Court filing

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	11/29/2006-12/1/2006 emails between Marie Villafatia and prison	Work Product
thru	employee regarding attempted contact with potential witness	Investigative Privilege
P-013971		Privac Act
P-013972	5/18/2007 email from Marie Villafaila to Matt Menchel informing him	Work Product
	of intent to subpoena Roy Black’s private investigator and steps taken to	6(e)
	obtain DOJ authorization	Deliberative Process
		Investigative Privilege
P-013973	5/18/2007 emails between Marie Villafaila and expert witness regarding	Work Product
thru	securing pre-indictment consultation contract	6(e)
P-013976		Investigative Privilege
P-013977	5/21/2007 email from Marie Villafaba to Myesha Braden (CEOS) re	Work Product
thru	2423(b) charging question	6(e)
P-013979		Deliberative Process
		Investi ative Privile e
P-013980	5/21/2007 email from Marie Villafaiia to Matt Menchel and Jeff Sloman	Work Product
	regarding guidance on grand jury presentation	6(e)
		Deliberative Process
P-013981	5/22/2007 email from Andy Laurie to Matt Menchel and Jeff Sloman	Work Product
	(cc: Marie Villafatia) re letter received from Gerald Lefcourt discussing	Deliberative Process
	a meeting to discuss Epstein investigation
P-013982	5/23/2007 email from Jason Richards to Marie Villafaila re extradition	Work Product
	research	A/C privilege
		Investigative Privilege
P-013983	5/23/2007 emails between Karen Atkinson and Marie Villafatia	Work Product
thru	regarding decision to meet with counsel for Epstein	Deliberative Process
P-013984

Bates Range	Description	Privilege(s) Asserted
P-013985	6/14/2007-6/21/2007 emails between Marie Villafafia, Karen Atkinson,	6(e)
thru	Andrew Lourie, Matt Menchel, and Jeff Sloman regarding addendum to	Work Product
P-013989	Pros Memo, grand jury presentation and changes to indictment, and	Deliberative Process
	meeting with counsel for Epstein	Investigative Privilege
P-013990	6/26/2007 email from Marie Villafalta to Jeff Sloman, Matt Menchel,	Work Product
thru	and Andrew Lourie addressing arguments regarding interstate nexus for	Deliberative Process
P-013991	2422(b) charges
P-013992	7/3/2007-7/4/2007 emails between Marie Villafalia and Andrew Lourie	6(e)
thru	regarding extension of time to respond to subpoenas requested by Lilly	Work Product
P-013994	Ann Sanchez and possible resolution of case	Investigative Privilege
		Deliberative Process
P-013995	6/12/2007-7/6/2007 series of emails between Marie Villafalia and	Work Product
thru	AUSAs Serene Nakano and James Cott re an earlier unrelated	Investigative Privilege
P-014010	investigation of Epstein	Privacy Act
P-014011	7/3/2007-7/13/2007 email chain between Matt Menchel and Marie	6(e)
thru	Villafafia regarding disagreement on Menchel’s plea negotiations and	Work Product
P-014025	written request for meeting between USAO management and victims	Deliberative Process
		Investigative Privilege
P-014026	7/16/2007 email from Marie Villafafia to Matt Menchel and Andrew	6(e)
thru	Lourie regarding correspondence from Roy Black and Motion to Quash	Work Product
P-014027		Deliberative Process
		Investigative Privilege
P-014028	7/18/2007 emails from Marie Villafafia to Andrew Lourie and Matt	6(e)
thru	Menchel regarding Motion to Quash grand jury subpoena and	Work Product
P-014030	supporting affidavit filed by Roy Black	Deliberative Process
		Investigative Privilege
P-014031	7/19/2007 email chain between Marie Villafalia, Andrew Lourie, Matt	6(e)
thru	Menchel, S/A Jason Richards and S/A Eliasib Ortiz regarding potential	Work Product
P-014032	service of target letters	Deliberative Process
		Investigative Privilege
		Attorney-Client Privilege

Bates Range	Description	Privilege(s) Asserted
P-014033	7/19/2007 email from Marie Villafafta to Andrew Lourie and Matt	Work Product
	Menchel regarding planned service of target letters	6(e)
		Investigative Privilege
		Deliberative Process
P-014034	7/26/2007 email from Marie Villafafta to Matt Menchel and Andrew	6(e)
	Lourie regarding proposed changes to the indictment	Work Product
		Deliberative Process
		Investigative Privilege
P-014035	7/31/2007 email from Marie Villafafia to Jeff Sloman, Matt Menchel,	Work Product
	and Andrew Lourie summarizing proposed plea terms as per Menchel	Deliberative Process
	recommendation
P-014036	7/31/2007-8/2/2007 email chain between Jeff Sloman, Matt Menchel,	Work Product
	Andrew Lourie, and Marie Villafaila regarding plea negotiations	Deliberative Process
		Investi ative Privile e
P-014037	8/2/2007 email drom Marie Villafafta to Jeff Sloman, Matt Menchel,	Work Product
	and Andrew Lourie with draft response to Epstein counsel regarding	Deliberative Process
	agreement	Investigative Privilege
P-014038	8/2/2007 emails between Matt Menchel, Jeff Sloman, Andy Lourie, and	Work Product
thru	Marie Villafaila regarding letter received from Lilly Ann Sanchez	Deliberative Process
P-014041
P-014042	8/3/2007 Email from Marie Villafafta to Matt Menchel, Andrew Lourie,	Work Product
	Jeff Sloman, and Karen Atkinson regarding draft response to	Deliberative Process
	correspondence from Epstein counsel and planned investigative steps if	Investigative Privilege
	agreement cannot be reached.
P-014043	Emails dated 8/6/2007 from Marie Villafafia to Cyndee	Work Product
thru	Campos/Frederica Devlin and Jeff Sloman regarding Matt Menchel’s	Deliberative Process
P-014044	correspondence prior to his departure.
P-014045	8/7/2007 email chain between Marie Villafaiia, Cyndee Campos, and	Work Product
thru	Alex Acosta regarding meeting to discuss Epstein matter	Deliberative Process
P-014046		Investigative Privilege

Bates Range	Description	Privilege(s) Asserted
P-014047	8/7/2007 email from Marie Villafafia to Andy Lourie regarding deadline	Work Product
	set for Epstein plea and Epstein’s plan to demand a meeting with CEOS.	Deliberative Process
		Investigative Privilege
P-014048	8/7/2007 email from Marie Villafafia to Andrew Oosterbaan regarding	Work Product
	Epstein meeting	Deliberative Process
		Investigative Privilege
P-014049	8/7/2007 email chain from Jeff Sloman to Andrew Oosterbaan, Marie	Work Product
thru	Villafafia, and Alex Acosta regarding Epstein meeting	Deliberative Process
P-014050		Investigative Privilege
P-014051	8/8/2007 emails between Marie Villafaiia and Andrew Oosterbaan	Work Product
	(CEOS) regarding case staffing and plea negotiations	Deliberative Process
		Investigative Privilege
P-014052	8/8/2007 email chain between Andrew Oosterbaan, Alex Acosta, Marie	Work Product
	Villafafia, Cyndee Campos, Jeff Sloman, and Andrew Lourie regarding	Deliberative Process
	”The meeting on Epstein”	Investigative Privilege
P-014053	8/8/2007 email from Marie Villafafia to Drew Oosterbaan regarding	Work Product
	plea negotiations, guideline calculations, and assistance in preparing	Investigative Privilege
	case for trial	Deliberative Process
P-014054	8/8/2007 email from Marie Villafafia to Alex Acosta, Cyndee Campos,	Work Product
	Jeff Sloman, Andrew Lourie, and Drew Oosterbaan regarding planning	6(e)
	meeting with Epstein counsel and service of target letters	Investigative Privilege
		Deliberative Process
P-014055	8/10/2007 Electronic correspondence from Marie Villafafia to expert	Work Product
	witness regarding topics for expert testimony
P-014056	8/10/2007 email from Marie Villafafia to Andrew Lourie regarding	Work Product
	I roduction of com uters et letters and sta in motion to com
P-014057	8/30/2007 email from Marie Villafafia to Jeff Sloman, Andrew Lourie,	Work Product
	Drew Oosterbaan, John McMillan, and Karen Atkinson regarding press
	coverage of meeting with Ken Starr
P-014058	9/4/2007-9/6/2007 emails between Marie Villafafia and Jeff Sloman	Work Product
	regarding planned participation of FBI ASAIC at 9/7/2007 meeting with	Deliberative Process
	Epstein defense team

Bates Range	Description	Privilege(s) Asserted
P-014059	9/6/2007 emails between Marie Villafafia, Jeff Sloman, Andrew Lourie	Work Product
thru	Drew Oosterbaan, and Rolando Garcia regarding status of plea	Deliberative Process
P-014061	negotiations, draft agreements, and need to confer with victims
P-014062	9/10/2007-9/14/2007 emails between Marie Villafafta, Andrew Lourie,	Work Product
thru	Jeff Sloman, Karen Atkinson, Rolando Garcia, Shawn Ball, and Alex	Deliberative Process
P-014068	Acosta regarding final plea negotiations, finalizing details with State	6(e)
	Attorney’s Office and final revisions to indictment package	Investigative Privilege
P-014069	9/10/2007 email from Marie Villafaila to Jeff Slornan and John	Work Product
	McMillan regarding Acosta inquiry about FBI investigation into State	6(e)
	grand jury proceeding	Investigative Privilege
P-014070	9/11/2007 emails between Marie Villafaiia, John McMillan, Drew	Work Product
thru	Oosterbaan, Nesbitt Kuyrkendall, and Jason Richards regarding changes	Deliberative Process
P-014074	to the draft indictment and status of plea negotiations	Investigative Privilege
		Attorney-Client Privilege
P-014075	9/10/2007-9/11/2007 emails between Marie Villafafta, Alex Acosta, and	Work Product
thru	Jeff Sloman regarding modifications to the proposed Non-Prosecution	Deliberative Process
P-014089	Agreement
P-014090	9/13/2007 emails from Marie Villafana to Andrew Lourie, Alex Acosta,	Work Product
thru	Jeff Sloman, Rolando Garcia, and Karen Atkinson regarding plea to	Deliberative Process
P-014102	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
P-014103	9/13/2007-9/14/2007 emails regarding Marie Villafaiia research	Work Product
thru	regarding victim trust fund set up in Alaska child exploitation case
P-014107
P-014108	9/17/2007-9/19/2007 emails between Marie Villafafta, Rolando Garcia,	Work Product
thru	Andrew Lourie, Alex Acosta, Karen Atkinson, and John McMillan	Deliberative Process
P-014134	regarding negotiations of a federal plea and a non-prosecution
	agreement

Bates Range	Description	Privilege(s) Asserted
P-014135	9/19/2007-9/20/2007 emails between Marie Villafafia, Andrew Lourie,	Work Product
thru	and Rolando Garcia regarding plea negotiations with counsel for	Deliberative Process
P-014149	Epstein
P-014150	9/20/2007 emails between Marie Villafafia and Andrew Lourie	Work Product
thru	regarding plea agreement to federal charges and factual proffer	Deliberative Process
P-014156
P-014157	9/21/2007 emails between Marie Villafafia and Andrew Lourie, Rolando	Work Product
thru	Garcia, Karen Atkinson, and John McMillan regarding revisions to the	Deliberative Process
P-014160	non-prosecution agreement
P-014161	9/21/2007 email from Marie Villafaila to Alex Acosta, Rolando Garcia,	Work Product
	Karen Atkinson, and Andrew Lourie regarding review of Epstein	Deliberative Process
	indictment package
P-014162	9/24/2007 series of emails between Marie Villafatia, Alex Acosta, and	Work Production
thru	Andrew Lourie regarding plea negotiations and revisions to non	Deliberative Process
P-014170	prosecution agreement
P-014171	9/23/2007-9/24/2007 series of emails between Alex Acosta, Marie	Work Product
thru	Villafafia, Andrew Lourie, Rolando Garcia, and Jeff Sloman regarding	Deliberative Process
P-014174	proposed revisions to non-prosecution agreement
P-014175	9/20/2007-9/24/2007 emails between Alex Acosta, Marie Villafafia, and	Work Product
thru	Andrew Lourie regarding revisions to the non-prosecution agreement	Deliberative Process
P-014203
P-014204	9/24/2007 emails between Marie Villafaila and Rolando Garcia	Work Product
thru	regarding notifying Palm Beach Police Chief and victims about	Deliberative Process
P-014205	agreement
P-014206	9/24/2007-9/25/2007 emails between Alex Acosta, Marie Villafafia,	Work Product
thru	Andrew Lourie, and Rolanda Garcia regarding Lefkowitz email about	Deliberative Process
P-014216	keeping agreement from becoming public and confidentiality provision
	in agreement
P-014217	10/5/2007-10/16/2007 emails between Marie Villafafia, Jeff Sloman,	Work Product
thru	and Alex Acosta re selection of Special Master and negotiation of	Deliberative Process
P-014238	revision/addendum to Non-Prosecution Agreement

Bates Range	Description	Privilege(s) Asserted
P-014239	10/18/2007 emails between Marie Villafaiia and Jeff Sloman regarding	Work Product
thru	Epstein’s request to delay his change of plea	Deliberative Process
P-014242
P-014243	10/19/2007 emails between Jeff Sloman and Marie Villafafia regarding	Work Product
thru	Special Master’s Selection of Attorney Representative	Deliberative Process
P-014251
P-014252	10/22/2007-10/31/2007 emails between Jeff Sloman, Alex Acosta, and	Work Product
thru	Marie Villafafia regarding negotiation of Addendum to Non-Prosecution	Deliberative Process
P-014275	Agreement and drafting of correspondence regarding scope of Special
	Master’s duties and selection criteria
P-014276	10/31/2007 email from Nesbitt Kurykendall to Marie Villafafia	Work Product
	regarding attempts to interview additional witnesses/victims	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	11/2/2007-11/5/2007 emails between Marie Villafafia and Jeff Sloman	Work Product
thrn	regarding drafting 11/5/2007 letter from Sloman to Lefkowitz	Deliberative Process
P-014282
P-014283	11/5/2007-11/7/2007 emails from Marie Villafatia to Jeff Sloman	Work Product
thrn	inquiring about status of matter and contact by Epstein investigators	Deliberative Process
P-014284	with victims
P-014285	11/8/2007-11/14/2007 emails between Marie Villafafia, Jeff Sloman,	Work Product
thrn	Karen Atkinson, and Jason Richards regarding response to objections	Deliberative Process
P-014298	raised by Epstein counsel and efforts to change date for guilty plea	Attorney-Client Privilege
P-014299	11/14/2007-11/19/2007 emails between Marie Villafafia, Jason	Work Product
thru	Richards, Jeff Sloman, Rolando Garcia, Alex Acosta, and Karen	Deliberative Process
P-014307	Atkinson regarding communications with State Attorney’s Office and	Attorney-Client Privilege
	Sheriff’s Office in an attempt to insure that Epstein was ineligible for
	work release

Bates Range	Description	Privilege(s) Asserted
P-014308	11/19/2007 emails between Marie Villafafta, Jeff Sloman, and Rolando	Work Product
thru	Garcia about efforts by Epstein’s counsel to change date for change of	Deliberative Process
P-014310	plea
P-014311	11/19/2007-11/28/2007 emails between Marie Villafafia, Nesbitt	Work Product
thru	Kuyrkendall, Jason Richards, and Jeff Sloman regarding drafting victim	Deliberative Process
P-014329	notification letter of upcoming plea	Attorney-Client Privilege
		6(e)
		Also contains information subject to
		privacy rights of victims who are not
		parties to this litigation
P-014330	11/28/2007 correspondence between Marie Villafafia, Andrew Lourie,	Work Product
thru	Drew Oosterbaan, and Rolando Garcia regarding Lefkowitz 11/27/2007	Deliberative Process
P-014337	email discussing presentation to DAAG
P-014338	11/29/2007-12/1/2007 emails between Marie Villafafia, Alex Acosta,	Work Product
thru	Jeff Sloman, Cyndee Campos, and Andrew Lourie regarding draft	Deliberative Process
P-014354	response to Jay Lefkowitz and victim notification letters
P-014355	12/3/2007 emails between Marie Villafafia, Alex Acosta, and Jeff	Work Product
thrn	Sloman regarding history of plea negotiations and drafting response to	Deliberative Process
P-014361	correspondence from Jay Lekowitz and Ken Starr
P-014362	12/3/2007-12/5/2007 correspondence between Alex Acosta, Jeff	Work Product
thru	Sloman, Marie Villafafia, Nesbitt Kuyrkendall, Cyndee Campos, and	Deliberative Process
P-014402	Annette Castillo about drafting and sending the 12/4/2007 Acosta letter	6(e)
	to Ken Starr	Attorney-Client Privilege
P-014403	12/6/2007 emails between Marie Villafalia, Andrew Lourie, Cyndee	Work Product
thrn	Campos, Jeff Sloman, Alex Acosta, Karen Atkinson, and Nesbitt	Deliberative Process
P-014414	Kuyrkendall regarding correspondence from Ken Starr, request for a
	meeting from Epstein counsel, and need to notify victims of upcoming
	plea
P-014415	12/6/2007-12/7/2007 emails between Marie Villafaila, Cyndee Campos,	Work Product
thru	Karen Atkinson, Jeff Sloman, and Alex Acosta regarding draft victim	Deliberative Process
P-014420	notification letter

Bates Range	Description	Privilege(s) Asserted
P-014421	12/6/2007-12/7/2007 emails between Marie Villafaria, Nesbitt	Work Product
thru	Kuyrkendall, Jason Richards, Jeff Sloman, Cyndee Campos, Annette	Deliberative Process
P-014428	Castillo, Karen Atkinson, and Shawn Ball regarding request from State	6(e)
	Attorney’s Office for draft plea proffer	Attorney-Client Privilege
		Investi ative Privilege
P-014429	12/9/2007-12/12/2007 emails between Marie Villafafta, Jeff Sloman,	Work Product
thru	Jason Richards, Nesbitt Kuyrkendall, Annette Castillo, Karen Atkinson,	Deliberative Process
P-014439	and Rolando Garcia regarding drafting response to personal attacks and upcoming meeting with Ken Starr
P-014440	12/11/2007 email from Marie Villafaila to Jeff Sloman and Alex Acosta	Work Product
	regarding call with lawyer for Jane Doe #2 (T.M.)	Deliberative Process
P-014441	12/12/2007 emails between Marie Villafafta, Frederica Devlin, and Bob	Work Product
	Senior regarding planning indictment review	Deliberative Process
		6(e)
P-014442	12/14/2007 email from Marie Villafafia to Jeff Sloman, Alex Acosta,	Work Product
	and Janice LeClainche regarding state cases mentioned by Epstein’s counsel	Deliberative Process
P-014443	12/14/2007 email from Marie Villafafia to Alex Acosta, Jeff Sloman,	Work Product
	Rolando Garcia, and Karen Atkinson with draft letters to State	Deliberative Process
	Attorney’s Office and victims
P-014444	12/17/2007 email from Marie Villafafta to Jeff Sloman inquiring about	Work Product
	case status and informing Sloman regarding agent concern about victim	Deliberative Process
	notifications
P-014445	12/19/2007 email from Marie Villafafia to Alex Acosta and Jeff Sloman	Work Product
thru	summarizing research into other cases where individuals were charged	Deliberative Process
P-014447	with violating 2422(b) based upon the use of a telephone	6(e)
P-014448	12/19/2007 emails between Marie Villafafta, Alex Acosta, and Jeff	Work Product
thru	Sloman regarding drafting response to concerns raised during December	Deliberative Process
P-014454	14, 2007 meeting between Epstein counsel, Alex Acosta, Jeff Sloman,
	the FBI SAIL and Marie Villafafta

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	12/19/2007 email from Marie Villafafia to Alex Acosta, Jeff Sloman,	Work Product
thin	and Janice LeClainche regarding challenge to state charge raised by	Deliberative Process
P-014456	Epstein counsel during 12/14/2007 meeting	6(e)
		Also contains information subject to
		privacy rights of victims who are not
		parties to this litigation
P-014457	12/20/2007 emails between Marie Villafafia and Jeff Sloman regarding	Work Product
thin	inquiries from State Attorney’s Office regarding Epstein plea to state	Deliberative Process
P-014464	charge and facts supporting state plea	6(e)
		Also contains information subject to
		privacy rights of victims who are not
		parties to this litigation
P-014465	12/18/2007-12/21/2007 emails between Marie Villafaila and other	Work Product
thin	AUSAs regarding other instances of charging 2422(b) based on the use	6(e)
P-014485	of a telephone as a “facility of interstate commerce”
P-014486	12/21/2007 email from Marie Villafafia to Jeff Sloman with thoughts on	Work Product
	recent correspondence from Jay Lefkowitz raising concerns about	Deliberative Process
	interpretation of the Non rosecution Agreement
P-014487	12/27/2007 email from Marie Villafafia to Alex Acosta and Jeff Slornan	Work Product
	regarding proposed approach to providing potential notice of breach of	Deliberative Process
	non-prosecution agreement
P-014488	12/27/2007 emails between Jeff Sloman, Alex Acosta, Annette Castillo,	Work Product
thru	Karen Atkinson, Rolando Garcia, and Marie Villafafia regarding Jay	Deliberative Process
P-014499	Lefkowitz letter of 12/26/2007
P-014500	1/2/2008 email from Jeff Sloman to Alex Acosta and Marie Villafafia	Work Product
	regarding telephone conversation with State Attomey’s Office about	Deliberative Process
	delay in Epstein state plea.
P-014501	1/2/2008 emails between Alex Acosta, Marie Villafafia, and Jeff Slornan	Work Product
thin	regarding requests from Alex Acosta to Marie Villafaila for information	Deliberative Process
P-014506	related to the handling of the investigation by the State Attorney’s Office

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	1/2/2008 emails from Marie Villafalta to Alex Acosta and Jeff Sloman	Work Product
thru	regarding renewed plea negotiations for federal plea agreement	Deliberative Process
P-014508		6(e)
P-014509	1/3/2008 emails between Marie Villafafia, Alex Acosta, and Jeff Sloman	Work Product
thru	regarding Alex Acosta telephone conference with Jay Lefkowitz where	Deliberative Process
P-014519	Lefkowitz admitted that he never intended to have Epstein plead guilty
	to an offense that required sex offender registration.
P-014520	1/3/2008 email from Marie Villafafia to Nesbitt Kuyrkendall and Jason	Attorney client privilege
	Richards regarding renewed plea negotiations and press coverage of	Deliberative Process
	Epstein matter.	Investigative Privilege
P-014521	1/7/2008 email from Marie Villafaila to Alex Acosta, Jeff Sloman,	Work Product
thru	Robert Senior, Karen Atkinson, and Rolando Garcia regarding proposed	Deliberative Process
P-014522	additional investigative steps in Epstein case.	6(e)
		Privacy Act
P-014523	1/9/2008 email from Jeff Sloman to Drew Oosterbaan, Alex Acosta, and	Work Product
	Marie Villafalta regarding informing Jay Lefkowitz that a CEOS	Deliberative Process
	attorney would join the SDFL team regarding the Epstein case and
	would review the prosecution and defense materials.
P-014524	1/9/2008-1/14/2008 emails between Marie Villafafia, Drew Oosterbaan,	Work Product
thru	Myesha Braden, Nesbitt Kuyrkendall, and Jason Richards regarding	Deliberative Process
P-014550	assigning a CEOS attorney to the investigation, meeting with the CEOS	Attorney-client privilege
	attorney and victims in Florida, the results of the meetings and planned	Investigative Privilege
	additional meetings, and revisions to the indictment in light of the	6(e)
	meetings.
P-014551	1/17/2008 email from Nesbitt Kuyrkendall to Marie Villafaila regarding	Attorney-client privilege
	updated summary charts for indictment preparation, meetings with	Investigative Privilege
	victims, and victim notification letters from FBI	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 Villafafia to Jeff Sloman and Alex Acosta	Work Product
	regarding FBI involvement in meeting in DC	Deliberative Process

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	1/25/2008 emails between Marie Villafaila and Myesha Braden	Work Product
thru	regarding press coverage of case and strategic decisions regarding	6(e)
P-014556	revisions to initial indictment	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 Villafafia and	6(e)
	Shawn Ball regarding research for purposes of issuing grand jury	Attorney-client privilege
	subpoenas.	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 Villafafia to Drew Oosterbaan and Myesha	Work Product
	Braden regarding status of meeting in DC and concerns regarding delay.	Deliberative Process
		6(e)
		Investigative Privilege
P-014559	1/28/2008-1/29/2008 emails between Marie Villafafia and Myesha	Work Product
thru	Braden regarding scheduling victim interviews on 1/31/2008-2/1/2008	6(e)
P-014562		Investigative Privilege
		Also contains information subject to
		privacy rights of victims who are not
		parties to this litigation
P-014563	1/30/2008 emails between Marie Villafafia, Alex Acosta, and Jeff	Work Product
thru	Sloman regarding Lefkowitz email about lawsuit filed against Epstein	Deliberative Process
P-014565	by one of the victims identified during the state investigation.	6(e)
		Also contains information subject to
		privacy rights of victims who are not
		parties to this litigation

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	1/31/2008 emails between Marie Villafafta and Nesbitt Kuyrkendall	Work Product
thru	regarding interviews with victims.	Investigative Privilege
P-014568		Attorney-client privilege
		Also contains information subject to
		privacy rights of victims who are not
		parties to this litigation
P-014569	1/31/2008-2/1/2008 emails between Marie Villafafta, Jeff Sloman, Alex	Work Product
thru	Acosta, Nesbitt Kuyrkendall, Jason Richards, and Alan Santiago	Deliberative Process
P-014573	regarding results of additional victim-witness interviews and requesting	6(e)
	intervention with CEOS to move review process along	Attorney-Client Privilege
		Also contains information subject to
		privacy rights of victims who are not
		parties to this litigation Investigative
		Privilege
P-014574	2/20/2008-2/21/2008 emails between Drew Oosterbaan, Marie	Work Product
thru	Villafafta, Robert Senior, Jeff Sloman, Sigal Mandelker, Karen	Deliberative Process
P-014583	Atkinson, Alex Acosta, Rolando Garcia and Myesha Braden regarding	6(e)
	status of CEOS plans to meet with counsel for Epstein and status of
	indictment review
P-014584	2/12/2008-2/22/2008 emails between Marie Villafafta, Nesbitt	Work Product
thru	Kuyrkendall, Jason Richards, and Myesha Braden analyzing facts	Attorney-Client Privilege
P-014622	gathered from grand jury investigation and discussing strategy for	Investigative Privilege
	drafting revised indictment	6(e)
		Also contains information subject to
		privacy rights of victims who are not
		parties to this litigation
P-014623	2/25/2008 emails between Marie Villafafta and Caroline Heck Miller	Work Product
thru	regarding ethical issue about whether or not to present proposed revised	Deliberative Process
P-014627	indictment to new grand jury	6(e)
P-014628	2/25/2008 email from Marie Villafafta to Jeff Slornan, Robert Senior,	Work Product
	Rolando Garcia, Karen Atkinson, and Myesha Braden regarding result	Deliberative Process
	of consultation with Caroline Heck Miller about grand jury question	6(e)

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 Villataiia to Myesha Braden regarding	Work Product
	CEOS review and draft indictment package	Deliberative Process
P-014630	2/26/2008 email from Marie Vitiate& to Jeff Slornan regarding Jeff	Work Product
thru	Sloman’s 2/25/2008 correspondence to Jay Lefkowitz further extending	Deliberative Process
P-014631	the plea deadline for Epstein	Investigative Privilege
		6(e)
P-014632	2/21/2008-2/27/2008 emails between Marie Villafafia, David Weinstein,	Work Product
thru	Robert Senior, Karen Atkinson, and Rolando Garcia regarding notifying	Deliberative Process
P-014646	DOD’s Civil Rights Division regarding the status of the case and the	6(e)
	planned indictment, and the draft written notification	Investigative Privilege
P-014647	2/28/2008 emails between Marie Villafafia and Susan Roe regarding	Work Product
thru	related investigation, potential investigatory leads, and CEOS review	Investigative Privilege
P-014649		6(e)
P-014650	2/27/2008-2/28/2008 emails between Marie Villafafia, Nesbitt	Work Product
thru	Kuyrkendall, and Jason Richards regarding review of evidence received	Investigative Privilege
P-014653	pursuant to subpoenas and planned interviews of additional potential	Attorney-client privilege
	victim-witnesses	6(e)
		Also contains information subject to
		privacy rights of victims who are not
		parties to this litigation
P-014654	2/29/2008 emails between Jeff Sloman, Marie Villafafia, Robert Senior,	Work Product
thru	and David Weinstein regarding continuing investigation and status of	Deliberative Process
P-014655	CEOS review	Investigative Privilege
		6(e)
P-014656	3/4/2008-3/5/2008 emails between Nesbitt Kuyrkendall and Marie	Work Product
thru	Villafafia regarding search warrant and victim contact with attorneys	Attorney-client privilege
P-014665		6(e)
		Investigative Privilege
		Also contains information subject to
		privacy rights of victims who are not
		parties to this litigation

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	3/5/2008-3/612008 emails between Marie Villafatia, Alex Acosta, Jeff	Work Product
thru	Sloman, Drew Oosterbaan, Robert Senior, Myesha Braden, Rolando	Deliberative Process
P-014693	Garcia, and Karen Atkinson regarding meeting in DC, additional	6(e)
	information to prepare for meeting, and new information from ongoing investigation	Investigative Privilege
P-014694	3/10/2008-3/12/2008 emails between Marie Villafaila, Robert Senior,	Work Product
thru	Myesha Braden, Krishna Patel, Nesbitt Kuyrkendall, E.J. Yera, and	Deliberative Process
P-014706	Karen Atkinson about Epstein attempts to contact victims and finding counsel for victims	Attorney-client privilege
P-014707	3/12/2008 emails between Marie Villafafia, Drew Oosterbaan, and	Work Product
thru	Myesha Braden regarding CEOS meeting with Epstein counsel
P-014711
P-014712	3/14/2008 emails between Marie Villafafia, Rolando Garcia, Karen	Work Product
thru	Atkinson, Frederica Devlin, and Shawn Ball regarding complete	Deliberative Process
P-014716	indictment package for Robert Senior final review	6(e)
P-014717	3/12/2008-3/17/2008 emails between Marie Villafafla, Nesbitt	Work Product
thru	Kuyrkendall and E.J. Yen regarding search warrant application and	Attorney client privilege
P-014721	execution of search warrant	Investigative Privilege
		Also contains information subject to
		privacy rights of victims who are not
		parties to this litigation
P-014722	3/14/2008-3/17/2008 emails between Marie Villafafia, Nesbitt	Work Product
thru	Kuyrkendall, Jason Richards, and Robert Senior regarding corrections	Deliberative Process
P-014727	to indictment package and proposed grand jury presentation	6(e)
		Attorney-Client Privilege
		Also contains information subject to
		privacy rights of victims who are not
		parties to this litigation

Case 9:08-cv-80736-KAM Document 329-1 Entered on FLED Docket 06/23/2015 Page 16 of 18¶

Bates Range	Description	Privilege(s) Asserted
P-014728	3/14/2008-3/19/2008 emails between Marie Villafafia, Nesibtt	Work Product
thru	Kuyrkendall, Jason Richards, Robert Senior, Jeff Sloman, Karen	Deliberative Process
P-014742	Atkinson, and Rolando Garcia about Epstein attempts to contact victims	Attorney-client privilege
	and finding counsel for victims	Also contains information subject to
		privacy rights of victims who are not
		parties to this litigation
P-014743	3/19/2008-3/21/2008 emails between Marie Villafaila, Drew Oosterbaan	Work Product
thru	(CEOS), Alexandra Gelber (CEOS), Jeff Sloman, and Robert Senior	6(e)
P-014780	about meeting between Esptein counsel and CEOS and follow-up	Deliberative Process
	questions	Investigative Privilege
P-014781	3/19/2008-3/27/2008 emails between Jeff Sloman, Bob Senior, Karen	Work Product
thru	Atkinson, Rolando Garcia, Nesbitt Kurykendall, and Jason Richards	Deliberative Process
P-014800	regarding waiting for DC’s decision regarding Epstein’s challenges to	Investigative Privilege
	NPA; status of ongoing investigation; problems with Epstein’s counsel	6(e)
	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
P-014801	3/28/2008 emails between Marie Villafafia, Nesbitt Kuyrkendall, Jeff	Work Product
thru	Slornan, Robert Senior, and Karen Atkinson regarding status of DC	6(e)
P-014810	review of case and preparing for grand jury presentation	Investigative Privilege
		Deliberative Process
P-014811	3/31/2008 emails between Marie Villafafia, Jeff Slornan, Robert Senior,	6(e)
thru	and Nesbitt Kuyrkendall regarding status of ongoing investigation,	Work Product
P-014829	planned presentation to grand jury, continued delay in awaiting decision	Deliberative Process
	from Washington, DC, and problems with victims being harassed	Investigative Privilege
P-014830	4/2/2008 emails between Marie Villafafia, Alex Acosta, Jeff Sloman,	Deliberative Process
thru	Karen Atkinson, Robert Senior, Rolando Garcia, and Nesbitt	Work Product
P-014837	Kuyrkendall regarding efforts by Jay Lefkowitz and Ken Starr to speak	Attorney-Client Privilege
	with Alex Acosta and instructions to direct question to Marie Villafafia
	and Karen Atkinson

Bates Range	Description	Privilege(s) Asserted
P-014838	4/4/2008-4/7/2008 emails between Marie Villafaila, Robert Senior,	Work Product
thru	Andrew Oosterbaan, and Jeff Sloman regarding status of CEOS review	6(e)
P-014843	of Epstein matter	Deliberative Process
P-014844	4/10/2008-4/18/2008 emails between Marie Villafaiia, Robert Senior,	6(e)
thru	Karen Atkinson, Nesbitt Kuyrkendall, and Jeff Slornan about continued	Work Product
P-014851	delay in presenting case to grand jury due to failure to receive decision	Deliberative Process
	from DC, status of grand jury presentation and ongoing investigation	Investigative Privilege
P-014852	4/11/20084/23/2008 emails between Marie Villafaria, Jeff Sloman, and	Work Product
thru	Dexter Lee regarding self-reporting to OPR false allegations of ethics	Deliberative Process
P-014864	violations	Privacy Act
P-014865	4/29/2008 email from Marie Villafaila to Robert Senior, Jeff Sloman,	Work Product
	Karen Atkins, on Rolando Garcia re grand jury presentation	6(e)
		Deliberative Process
		Investigative Privilege
P-014866	4/21/2008-5/1/2008 emails between Marie Villafatla, Robert Senior, Jeff	6(e)
thru	Sloman, Karen Atkinson, Nesbitt Kuyrkendall, and Drew Oosterbaan	Work Product
P-014883	about continued delay in presenting case to grand jury due to failure to	Deliberative Process
	receive decision from DC, status of grand jury presentation and ongoing	Investigative Privilege
	investigation, staffing of case for purposes of trial, and meeting to
	prepare for grand jury presentation
P-014884	5/2/2008 emails between Robert Senior, Marie Villafaria, Karen	6(e)
thru	Atkinson, Nesbitt Kuyrkendall, and Jason Richards regarding	Work Product
P-014886	developments in Epstein investigation and impact on grand jury	Attorney-Client Privilege
	presentation	Investigative Privilege
		Deliberative Process
P-014887	4/29/2008-5/2/2008 emails between Marie Villafaria and Jeff Sloman	6(e)
thru	regarding contact by Epstein counsel and victims and draft letter to	Work Product
P-014894	counsel for Epstein	Deliberative Process
		Investigative Privilege

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	517/2008-5/912008 emails between Marie Villafaiia, Robert Senior, Jeff	Work Product
thru	Sloman, Nesbitt Kuyrkendall, and Jason Richards regarding awaiting	6(e)
P-014900	approval from DC and status of ongoing investigation	Deliberative Process
		Attorney-Client Privilege
		Investigative Privilege
P-014901	5/15/2008-5/16/2008 emails between Jeff Sloman, Marie Villafaila, and	Work Product
thru	Robert Senior regarding receiving final approval from DC	Deliberative Process
P-014906
P-014907	5/19/2008-5/22/2008 emails between Marie Villafafia, Karen Atkinson,	6(e)
thru	Robert Senior, and Jeff Sloman regarding preparation for grand jury	Work Product
P-014911	presentation; communication with S/A Kuyrkendall regarding plea	Deliberative Process
	negotiations; and status of ongoing investigation	Investigative Privilege
P-014912	5/23/2008-5/27/2008 emails between Marie Villafaiia, Robert Senior,	Work Product
thru	Jeff Sloman, Karen Atkinson, Nesbitt Kuyrkendall (FBI), and Jason	6(e)
P-014919	Richards (FBI) re status of investigation, indictment review, grand jury	Deliberative Process
	preparation, and Epstein’s attempt to revisit plea negotiations	Investigative Privilege
P-014920	8/15/2008 email from Marie Villafaiia to Alex Acosta, Jeff Sloman,	Work Product
thru	Robert Senior, Karen Atkinson, and Dexter Lee containing draft	Deliberative Process
P-014923	response to 8/15/2008 email from Jay Lefkowitz regarding
	implementation of the NPA. (Redacted version produced to opposing
	counsel)