Executive Office for United States Attorneys, and Benjamin Greenberg, First Assistant U.S. Attorney, Southern District of Florida, regarding Recusal matter, dated July 28, August 3, and August 24, 2011 Attorney-Client Privilege Box #3 P-013254 Thru P-013257 Emails between Richard Sudder, Assistant General Counsel, Executive Office for United States Attorneys, and Benjamin Greenberg, First Assistant U.S. Attorney, Southern District of Florida, regarding Formal Notice of Office-wide Recusal of Southern District of Florida dated August 24 and August 29, 2011 Attorney-Client Privilege Box #3 P-013258 Thru P-013259 Emails between Richard Sudder, Assistant General Counsel, Executive Office for United States Attorneys, and Benjamin Greenberg, First Assistant U.S. Attorney, Southern District of Florida, regarding Format Notice of Office-wide Recusal of Southern District of Florida dated July 28 and August 3, 2011 Attorney-Client Privilege Box #3 P-013260 Thru P-013262 Email from Richard Sudder, Assistant General Counsel, Executive Office for United States Attorneys, to Wifredo Ferrer (U.S. Attorney, SDFL), Robert O'Neill (U.S. Attorney, MDFL), Benjamin Greenberg, (FAUSA, SDFL), and Lee Bentley (FAUSA, MDFL) regarding Formal Notice of Office-wide Recusal of Southern District of Florida dated August 24, 2011. CC's David Margolis (ODAG), Jay MackSJSAEO), Thomas Anderson (USAEO), Tapken (USAEO), James Read (USAEO) Attorney-Client Privilege 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 Thru for United States Attorneys, and Dexter Lee, Southern District of Florida, seeking advice P-013278 regarding office-wide recusal, dated December 16 and 17, 2010, with attached letter from Paul Cassell to Wifredo A. Ferrer, dated December 10, 2010 Page 23 of 23 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) (2) (3) (4) (5) (6) (7) (8) One DVD containing documents Bates Stamped 000001 thru 000979; Documents bearing Bates Nos. P-003652 thru P-003663; Documents bearing Bates Nos. P-008300 thru P-008343; Documents bearing Bates Nos. P-008891 thru P-009103; Documents bearing Bates Nos. P-009114 thru P-009115; Documents bearing Bates Nos. P-009712 thru P-009819; A copy of the Privilege Log that was filed with the Court; and 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 By: cc: Dexter Lee, Esq. Ui iM4 Sues Atto • ey A. Mane Vi afafia Assistant United States Attorney 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 Matt Menchel informing him of intent to subpoena Roy Black's private investigator and steps taken to obtain DOJ authorization Work Product 6(e) Deliberative Process Investigative Privilege 2 5/21/2007 email from Marie Villafafta to Myesha Braden (CEOS) re 2423(b) charging question Work Product 6(e) Deliberative Process Investigative Privilege 3 5/21/2007 email from Marie Villafafia to Matt Menchel and Jeff &man regarding guidance on grand jury presentation Work Product 6(e) Deliberative Process 4 6/12/2007-7/6/2007 series of emails between Marie Villafafia and AU SAs Serene Nakano and James Cott re an earlier unrelated investigation of Epstein Work Product Investigative Privilege Privacy Act 5 7/3/2007-7/13/2007 email chain between Matt Menchel and Marie Villafafia regarding disagreement on Menchel's plea negotiations and written request for meeting between USAO management and victims 6(e) Work Product Deliberative Process Investigative Privilege 6 7/16/2007 email from Marie Villafafia to Matt Menchel and Andrew Lourie regarding correspondence from Roy Black and Motion to Quash 6(e) Work Product Deliberative Process Investigative Privilege 7 7/18/2007 emails from Marie Villafafia to Andrew Lourie and Matt Menchel regarding Motion to Quash grand jury subpoena and supporting affidavit filed by Roy Black 6(e) Work Product Deliberative Process Investigative Privilege 8 7/19/2007 email chain between Marie Villafafta, Andrew Lourie, Matt Menchel, S/A Jason Richards and S/A Eliasib Ortiz regarding potential service of target letters 6(e) Work Product Deliberative Process Investigative Privilege Attorney-Client Privilege 9 7/26/2007 email from Marie Villafafia to Matt Menchel and Andrew Lourie regarding proposed changes to the indictment 6(e) Work Product 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 Sloman, Matt Menchel, and Andrew Lourie with draft response to Epstein counsel regarding agreement Work Product Deliberative Process Investigative Privilege 11 7/31/2007-8/2/2007 email chain between Jeff Sloman, Matt Menchel, Andrew Lourie, and Marie Villafafia regarding plea negotiations Work Product Deliberative Process Investigative Privilege 12 8/3/2007 Email from Marie Villafafia to Matt Menchel, Andrew Lourie, Jeff Sloman, and Karen Atkinson regarding draft response to correspondence from Epstein counsel and planned investigative steps if agreement cannot be reached. Work Product Deliberative Process Investigative Privilege 13 Emails dated 8/6/2007 from Marie Villafafia to Cyndee Campos/Frederica Devlin and Jeff Sloman regarding Matt Menchel's correspondence prior to his departure. Work Product Deliberative Process 14 8/7/2007 email chain between Marie Villafafia, Cyndee Campos, and Alex Acosta regarding meeting to discuss Epstein matter Work Product Deliberative Process Investigative Privilege 15 8/7/2007 email from Marie Villafafia to Andy Lourie regarding deadline set for Epstein plea and Epstein's plan to demand a meeting with CEOS. Work Product Deliberative Process Investigative Privilege 16 8/7/2007 email from Marie Villafafia to Andrew Oosterbaan regarding Epstein meeting Work Product Deliberative Process Investigative Privilege Work Product Deliberative Process Investigative Privilege 17 8/7/2007 email chain from Jeff Sloman to Andrew Oosterbaan, Mark Villafafia, and Alex Acosta regarding Epstein meeting 18 8/8/2007 emails between Marie Villafafia and Andrew Oosterbaan (CEOS) regarding case staffing and plea negotiations Work Product Deliberative Process Investigative Privilege 19 8/8/2007 email chain between Andrew Oosterbaan, Alex Acosta, Marie Villafafia, Cyndee Campos, Jeff Sloman, and Andrew Lourie regarding "The meeting on Epstein" Work Product Deliberative Process Investigative Privilege 20 8/10/2007 Electronic correspondence from Marie Villafafia to expert witness regarding topics for expert testimony Work Product 21 9/21/2007 emails between Marie Villafafia and Andrew Lourie, Rolando Garcia, Karen Atkinson, and John McMillan regarding revisions to the non-prosecution agreement Work Product Deliberative Process Page 2 of 12 EFTA00191239 Bates Range Description Privilege(s) Asserted 22 9/24/2007 series of emails between Marie Villafafia, Alex Acosta, and Andrew Lourie regarding plea negotiations and revisions to non-prosecution agreement Work Production Deliberative Process 23 9/23/2007-9/24/2007 series of emails between Alex Acosta, Marie Villafafia, Andrew Lourie, Rolando Garcia, and Jeff Sloman regarding proposed revisions to non- prosecution agreement Work Product Deliberative Process 24 4/29/2008 email from Marie Villafafia to Robert Senior, Jeff Sloman, Karen Atkins, on Rolando Garcia re grand jury presentation Work Product 6(e) Deliberative Process Investigative Privilege 25 5/23/2008-5/27/2008 emails between Marie Villafafia, Robert Senior, J,11Sloman, Karen Atkinson, Nesbitt Kuyrketidall (FBI), and Jason Richards (FBI) re status of investigation, indictment review, grand jury preparation, and Epstein's attempt to revisit plea negotiations Work Product 6(e) Deliberative Process Investigative Privilege 26 5/22/2007 email from Andy Lourie to Matt Menchel and Jeff Sloman (cc: Marie Villafaita) re letter received from Gerald Lefcourt discussing a meeting to discuss Epstein investigation Work Product Deliberative Process 27 5/23/2007 email from Jason Richards to Marie Villafafia re extradition research Work Product A/C privilege Investigative Privilege 28 5/23/2007 emails between Karen Atkinson and Marie Villafafia regarding decision to meet with counsel for Epstein Work Product Deliberative Process 29 4/2/2008 emails between Marie Villafafia, Alex Acosta, Jeff Sloman, Karen Atkinson, Robert Senior, Rolando Garcia, and Nesbitt Kuyrkendall regarding efforts by Jay Lefkowitz and Ken Starr to speak with Alex Acosta and instructions to direct question to Marie Villafalla and Karen Atkinson Deliberative Process Work Product Attorney-Client Privilege 30 3/19/2008-3/21/2008 emails between Marie Villafafia, Drew Oosterbaan (CEOS), Gelber (CEOS), Jeff Sloman, and Robert Senior about meeting between Esptein counsel and CEOS and follow-up questions Work Product 6(e) Deliberative Process Investigative Privilege Page 3 of 12 EFTA00191240 Bates Range Description Privilege(s) Asserted 31 4/4/20084/7/2008 emails between Marie Villafafta, Robert Senior, Andrew Oosterbaan, and Jeff Sloman regarding status of CEOS review of Epstein matter Work Product 6(e) Deliberative Process 32 4/11/2008-4/23/2008 emails between Marie Villafafla, Jeff Sloman, and Dexter Lee regarding self-reporting to OPR false allegations of ethics violations Work Product Deliberative Process Privacy Act 33 5/15/2008-5/16/2008 emails between Jeff Sloman, Marie Villafafia, and Robert Senior regarding receiving final approval from DC Work Product Deliberative Process 34 5/7/2008-5/9/2008 emails between Marie Villafafia, Robert Senior, Jeff Sloman, Nesbitt Kuyrkendall, and Jason Richards regarding awaiting approval from DC and status of ongoing investigation Work Product 6(e) Deliberative Process Attorney-Client Privilege Investigative Privilege 35 5/2/2008 emails between Robert Senior, Marie Villafafta, Karen Atkinson, Nesbitt Kuyrkendall, and Jason Richards regarding developments in Epstein investigation and impact on grand jury presentation 6(e) Work Product Attorney-Client Privilege Investigative Privilege Deliberative Process 36 4/29/2008-5/2/2008 emails between Marie Villafafia and Jeff Sloman regarding contact by Epstein counsel and victims and draft letter to counsel for Epstein 6(e) Work Product Deliberative Process Investigative Privilege 37 11/29/2006-12/1/2006 emails between Marie Villafafia and prison employee regarding attempted contact with potential witness Work Product Investigative Privilege Privacy Act 38 7/19/2007 email from Marie Villafafia to Andrew Lourie and Matt Menchel regarding planned service of target letters Work Product 6(e) Investigative Privilege Deliberative Process 39 5/18/2007 emails between Marie Villafafia and expert witness regarding securing pre- indictment consultation contract Work Product 6(e) Investigative Privilege 40 7/3/2007-7/4/2007 emails between Marie Villafafla and Andrew Lourie regarding extension of time to respond to subpoenas requested by Lilly Ann Sanchez and possible resolution of case 6(e) Work Product Investigative Privilege Deliberative Process 41 9/19/2007-9/20/2007 emails between Marie Villafafta, Andrew Lourie, and Rolando Garcia regarding plea negotiations with counsel for Epstein Work Product Deliberative Process Page 4 of 12 EFTA00191241 Bates Range Description Privilege(s) Asserted 42 6/26/2007 email from Marie Villafafia to Jeff Sloman, Matt Menchel, and Andrew Lourie addressing arguments regarding interstate nexus for 2422(b) charges Work Product Deliberative Process 43 3/28/2008 emails between Marie Villafafia, Nesbitt Kuyrkendall, Jeff Sloman, Robert Senior, and Karen Atkinson regarding status of DC review of case and preparing for grand jury presentation Work Product 6(e) Investigative Privilege Deliberative Process 44 7/31/2007 email from Marie Villafafia to Jeff Sloman, Matt Menchel, and Andrew Lourie summarizing proposed plea terms as per Menchel recommendation Work Product Deliberative Process 45 8/8/2007 email from Marie Villafafia to Drew Oosterbaan regarding plea negotiations, guideline calculations, and assistance in preparing case for trial Work Product Investigative Privilege Deliberative Process 46 8/8/2007 email from Marie Villafafia to Alex Acosta, Cyndee Campos, Jeff Slonum, Andrew Lourie, and Drew Oosterbaan regarding planning meeting with Epstein counsel and service of target letters Work Product 6(e) Investigative Privilege Deliberative Process 47 6/14/2007-6/21/2007 emails between Marie Viilafalla, Karen Atkinson, Andrew Lourie, Matt Menchel, and Jeff Sloman regarding addendum to Pros Memo, grand jury presentation and changes to indictment, and meeting with counsel for Epstein 6(e) Work Product Deliberative Process Investigative Privilege 48 8/2/2007 emails between Matt Menchel, Jeff Sloman, Andy Lourie, and Marie Villafafia regarding letter received from Lilly Ann Sanchez Work Product Deliberative Process 49 3/19/2008-3/27/2008 emails between Jeff Sloman, Bob Senior, Karen Atkinson, Rolando Garcia, Nesbitt Kurykendall, and Jason Richards regarding waiting for DC's 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 Work Product Deliberative Process Investigative Privilege 6(e) Page 5 of 12 EFTA00191242 Bates Range Description Privilege(s) Asserted 50 3/31/2008 emails between Marie Villafafia, Jeff Sloman, Robert Senior, and Nesbitt Kuyrkendall regarding status of ongoing investigation, planned presentation to grand jury, continued delay in awaiting decision from Washington, DC, and problems with victims being harassed 6(e) Work Product Deliberative Process Investigative Privilege 51 4/10/20084/18/2008 emails between Marie Villafafia, Robert Senior, Karen Atkinson, Nesbitt Kuyrkendall, and Jeff Sloman about continued delay in presenting case to grand jury due to failure to receive decision from DC, status of grand jury presentation and ongoing investigation 6(e) Work Product Deliberative Process Investigative Privilege 52 4/21/2008-5/1/2008 emails between Marie Villafaila, Robert Senior, Jeff Sloman, Karen Atkinson, Nesbitt Kuyrkendall, and Drew Oosterbaan about continued delay in 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 6(e) Work Product Deliberative Process Investigative Privilege 53 5/19/2008-5/22/2008 emails between Marie Villafafia, Karen Atkinson, Robert Senior, and Jeff Sloman regarding preparation for grand jury presentation; communication with S/A Kuyrkendall regarding plea negotiations; and status of ongoing investigation 6(e) Work Product Deliberative Process Investigative Privilege 54 8/15/2008 email from Marie Villafafia to Alex Acosta, Jeff Sloman, Robert Senior, 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) Work Product Deliberative Process 55 12/3/2007-12/5/2007 correspondence between Alex Acosta, Jeff Sloman, Marie Villafafta, Nesbitt Kuyrkendall, Cyndee Campos, and Annette Castillo about drafting and sending the 12/4/2007 Acosta letter to Ken Starr Work Product Deliberative Process 6(e) Attorney-Client Privilege Page 6 of 12 EFTA00191243 Bates Range Description Privilege(s) Asserted 56 12/18/2007 emails from other AUSAs to Marie Villaftula regarding other instances of charging 2422(b) based only on the use of a telephone Work Product 6(e) 57 11/28/2007 correspondence between Marie Villafafta, Andrew Lourie, Drew Oosterbaan, and Rolando Garcia regarding Lefkowitz 11/27/2007 email discussing presentation to DAAG Work Product Deliberative Process 58 11/19/2007-11/28/2007 emails between Marie Villafafla, Nesbitt Kuyrkendall, Jason Richards, and Jeff Sloman regarding drafting victim notification letter of upcoming plea Work Product Deliberative Process Attorney-Client Privilege 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 Jeff Sloman and Alex Acosta regarding call with lawyer for Jane Doe #2 (T.M.) Work Product Deliberative Process 60 12/3/2007 emails between Marie Villafatta, Alex Acosta, and Jeff Sloman regarding history of plea negotiations and drafting response to correspondence from Jay Lekowitz and Ken Starr Work Product Deliberative Process 61 8/10/2007 email from Marie Villafafia to Andrew Lourie regarding target letters and staying motion to compel production of computers Work Product 62 8/30/2007 email from Marie Villafafta to Jeff Sloman, Andrew Lourie, Drew Oosterbaan, John McMillan, and Karen Atkinson regarding press coverage of meeting with Ken Starr Work Product 63 9/4/2007-9/6/2007 emails between Marie Villafafia and Jeff Sloman regarding planned participation of FBI ASAIC at 9/7/2007 meeting with Epstein defense team Work Product Deliberative Process 64 9/6/2007 emails between Marie Villafafia, Jeff Sloman, Andrew Lourie Drew Oosterbaan, and Rolando Garcia regarding status of plea negotiations, draft agreements, and need to confer with victims Work Product Deliberative Process Page 7 of 12 EFTA00191244 Bates Range Description Privilege(s) Asserted 65 9/11/2007 emails between Marie Villafafia, John McMillan, Drew Oosterbaan, Nesbitt Kuyrkendall, and Jason Richards regarding changes to the draft indictment and status of plea negotiations Work Product Deliberative Process Investigative Privilege Attorney-Client Privilege 66 9/10/2007-9/11/2007 emails between Marie Villafafta, Alex Acosta, and Jeff Sloman regarding modifications to the proposed Non-Prosecution Agreement Work Product Deliberative Process 67 9/13/2007 emails from Marie Villafafta to Andrew Lourie, Alex Acosta, Jeff Sloman, 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 Work Product Deliberative Process 68 9/13/2007-9/14/2007 emails regarding Marie Villafafla research regarding victim trust fund set up in Alaska child exploitation case Work Product 69 9/17/2007-9/19/2007 emails between Marie Villafafia, Rolando Garcia, Andrew Lourie, Alex Acosta, Karen Atkinson, and John McMillan regarding negotiations of a federal plea and a non-prosecution agreement Work Product Deliberative Process 70 9/20/2007 emails between Marie Villafafta and Andrew Lourie regarding plea agreement to federal charges and factual proffer Work Product Deliberative Process 71 9/20/2007-9/24/2007 emails between Alex Acosta, Marie Villafafia, and Andrew Lourie regarding revisions to the non-prosecution agreement Work Product Deliberative Process 72 9/21/2007 email from Marie Villafafia to Alex Acosta, Rolando Garcia, Karen Atkinson, and Andrew Lourie regarding review of Epstein indictment package Work Product Deliberative Process 73 9/24/2007 emails between Marie Villafafia and Rolando Garcia regarding notifying Palm Beach Police Chief and victims about agreement Work Product Deliberative Process Page 8 of 12 EFTA00191245 Bates Range Description Privilege(s) Asserted 74 9/24/2007-9/25/2007 emails between Alex Acosta, Marie Villafafia, Andrew Lourie, and Rolanda Garcia regarding Letkowitz email about keeping agreement from becoming public and confidentiality provision in agreement Work Product Deliberative Process 75 10/5/2007-10/16/2007 emails between Marie Villafafia, Jeff Sloman, and Alex Acosta re selection of Special Master and negotiation of revision/addendum to Non-Prosecution Agreement Work Product Deliberative Process 76 11/14/2007-11/19/2007 emails between AMCV, Jason Richards, Jeff Sloman, Rolando Garcia, Alex Acosta, and Karen Atkinson regarding communications with State Attorney's Office and Sheriff's Office in an attempt to insure that Epstein was ineligible for work release WP DP Attorney-Client Privilege 77 11/19/2007 emails between AMCV, Jeff Sloman, and Rolando Garcia about efforts by Epstein's counsel to change date for change of plea WP DP 78 11/8/2007-11/14/2007 emails between AMCV, Jeff Sloman, Karen Atkinson, and Jason Richards regarding response to objections raised by Epstein counsel and efforts to change date for guilty plea WP DP Attorney-Client Privilege 79 10/31/2007 email from Nesbitt Kurykendall to AMCV regarding attempts to interview additional witnesses/victims WP Attorney-Client Privilege 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 Sloman, Alex Acosta, and AMCV regarding negotiation of Addendum to Non- Prosecution Agreement and drafting of correspondence regarding scope of Special Master's duties and selection criteria WP DP 81 10/19/2007 emails between Jeff Sloman and AMCV regarding Special Master's Selection of Attorney Representative WP DP Page 9 of 12 EFTA00191246 Bates Range Description Privilege(s) Asserted 82 10/18/2007 emails between AMCV and Jeff Sloman regarding Epstein's request to delay his change of plea WP DP 83 11/2/2007-11/5/2007 emails between AMCV and Jeff Sloman regarding drafting 11/5/2007 letter from Sloman to Lefkowitz WP DP 84 11/5/2007-11/7/2007 emails from AMCV to Jeff Sloman inquiring about status of matter and contact by Epstein investigators with victims WP DP 85 12/6/2007 emails between AMCV, Andrew Lourie, Cyndee Campos, Jeff Sloman, Alex 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 WP DP 86 12/6/2007-12/7/2007 emails between AMCV, Cyndee Campos, Karen Atkinson, Jeff Sloman, and Alex Acosta regarding draft victim notification letter WP DP 87 9/10/2007-/I4/2007 emails between AMCV, Andrew Lourie, Jeff Sloman, Karen Atkinson, Rolando Garcia, Shawn Ball, and Alex Acosta regarding final plea negotiations, finalizing details with State Attorney's Office and final revisions to indictment package WP DP 6(e) III 88 9/10/2007 email from AMCV to Jeff Sloman and John McMillan regarding Acosta inquiry about FBI investigation into State grand jury proceeding WP 6(e) IP 89 11/29/2007-12/1/2007 emails between AMCV, Alex Acosta, Jeff Sloman, Cyndee Campos, and Andrew Lourie regarding draft response to Jay Lefkowitz and victim notification letters WP DP 90 12/6/2007-12/7/2007 emails between AMCV, Nesbitt Kuyrkendall, Jason Richards, Jeff Sloman, Cyndee Campos, Annette Castillo, Karen Atkinson, and Shawn Ball regarding request from State Attorney's Office for draft plea proffer WP DP 6(e) Attorney-Client Privilege IP Page 10 of 12 EFTA00191247 Bates Range Description Privilege(s) Asserted 91 12/14/2007 email from AMCV to Jeff Sloman, Alex Acosta, and Janice LeClainche regarding state cases mentioned by Epstein's counsel WP DP 92 12/14/2007 email from AMCV to Alex Acosta, Jeff Sloman, Rolando Garcia, and Karen Atkinson with draft letters to State Attorney's Office and victims WP DP 93 12/9/2007-12/12/2007 emails between AMCV, Jeff Sloman, Jason Richards, Nesbitt Kuyrkendall, Annette Castillo, Karen Atkinson, and Rolando Garcia regarding drafting response to personal attacks and upcoming meeting with Ken Starr WP DP 94 12/12/2007 emails between AMCV, Frederica Devlin, and Bob Senior regarding planning indictment review WP DP 6(e) 95 12/17/2007 email from AMCV to Jeff Sloman inquiring about case status and informing Sloman regarding agent concern about victim notifications WP DP 96 3/10/2008-3/12/2008 emails between AMCV, Robert Senior, Myesha Braden, Krishna Patel, Nesbitt Kuyrkendall, E.J. Yera, and Karen Atkinson about Epstein attempts to contact victims and finding counsel for victims WP DP Attorney-client privilege 97 3/12/2008-3/17/2008 emails between AMCV, Nesbitt Kuyrkendall and E.J. Yera regarding search warrant application and execution of search warrant WP Attorney client privilege IP 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 AMCV, Nesbitt Kuyrkendall, Jason Richards, and Robert Senior regarding corrections to indictment package and proposed grand jury presentation WP DP 6(e) Attorney-Client Privilege 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 AMCV, Nesibtt Kuyrkendall, Jason Richards, Robert Senior, Jeff Sloman, Karen Atkinson, and Rolando Garcia about Epstein attempts to contact victims and finding counsel for victims WP DP Attorney-client privilege Also contains information subject to privacy rights of victims who are not parties to this litigation 100 3/14/2008 emails between AMCV, Rolando Garcia, Karen Atkinson, Frederica Devlin, and Shawn Ball regarding complete indictment package for Robert Senior final review WP DP 6(e) 101 3/12/2008 emails between AMCV, Drew Oosterbaan, and Myesha Braden regarding CEOS meeting with Epstein counsel WP 102 3/5/2008-3/6/2008 emails between AMCV, Alex Acosta, Jeff Sloman, Drew Oosterbaan, Robert Senior, Myesha Braden, Rolando Garcia, and Karen Atkinson regarding meeting in DC, additional information to prepare for meeting, and new information from ongoing investigation WP DP 6(e) lP 103 Page 12 of 12 EFTA00191249 SUPPLEMENTAL PRIVILEGE LOG Bates Range Description Privilege(s) Asserted Attorney-Client Privilege Work Product Suppl. Box #3 P-013279 Thru P-013280 8/15/08 Emails between A. Acosta and A. Marie Villafa0a, R. Senior, D. Lee and K. Atkinson re proposed correspondence to Jay Lefkowitz Suppl. Box #3 P-013281 Handwritten note re Epstein investigation Attorney-Client Privilege Work Product Investigative privilege Also contains information subject to privacy rights of victims who are not parties to this litigation Suppl. Box #3 P-013282 Thru P-013283 7/9/08 Email from A. Marie Villafafia to A. Acosta, J. Sloman, K. Atkinson, and FBI re proposed response to Goldberger letter re victim notification Attorney-Client Privilege Work product Deliberative Process Suppl. Box #3 P-013284 7/10/08 Emails between J. Sloman and A. Marie Villafafia, K. Atkinson, and FBI re proposed response to Goldberger's letter re victim notification Attorney-Client Privilege Work Product Deliberative Process Suppl. Box #3 P-013285 Thru P-013289 File folder entitled "8/5/08 AMCV c-mail re correct agrmt" containing 8/5/08 email from A. Marie Villafafia to A. Acosta, J. Sloman, R. 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 Attorney-Client Privilege Work Product Deliberative Process Suppl. Box #3 P-013290 Thru P-013292 File folder entitled "8/14/08 E-mail from Lefk to AMCV" containing (undated) emails from A. Marie Villafafia to R. Senior, J. Sloman, A. Acosta, K. Atkinson, D. Lce re draft response to 8/14/08 email from J. Lefkowitz regarding "the December 2007 proposal" Attorney-Client Privilege Work Product Page 1 of 14 EFTA00191250 Bates Range Description Privilege(s) Asserted Suppl. Box #3 P-013293 Thru P-013299 File folder entitled "8/15/08 AMCV e-mail re Agrmt" containing 8/15/08 e-mails from A. Marie Villafafta to A. Acosta, J. Sloman, R. Senior, K. 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 Attorney-Client Privilege Work Product Deliberative Process Suppl. Box #3 P-013300 Thru P-0133303 File folder entitled "8/18/08 Lefkowitz Ltr to AMCV" containing A. Marie Villafafta's handwritten draft notes for proposed letter to J. 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 Attorney-Client Privilege Work Product Suppl. Box #3 P-013304 Thru P-013325 File folder entitled "6/25/07 Lefcourt to Sloman & Lourie containing 6/25/07 letter (with handwritten notes by A. Marie Villafafta) from G. 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 Attorney-Client Privilege Work Product Suppl. Box #3 P-013326 Thru P-013329 File folder entitled "9/17/07 Villafafia to Lefkowitz containing 9/17/07 e-mail from A. Marie Villafafta to R. Garcia, A. Lourie and from R. Garcia to A. Marie Villafana concerning status of plea negotiations Attorney-Client Privilege Work Product Suppl. Box #3 P-013330 Thru P-013333 File folder entitled "11/8/07 Lefkowitz to Sloman" containing 11/8/07 letter from J. Lefkowitz it issues arising during pendency of matter with attorney handwritten notes Attorney-Client Privilege Work Product Suppl. Box #3 P-013334 Thru P-013337 File folder entitled "I 1/13/07 Sloman to Lefkowitz (was this sent?)" containing draft 11/13/07 letter from J. Sloman responding to J. Lefkowitz's letter Attorney-Client Privilege Work Product Page 2 of 14 EFTA00191251 Bates Range Description Privilege(s) Asserted Suppl. Box #3 P-013338 Thm 013341 File folder entitled "12/6/07 Sloman to Lefkowitz" containing 12/5/07 faxed letter w/ cover sheet from K. Starr and J. Lefkowitz to A. Acosta [Not considered privileged. Will be produced to opposing counsel upon lifting of stay) Suppl. Box #3 P-013342 Thru P-013350 File folder entitled "12/05/07 Starr to Acosta" containing drafts of 11/30/07 letters from A. Acosta to K. Starr and from J. Sloman to J. Lefkowitz re performance and victim notification with handwritten notes and edits by A. Marie Villafafia Attorney-Client Privilege Work Product Deliberative Process Suppl. Box #3 P-13351 Thru P-013361 File folder entitled "12/21/07 Lefkowitz to Acosta" containing handwritten notes by A. Marie Villafafia, 12/21/07 letter from J. Lefkowitz to A. Acosta re performance of NPA and appeal to Washington with attorney handwritten notes Attorney-Client Privilege Work Product Suppl. Box #3 P-013362 Thru P-013366 File folder labeled "12/26/07 Lefkowitz to Acosta" containing 2 copies of draft letter from A. Acosta to J. Lefkowitz (with 12/28/07 fax header) Attorney-Client Privilege Work Product Deliberative Process Suppl. Box #3 P-013367 Thru P-013372 File folder labeled "Draft Itr from Sloman to Lefkowitz re termination" containing draft letter dated "April , 2008" from J. Sloman to J. Letkowitz concerning the compliance with the Agreement Attorney-Client Privilege Work Product Suppl. Box #3 P-013373 Thru P-013503 File folder labeled "6/3/08 Sloman Submission to the DAG" containing 6/3/08 letter from J. Sloman to Mark Filip, Office of the DAG, cc'd to R. Senior, A. Marie Villafafia, K. Atkinson, re Jeffrey Epstein, detailing events concerning the Agreement and thereafter and with relevant attachments Attorney-Client Privilege Deliberative