EFTA00191199.pdf
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
Case No. 08-80736-CIV-Marra/Matthewman
JANE DOE # I and JANE DOE #2,
Petitioners,
I
UNITED STATES OF AMERICA,
Respondent.
UNITED STATES' RESPONSE TO
PETITIONERS' FIRST REOUEST FOR ADMISSIONS TO THE GOVERNMENT
The United States (hereinafter the "government") hereby responds to Jane Doe #1 and
Jane Doe #2's First Requestfor Admissions to the Government Regarding Questions Relevant to
Their Pending Action Concerning the Crime Victims Rights Act (hereinafter the "Request for
Admissions"), and states as follows:'
I. The government admits that the FBI and the U.S. Attorney's Office for the Southern
District of Florida ("USAO") conducted an investigation into Jeffrey Epstein
("Epstein") and developed evidence and information in contemplation of a potential
federal prosecution against Epstein for many federal sex offenses. Except as
otherwise admitted above, the government denies Request No. I.
The government's response is confined to Request No. I through Request No. 26 in the
"Discovery Requested" section of the Request for Admissions and does not intend to respond to
assertions in any other section of the Request for Admissions (including the "Background"
section), none of which appear to separately state any matter calling for an admission.
Nonetheless, the government denies the assertion that the government has declined the request of
Jane Doe #1 and Jane Doe #2 to stipulate to undisputed facts in this case.
EFTA00191199
2. (a) The government admits that, after Epstein's attorneys learned of the notification
that the government planned to provide to Jane Doe #2, who claimed that she was
not a victim, Epstein's attorneys contacted the USAO and objected to the
procedures for notification and the legal bases therefor. The government further
admits that the USAO considered those objections when evaluating what
notification to provide to victims. Except as otherwise admitted above, the
government denies Request No. 2(a).
(b) Admitted.
(c) The government admits that, as a result of objections lodged by Epstein's
attorneys, the government reevaluated the notifications that it had intended to
provide to victims and, as a result of that reevaluation, the USAO altered the
scope, nature, and timing of notifications that it had contemplated providing to
victims. With regard to Jane Doe #2, the government further admits that, as a
result of representations made by Jane Doe #2 that she was not a victim and
objections lodged by Epstein's attorneys, the USAO stopped making notifications
to Jane Doe #2. Except as otherwise admitted above, the government denies
Request No. 2(c).
(d) The government admits that, after the USAO received objections to victim
notifications from Epstein's counsel and reevaluated its victim notification
obligations, the USAO altered the language that was ultimately contained in the
July 9, 2008 notification letter to Jane Doe #1 in care of Bradley Edwards.
Except as otherwise admitted above, the government denies Request No. 2(d).
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(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.
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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).
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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."
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(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
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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
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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.
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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.
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22. (a) Admitted.
(b) Admitted.
(c) Admitted.
23. The government admits that the non-prosecution agreement signed by the USAO and
Jeffrey Epstein currently blocks the USA() from prosecuting sex offenses committed
by Epstein against Jane Doe #1 and Jane Doe #2 in the Southern District of Florida
from in or around 2001 through in or around September 2007, provided that those
offenses are set out on pages I and 2 of the non-prosecution agreement, were the
subject of the joint investigation by the FBI and the USAO, or arose from the federal
grand jury investigation. Except as otherwise admitted above, the government denies
Request No. 23.
24. Admitted; Jeffrey Epstein provided valuable consideration to the federal government
through the non-prosecution agreement he entered with the USAO.
25. Denied.
26. The government objects to Request No. 26 because it seeks information protected
from disclosure by the law enforcement investigative privilege.
/II
I0
EFTA00191208
Respectfully submitted,
WIFREDO A. FERRER
UNITED STATES ATTORNEY
By: Is Dexter A. Lee
Dexter A. Lee
Assistant United States Attorney
Florida Bar No. 0936693
99 N.E. 4th Street
Miami, Florida 33132
Tel: (305) 961-9320; Fax: (305) 530-7139
Email: dexter.lee®usdoj.gov
A. Marie Villafana
Assistant United States Attorney
Florida Bar No. 0018255
500 S. Australian Avenue, Suite 400
West Palm Beach, FL 33401
Tel: (561) 820-8711; Fax: (561) 820-8777
Email: ann.marie.c.villafana®usdoj.gov
Eduardo I. Sanchez
Assistant United States Attorney
Florida Bar No. 877875
99 N.E. 4th Street
Miami, Florida 33132
Tel: (305) 961-9057; Fax: (305) 536-4676
Email: eduardo.i.sanchez@usdoj.gov
Attorneys for United States
CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the foregoing United States' Response to
Petitioners' First Request for Admissions to the Government was served via CM/ECF on this
19th day of July, 2013, on the parties and counsel appearing on the attached service list.
/s Dexter A. Lee
Assistant United States Attorney
II
EFTA00191209
SERVICE LIST
Jane Does 1and 4 United States,
Case No. 08-80736-CIV-MARRA/MATTHEWMAN
United States District Court, Southern District of Florida
Brad Edwards, Esq., Roy Black, Esq.
Farmer, Jaffe, Weissing, Jackie Perczek, Esq.
Edwards, Fistos & Lehrman, P.L. Black, Srebnick, Kornspan & Stumpf, P.A.
425 North Andrews Avenue, Suite 2 201 South Biscayne Boulevard, Suite 1300
Fort Lauderdale, Florida 33301 Miami, FL 33131
(954)524-2820 (305) 371-6421
Fax: (954) 524-2822 Fax: (305)358-2006
E-mail: brad@pathtojustice.com E-mail: pleading@iroyblack.com
Paul G. Cassell Martin G. Weinberg
S.J. Quinney College of Law at the MARTIN G. WEINBERG, P.C.
University ofUtah 20 Park Plaza
332 S. 1400 E. Suite 1000
Salt Lake City, Utah 84112 Boston, MA 02116
(801) 585-5202 Office: (617) 227-3700
Fax: (801) 585-6833 Fax: (617) 338-9538
E-mail: casselp®law.utah.edu Email: owlmgw@attnet
Attorneys for Jane Doe # 1 and Jane Doe # 2
Jay P. Letkowitz
Kirkland &Ellis, LLP
601 Lexington Avenue
New York. NY 10022
Fax:
Email: lefkowitz@kirkland.com
12
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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
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(801) 585-5202
Fax: (801) 585-6833
E-mail: casselpialaw.utah.edu
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EFTA00191213
PRIVILEGE LOG
Bates Range Description Privilege(s) Asserted
Box #1 File folder entitled "CORR RE GJ 6(e)
P-000001 SUBPOENAS" containing correspondence Work Product
thru related to various grand jury subpoenas and
P-000039 attorney (Villafada) handwritten notes
Box #1 Operation Leap Year Grand Jury Log 6(e)
P-000040 containing subpoenas OLY-01 through OLY-81, Work Product
thru correspondence and research related to Contains documents subject
P-000549 enforcement of same, documents produced in to investigative privilege
response to some subpoenas; and attorney Also contains documents
(Villafafla) handwritten notes subject to privacy rights of
victims who are not parties to
this litigation
Box #1 File folder entitled "Ritz Compact Flash SW" 6(e)
P-000550 containing copies of a sealed search warrant Contains information subject
thru application, warrant, and supporting documents to investigative privilege
P-000621 Also contains information
subject to privacy rights of
victims who are not parties to
this litigation
Box #1 File folder entitled "PNY Technologies Compact 6(e)
P-000622 Flash SW" containing copies of a sealed search Contains information subject
thru warrant application, warrant, and supporting to investigative privilege
P-000693 documents Also contains information
subject to privacy rights of
victims who are not parties to
this litigation
Box #1 File folder entitled "JE Corporations" containing Work Product
P-000694 attorney research on Epstein-owned corporations Contains information subject
thru and prior litigation to investigative privilege
P-000781
Box #1 File folder entitled "Capital One" 6(e)
P-000782 containing subpoena and correspondence
thru
P-000803
Box #1 File folder entitled "DTG Operations/Dollar 6(e)
P-000804 Rent-a-Car" containing subpoena and responsive Contains documents and
thru documents information subject to
P-000854 investigative privilege
Also contains documents and
information subject to privacy
rights of victims who are not
parties to this litigation
Page 1 of 23
EFTA00191214
Bates Range Description Privilege(s) Asserted
Box #1 File folder entitled "JP Morgan Chase" 6(e)
P-000855 containing subpoena, correspondence, and Contains documents and
thru responsive documents information subject to
P-000937 investigative privilege
Box #1 File folder entitled "Washington Mutual" 6(e)
P-000938 containing subpoena, correspondence, and Contains documents and
thru responsive documents information subject to
P-000947 investigative privilege
Box #1 File folder entitled "Computer Search &" Work Product
P-000948 containing legal research on computer search and Attorney-Client
thru handwritten notes on indictment preparation Contains information subject
P-000982 to investigative privilege.
Also contains information
subject to privacy rights of
victims who are not parties to
this litigation
Box #1 File folder entitled "Attorney Notes from Work product
P-000983 Document Review" containing typed and 6(e)
thru handwritten attorney (Villafada) notes, target Contains information subject
P-001007 letters, correspondence re grand jury subpoena to investigative privilege.
Also contains information
subject to privacy rights of
victims who are not parties to
this litigation
Box #1 File folder entitled "Notes from Fed Ex Records" Work Product
P-001008 containing handwritten and typed attorney 6(e)
thru (Villafafia) notes and screen shots of FedEx Contains information subject
P-001056 subpoena response electronic file to investigative privilege.
Also contains information
subject to privacy rights of
victims who are not parties to
this litigation
Box #1 File folder entitled "Colonial Bank Records" 6(e)
P-001057 containing records received in response to grand Contains information subject
thru jury subpoena to investigative privilege
P-001959
Box #1 File folder entitled "OLY Grand Jury Log Vol 2: 6(e)
P-001960 OLY-51 THROUGH" containing subpoenas Contains information subject
Thru numbered OLY-51 through OLY-81 with related to investigative privilege.
P-002089 correspondence Also contains information
subject to privacy rights of
victims who are not parties to
this litigation
Page 2 of 23
EFTA00191215
Bates Range Description Privilege(s) Asserted
Box #1 File folder entitled "Epstein Corporate Records: 6(e)
P-002090 OLY-51, OLY-52, OLY-53, OLY-54" containing Contains information and
Thru subpoenas, records received in response to documents subject to
P-002169 subpoenas, and related correspondence investigative privilege
Box #1 File folder entitled "Colonial Bank" containing 6(e)
P-002170 subpoenas, correspondence related to subpoenas, Contains information and
Thru records received in response to subpoenas documents subject to
P-002246 investigative privilege
Box #1 File folder entitled "JEGE & Hyperion from 6(e)
P-002247 Goldberger OLY-46 & OLY-47" containing Contains information and
Thru documents received in response to subpoenas documents subject to
P-002265 investigative privilege
Box #1 Indictment preparation binder containing: Work product
P-002266 Grand jury subpoena log, evidence/activity 6(e)
Thru summary chart, witness/victim names and contact Contains information and
P-002386 list, attorney (Villafafia) handwritten notes, 302s, documents subject to
portions of state investigative file, attorney investigative privilege. Also
(Villafafia) typed notes, of individuals listed as contains information and
"Additional victims" documents subject to privacy
rights of victims who are not
parties to this litigation
Box #1 Indictment preparation binder containing: Work product
P-002387 Grand jury subpoena log, evidence/activity 6(e)
Thru summary chart, witness/victim names and contact Contains information and
P402769 list, attorney (Villafafia) handwritten notes, 302s, documents subject to
portions of state investigative file, attorney investigative privilege. Also
(Villafafia) typed notes, relevant pieces of grand contains information and
jury materials, telephone records/flight records documents subject to privacy
analysis charts, victim/witness photographs, rights of victims who are not
DAVID records, NCICs, and related materials for parties to this litigation
persons identified as Jane Does #15, 16, 17, 18,
19, Past Employees, Misc. Witnesses
Box #1 Indictment preparation binder containing: Work product
P-002770 witness/victim list with identifying information, 6(e)
Thrti sexual activity summary, telephone call summary Contains information and
P-00321 I chart, attorney (Villafafia) handwritten notes, documents subject to
302s, portions of state investigative file, attorney investigative privilege. Also
(Villafafia) typed notes, relevant pieces of grand contains information and
jury materials, telephone records/flight records documents subject to privacy
analysis charts, victim/witness photographs, rights of victims who are not
DAVID records, NCICs, and related materials for parties to this litigation
persons identified as Jane Does #1, 2, 3, 4, 5, 6, 7,
8
Page 3 of 23
EFTA00191216
Bates Range Description Privilege(s) Asserted
Box #1 Indictment preparation binder containing meta- Work product
P-003212 analysis charts of telephone/flight/grand jury 6(e)
Thru information for a number of victim/witnesses, Contains information and
P-003545 Nadia Marcinkova, and Adriana Mucinska documents subject to
investigative privilege. Also
contains information and
documents subject to privacy
rights of victims who are not
parties to this litigation
Box #1 FBI Reports of March 2008 interviews of Work product
P-003546 additional witness/victim located in New York 6(e) .
Thru Contains information and
P-003552 documents subject to
investigative privilege. Also
contains information and
documents subject to privacy
rights of victims who are not
parties to this litigation
Box 141 Printout of filenames from Federal Express Work product
P-003553 subpoena response with Attorney notations 6(e)
Thru
P-003555B
Box #1 Document entitled "Identified Numbers" with Work product
P-003556 accompanying handwritten attorney list compiled 6(e)
Thru from grand jury materials and attorney analysis of Contains information subject
P-003562 records to investigative privilege
Box #1 Folder entitled "Flight Manifests" containing 6(e)
P-003563 manifests received pursuant to grand jury Contains information and
Thru subpoena documents subject to
P-003629 investigative privilege
Box #1 File folder entitled "Recent Attorney Notes" Work product
P-003630 containing handwritten attorney (Villafada) notes 6(e)
Thru regarding document review and case strategy Investigative privilege
P-003633 Deliberative process
Box #1 File folder bearing victim name containing FBI Work product
P-003634 interview report from May 2008, telephone Attorney-client privilege
Thru activity report with attorney (Villafanana) 6(e)
P-003646 handwritten notes, related grand jury material Investigative privilege
Also contains information and
documents subject to privacy
rights of victims who are not
parties to this litigation
Page 4 of 23
EFTA00191217
Bates Range Description Privilege(s) Asserted
Box #1 File folder entitled "Summary of Sexual Activity" Work product
P-003647 containing chart bearing handwritten title "Sexual 6(e)
Thru Activity — Summary" with meta-analysis of Investigative privilege
P-003651 information, sorted by name of each Deliberative process
victim/witness, including name and identifying Also contains information and
information of each victim/witness documents subject to privacy
rights of victims who are not
parties to this litigation
Box #1 File folder entitled "Victim Civil Suits" Not privileged.
P-003652 Produced to counsel for
Thru Petitioners
P-003663
Box #1 File folder entitled "Research re JE Websites" Work product
P-003664 containing attorney research
Thru
P-003678
Box #1 File folder entitled "Serene Cano (N.Y. AUSA)" Work product
P-003679 containing attorney (Villafafla) handwritten notes
Thru
P-003680
Box #1 File folder entitled "Dr. Anna Salter" containing Work product
P-003681 attorney (Villafafia) memo to expert witness and Investigative privilege
Thru handwritten attorney notes
P-003687
Box #1 la
File folder entitled GO Interview" containing Work product
P-003688 attorney handwritten notes of interview, and Investigative privilege
Thru attorney handwritten notes regarding potential Also contains information
P-003693 charges subject to privacy rights of
victims who are not parties to
this litigation
Box #I File folder entitled "Research re Travel for Work product
P-003694 Prostitution" containing attorney (Villafafia) 6(e)
Thru handwritten notes regarding grand jury Investigative privilege
P-003711 presentation, chart entitled "Brought to Epstein's Also contains information and
House" with handwritten notes, Message Pad documents subject to privacy
meta-analysis chart, summary of evidence related rights of victims who are not
to one victim/witness, and relevant grand jury parties to this litigation
information
Box #1 Empty file folder bearing name of victim/witness Investigative privilege
P-003712 Also contains information
subject to privacy rights of
victim who is not a party to
this litigation
Page 5 of 23
EFTA00191218
Bates Range Description Privilege(s) Asserted
Box #1 File folder entitled "T(] M(]" containing grand 6(e)
P-003713 jury subpoenas, motion and order to compel Documents under seal
Thru testimony, and correspondence regarding same pursuant to court order
P-003746
Box #1 File folder entitled "Adrian Ross" containing 6(e)
P-003747 subpoena and correspondence regarding same
Thru
P-003751
Box #1 File folder entitled "PBPD Investigative File" 6(e)
P-003752 obtained via subpoena Investigative privilege
Thru Also contains information and
P-004295 documents subject to privacy
rights of victims who are not
parties to this litigation
Box #1 of
File folder bearing name victim/witness Work product
P-004296 containing meta-analysis chart showing telephone 6(e)
Thru calls, travel, and grand jury materials relevant to Investigative privilege
P-004350 possible charges Also contains information and
documents subject to privacy
rights of victims who are not
parties to this liti tion
Box #1 File folder entitled "Daniel Documents Work product
P-004351 53909-004" containing attorney research related
Thru to bias issue
P-004381
Box #1 File Folder entitled "FEDEX" containing 6(e)
P-004382 documents obtained via subpoena Investigative privilege
Thru
P-004478
Box #1 File Folder entitled "State of Delaware Records" 6(e)
P-004479 containing documents obtained in preparation for Investigative privilege
Thru indictment Work product
P-004551
Box #1 File folder entitled "Jet Blue Records" containing 6(e)
P-004552 documents obtained via subpoena Work product
Thru Investigative privilege
P-004555 Also contains information and
documents subject to privacy
rights of victims who are not
parties to this litigation
Box #1 File folder entitled "FL EMPLOYMENT Investigative privilege
P-004556 RECORDS" containing FDLE records on targets Work product
Thru
SOUTHERN DISTRICT OF FLORIDA
Case No. 08-80736-CIV-Marra/Matthewman
JANE DOE # I and JANE DOE #2,
Petitioners,
I
UNITED STATES OF AMERICA,
Respondent.
UNITED STATES' RESPONSE TO
PETITIONERS' FIRST REOUEST FOR ADMISSIONS TO THE GOVERNMENT
The United States (hereinafter the "government") hereby responds to Jane Doe #1 and
Jane Doe #2's First Requestfor Admissions to the Government Regarding Questions Relevant to
Their Pending Action Concerning the Crime Victims Rights Act (hereinafter the "Request for
Admissions"), and states as follows:'
I. The government admits that the FBI and the U.S. Attorney's Office for the Southern
District of Florida ("USAO") conducted an investigation into Jeffrey Epstein
("Epstein") and developed evidence and information in contemplation of a potential
federal prosecution against Epstein for many federal sex offenses. Except as
otherwise admitted above, the government denies Request No. I.
The government's response is confined to Request No. I through Request No. 26 in the
"Discovery Requested" section of the Request for Admissions and does not intend to respond to
assertions in any other section of the Request for Admissions (including the "Background"
section), none of which appear to separately state any matter calling for an admission.
Nonetheless, the government denies the assertion that the government has declined the request of
Jane Doe #1 and Jane Doe #2 to stipulate to undisputed facts in this case.
EFTA00191199
2. (a) The government admits that, after Epstein's attorneys learned of the notification
that the government planned to provide to Jane Doe #2, who claimed that she was
not a victim, Epstein's attorneys contacted the USAO and objected to the
procedures for notification and the legal bases therefor. The government further
admits that the USAO considered those objections when evaluating what
notification to provide to victims. Except as otherwise admitted above, the
government denies Request No. 2(a).
(b) Admitted.
(c) The government admits that, as a result of objections lodged by Epstein's
attorneys, the government reevaluated the notifications that it had intended to
provide to victims and, as a result of that reevaluation, the USAO altered the
scope, nature, and timing of notifications that it had contemplated providing to
victims. With regard to Jane Doe #2, the government further admits that, as a
result of representations made by Jane Doe #2 that she was not a victim and
objections lodged by Epstein's attorneys, the USAO stopped making notifications
to Jane Doe #2. Except as otherwise admitted above, the government denies
Request No. 2(c).
(d) The government admits that, after the USAO received objections to victim
notifications from Epstein's counsel and reevaluated its victim notification
obligations, the USAO altered the language that was ultimately contained in the
July 9, 2008 notification letter to Jane Doe #1 in care of Bradley Edwards.
Except as otherwise admitted above, the government denies Request No. 2(d).
2
EFTA00191200
(e) The government admits that, at least in part as a result of objections lodged by
Epstein's lawyers to victim notifications, the USAO reevaluated its obligations to
provide notifications to victims, and Jane Doe #1 was thus not told that the USA(?)
had entered into a non-prosecution agreement with Epstein until after the
agreement was signed. The government further admits that Jane Doe #2 was not
told that the USAO had entered into a non-prosecution agreement with Epstein
until after the agreement was signed, but denies that the USA() did not inform
Jane Doe #2 as a result of any negotiations involving Epstein or any objections
lodged by Epstein's lawyers; the USAO did not consider Jane Doe #2 a victim
after she informed the USAO and the FBI that she was not a victim of any offense
committed by Epstein, and, as a result, the USAO did not consider informing Jane
Doe #2 about the non-prosecution agreement. Except as otherwise admitted
above, the government denies Request No. 2(e).
3. Denied.
4. Denied.
5. The government admits that, during the negotiations with Jeffrey Epstein regarding
the non-prosecution agreement, at least one experienced attorney within the USAO
subscribed to the position that the CVRA required notifications to the victims in this
case and that position was communicated to Epstein's counsel. To the extent that
Request No. 5 seeks admissions regarding the positions held by attorneys within the
USAO that were not communicated to non-government personnel regarding whether
or not the CVRA ultimately required notifications to the victims in this case, the
government objects to Request No. 5 as violative of the deliberative process privilege.
3
EFTA00191201
6. (a) Denied.
(b) Denied.
(c) Admitted.
(d) Admitted.
(e) Admitted to the extent that the reference to "Lillian Sanchez" was meant to refer
to Lilly Ann Sanchez.
(0 Admitted.
(g) Admitted.
7. The government admits that, on about January 10, 2008, when Jane Doe # I and Jane
Doe #2 were sent letters advising them that "this case is currently under
investigation," the U.S. Attorney's Office had already signed a non-prosecution
agreement with Jeffrey Epstein, but that, on that date, the non-prosecution agreement
nonetheless remained in a state of some flux and was subject to being set aside as
Epstein was challenging the propriety of the non-prosecution agreement and seeking
further review from the Department of Justice.
8. Denied.
9. (a) The government admits that, at Epstein's insistence, the USAO agreed to a
provision in the non-prosecution agreement that provided as follows: "The parties
anticipate that this agreement will not be made part of any public record. If the
United States receives a freedom of Information Act request or any compulsory
process commanding the disclosure of the agreement, it will provide notice to
Epstein before making that disclosure." Except as otherwise admitted above, the
government denies Request No. 9(a).
4
EFTA00191202
(b) Admitted.
(c) Denied.
(d) Denied.
(e) The government admits that, during the period from September 24, 2007 through
June 2008, the USAO did not notify Jane Doe #2 of the existence of the non-
prosecution agreement. The government further admits that, although FBI agents
notified Jane Doe #1 of the existence and substance of the agreement at the
request of the USAO on or about October 27, 2007, no employee of the USAO
personally notified Jane Doe #1 of the existence of the non-prosecution agreement
during the period from September 24, 2007 through June 2008. Except as
otherwise admitted above, the government denies Request No. 9(c).
10. (a) Admitted. Because Request No. 10 appears directed solely to the communica-
tions between FBI agents and Jane Doe #1 during their meeting on or about
October 26, 2007, the government responses to Requests No. 10(b) through 10(g)
address only that meeting.
(b) The government admits that, on or about October 26, 2007, FBI agents explained
to Jane Doe #1 that Epstein would plead guilty to state charges for procuring
minors to engage in prostitution; that Epstein would be required to register as a
sex offender; that Jane Doe #1 would be entitled to seek damages from Epstein;
and that, if she desired, Jane Doc //I would be entitled to use the services of an
attorney at no expense to her in seeking those damages from Epstein. The
government denies that the FBI agents explained that the state charges
"involv[ed] another victim."
5
EFTA00191203
(c) The government denies that the FBI agents did not explain to Jane Doc #1 that an
agreement had already been signed; denies that the FBI agents did not explain to
Jane Doe #1 that the agreement resolved the investigation of the federal case
involving Jane Doe #1; and denies that the FBI agents did not explain to Jane Doe
other terms of that agreement Except as otherwise admitted above, the
government denies Request No. 10(c).
(d) Denied.
(e) Denied.
(f) Denied.
(g) Denied.
I I. The government admits that, on or about November 28, 2007, A. Marie Villafalia of
the USAO sent a draft of a crime victim notification letter to Jay Lefkowitz, counsel
for Jeffrey Epstein, and that the draft notification letter stated, in part: "I am writing
to inform you that the federal investigation of Jeffrey Epstein has been completed,
and Mr. Epstein and the U.S. Attorney's Office have reached an agreement
containing the following terms . . . ." The government further admits that, in part as a
result of objections lodged by Epstein's lawyers, the USAO reevaluated its
obligations to provide notifications to victims, and, as a result of that reevaluation and
other considerations and developments, the USAO never sent victims the draft
notification letter that was sent to Jay Lefkowitz on or about November 28, 2007.
Except as otherwise admitted above, the government denies Request No. I I.
12. The government admits that, prior to July 3, 2008, the USAO had already entered a
binding non-prosecution agreement with Jeffrey Epstein. The government is without
6
EFTA00191204
knowledge of precisely when "Bradley J. Edwards was working on a letter to the U.S.
Attorney's Office concerning the need to federally prosecute Epstein for sex offenses
committed against Jane Doe #1 and Jane Doe #2," and, accordingly, the government
denies the assertion that Edwards worked on that letter on July 3, 2008. Except as
otherwise admitted above, the government denies Request No. 12.
13. (a) The government admits that, when Epstein pled guilty to state charges on June 30,
2008, Jane Doe #2 had not been informed by the USAO of the existence of the
non-prosecution agreement. The government further admits that, although the
USAO, through FBI agents, had notified Jane Doe ill of the existence of the non-
prosecution agreement prior to Epstein's June 30, 2008 guilty plea, no employee
of the USAO had personally notified Jane Doe #1 at that time of the existence of
the non-prosecution agreement. Except as otherwise admitted above, the
government denies Request No. I3(a).
(b) The government denies that, by the time of Epstein's June 30, 2008 guilty plea, an
attorney for the government working at the USAO had not already conferred with
Jane Doe #1 and Jane Doe #2 about their opinions regarding how the federal
investigation and potential prosecution of Epstein should proceed. The
government admits that the USAO had not conferred with Jane Doe #2 about the
non-prosecution agreement prior to Epstein's June 30, 2008 guilty plea. The
government further admits that, although the USAO had communicated with Jane
Doe #1 about the non-prosecution agreement through FBI agents prior to
Epstein's June 30, 2008 guilty plea, no employee of the USAO had personally
conferred with Jane Doe #1 about the non-prosecution agreement prior to
7
EFTA00191205
Epstein's guilty plea. Except as otherwise admitted above, the government denies
Request No. I3(b).
(c) Although the government was aware that Jane Doe #2 had been represented by
counsel paid for by Epstein, the government is unaware of the extent of Epstein's
defense attorneys' awareness of the USAO's communications with Jane Doe #1
and Jane Doe #2 about the agreement, as described in the responses to Requests
No. 13(a) and 13(b), and therefore can neither deny nor admit Request No. 13(c).
Except as otherwise admitted above and in the responses to Requests No. 13(a)
and 13(b), the government denies Request No. I3(c).
(d) The government admits that Epstein's attorneys negotiated with the USAO for a
provision in the non-prosecution agreement that ultimately provided as follows:
"The parties anticipate that this agreement will not be made part of any public
record. If the United States receives a Freedom of Information Act request or any
compulsory process commanding the disclosure of the agreement, it will provide
notice to Epstein before making that disclosure." Except as otherwise admitted
above, the government denies Request No. 13(d).
14. The government admits that, when Epstein was pleading guilty to the state charges
discussed in the non-prosecution agreement, the USAO and Epstein's defense
attorneys sought to keep the document memorializing the non-prosecution agreement
confidential, but denies that they sought at that time to keep the existence of the non-
prosecution agreement confidential. Except as otherwise admitted above, the
government denies Request No. 14.
8
EFTA00191206
IS. (a) The government admits that, while Bruce E. Reinhart was an Assistant U.S.
Attorney, he learned confidential, non-public information about the Epstein
matter.
(b) The government admits that, while Bruce E. Reinhart was an Assistant U.S.
Attorney, he discussed the Epstein matter with another Assistant U.S. Attorney
working on the Epstein matter.
(c) Denied.
16. Admitted.
17. Admitted.
18. (a) Denied.
(b) Denied.
19. To the extent that Request No. 19 is directed to the business or personal relationships
of the 93 U.S. Attorneys and over 5,400 Assistant U.S. Attorneys serving across this
country, or the countless individuals who have formerly served as U.S. Attorneys and
Assistant U.S. Attorneys throughout this nation, the government objects to Request
No. 19 as overly broad and burdensome and not calculated to lead to or involve
information relevant to the instant matter. The government denies possessing or
having any knowledge or information about a personal or business relationship
between Jeffrey Epstein and either the U.S. Attorney or any Assistant U.S. Attorney
serving in the Southern District of Florida. Except as otherwise admitted above, the
government denies Request No. 19.
20. Admitted.
21. Denied.
9
EFTA00191207
22. (a) Admitted.
(b) Admitted.
(c) Admitted.
23. The government admits that the non-prosecution agreement signed by the USAO and
Jeffrey Epstein currently blocks the USA() from prosecuting sex offenses committed
by Epstein against Jane Doe #1 and Jane Doe #2 in the Southern District of Florida
from in or around 2001 through in or around September 2007, provided that those
offenses are set out on pages I and 2 of the non-prosecution agreement, were the
subject of the joint investigation by the FBI and the USAO, or arose from the federal
grand jury investigation. Except as otherwise admitted above, the government denies
Request No. 23.
24. Admitted; Jeffrey Epstein provided valuable consideration to the federal government
through the non-prosecution agreement he entered with the USAO.
25. Denied.
26. The government objects to Request No. 26 because it seeks information protected
from disclosure by the law enforcement investigative privilege.
/II
I0
EFTA00191208
Respectfully submitted,
WIFREDO A. FERRER
UNITED STATES ATTORNEY
By: Is Dexter A. Lee
Dexter A. Lee
Assistant United States Attorney
Florida Bar No. 0936693
99 N.E. 4th Street
Miami, Florida 33132
Tel: (305) 961-9320; Fax: (305) 530-7139
Email: dexter.lee®usdoj.gov
A. Marie Villafana
Assistant United States Attorney
Florida Bar No. 0018255
500 S. Australian Avenue, Suite 400
West Palm Beach, FL 33401
Tel: (561) 820-8711; Fax: (561) 820-8777
Email: ann.marie.c.villafana®usdoj.gov
Eduardo I. Sanchez
Assistant United States Attorney
Florida Bar No. 877875
99 N.E. 4th Street
Miami, Florida 33132
Tel: (305) 961-9057; Fax: (305) 536-4676
Email: eduardo.i.sanchez@usdoj.gov
Attorneys for United States
CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the foregoing United States' Response to
Petitioners' First Request for Admissions to the Government was served via CM/ECF on this
19th day of July, 2013, on the parties and counsel appearing on the attached service list.
/s Dexter A. Lee
Assistant United States Attorney
II
EFTA00191209
SERVICE LIST
Jane Does 1and 4 United States,
Case No. 08-80736-CIV-MARRA/MATTHEWMAN
United States District Court, Southern District of Florida
Brad Edwards, Esq., Roy Black, Esq.
Farmer, Jaffe, Weissing, Jackie Perczek, Esq.
Edwards, Fistos & Lehrman, P.L. Black, Srebnick, Kornspan & Stumpf, P.A.
425 North Andrews Avenue, Suite 2 201 South Biscayne Boulevard, Suite 1300
Fort Lauderdale, Florida 33301 Miami, FL 33131
(954)524-2820 (305) 371-6421
Fax: (954) 524-2822 Fax: (305)358-2006
E-mail: brad@pathtojustice.com E-mail: pleading@iroyblack.com
Paul G. Cassell Martin G. Weinberg
S.J. Quinney College of Law at the MARTIN G. WEINBERG, P.C.
University ofUtah 20 Park Plaza
332 S. 1400 E. Suite 1000
Salt Lake City, Utah 84112 Boston, MA 02116
(801) 585-5202 Office: (617) 227-3700
Fax: (801) 585-6833 Fax: (617) 338-9538
E-mail: casselp®law.utah.edu Email: owlmgw@attnet
Attorneys for Jane Doe # 1 and Jane Doe # 2
Jay P. Letkowitz
Kirkland &Ellis, LLP
601 Lexington Avenue
New York. NY 10022
Fax:
Email: lefkowitz@kirkland.com
12
EFTA00191210
Page I of 1
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EFTA00191212
Brad Edwards, Esq.,
Farmer Jaffe Weissing Edwards Fistos Lehrman
425 N AndreWs Ave Ste 2
Fort Lauderdale, FL 33301-3268
brad©pathtojustice.com
954-524-2820
Fax: 954-524-2822
Paul G. Cassell
S.J. Quinney College of Law at the
University of Utah
332 S. 1400 E.
Salt Lake City, Utah 84112
(801) 585-5202
Fax: (801) 585-6833
E-mail: casselpialaw.utah.edu
t>") CA.)-recd
EFTA00191213
PRIVILEGE LOG
Bates Range Description Privilege(s) Asserted
Box #1 File folder entitled "CORR RE GJ 6(e)
P-000001 SUBPOENAS" containing correspondence Work Product
thru related to various grand jury subpoenas and
P-000039 attorney (Villafada) handwritten notes
Box #1 Operation Leap Year Grand Jury Log 6(e)
P-000040 containing subpoenas OLY-01 through OLY-81, Work Product
thru correspondence and research related to Contains documents subject
P-000549 enforcement of same, documents produced in to investigative privilege
response to some subpoenas; and attorney Also contains documents
(Villafafla) handwritten notes subject to privacy rights of
victims who are not parties to
this litigation
Box #1 File folder entitled "Ritz Compact Flash SW" 6(e)
P-000550 containing copies of a sealed search warrant Contains information subject
thru application, warrant, and supporting documents to investigative privilege
P-000621 Also contains information
subject to privacy rights of
victims who are not parties to
this litigation
Box #1 File folder entitled "PNY Technologies Compact 6(e)
P-000622 Flash SW" containing copies of a sealed search Contains information subject
thru warrant application, warrant, and supporting to investigative privilege
P-000693 documents Also contains information
subject to privacy rights of
victims who are not parties to
this litigation
Box #1 File folder entitled "JE Corporations" containing Work Product
P-000694 attorney research on Epstein-owned corporations Contains information subject
thru and prior litigation to investigative privilege
P-000781
Box #1 File folder entitled "Capital One" 6(e)
P-000782 containing subpoena and correspondence
thru
P-000803
Box #1 File folder entitled "DTG Operations/Dollar 6(e)
P-000804 Rent-a-Car" containing subpoena and responsive Contains documents and
thru documents information subject to
P-000854 investigative privilege
Also contains documents and
information subject to privacy
rights of victims who are not
parties to this litigation
Page 1 of 23
EFTA00191214
Bates Range Description Privilege(s) Asserted
Box #1 File folder entitled "JP Morgan Chase" 6(e)
P-000855 containing subpoena, correspondence, and Contains documents and
thru responsive documents information subject to
P-000937 investigative privilege
Box #1 File folder entitled "Washington Mutual" 6(e)
P-000938 containing subpoena, correspondence, and Contains documents and
thru responsive documents information subject to
P-000947 investigative privilege
Box #1 File folder entitled "Computer Search &" Work Product
P-000948 containing legal research on computer search and Attorney-Client
thru handwritten notes on indictment preparation Contains information subject
P-000982 to investigative privilege.
Also contains information
subject to privacy rights of
victims who are not parties to
this litigation
Box #1 File folder entitled "Attorney Notes from Work product
P-000983 Document Review" containing typed and 6(e)
thru handwritten attorney (Villafada) notes, target Contains information subject
P-001007 letters, correspondence re grand jury subpoena to investigative privilege.
Also contains information
subject to privacy rights of
victims who are not parties to
this litigation
Box #1 File folder entitled "Notes from Fed Ex Records" Work Product
P-001008 containing handwritten and typed attorney 6(e)
thru (Villafafia) notes and screen shots of FedEx Contains information subject
P-001056 subpoena response electronic file to investigative privilege.
Also contains information
subject to privacy rights of
victims who are not parties to
this litigation
Box #1 File folder entitled "Colonial Bank Records" 6(e)
P-001057 containing records received in response to grand Contains information subject
thru jury subpoena to investigative privilege
P-001959
Box #1 File folder entitled "OLY Grand Jury Log Vol 2: 6(e)
P-001960 OLY-51 THROUGH" containing subpoenas Contains information subject
Thru numbered OLY-51 through OLY-81 with related to investigative privilege.
P-002089 correspondence Also contains information
subject to privacy rights of
victims who are not parties to
this litigation
Page 2 of 23
EFTA00191215
Bates Range Description Privilege(s) Asserted
Box #1 File folder entitled "Epstein Corporate Records: 6(e)
P-002090 OLY-51, OLY-52, OLY-53, OLY-54" containing Contains information and
Thru subpoenas, records received in response to documents subject to
P-002169 subpoenas, and related correspondence investigative privilege
Box #1 File folder entitled "Colonial Bank" containing 6(e)
P-002170 subpoenas, correspondence related to subpoenas, Contains information and
Thru records received in response to subpoenas documents subject to
P-002246 investigative privilege
Box #1 File folder entitled "JEGE & Hyperion from 6(e)
P-002247 Goldberger OLY-46 & OLY-47" containing Contains information and
Thru documents received in response to subpoenas documents subject to
P-002265 investigative privilege
Box #1 Indictment preparation binder containing: Work product
P-002266 Grand jury subpoena log, evidence/activity 6(e)
Thru summary chart, witness/victim names and contact Contains information and
P-002386 list, attorney (Villafafia) handwritten notes, 302s, documents subject to
portions of state investigative file, attorney investigative privilege. Also
(Villafafia) typed notes, of individuals listed as contains information and
"Additional victims" documents subject to privacy
rights of victims who are not
parties to this litigation
Box #1 Indictment preparation binder containing: Work product
P-002387 Grand jury subpoena log, evidence/activity 6(e)
Thru summary chart, witness/victim names and contact Contains information and
P402769 list, attorney (Villafafia) handwritten notes, 302s, documents subject to
portions of state investigative file, attorney investigative privilege. Also
(Villafafia) typed notes, relevant pieces of grand contains information and
jury materials, telephone records/flight records documents subject to privacy
analysis charts, victim/witness photographs, rights of victims who are not
DAVID records, NCICs, and related materials for parties to this litigation
persons identified as Jane Does #15, 16, 17, 18,
19, Past Employees, Misc. Witnesses
Box #1 Indictment preparation binder containing: Work product
P-002770 witness/victim list with identifying information, 6(e)
Thrti sexual activity summary, telephone call summary Contains information and
P-00321 I chart, attorney (Villafafia) handwritten notes, documents subject to
302s, portions of state investigative file, attorney investigative privilege. Also
(Villafafia) typed notes, relevant pieces of grand contains information and
jury materials, telephone records/flight records documents subject to privacy
analysis charts, victim/witness photographs, rights of victims who are not
DAVID records, NCICs, and related materials for parties to this litigation
persons identified as Jane Does #1, 2, 3, 4, 5, 6, 7,
8
Page 3 of 23
EFTA00191216
Bates Range Description Privilege(s) Asserted
Box #1 Indictment preparation binder containing meta- Work product
P-003212 analysis charts of telephone/flight/grand jury 6(e)
Thru information for a number of victim/witnesses, Contains information and
P-003545 Nadia Marcinkova, and Adriana Mucinska documents subject to
investigative privilege. Also
contains information and
documents subject to privacy
rights of victims who are not
parties to this litigation
Box #1 FBI Reports of March 2008 interviews of Work product
P-003546 additional witness/victim located in New York 6(e) .
Thru Contains information and
P-003552 documents subject to
investigative privilege. Also
contains information and
documents subject to privacy
rights of victims who are not
parties to this litigation
Box 141 Printout of filenames from Federal Express Work product
P-003553 subpoena response with Attorney notations 6(e)
Thru
P-003555B
Box #1 Document entitled "Identified Numbers" with Work product
P-003556 accompanying handwritten attorney list compiled 6(e)
Thru from grand jury materials and attorney analysis of Contains information subject
P-003562 records to investigative privilege
Box #1 Folder entitled "Flight Manifests" containing 6(e)
P-003563 manifests received pursuant to grand jury Contains information and
Thru subpoena documents subject to
P-003629 investigative privilege
Box #1 File folder entitled "Recent Attorney Notes" Work product
P-003630 containing handwritten attorney (Villafada) notes 6(e)
Thru regarding document review and case strategy Investigative privilege
P-003633 Deliberative process
Box #1 File folder bearing victim name containing FBI Work product
P-003634 interview report from May 2008, telephone Attorney-client privilege
Thru activity report with attorney (Villafanana) 6(e)
P-003646 handwritten notes, related grand jury material Investigative privilege
Also contains information and
documents subject to privacy
rights of victims who are not
parties to this litigation
Page 4 of 23
EFTA00191217
Bates Range Description Privilege(s) Asserted
Box #1 File folder entitled "Summary of Sexual Activity" Work product
P-003647 containing chart bearing handwritten title "Sexual 6(e)
Thru Activity — Summary" with meta-analysis of Investigative privilege
P-003651 information, sorted by name of each Deliberative process
victim/witness, including name and identifying Also contains information and
information of each victim/witness documents subject to privacy
rights of victims who are not
parties to this litigation
Box #1 File folder entitled "Victim Civil Suits" Not privileged.
P-003652 Produced to counsel for
Thru Petitioners
P-003663
Box #1 File folder entitled "Research re JE Websites" Work product
P-003664 containing attorney research
Thru
P-003678
Box #1 File folder entitled "Serene Cano (N.Y. AUSA)" Work product
P-003679 containing attorney (Villafafla) handwritten notes
Thru
P-003680
Box #1 File folder entitled "Dr. Anna Salter" containing Work product
P-003681 attorney (Villafafia) memo to expert witness and Investigative privilege
Thru handwritten attorney notes
P-003687
Box #1 la
File folder entitled GO Interview" containing Work product
P-003688 attorney handwritten notes of interview, and Investigative privilege
Thru attorney handwritten notes regarding potential Also contains information
P-003693 charges subject to privacy rights of
victims who are not parties to
this litigation
Box #I File folder entitled "Research re Travel for Work product
P-003694 Prostitution" containing attorney (Villafafia) 6(e)
Thru handwritten notes regarding grand jury Investigative privilege
P-003711 presentation, chart entitled "Brought to Epstein's Also contains information and
House" with handwritten notes, Message Pad documents subject to privacy
meta-analysis chart, summary of evidence related rights of victims who are not
to one victim/witness, and relevant grand jury parties to this litigation
information
Box #1 Empty file folder bearing name of victim/witness Investigative privilege
P-003712 Also contains information
subject to privacy rights of
victim who is not a party to
this litigation
Page 5 of 23
EFTA00191218
Bates Range Description Privilege(s) Asserted
Box #1 File folder entitled "T(] M(]" containing grand 6(e)
P-003713 jury subpoenas, motion and order to compel Documents under seal
Thru testimony, and correspondence regarding same pursuant to court order
P-003746
Box #1 File folder entitled "Adrian Ross" containing 6(e)
P-003747 subpoena and correspondence regarding same
Thru
P-003751
Box #1 File folder entitled "PBPD Investigative File" 6(e)
P-003752 obtained via subpoena Investigative privilege
Thru Also contains information and
P-004295 documents subject to privacy
rights of victims who are not
parties to this litigation
Box #1 of
File folder bearing name victim/witness Work product
P-004296 containing meta-analysis chart showing telephone 6(e)
Thru calls, travel, and grand jury materials relevant to Investigative privilege
P-004350 possible charges Also contains information and
documents subject to privacy
rights of victims who are not
parties to this liti tion
Box #1 File folder entitled "Daniel Documents Work product
P-004351 53909-004" containing attorney research related
Thru to bias issue
P-004381
Box #1 File Folder entitled "FEDEX" containing 6(e)
P-004382 documents obtained via subpoena Investigative privilege
Thru
P-004478
Box #1 File Folder entitled "State of Delaware Records" 6(e)
P-004479 containing documents obtained in preparation for Investigative privilege
Thru indictment Work product
P-004551
Box #1 File folder entitled "Jet Blue Records" containing 6(e)
P-004552 documents obtained via subpoena Work product
Thru Investigative privilege
P-004555 Also contains information and
documents subject to privacy
rights of victims who are not
parties to this litigation
Box #1 File folder entitled "FL EMPLOYMENT Investigative privilege
P-004556 RECORDS" containing FDLE records on targets Work product
Thru