EFTA00020711.pdf
1.49 MB
Extraction Summary
21
People
9
Organizations
2
Locations
5
Events
4
Relationships
6
Quotes
Document Information
Type:
Privilege log (second supplemental privilege log - box #4)
File Size:
1.49 MB
Summary
This document is a 'Second Supplemental Privilege Log' from the case Jane Doe v. United States, listing internal DOJ, FBI, and USAO communications withheld from civil discovery. The log chronicles the timeline of the Jeffrey Epstein investigation from late 2006 to August 2008, detailing the internal deliberations regarding the Non-Prosecution Agreement (NPA), plea negotiations, and the drafting of the indictment. It reveals critical details such as internal disagreements over plea terms, Epstein's refusal to plead to anything other than 'assault on the plane,' Jay Lefkowitz's admission that he never intended Epstein to register as a sex offender, and the government's struggles with victim notification and harassment by Epstein's defense team.
People (21)
| Name | Role | Context |
|---|---|---|
| Marie Villafaña | AUSA (Assistant United States Attorney) |
Primary author/recipient of emails; lead prosecutor handling day-to-day investigation, plea negotiations, and draftin...
|
| Matt Menchel | AUSA/Chief of Criminal Division (implied) |
Involved in early plea negotiations; disagreement noted with Villafaña regarding his plea negotiations (July 2007).
|
| Jeff Sloman | First Assistant U.S. Attorney |
Senior DOJ official involved in high-level strategy, plea negotiations, and communications with Epstein's defense team.
|
| Alex Acosta | U.S. Attorney (SDFL) |
Top decision maker; involved in final plea negotiations, meetings with Epstein's counsel (Ken Starr, Jay Lefkowitz), ...
|
| Andrew Lourie | AUSA |
Heavily involved in drafting the indictment and plea agreements.
|
| Karen Atkinson | AUSA |
Involved in strategy, victim issues, and plea negotiations.
|
| Jason Richards | FBI Special Agent |
Investigating agent; involved in victim interviews and serving target letters.
|
| Nesbitt Kuyrkendall | FBI Special Agent |
Investigating agent; involved in victim interviews, search warrants, and victim notification.
|
| Eliasib Ortiz | FBI Special Agent |
Investigating agent.
|
| Roy Black | Epstein Defense Counsel |
Early defense attorney; filed Motion to Quash grand jury subpoena.
|
| Gerald Lefcourt | Epstein Defense Counsel |
Discussed meetings to discuss Epstein investigation.
|
| Lilly Ann Sanchez | Epstein Defense Counsel |
Requested extensions for subpoenas.
|
| Jay Lefkowitz | Epstein Defense Counsel |
High-profile defense attorney; negotiated the NPA; admitted he never intended Epstein to plead to a sex offense requi...
|
| Ken Starr | Epstein Defense Counsel |
High-profile defense attorney; met with Acosta and DOJ officials.
|
| Drew Oosterbaan | DOJ/CEOS (Child Exploitation and Obscenity Section) |
Washington DC based official reviewing the case and indictment.
|
| Myesha Braden | DOJ/CEOS |
Washington DC based official reviewing charges (2423(b)) and indictment.
|
| Rolando Garcia | AUSA |
Involved in later stages of plea negotiations and NPA drafting.
|
| Robert Senior | AUSA |
Involved in later stages, particularly indictment review and grand jury preparation.
|
| Dexter Lee | AUSA |
Involved in self-reporting to OPR regarding false allegations of ethics violations.
|
| Jane Doe #2 (T.M.) | Victim |
Mentioned in context of a call with her lawyer.
|
| Caroline Heck Miller | AUSA |
Consulted regarding ethical issue of presenting revised indictment to a new grand jury.
|
Organizations (9)
Timeline (5 events)
2007-08-08
"The meeting on Epstein" involving Acosta, Oosterbaan, and others.
Unknown
2007-12-14
Meeting between Epstein counsel, Alex Acosta, Jeff Sloman, the FBI SAC, and Marie Villafaña where concerns were raised.
Unknown
2008-01-31 to 2008-02-01
Victim interviews conducted.
Unknown
Locations (2)
| Location | Context |
|---|---|
Relationships (4)
Villafaña reports to Acosta on plea negotiations and meeting outcomes.
Telephone conferences regarding plea terms and sex offender registration.
Disagreement regarding Menchel's plea negotiations.
Epstein Counsel
→
Harassment/Legal Pressure
→
Victims
Emails regarding 'problems with victims being harassed' and counsel contacting victims under guise of depositions.
Key Quotes (6)
"Epstein was only willing to plead to assault on the plane; and rejection of facts supporting assault on the plane charge"Source
EFTA00020711.pdf
Quote #1
"Lefkowitz admitted that he never intended to have Epstein plead guilty to an offense that required sex offender registration"Source
EFTA00020711.pdf
Quote #2
"disagreement on Menchel's plea negotiations"Source
EFTA00020711.pdf
Quote #3
"The meeting on Epstein"Source
EFTA00020711.pdf
Quote #4
"self-reporting to OPR false allegations of ethics violations"Source
EFTA00020711.pdf
Quote #5
"problems with Epstein's counsel contacting victims in the guise of deposing them for the state criminal action"Source
EFTA00020711.pdf
Quote #6
Full Extracted Text
Complete text extracted from the document (38,219 characters)
Case 9:08-cv-80736-KAM Document 329-1 Entered on FLSD Docket 06/23/2015 Page 1 of 18
JANE DOE v. UNITED STATES
COURT FILE NO. 08-80736-CV-MARRA
SECOND SUPPLEMENTAL PRIVILEGE LOG - BOX #4
JANE DOE v. UNITED STATES
COURT FILE NO. 08-80736-CV-MARRA
SECOND SUPPLEMENTAL PRIVILEGE LOG - BOX #4
Bates Range Description Privilege(s) Asserted
P-013970 thru P-013971 11/29/2006-12/1/2006 emails between Marie Villafaña and prison employee regarding attempted contact with potential witness Work Product Investigative Privilege Privacy Act
P-013972 5/18/2007 email from Marie Villafaña 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
P-013973 thru P-013976 5/18/2007 emails between Marie Villafaña and expert witness regarding securing pre-indictment consultation contract Work Product 6(e) Investigative Privilege
P-013977 thru P-013979 5/21/2007 email from Marie Villafaña to Myesha Braden (CEOS) re 2423(b) charging question Work Product 6(e) Deliberative Process Investigative Privilege
P-013980 5/21/2007 email from Marie Villafaña to Matt Menchel and Jeff Sloman regarding guidance on grand jury presentation Work Product 6(e) Deliberative Process
P-013981 5/22/2007 email from Andy Laurie to Matt Menchel and Jeff Sloman (cc: Marie Villafaña) re letter received from Gerald Lefcourt discussing a meeting to discuss Epstein investigation Work Product Deliberative Process
P-013982 5/23/2007 email from Jason Richards to Marie Villafaña re extradition research Work Product A/C privilege Investigative Privilege
P-013983 thru P-013984 5/23/2007 emails between Karen Atkinson and Marie Villafaña regarding decision to meet with counsel for Epstein Work Product Deliberative Process
Page 1 of 18
EFTA00020711
P-013970 thru P-013971 11/29/2006-12/1/2006 emails between Marie Villafaña and prison employee regarding attempted contact with potential witness Work Product Investigative Privilege Privacy Act
P-013972 5/18/2007 email from Marie Villafaña 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
P-013973 thru P-013976 5/18/2007 emails between Marie Villafaña and expert witness regarding securing pre-indictment consultation contract Work Product 6(e) Investigative Privilege
P-013977 thru P-013979 5/21/2007 email from Marie Villafaña to Myesha Braden (CEOS) re 2423(b) charging question Work Product 6(e) Deliberative Process Investigative Privilege
P-013980 5/21/2007 email from Marie Villafaña to Matt Menchel and Jeff Sloman regarding guidance on grand jury presentation Work Product 6(e) Deliberative Process
P-013981 5/22/2007 email from Andy Laurie to Matt Menchel and Jeff Sloman (cc: Marie Villafaña) re letter received from Gerald Lefcourt discussing a meeting to discuss Epstein investigation Work Product Deliberative Process
P-013982 5/23/2007 email from Jason Richards to Marie Villafaña re extradition research Work Product A/C privilege Investigative Privilege
P-013983 thru P-013984 5/23/2007 emails between Karen Atkinson and Marie Villafaña regarding decision to meet with counsel for Epstein Work Product Deliberative Process
Page 1 of 18
EFTA00020711
Case 9:08-cv-80736-KAM Document 329-1 Entered on FLSD Docket 06/23/2015 Page 2 of 18
Bates Range Description Privilege(s) Asserted
P-013985 thru P-013989 6/14/2007-6/21/2007 emails between Marie Villafaña, 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
P-013990 thru P-013991 6/26/2007 email from Marie Villafaña to Jeff Sloman, Matt Menchel, and Andrew Lourie addressing arguments regarding interstate nexus for 2422(b) charges Work Product Deliberative Process
P-013992 thru P-013994 7/3/2007-7/4/2007 emails between Marie Villafaña 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
P-013995 thru P-014010 6/12/2007-7/6/2007 series of emails between Marie Villafaña and AUSAs Serene Nakano and James Cott re an earlier unrelated investigation of Epstein Work Product Investigative Privilege Privacy Act
P-014011 thru P-014025 7/3/2007-7/13/2007 email chain between Matt Menchel and Marie Villafaña 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
P-014026 thru P-014027 7/16/2007 email from Marie Villafaña to Matt Menchel and Andrew Lourie regarding correspondence from Roy Black and Motion to Quash 6(e) Work Product Deliberative Process Investigative Privilege
P-014028 thru P-014030 7/18/2007 emails from Marie Villafaña 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
P-014031 thru P-014032 7/19/2007 email chain between Marie Villafaña, 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
Page 2 of 18
EFTA00020712
Bates Range Description Privilege(s) Asserted
P-013985 thru P-013989 6/14/2007-6/21/2007 emails between Marie Villafaña, 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
P-013990 thru P-013991 6/26/2007 email from Marie Villafaña to Jeff Sloman, Matt Menchel, and Andrew Lourie addressing arguments regarding interstate nexus for 2422(b) charges Work Product Deliberative Process
P-013992 thru P-013994 7/3/2007-7/4/2007 emails between Marie Villafaña 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
P-013995 thru P-014010 6/12/2007-7/6/2007 series of emails between Marie Villafaña and AUSAs Serene Nakano and James Cott re an earlier unrelated investigation of Epstein Work Product Investigative Privilege Privacy Act
P-014011 thru P-014025 7/3/2007-7/13/2007 email chain between Matt Menchel and Marie Villafaña 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
P-014026 thru P-014027 7/16/2007 email from Marie Villafaña to Matt Menchel and Andrew Lourie regarding correspondence from Roy Black and Motion to Quash 6(e) Work Product Deliberative Process Investigative Privilege
P-014028 thru P-014030 7/18/2007 emails from Marie Villafaña 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
P-014031 thru P-014032 7/19/2007 email chain between Marie Villafaña, 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
Page 2 of 18
EFTA00020712
Case 9:08-cv-80736-KAM Document 329-1 Entered on FLSD Docket 06/23/2015 Page 3 of 18
Bates Range Description Privilege(s) Asserted
P-014033 7/19/2007 email from Marie Villafaña to Andrew Lourie and Matt Menchel regarding planned service of target letters Work Product 6(e) Investigative Privilege Deliberative Process
P-014034 7/26/2007 email from Marie Villafaña to Matt Menchel and Andrew Lourie regarding proposed changes to the indictment 6(e) Work Product Deliberative Process Investigative Privilege
P-014035 7/31/2007 email from Marie Villafaña to Jeff Sloman, Matt Menchel, and Andrew Lourie summarizing proposed plea terms as per Menchel recommendation Work Product Deliberative Process
P-014036 7/31/2007-8/2/2007 email chain between Jeff Sloman, Matt Menchel, Andrew Lourie, and Marie Villafaña regarding plea negotiations Work Product Deliberative Process Investigative Privilege
P-014037 8/2/2007 email drom Marie Villafaña to Jeff Sloman, Matt Menchel, and Andrew Lourie with draft response to Epstein counsel regarding agreement Work Product Deliberative Process Investigative Privilege
P-014038 thru P-014041 8/2/2007 emails between Matt Menchel, Jeff Sloman, Andy Lourie, and Marie Villafaña regarding letter received from Lilly Ann Sanchez Work Product Deliberative Process
P-014042 8/3/2007 Email from Marie Villafaña 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
P-014043 thru P-014044 Emails dated 8/6/2007 from Marie Villafaña to Cyndee Campos/Frederica Devlin and Jeff Sloman regarding Matt Menchel's correspondence prior to his departure. Work Product Deliberative Process
P-014045 thru P-014046 8/7/2007 email chain between Marie Villafaña, Cyndee Campos, and Alex Acosta regarding meeting to discuss Epstein matter Work Product Deliberative Process Investigative Privilege
Page 3 of 18
EFTA00020713
Bates Range Description Privilege(s) Asserted
P-014033 7/19/2007 email from Marie Villafaña to Andrew Lourie and Matt Menchel regarding planned service of target letters Work Product 6(e) Investigative Privilege Deliberative Process
P-014034 7/26/2007 email from Marie Villafaña to Matt Menchel and Andrew Lourie regarding proposed changes to the indictment 6(e) Work Product Deliberative Process Investigative Privilege
P-014035 7/31/2007 email from Marie Villafaña to Jeff Sloman, Matt Menchel, and Andrew Lourie summarizing proposed plea terms as per Menchel recommendation Work Product Deliberative Process
P-014036 7/31/2007-8/2/2007 email chain between Jeff Sloman, Matt Menchel, Andrew Lourie, and Marie Villafaña regarding plea negotiations Work Product Deliberative Process Investigative Privilege
P-014037 8/2/2007 email drom Marie Villafaña to Jeff Sloman, Matt Menchel, and Andrew Lourie with draft response to Epstein counsel regarding agreement Work Product Deliberative Process Investigative Privilege
P-014038 thru P-014041 8/2/2007 emails between Matt Menchel, Jeff Sloman, Andy Lourie, and Marie Villafaña regarding letter received from Lilly Ann Sanchez Work Product Deliberative Process
P-014042 8/3/2007 Email from Marie Villafaña 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
P-014043 thru P-014044 Emails dated 8/6/2007 from Marie Villafaña to Cyndee Campos/Frederica Devlin and Jeff Sloman regarding Matt Menchel's correspondence prior to his departure. Work Product Deliberative Process
P-014045 thru P-014046 8/7/2007 email chain between Marie Villafaña, Cyndee Campos, and Alex Acosta regarding meeting to discuss Epstein matter Work Product Deliberative Process Investigative Privilege
Page 3 of 18
EFTA00020713
Case 9:08-cv-80736-KAM Document 329-1 Entered on FLSD Docket 06/23/2015 Page 4 of 18
Bates Range Description Privilege(s) Asserted
P-014047 8/7/2007 email from Marie Villafaña 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
P-014048 8/7/2007 email from Marie Villafaña to Andrew Oosterbaan regarding Epstein meeting Work Product Deliberative Process Investigative Privilege
P-014049 thru P-014050 8/7/2007 email chain from Jeff Sloman to Andrew Oosterbaan, Marie Villafaña, and Alex Acosta regarding Epstein meeting Work Product Deliberative Process Investigative Privilege
P-014051 8/8/2007 emails between Marie Villafaña and Andrew Oosterbaan (CEOS) regarding case staffing and plea negotiations Work Product Deliberative Process Investigative Privilege
P-014052 8/8/2007 email chain between Andrew Oosterbaan, Alex Acosta, Marie Villafaña, Cyndee Campos, Jeff Sloman, and Andrew Lourie regarding "The meeting on Epstein" Work Product Deliberative Process Investigative Privilege
P-014053 8/8/2007 email from Marie Villafaña to Drew Oosterbaan regarding plea negotiations, guideline calculations, and assistance in preparing case for trial Work Product Investigative Privilege Deliberative Process
P-014054 8/8/2007 email from Marie Villafaña to Alex Acosta, Cyndee Campos, Jeff Sloman, Andrew Lourie, and Drew Oosterbaan regarding planning meeting with Epstein counsel and service of target letters Work Product 6(e) Investigative Privilege Deliberative Process
P-014055 8/10/2007 Electronic correspondence from Marie Villafaña to expert witness regarding topics for expert testimony Work Product
P-014056 8/10/2007 email from Marie Villafaña to Andrew Lourie regarding target letters and staying motion to compel production of computers Work Product
P-014057 8/30/2007 email from Marie Villafaña to Jeff Sloman, Andrew Lourie, Drew Oosterbaan, John McMillan, and Karen Atkinson regarding press coverage of meeting with Ken Starr Work Product
P-014058 9/4/2007-9/6/2007 emails between Marie Villafaña and Jeff Sloman regarding planned participation of FBI ASAIC at 9/7/2007 meeting with Epstein defense team Work Product Deliberative Process
Page 4 of 18
EFTA00020714
Bates Range Description Privilege(s) Asserted
P-014047 8/7/2007 email from Marie Villafaña 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
P-014048 8/7/2007 email from Marie Villafaña to Andrew Oosterbaan regarding Epstein meeting Work Product Deliberative Process Investigative Privilege
P-014049 thru P-014050 8/7/2007 email chain from Jeff Sloman to Andrew Oosterbaan, Marie Villafaña, and Alex Acosta regarding Epstein meeting Work Product Deliberative Process Investigative Privilege
P-014051 8/8/2007 emails between Marie Villafaña and Andrew Oosterbaan (CEOS) regarding case staffing and plea negotiations Work Product Deliberative Process Investigative Privilege
P-014052 8/8/2007 email chain between Andrew Oosterbaan, Alex Acosta, Marie Villafaña, Cyndee Campos, Jeff Sloman, and Andrew Lourie regarding "The meeting on Epstein" Work Product Deliberative Process Investigative Privilege
P-014053 8/8/2007 email from Marie Villafaña to Drew Oosterbaan regarding plea negotiations, guideline calculations, and assistance in preparing case for trial Work Product Investigative Privilege Deliberative Process
P-014054 8/8/2007 email from Marie Villafaña to Alex Acosta, Cyndee Campos, Jeff Sloman, Andrew Lourie, and Drew Oosterbaan regarding planning meeting with Epstein counsel and service of target letters Work Product 6(e) Investigative Privilege Deliberative Process
P-014055 8/10/2007 Electronic correspondence from Marie Villafaña to expert witness regarding topics for expert testimony Work Product
P-014056 8/10/2007 email from Marie Villafaña to Andrew Lourie regarding target letters and staying motion to compel production of computers Work Product
P-014057 8/30/2007 email from Marie Villafaña to Jeff Sloman, Andrew Lourie, Drew Oosterbaan, John McMillan, and Karen Atkinson regarding press coverage of meeting with Ken Starr Work Product
P-014058 9/4/2007-9/6/2007 emails between Marie Villafaña and Jeff Sloman regarding planned participation of FBI ASAIC at 9/7/2007 meeting with Epstein defense team Work Product Deliberative Process
Page 4 of 18
EFTA00020714
Case 9:08-cv-80736-KAM Document 329-1 Entered on FLSD Docket 06/23/2015 Page 5 of 18
Bates Range Description Privilege(s) Asserted
P-014059 thru P-014061 9/6/2007 emails between Marie Villafaña, 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
P-014062 thru P-014068 9/10/2007-9/14/2007 emails between Marie Villafaña, 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 Work Product Deliberative Process 6(e) Investigative Privilege
P-014069 9/10/2007 email from Marie Villafaña to Jeff Sloman and John McMillan regarding Acosta inquiry about FBI investigation into State grand jury proceeding Work Product 6(e) Investigative Privilege
P-014070 thru P-014074 9/11/2007 emails between Marie Villafaña, 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
P-014075 thru P-014089 9/10/2007-9/11/2007 emails between Marie Villafaña, Alex Acosta, and Jeff Sloman regarding modifications to the proposed Non-Prosecution Agreement Work Product Deliberative Process
P-014090 thru P-014102 9/13/2007 emails from Marie Villafaña 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
P-014103 thru P-014107 9/13/2007-9/14/2007 emails regarding Marie Villafaña research regarding victim trust fund set up in Alaska child exploitation case Work Product
P-014108 thru P-014134 9/17/2007-9/19/2007 emails between Marie Villafaña, 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
Page 5 of 18
EFTA00020715
Bates Range Description Privilege(s) Asserted
P-014059 thru P-014061 9/6/2007 emails between Marie Villafaña, 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
P-014062 thru P-014068 9/10/2007-9/14/2007 emails between Marie Villafaña, 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 Work Product Deliberative Process 6(e) Investigative Privilege
P-014069 9/10/2007 email from Marie Villafaña to Jeff Sloman and John McMillan regarding Acosta inquiry about FBI investigation into State grand jury proceeding Work Product 6(e) Investigative Privilege
P-014070 thru P-014074 9/11/2007 emails between Marie Villafaña, 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
P-014075 thru P-014089 9/10/2007-9/11/2007 emails between Marie Villafaña, Alex Acosta, and Jeff Sloman regarding modifications to the proposed Non-Prosecution Agreement Work Product Deliberative Process
P-014090 thru P-014102 9/13/2007 emails from Marie Villafaña 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
P-014103 thru P-014107 9/13/2007-9/14/2007 emails regarding Marie Villafaña research regarding victim trust fund set up in Alaska child exploitation case Work Product
P-014108 thru P-014134 9/17/2007-9/19/2007 emails between Marie Villafaña, 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
Page 5 of 18
EFTA00020715
Case 9:08-cv-80736-KAM Document 329-1 Entered on FLSD Docket 06/23/2015 Page 6 of 18
Bates Range Description Privilege(s) Asserted
P-014135 thru P-014149 9/19/2007-9/20/2007 emails between Marie Villafaña, Andrew Lourie, and Rolando Garcia regarding plea negotiations with counsel for Epstein Work Product Deliberative Process
P-014150 thru P-014156 9/20/2007 emails between Marie Villafaña and Andrew Lourie regarding plea agreement to federal charges and factual proffer Work Product Deliberative Process
P-014157 thru P-014160 9/21/2007 emails between Marie Villafaña and Andrew Lourie, Rolando Garcia, Karen Atkinson, and John McMillan regarding revisions to the non-prosecution agreement Work Product Deliberative Process
P-014161 9/21/2007 email from Marie Villafaña to Alex Acosta, Rolando Garcia, Karen Atkinson, and Andrew Lourie regarding review of Epstein indictment package Work Product Deliberative Process
P-014162 thru P-014170 9/24/2007 series of emails between Marie Villafaña, Alex Acosta, and Andrew Lourie regarding plea negotiations and revisions to non-prosecution agreement Work Product Deliberative Process
P-014171 thru P-014174 9/23/2007-9/24/2007 series of emails between Alex Acosta, Marie Villafaña, Andrew Lourie, Rolando Garcia, and Jeff Sloman regarding proposed revisions to non-prosecution agreement Work Product Deliberative Process
P-014175 thru P-014203 9/20/2007-9/24/2007 emails between Alex Acosta, Marie Villafaña, and Andrew Lourie regarding revisions to the non-prosecution agreement Work Product Deliberative Process
P-014204 thru P-014205 9/24/2007 emails between Marie Villafaña and Rolando Garcia regarding notifying Palm Beach Police Chief and victims about agreement Work Product Deliberative Process
P-014206 thru P-014216 9/24/2007-9/25/2007 emails between Alex Acosta, Marie Villafaña, Andrew Lourie, and Rolanda Garcia regarding Lefkowitz email about keeping agreement from becoming public and confidentiality provision in agreement Work Product Deliberative Process
P-014217 thru P-014238 10/5/2007-10/16/2007 emails between Marie Villafaña, Jeff Sloman, and Alex Acosta re selection of Special Master and negotiation of revision/addendum to Non-Prosecution Agreement Work Product Deliberative Process
Page 6 of 18
EFTA00020716
Bates Range Description Privilege(s) Asserted
P-014135 thru P-014149 9/19/2007-9/20/2007 emails between Marie Villafaña, Andrew Lourie, and Rolando Garcia regarding plea negotiations with counsel for Epstein Work Product Deliberative Process
P-014150 thru P-014156 9/20/2007 emails between Marie Villafaña and Andrew Lourie regarding plea agreement to federal charges and factual proffer Work Product Deliberative Process
P-014157 thru P-014160 9/21/2007 emails between Marie Villafaña and Andrew Lourie, Rolando Garcia, Karen Atkinson, and John McMillan regarding revisions to the non-prosecution agreement Work Product Deliberative Process
P-014161 9/21/2007 email from Marie Villafaña to Alex Acosta, Rolando Garcia, Karen Atkinson, and Andrew Lourie regarding review of Epstein indictment package Work Product Deliberative Process
P-014162 thru P-014170 9/24/2007 series of emails between Marie Villafaña, Alex Acosta, and Andrew Lourie regarding plea negotiations and revisions to non-prosecution agreement Work Product Deliberative Process
P-014171 thru P-014174 9/23/2007-9/24/2007 series of emails between Alex Acosta, Marie Villafaña, Andrew Lourie, Rolando Garcia, and Jeff Sloman regarding proposed revisions to non-prosecution agreement Work Product Deliberative Process
P-014175 thru P-014203 9/20/2007-9/24/2007 emails between Alex Acosta, Marie Villafaña, and Andrew Lourie regarding revisions to the non-prosecution agreement Work Product Deliberative Process
P-014204 thru P-014205 9/24/2007 emails between Marie Villafaña and Rolando Garcia regarding notifying Palm Beach Police Chief and victims about agreement Work Product Deliberative Process
P-014206 thru P-014216 9/24/2007-9/25/2007 emails between Alex Acosta, Marie Villafaña, Andrew Lourie, and Rolanda Garcia regarding Lefkowitz email about keeping agreement from becoming public and confidentiality provision in agreement Work Product Deliberative Process
P-014217 thru P-014238 10/5/2007-10/16/2007 emails between Marie Villafaña, Jeff Sloman, and Alex Acosta re selection of Special Master and negotiation of revision/addendum to Non-Prosecution Agreement Work Product Deliberative Process
Page 6 of 18
EFTA00020716
Case 9:08-cv-80736-KAM Document 329-1 Entered on FLSD Docket 06/23/2015 Page 7 of 18
Bates Range Description Privilege(s) Asserted
P-014239 thru P-014242 10/18/2007 emails between Marie Villafaña and Jeff Sloman regarding Epstein's request to delay his change of plea Work Product Deliberative Process
P-014243 thru P-014251 10/19/2007 emails between Jeff Sloman and Marie Villafaña regarding Special Master's Selection of Attorney Representative Work Product Deliberative Process
P-014252 thru P-014275 10/22/2007-10/31/2007 emails between Jeff Sloman, Alex Acosta, and Marie Villafaña regarding negotiation of Addendum to Non-Prosecution Agreement and drafting of correspondence regarding scope of Special Master's duties and selection criteria Work Product Deliberative Process
P-014276 10/31/2007 email from Nesbitt Kurykendall to Marie Villafaña regarding attempts to interview additional witnesses/victims Work Product Attorney-Client Privilege Investigative Privilege 6(e) Also contains information subject to privacy rights of victims who are not parties to this litigation
P-014277 thru P-014282 11/2/2007-11/5/2007 emails between Marie Villafaña and Jeff Sloman regarding drafting 11/5/2007 letter from Sloman to Lefkowitz Work Product Deliberative Process
P-014283 thru P-014284 11/5/2007-11/7/2007 emails from Marie Villafaña to Jeff Sloman inquiring about status of matter and contact by Epstein investigators with victims Work Product Deliberative Process
P-014285 thru P-014298 11/8/2007-11/14/2007 emails between Marie Villafaña, Jeff Sloman, Karen Atkinson, and Jason Richards regarding response to objections raised by Epstein counsel and efforts to change date for guilty plea Work Product Deliberative Process Attorney-Client Privilege
P-014299 thru P-014307 11/14/2007-11/19/2007 emails between Marie Villafaña, 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 Work Product Deliberative Process Attorney-Client Privilege
Page 7 of 18
EFTA00020717
Bates Range Description Privilege(s) Asserted
P-014239 thru P-014242 10/18/2007 emails between Marie Villafaña and Jeff Sloman regarding Epstein's request to delay his change of plea Work Product Deliberative Process
P-014243 thru P-014251 10/19/2007 emails between Jeff Sloman and Marie Villafaña regarding Special Master's Selection of Attorney Representative Work Product Deliberative Process
P-014252 thru P-014275 10/22/2007-10/31/2007 emails between Jeff Sloman, Alex Acosta, and Marie Villafaña regarding negotiation of Addendum to Non-Prosecution Agreement and drafting of correspondence regarding scope of Special Master's duties and selection criteria Work Product Deliberative Process
P-014276 10/31/2007 email from Nesbitt Kurykendall to Marie Villafaña regarding attempts to interview additional witnesses/victims Work Product Attorney-Client Privilege Investigative Privilege 6(e) Also contains information subject to privacy rights of victims who are not parties to this litigation
P-014277 thru P-014282 11/2/2007-11/5/2007 emails between Marie Villafaña and Jeff Sloman regarding drafting 11/5/2007 letter from Sloman to Lefkowitz Work Product Deliberative Process
P-014283 thru P-014284 11/5/2007-11/7/2007 emails from Marie Villafaña to Jeff Sloman inquiring about status of matter and contact by Epstein investigators with victims Work Product Deliberative Process
P-014285 thru P-014298 11/8/2007-11/14/2007 emails between Marie Villafaña, Jeff Sloman, Karen Atkinson, and Jason Richards regarding response to objections raised by Epstein counsel and efforts to change date for guilty plea Work Product Deliberative Process Attorney-Client Privilege
P-014299 thru P-014307 11/14/2007-11/19/2007 emails between Marie Villafaña, 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 Work Product Deliberative Process Attorney-Client Privilege
Page 7 of 18
EFTA00020717
Case 9:08-cv-80736-KAM Document 329-1 Entered on FLSD Docket 06/23/2015 Page 8 of 18
Bates Range Description Privilege(s) Asserted
P-014308 thru P-014310 11/19/2007 emails between Marie Villafaña, Jeff Sloman, and Rolando Garcia about efforts by Epstein's counsel to change date for change of plea Work Product Deliberative Process
P-014311 thru P-014329 11/19/2007-11/28/2007 emails between Marie Villafaña, 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
P-014330 thru P-014337 11/28/2007 correspondence between Marie Villafaña, Andrew Lourie, Drew Oosterbaan, and Rolando Garcia regarding Lefkowitz 11/27/2007 email discussing presentation to DAAG Work Product Deliberative Process
P-014338 thru P-014354 11/29/2007-12/1/2007 emails between Marie Villafaña, Alex Acosta, Jeff Sloman, Cyndee Campos, and Andrew Lourie regarding draft response to Jay Lefkowitz and victim notification letters Work Product Deliberative Process
P-014355 thru P-014361 12/3/2007 emails between Marie Villafaña, Alex Acosta, and Jeff Sloman regarding history of plea negotiations and drafting response to correspondence from Jay Lefkowitz and Ken Starr Work Product Deliberative Process
P-014362 thru P-014402 12/3/2007-12/5/2007 correspondence between Alex Acosta, Jeff Sloman, Marie Villafaña, 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
P-014403 thru P-014414 12/6/2007 emails between Marie Villafaña, Andrew Lourie, Cyndee Campos, Jeff Sloman, Alex Acosta, Karen Atkinson, and Nesbitt Kuyrkendall regarding correspondence from Ken Starr, request for a meeting from Epstein counsel, and need to notify victims of upcoming plea Work Product Deliberative Process
P-014415 thru P-014420 12/6/2007-12/7/2007 emails between Marie Villafaña, Cyndee Campos, Karen Atkinson, Jeff Sloman, and Alex Acosta regarding draft victim notification letter Work Product Deliberative Process
Page 8 of 18
EFTA00020718
Bates Range Description Privilege(s) Asserted
P-014308 thru P-014310 11/19/2007 emails between Marie Villafaña, Jeff Sloman, and Rolando Garcia about efforts by Epstein's counsel to change date for change of plea Work Product Deliberative Process
P-014311 thru P-014329 11/19/2007-11/28/2007 emails between Marie Villafaña, 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
P-014330 thru P-014337 11/28/2007 correspondence between Marie Villafaña, Andrew Lourie, Drew Oosterbaan, and Rolando Garcia regarding Lefkowitz 11/27/2007 email discussing presentation to DAAG Work Product Deliberative Process
P-014338 thru P-014354 11/29/2007-12/1/2007 emails between Marie Villafaña, Alex Acosta, Jeff Sloman, Cyndee Campos, and Andrew Lourie regarding draft response to Jay Lefkowitz and victim notification letters Work Product Deliberative Process
P-014355 thru P-014361 12/3/2007 emails between Marie Villafaña, Alex Acosta, and Jeff Sloman regarding history of plea negotiations and drafting response to correspondence from Jay Lefkowitz and Ken Starr Work Product Deliberative Process
P-014362 thru P-014402 12/3/2007-12/5/2007 correspondence between Alex Acosta, Jeff Sloman, Marie Villafaña, 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
P-014403 thru P-014414 12/6/2007 emails between Marie Villafaña, Andrew Lourie, Cyndee Campos, Jeff Sloman, Alex Acosta, Karen Atkinson, and Nesbitt Kuyrkendall regarding correspondence from Ken Starr, request for a meeting from Epstein counsel, and need to notify victims of upcoming plea Work Product Deliberative Process
P-014415 thru P-014420 12/6/2007-12/7/2007 emails between Marie Villafaña, Cyndee Campos, Karen Atkinson, Jeff Sloman, and Alex Acosta regarding draft victim notification letter Work Product Deliberative Process
Page 8 of 18
EFTA00020718
Case 9:08-cv-80736-KAM Document 329-1 Entered on FLSD Docket 06/23/2015 Page 9 of 18
Bates Range Description Privilege(s) Asserted
P-014421 thru P-014428 12/6/2007-12/7/2007 emails between Marie Villafaña, 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 Work Product Deliberative Process 6(e) Attorney-Client Privilege Investigative Privilege
P-014429 thru P-014439 12/9/2007-12/12/2007 emails between Marie Villafaña, 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 Work Product Deliberative Process
P-014440 12/11/2007 email from Marie Villafaña to Jeff Sloman and Alex Acosta regarding call with lawyer for Jane Doe #2 (T.M.) Work Product Deliberative Process
P-014441 12/12/2007 emails between Marie Villafaña, Frederica Devlin, and Bob Senior regarding planning indictment review Work Product Deliberative Process 6(e)
P-014442 12/14/2007 email from Marie Villafaña to Jeff Sloman, Alex Acosta, and Janice LeClainche regarding state cases mentioned by Epstein's counsel Work Product Deliberative Process
P-014443 12/14/2007 email from Marie Villafaña to Alex Acosta, Jeff Sloman, Rolando Garcia, and Karen Atkinson with draft letters to State Attorney's Office and victims Work Product Deliberative Process
P-014444 12/17/2007 email from Marie Villafaña to Jeff Sloman inquiring about case status and informing Sloman regarding agent concern about victim notifications Work Product Deliberative Process
P-014445 thru P-014447 12/19/2007 email from Marie Villafaña to Alex Acosta and Jeff Sloman summarizing research into other cases where individuals were charged with violating 2422(b) based upon the use of a telephone Work Product Deliberative Process 6(e)
P-014448 thru P-014454 12/19/2007 emails between Marie Villafaña, Alex Acosta, and Jeff Sloman regarding drafting response to concerns raised during December 14, 2007 meeting between Epstein counsel, Alex Acosta, Jeff Sloman, the FBI SAIC, and Marie Villafaña Work Product Deliberative Process
Page 9 of 18
EFTA00020719
Bates Range Description Privilege(s) Asserted
P-014421 thru P-014428 12/6/2007-12/7/2007 emails between Marie Villafaña, 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 Work Product Deliberative Process 6(e) Attorney-Client Privilege Investigative Privilege
P-014429 thru P-014439 12/9/2007-12/12/2007 emails between Marie Villafaña, 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 Work Product Deliberative Process
P-014440 12/11/2007 email from Marie Villafaña to Jeff Sloman and Alex Acosta regarding call with lawyer for Jane Doe #2 (T.M.) Work Product Deliberative Process
P-014441 12/12/2007 emails between Marie Villafaña, Frederica Devlin, and Bob Senior regarding planning indictment review Work Product Deliberative Process 6(e)
P-014442 12/14/2007 email from Marie Villafaña to Jeff Sloman, Alex Acosta, and Janice LeClainche regarding state cases mentioned by Epstein's counsel Work Product Deliberative Process
P-014443 12/14/2007 email from Marie Villafaña to Alex Acosta, Jeff Sloman, Rolando Garcia, and Karen Atkinson with draft letters to State Attorney's Office and victims Work Product Deliberative Process
P-014444 12/17/2007 email from Marie Villafaña to Jeff Sloman inquiring about case status and informing Sloman regarding agent concern about victim notifications Work Product Deliberative Process
P-014445 thru P-014447 12/19/2007 email from Marie Villafaña to Alex Acosta and Jeff Sloman summarizing research into other cases where individuals were charged with violating 2422(b) based upon the use of a telephone Work Product Deliberative Process 6(e)
P-014448 thru P-014454 12/19/2007 emails between Marie Villafaña, Alex Acosta, and Jeff Sloman regarding drafting response to concerns raised during December 14, 2007 meeting between Epstein counsel, Alex Acosta, Jeff Sloman, the FBI SAIC, and Marie Villafaña Work Product Deliberative Process
Page 9 of 18
EFTA00020719
Case 9:08-cv-80736-KAM Document 329-1 Entered on FLSD Docket 06/23/2015 Page 10 of 18
Bates Range Description Privilege(s) Asserted
P-014455 thru P-014456 12/19/2007 email from Marie Villafaña to Alex Acosta, Jeff Sloman, and Janice LeClainche regarding challenge to state charge raised by Epstein counsel during 12/14/2007 meeting Work Product Deliberative Process 6(e) Also contains information subject to privacy rights of victims who are not parties to this litigation
P-014457 thru P-014464 12/20/2007 emails between Marie Villafaña and Jeff Sloman regarding inquiries from State Attorney's Office regarding Epstein plea to state charge and facts supporting state plea Work Product Deliberative Process 6(e) Also contains information subject to privacy rights of victims who are not parties to this litigation
P-014465 thru P-014485 12/18/2007-12/21/2007 emails between Marie Villafaña and other AUSAs regarding other instances of charging 2422(b) based on the use of a telephone as a "facility of interstate commerce" Work Product 6(e)
P-014486 12/21/2007 email from Marie Villafaña to Jeff Sloman with thoughts on recent correspondence from Jay Lefkowitz raising concerns about interpretation of the Nonprosecution Agreement Work Product Deliberative Process
P-014487 12/27/2007 email from Marie Villafaña to Alex Acosta and Jeff Sloman regarding proposed approach to providing potential notice of breach of non-prosecution agreement Work Product Deliberative Process
P-014488 thru P-014499 12/27/2007 emails between Jeff Sloman, Alex Acosta, Annette Castillo, Karen Atkinson, Rolando Garcia, and Marie Villafaña regarding Jay Lefkowitz letter of 12/26/2007 Work Product Deliberative Process
P-014500 1/2/2008 email from Jeff Sloman to Alex Acosta and Marie Villafaña regarding telephone conversation with State Attorney's Office about delay in Epstein state plea. Work Product Deliberative Process
P-014501 thru P-014506 1/2/2008 emails between Alex Acosta, Marie Villafaña, and Jeff Sloman regarding requests from Alex Acosta to Marie Villafaña for information related to the handling of the investigation by the State Attorney's Office Work Product Deliberative Process
Page 10 of 18
EFTA00020720
Bates Range Description Privilege(s) Asserted
P-014455 thru P-014456 12/19/2007 email from Marie Villafaña to Alex Acosta, Jeff Sloman, and Janice LeClainche regarding challenge to state charge raised by Epstein counsel during 12/14/2007 meeting Work Product Deliberative Process 6(e) Also contains information subject to privacy rights of victims who are not parties to this litigation
P-014457 thru P-014464 12/20/2007 emails between Marie Villafaña and Jeff Sloman regarding inquiries from State Attorney's Office regarding Epstein plea to state charge and facts supporting state plea Work Product Deliberative Process 6(e) Also contains information subject to privacy rights of victims who are not parties to this litigation
P-014465 thru P-014485 12/18/2007-12/21/2007 emails between Marie Villafaña and other AUSAs regarding other instances of charging 2422(b) based on the use of a telephone as a "facility of interstate commerce" Work Product 6(e)
P-014486 12/21/2007 email from Marie Villafaña to Jeff Sloman with thoughts on recent correspondence from Jay Lefkowitz raising concerns about interpretation of the Nonprosecution Agreement Work Product Deliberative Process
P-014487 12/27/2007 email from Marie Villafaña to Alex Acosta and Jeff Sloman regarding proposed approach to providing potential notice of breach of non-prosecution agreement Work Product Deliberative Process
P-014488 thru P-014499 12/27/2007 emails between Jeff Sloman, Alex Acosta, Annette Castillo, Karen Atkinson, Rolando Garcia, and Marie Villafaña regarding Jay Lefkowitz letter of 12/26/2007 Work Product Deliberative Process
P-014500 1/2/2008 email from Jeff Sloman to Alex Acosta and Marie Villafaña regarding telephone conversation with State Attorney's Office about delay in Epstein state plea. Work Product Deliberative Process
P-014501 thru P-014506 1/2/2008 emails between Alex Acosta, Marie Villafaña, and Jeff Sloman regarding requests from Alex Acosta to Marie Villafaña for information related to the handling of the investigation by the State Attorney's Office Work Product Deliberative Process
Page 10 of 18
EFTA00020720
Case 9:08-cv-80736-KAM Document 329-1 Entered on FLSD Docket 06/23/2015 Page 11 of 18
Bates Range Description Privilege(s) Asserted
P-014507 thru P-014508 1/2/2008 emails from Marie Villafaña to Alex Acosta and Jeff Sloman regarding renewed plea negotiations for federal plea agreement Work Product Deliberative Process 6(e)
P-014509 thru P-014519 1/3/2008 emails between Marie Villafaña, Alex Acosta, and Jeff Sloman regarding Alex Acosta telephone conference with Jay Lefkowitz where Lefkowitz admitted that he never intended to have Epstein plead guilty to an offense that required sex offender registration. Work Product Deliberative Process
P-014520 1/3/2008 email from Marie Villafaña to Nesbitt Kuyrkendall and Jason Richards regarding renewed plea negotiations and press coverage of Epstein matter. Attorney client privilege Deliberative Process Investigative Privilege
P-014521 thru P-014522 1/7/2008 email from Marie Villafaña to Alex Acosta, Jeff Sloman, Robert Senior, Karen Atkinson, and Rolando Garcia regarding proposed additional investigative steps in Epstein case. Work Product Deliberative Process 6(e) Privacy Act
P-014523 1/9/2008 email from Jeff Sloman to Drew Oosterbaan, Alex Acosta, and Marie Villafaña regarding informing Jay Lefkowitz that a CEOS attorney would join the SDFL team regarding the Epstein case and would review the prosecution and defense materials. Work Product Deliberative Process
P-014524 thru P-014550 1/9/2008-1/14/2008 emails between Marie Villafaña, Drew Oosterbaan, Myesha Braden, Nesbitt Kuyrkendall, and Jason Richards regarding assigning a CEOS attorney to the investigation, meeting with the CEOS attorney and victims in Florida, the results of the meetings and planned additional meetings, and revisions to the indictment in light of the meetings. Work Product Deliberative Process Attorney-client privilege Investigative Privilege 6(e)
P-014551 1/17/2008 email from Nesbitt Kuyrkendall to Marie Villafaña regarding updated summary charts for indictment preparation, meetings with victims, and victim notification letters from FBI Attorney-client privilege Investigative Privilege Also contains information subject to privacy rights of victims who are not parties to this litigation 6(e)
P-014552 1/23/2008 email from Marie Villafaña to Jeff Sloman and Alex Acosta regarding FBI involvement in meeting in DC Work Product Deliberative Process
Page 11 of 18
EFTA00020721
Bates Range Description Privilege(s) Asserted
P-014507 thru P-014508 1/2/2008 emails from Marie Villafaña to Alex Acosta and Jeff Sloman regarding renewed plea negotiations for federal plea agreement Work Product Deliberative Process 6(e)
P-014509 thru P-014519 1/3/2008 emails between Marie Villafaña, Alex Acosta, and Jeff Sloman regarding Alex Acosta telephone conference with Jay Lefkowitz where Lefkowitz admitted that he never intended to have Epstein plead guilty to an offense that required sex offender registration. Work Product Deliberative Process
P-014520 1/3/2008 email from Marie Villafaña to Nesbitt Kuyrkendall and Jason Richards regarding renewed plea negotiations and press coverage of Epstein matter. Attorney client privilege Deliberative Process Investigative Privilege
P-014521 thru P-014522 1/7/2008 email from Marie Villafaña to Alex Acosta, Jeff Sloman, Robert Senior, Karen Atkinson, and Rolando Garcia regarding proposed additional investigative steps in Epstein case. Work Product Deliberative Process 6(e) Privacy Act
P-014523 1/9/2008 email from Jeff Sloman to Drew Oosterbaan, Alex Acosta, and Marie Villafaña regarding informing Jay Lefkowitz that a CEOS attorney would join the SDFL team regarding the Epstein case and would review the prosecution and defense materials. Work Product Deliberative Process
P-014524 thru P-014550 1/9/2008-1/14/2008 emails between Marie Villafaña, Drew Oosterbaan, Myesha Braden, Nesbitt Kuyrkendall, and Jason Richards regarding assigning a CEOS attorney to the investigation, meeting with the CEOS attorney and victims in Florida, the results of the meetings and planned additional meetings, and revisions to the indictment in light of the meetings. Work Product Deliberative Process Attorney-client privilege Investigative Privilege 6(e)
P-014551 1/17/2008 email from Nesbitt Kuyrkendall to Marie Villafaña regarding updated summary charts for indictment preparation, meetings with victims, and victim notification letters from FBI Attorney-client privilege Investigative Privilege Also contains information subject to privacy rights of victims who are not parties to this litigation 6(e)
P-014552 1/23/2008 email from Marie Villafaña to Jeff Sloman and Alex Acosta regarding FBI involvement in meeting in DC Work Product Deliberative Process
Page 11 of 18
EFTA00020721
Case 9:08-cv-80736-KAM Document 329-1 Entered on FLSD Docket 06/23/2015 Page 12 of 18
Bates Range Description Privilege(s) Asserted
P-014553 thru P-014556 1/25/2008 emails between Marie Villafaña and Myesha Braden regarding press coverage of case and strategic decisions regarding revisions to initial indictment Work Product 6(e) Deliberative Process Investigative Privilege Also contains information subject to privacy rights of victims who are not parties to this litigation
P-014557 1/25/2008 email from Nesbitt Kuyrkendall to Marie Villafaña and Shawn Ball regarding research for purposes of issuing grand jury subpoenas. 6(e) Attorney-client privilege Investigative Privilege Also contains information subject to privacy rights of victims who are not parties to this litigation
P-014558 1/29/2008 email from Marie Villafaña to Drew Oosterbaan and Myesha Braden regarding status of meeting in DC and concerns regarding delay. Work Product Deliberative Process 6(e) Investigative Privilege
P-014559 thru P-014562 1/28/2008-1/29/2008 emails between Marie Villafaña and Myesha Braden regarding scheduling victim interviews on 1/31/2008-2/1/2008 Work Product 6(e) Investigative Privilege Also contains information subject to privacy rights of victims who are not parties to this litigation
P-014563 thru P-014565 1/30/2008 emails between Marie Villafaña, Alex Acosta, and Jeff Sloman regarding Lefkowitz email about lawsuit filed against Epstein by one of the victims identified during the state investigation. Work Product Deliberative Process 6(e) Also contains information subject to privacy rights of victims who are not parties to this litigation
Page 12 of 18
EFTA00020722
Bates Range Description Privilege(s) Asserted
P-014553 thru P-014556 1/25/2008 emails between Marie Villafaña and Myesha Braden regarding press coverage of case and strategic decisions regarding revisions to initial indictment Work Product 6(e) Deliberative Process Investigative Privilege Also contains information subject to privacy rights of victims who are not parties to this litigation
P-014557 1/25/2008 email from Nesbitt Kuyrkendall to Marie Villafaña and Shawn Ball regarding research for purposes of issuing grand jury subpoenas. 6(e) Attorney-client privilege Investigative Privilege Also contains information subject to privacy rights of victims who are not parties to this litigation
P-014558 1/29/2008 email from Marie Villafaña to Drew Oosterbaan and Myesha Braden regarding status of meeting in DC and concerns regarding delay. Work Product Deliberative Process 6(e) Investigative Privilege
P-014559 thru P-014562 1/28/2008-1/29/2008 emails between Marie Villafaña and Myesha Braden regarding scheduling victim interviews on 1/31/2008-2/1/2008 Work Product 6(e) Investigative Privilege Also contains information subject to privacy rights of victims who are not parties to this litigation
P-014563 thru P-014565 1/30/2008 emails between Marie Villafaña, Alex Acosta, and Jeff Sloman regarding Lefkowitz email about lawsuit filed against Epstein by one of the victims identified during the state investigation. Work Product Deliberative Process 6(e) Also contains information subject to privacy rights of victims who are not parties to this litigation
Page 12 of 18
EFTA00020722
Case 9:08-cv-80736-KAM Document 329-1 Entered on FLSD Docket 06/23/2015 Page 13 of 18
Bates Range Description Privilege(s) Asserted
P-014566 thru P-014568 1/31/2008 emails between Marie Villafaña and Nesbitt Kuyrkendall regarding interviews with victims. Work Product Investigative Privilege Attorney-client privilege Also contains information subject to privacy rights of victims who are not parties to this litigation
P-014569 thru P-014573 1/31/2008-2/1/2008 emails between Marie Villafaña, Jeff Sloman, Alex Acosta, Nesbitt Kuyrkendall, Jason Richards, and Alan Santiago regarding results of additional victim-witness interviews and requesting intervention with CEOS to move review process along Work Product Deliberative Process 6(e) Attorney-Client Privilege Also contains information subject to privacy rights of victims who are not parties to this litigation Investigative Privilege
P-014574 thru P-014583 2/20/2008-2/21/2008 emails between Drew Oosterbaan, Marie Villafaña, Robert Senior, Jeff Sloman, Sigal Mandelker, Karen Atkinson, Alex Acosta, Rolando Garcia and Myesha Braden regarding status of CEOS plans to meet with counsel for Epstein and status of indictment review Work Product Deliberative Process 6(e)
P-014584 thru P-014622 2/12/2008-2/22/2008 emails between Marie Villafaña, Nesbitt Kuyrkendall, Jason Richards, and Myesha Braden analyzing facts gathered from grand jury investigation and discussing strategy for drafting revised indictment Work Product Attorney-Client Privilege Investigative Privilege 6(e) Also contains information subject to privacy rights of victims who are not parties to this litigation
P-014623 thru P-014627 2/25/2008 emails between Marie Villafaña and Caroline Heck Miller regarding ethical issue about whether or not to present proposed revised indictment to new grand jury Work Product Deliberative Process 6(e)
P-014628 2/25/2008 email from Marie Villafaña to Jeff Sloman, Robert Senior, Rolando Garcia, Karen Atkinson, and Myesha Braden regarding result of consultation with Caroline Heck Miller about grand jury question Work Product Deliberative Process 6(e)
Page 13 of 18
EFTA00020723
Bates Range Description Privilege(s) Asserted
P-014566 thru P-014568 1/31/2008 emails between Marie Villafaña and Nesbitt Kuyrkendall regarding interviews with victims. Work Product Investigative Privilege Attorney-client privilege Also contains information subject to privacy rights of victims who are not parties to this litigation
P-014569 thru P-014573 1/31/2008-2/1/2008 emails between Marie Villafaña, Jeff Sloman, Alex Acosta, Nesbitt Kuyrkendall, Jason Richards, and Alan Santiago regarding results of additional victim-witness interviews and requesting intervention with CEOS to move review process along Work Product Deliberative Process 6(e) Attorney-Client Privilege Also contains information subject to privacy rights of victims who are not parties to this litigation Investigative Privilege
P-014574 thru P-014583 2/20/2008-2/21/2008 emails between Drew Oosterbaan, Marie Villafaña, Robert Senior, Jeff Sloman, Sigal Mandelker, Karen Atkinson, Alex Acosta, Rolando Garcia and Myesha Braden regarding status of CEOS plans to meet with counsel for Epstein and status of indictment review Work Product Deliberative Process 6(e)
P-014584 thru P-014622 2/12/2008-2/22/2008 emails between Marie Villafaña, Nesbitt Kuyrkendall, Jason Richards, and Myesha Braden analyzing facts gathered from grand jury investigation and discussing strategy for drafting revised indictment Work Product Attorney-Client Privilege Investigative Privilege 6(e) Also contains information subject to privacy rights of victims who are not parties to this litigation
P-014623 thru P-014627 2/25/2008 emails between Marie Villafaña and Caroline Heck Miller regarding ethical issue about whether or not to present proposed revised indictment to new grand jury Work Product Deliberative Process 6(e)
P-014628 2/25/2008 email from Marie Villafaña to Jeff Sloman, Robert Senior, Rolando Garcia, Karen Atkinson, and Myesha Braden regarding result of consultation with Caroline Heck Miller about grand jury question Work Product Deliberative Process 6(e)
Page 13 of 18
EFTA00020723
Case 9:08-cv-80736-KAM Document 329-1 Entered on FLSD Docket 06/23/2015 Page 14 of 18
Bates Range Description Privilege(s) Asserted
P-014629 2/26/2008 email from Marie Villafaña to Myesha Braden regarding CEOS review and draft indictment package Work Product Deliberative Process
P-014630 thru P-014631 2/26/2008 email from Marie Villafaña to Jeff Sloman regarding Jeff Sloman's 2/25/2008 correspondence to Jay Lefkowitz further extending the plea deadline for Epstein Work Product Deliberative Process Investigative Privilege 6(e)
P-014632 thru P-014646 2/21/2008-2/27/2008 emails between Marie Villafaña, David Weinstein, Robert Senior, Karen Atkinson, and Rolando Garcia regarding notifying DOJ's Civil Rights Division regarding the status of the case and the planned indictment, and the draft written notification Work Product Deliberative Process 6(e) Investigative Privilege
P-014647 thru P-014649 2/28/2008 emails between Marie Villafaña and Susan Roe regarding related investigation, potential investigatory leads, and CEOS review Work Product Investigative Privilege 6(e)
P-014650 thru P-014653 2/27/2008-2/28/2008 emails between Marie Villafaña, Nesbitt Kuyrkendall, and Jason Richards regarding review of evidence received pursuant to subpoenas and planned interviews of additional potential victim-witnesses Work Product Investigative Privilege Attorney-client privilege 6(e) Also contains information subject to privacy rights of victims who are not parties to this litigation
P-014654 thru P-014655 2/29/2008 emails between Jeff Sloman, Marie Villafaña, Robert Senior, and David Weinstein regarding continuing investigation and status of CEOS review Work Product Deliberative Process Investigative Privilege 6(e)
P-014656 thru P-014665 3/4/2008-3/5/2008 emails between Nesbitt Kuyrkendall and Marie Villafaña regarding search warrant and victim contact with attorneys Work Product Attorney-client privilege 6(e) Investigative Privilege Also contains information subject to privacy rights of victims who are not parties to this litigation
Page 14 of 18
EFTA00020724
Bates Range Description Privilege(s) Asserted
P-014629 2/26/2008 email from Marie Villafaña to Myesha Braden regarding CEOS review and draft indictment package Work Product Deliberative Process
P-014630 thru P-014631 2/26/2008 email from Marie Villafaña to Jeff Sloman regarding Jeff Sloman's 2/25/2008 correspondence to Jay Lefkowitz further extending the plea deadline for Epstein Work Product Deliberative Process Investigative Privilege 6(e)
P-014632 thru P-014646 2/21/2008-2/27/2008 emails between Marie Villafaña, David Weinstein, Robert Senior, Karen Atkinson, and Rolando Garcia regarding notifying DOJ's Civil Rights Division regarding the status of the case and the planned indictment, and the draft written notification Work Product Deliberative Process 6(e) Investigative Privilege
P-014647 thru P-014649 2/28/2008 emails between Marie Villafaña and Susan Roe regarding related investigation, potential investigatory leads, and CEOS review Work Product Investigative Privilege 6(e)
P-014650 thru P-014653 2/27/2008-2/28/2008 emails between Marie Villafaña, Nesbitt Kuyrkendall, and Jason Richards regarding review of evidence received pursuant to subpoenas and planned interviews of additional potential victim-witnesses Work Product Investigative Privilege Attorney-client privilege 6(e) Also contains information subject to privacy rights of victims who are not parties to this litigation
P-014654 thru P-014655 2/29/2008 emails between Jeff Sloman, Marie Villafaña, Robert Senior, and David Weinstein regarding continuing investigation and status of CEOS review Work Product Deliberative Process Investigative Privilege 6(e)
P-014656 thru P-014665 3/4/2008-3/5/2008 emails between Nesbitt Kuyrkendall and Marie Villafaña regarding search warrant and victim contact with attorneys Work Product Attorney-client privilege 6(e) Investigative Privilege Also contains information subject to privacy rights of victims who are not parties to this litigation
Page 14 of 18
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Case 9:08-cv-80736-KAM Document 329-1 Entered on FLSD Docket 06/23/2015 Page 15 of 18
Bates Range Description Privilege(s) Asserted
P-014666 thru P-014693 3/5/2008-3/6/2008 emails between Marie Villafaña, 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 Work Product Deliberative Process 6(e) Investigative Privilege
P-014694 thru P-014706 3/10/2008-3/12/2008 emails between Marie Villafaña, 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 Work Product Deliberative Process Attorney-client privilege
P-014707 thru P-014711 3/12/2008 emails between Marie Villafaña, Drew Oosterbaan, and Myesha Braden regarding CEOS meeting with Epstein counsel Work Product
P-014712 thru P-014716 3/14/2008 emails between Marie Villafaña, Rolando Garcia, Karen Atkinson, Frederica Devlin, and Shawn Ball regarding complete indictment package for Robert Senior final review Work Product Deliberative Process 6(e)
P-014717 thru P-014721 3/12/2008-3/17/2008 emails between Marie Villafaña, Nesbitt Kuyrkendall and E.J. Yera regarding search warrant application and execution of search warrant Work Product Attorney client privilege Investigative Privilege Also contains information subject to privacy rights of victims who are not parties to this litigation
P-014722 thru P-014727 3/14/2008-3/17/2008 emails between Marie Villafaña, Nesbitt Kuyrkendall, Jason Richards, and Robert Senior regarding corrections to indictment package and proposed grand jury presentation Work Product Deliberative Process 6(e) Attorney-Client Privilege Also contains information subject to privacy rights of victims who are not parties to this litigation
Page 15 of 18
EFTA00020725
Bates Range Description Privilege(s) Asserted
P-014666 thru P-014693 3/5/2008-3/6/2008 emails between Marie Villafaña, 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 Work Product Deliberative Process 6(e) Investigative Privilege
P-014694 thru P-014706 3/10/2008-3/12/2008 emails between Marie Villafaña, 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 Work Product Deliberative Process Attorney-client privilege
P-014707 thru P-014711 3/12/2008 emails between Marie Villafaña, Drew Oosterbaan, and Myesha Braden regarding CEOS meeting with Epstein counsel Work Product
P-014712 thru P-014716 3/14/2008 emails between Marie Villafaña, Rolando Garcia, Karen Atkinson, Frederica Devlin, and Shawn Ball regarding complete indictment package for Robert Senior final review Work Product Deliberative Process 6(e)
P-014717 thru P-014721 3/12/2008-3/17/2008 emails between Marie Villafaña, Nesbitt Kuyrkendall and E.J. Yera regarding search warrant application and execution of search warrant Work Product Attorney client privilege Investigative Privilege Also contains information subject to privacy rights of victims who are not parties to this litigation
P-014722 thru P-014727 3/14/2008-3/17/2008 emails between Marie Villafaña, Nesbitt Kuyrkendall, Jason Richards, and Robert Senior regarding corrections to indictment package and proposed grand jury presentation Work Product Deliberative Process 6(e) Attorney-Client Privilege Also contains information subject to privacy rights of victims who are not parties to this litigation
Page 15 of 18
EFTA00020725
Case 9:08-cv-80736-KAM Document 329-1 Entered on FLSD Docket 06/23/2015 Page 16 of 18
Bates Range Description Privilege(s) Asserted
P-014728 thru P-014742 3/14/2008-3/19/2008 emails between Marie Villafaña, Nesbitt Kuyrkendall, Jason Richards, Robert Senior, Jeff Sloman, Karen Atkinson, and Rolando Garcia about Epstein attempts to contact victims and finding counsel for victims Work Product Deliberative Process Attorney-client privilege Also contains information subject to privacy rights of victims who are not parties to this litigation
P-014743 thru P-014780 3/19/2008-3/21/2008 emails between Marie Villafaña, Drew Oosterbaan (CEOS), Alexandra Gelber (CEOS), Jeff Sloman, and Robert Senior about meeting between Epstein counsel and CEOS and follow-up questions Work Product 6(e) Deliberative Process Investigative Privilege
P-014781 thru P-014800 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)
P-014801 thru P-014810 3/28/2008 emails between Marie Villafaña, 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
P-014811 thru P-014829 3/31/2008 emails between Marie Villafaña, 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
P-014830 thru P-014837 4/2/2008 emails between Marie Villafaña, 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 Villafaña and Karen Atkinson Deliberative Process Work Product Attorney-Client Privilege
Page 16 of 18
EFTA00020726
Bates Range Description Privilege(s) Asserted
P-014728 thru P-014742 3/14/2008-3/19/2008 emails between Marie Villafaña, Nesbitt Kuyrkendall, Jason Richards, Robert Senior, Jeff Sloman, Karen Atkinson, and Rolando Garcia about Epstein attempts to contact victims and finding counsel for victims Work Product Deliberative Process Attorney-client privilege Also contains information subject to privacy rights of victims who are not parties to this litigation
P-014743 thru P-014780 3/19/2008-3/21/2008 emails between Marie Villafaña, Drew Oosterbaan (CEOS), Alexandra Gelber (CEOS), Jeff Sloman, and Robert Senior about meeting between Epstein counsel and CEOS and follow-up questions Work Product 6(e) Deliberative Process Investigative Privilege
P-014781 thru P-014800 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)
P-014801 thru P-014810 3/28/2008 emails between Marie Villafaña, 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
P-014811 thru P-014829 3/31/2008 emails between Marie Villafaña, 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
P-014830 thru P-014837 4/2/2008 emails between Marie Villafaña, 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 Villafaña and Karen Atkinson Deliberative Process Work Product Attorney-Client Privilege
Page 16 of 18
EFTA00020726
Case 9:08-cv-80736-KAM Document 329-1 Entered on FLSD Docket 06/23/2015 Page 17 of 18
Bates Range Description Privilege(s) Asserted
P-014838 thru P-014843 4/4/2008-4/7/2008 emails between Marie Villafaña, Robert Senior, Andrew Oosterbaan, and Jeff Sloman regarding status of CEOS review of Epstein matter Work Product 6(e) Deliberative Process
P-014844 thru P-014851 4/10/2008-4/18/2008 emails between Marie Villafaña, 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
P-014852 thru P-014864 4/11/2008-4/23/2008 emails between Marie Villafaña, Jeff Sloman, and Dexter Lee regarding self-reporting to OPR false allegations of ethics violations Work Product Deliberative Process Privacy Act
P-014865 4/29/2008 email from Marie Villafaña to Robert Senior, Jeff Sloman, Karen Atkins, on Rolando Garcia re grand jury presentation Work Product 6(e) Deliberative Process Investigative Privilege
P-014866 thru P-014883 4/21/2008-5/1/2008 emails between Marie Villafaña, 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
P-014884 thru P-014886 5/2/2008 emails between Robert Senior, Marie Villafaña, 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
P-014887 thru P-014894 4/29/2008-5/2/2008 emails between Marie Villafaña 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
Page 17 of 18
EFTA00020727
Bates Range Description Privilege(s) Asserted
P-014838 thru P-014843 4/4/2008-4/7/2008 emails between Marie Villafaña, Robert Senior, Andrew Oosterbaan, and Jeff Sloman regarding status of CEOS review of Epstein matter Work Product 6(e) Deliberative Process
P-014844 thru P-014851 4/10/2008-4/18/2008 emails between Marie Villafaña, 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
P-014852 thru P-014864 4/11/2008-4/23/2008 emails between Marie Villafaña, Jeff Sloman, and Dexter Lee regarding self-reporting to OPR false allegations of ethics violations Work Product Deliberative Process Privacy Act
P-014865 4/29/2008 email from Marie Villafaña to Robert Senior, Jeff Sloman, Karen Atkins, on Rolando Garcia re grand jury presentation Work Product 6(e) Deliberative Process Investigative Privilege
P-014866 thru P-014883 4/21/2008-5/1/2008 emails between Marie Villafaña, 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
P-014884 thru P-014886 5/2/2008 emails between Robert Senior, Marie Villafaña, 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
P-014887 thru P-014894 4/29/2008-5/2/2008 emails between Marie Villafaña 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
Page 17 of 18
EFTA00020727
Case 9:08-cv-80736-KAM Document 329-1 Entered on FLSD Docket 06/23/2015 Page 18 of 18
Bates Range Description Privilege(s) Asserted
P-014895 thru P-014900 5/7/2008-5/9/2008 emails between Marie Villafaña, 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
P-014901 thru P-014906 5/15/2008-5/16/2008 emails between Jeff Sloman, Marie Villafaña, and Robert Senior regarding receiving final approval from DC Work Product Deliberative Process
P-014907 thru P-014911 5/19/2008-5/22/2008 emails between Marie Villafaña, 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
P-014912 thru P-014919 5/23/2008-5/27/2008 emails between Marie Villafaña, Robert Senior, Jeff Sloman, Karen Atkinson, Nesbitt Kuyrkendall (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
P-014920 thru P-014923 8/15/2008 email from Marie Villafaña 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
Page 18 of 18
EFTA00020728
Bates Range Description Privilege(s) Asserted
P-014895 thru P-014900 5/7/2008-5/9/2008 emails between Marie Villafaña, 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
P-014901 thru P-014906 5/15/2008-5/16/2008 emails between Jeff Sloman, Marie Villafaña, and Robert Senior regarding receiving final approval from DC Work Product Deliberative Process
P-014907 thru P-014911 5/19/2008-5/22/2008 emails between Marie Villafaña, 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
P-014912 thru P-014919 5/23/2008-5/27/2008 emails between Marie Villafaña, Robert Senior, Jeff Sloman, Karen Atkinson, Nesbitt Kuyrkendall (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
P-014920 thru P-014923 8/15/2008 email from Marie Villafaña 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
Page 18 of 18
EFTA00020728
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