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# UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA

## CASE NO. 08-80736-CIV-MARRA

JANE DOE #1 and JANE DOE #2,

Petitioners.

vs.

UNITED STATES OF AMERICA,

Respondents.

# UNITED STATES OF AMERICA’S RESPONSE TO PETITIONERS’ REQUEST FOR PRODUCTION

Respondent United States of America, in response to petitioners’ Request for Production, submits the following:

## Request for Production No. 1:

(a) FBI Case File on the Epstein case (P).

(b)

(c)

(d) Prosecution Memorandum, “Operation Leap Year,” May 1, 2007 (82 pages), Author: A. Marie Villafana. Addressees: R. Alexander Acosta, United States Attorney; Jeff Sloman, First Assistant U.S. Attorney; Matthew Menchel, Chief, Criminal Division; Andrew Lourie; Managing Assistant U.S. Attorney, Northern Region; and Karen Atkinson, Chief, Northern Region. (P).

Draft Indictment (54 pages)(P).

(e) Draft indictments (P)

## Request for Production No. 2:

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Rights (2 pages); Author: A. Marie Villafana.

Letter to R. Alexander Acosta, dated December 26, 2007, RE: Jeffrey Epstein (5

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pages), Author: Jay Lefkowitz

Request for Production No. 3 (confidentiality provision)

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E-mail, Jay Lefkowitz to Marie Villafana, dated September 23, 2007 8:39 p.m., RE: no subject (2 pages)

E-mail, Marie Villafana to Jay Lefkowitz, dated September 23, 2007 8:58 p.m., RE: Epstein Agreement (1 page with 6 page draft Non-Prosecution Agreement attached)

E-mail, Jay Lefkowitz to Marie Villafana, dated September 24, 2007 7:54 a.m., RE: Epstein (1 page)

E-mail, Marie Villafana to Jay Lefkowitz, dated September 24, 2007 10:14 a.m., RE: Epstein agreement as reviewed by the U.S. Attorney (1 page with 6 page draft Non-Prosecution Agreement attached)

E-mail, Jay Lefkowitz to Marie Villafana, dated September 24, 2007 11:46 a.m., RE: Epstein agreement as reviewed by the U.S. Attorney (1 page with 6 page Non-Prosecution Agreement, and 8 page Non-Prosecution Agreement, attached)

E-mail, Marie Villafana to Jay Lefkowitz, dated September 24, 2007 1:28 p.m., RE: Epstein agreement as reviewed by the U.S. Attorney (3 pages with 7 page draft Non-Prosecution Agreement attached)

E-mail, Marie Villafana to Jay Lefkowitz, dated September 24, 2007 2:16 p.m., RE: The final final (1 page with 7 page Non-Prosecution Agreement attached)

E-mail, Jay Lefkowitz to Marie Villafana, dated September 24, 2007 4:06 p.m., RE: Do you have a signed copy? (1 page with 9 page Non-Prosecution Agreement attached)

E-mail, Marie Villafana to Jay Lefkowitz, dated September 24, 2007 4:03 p.m., RE: Do you have a signed copy? (1 page)

E-mail, Marie Villafana to Jay Lefkowitz, dated September 24, 2007 4:32 p.m., RE: Do you have a signed copy? (1 page)

Request for Production No. 5 (legal representation of victims)

E-mail, Marie Villafana to Jay Lefkowitz, dated September 25, 2007 8:37 p.m., RE: Other attorneys (1 page)

E-mail, Marie Villafana to Jay Lefkowitz, dated September 26, 2007 11:01 a.m., RE: Other attorneys (2 pages)

E-mail, Marie Villafana to Jay Lefkowitz, dated September 26, 2007 11:49 a.m., RE: One more thing (2 pages)

E-mail, Marie Villafana to Jay Lefkowitz, dated September 27, 2007 10:52 a.m., RE Conference Call with Bert Ocariz (1 page)

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E-mail, Jay Lefkowitz to Marie Villafana, dated September 27, 2007 10:57 a.m., RE: Conference call with Bert Ocariz (2 pages)

E-mail, Marie Villafana to Jay Lefkowtiz, dated September 27, 2007 11:08 a.m., RE: Conference Call with Bert Ocariz (2 pages)

E-mail, Marie Villafana to Jay Lefkowitz, dated September 27, 2007 3:06 p.m., RE: Conference Call with Bert Ocariz (3 pages)

E-mail, Marie Villafana to Jay Lefkowitz, dated October 3, 2007 3:15 p.m., RE: no subject (2 pages, with 1 page Special Master Proposal attached)

E-mail, Marie Villafana to Jay Lefkowitz, dated October 3, 2007 3:38 p.m., RE: no subject (2 pages)

E-mail, Marie Villafana to Jay Lefkowitz, dated October 3, 2007 4:23 p.m., RE: Proposed Letter to Special Master (2 pages with 2 page Proposed Letter to the Special Master attached)

E-mail, Marie Villafana to Jay Lefkowitz, dated October 3, 2007 7:30 p.m., RE: Proposed Letter to Special Master (1 page)

E-mail, Marie Villafana to Jay Lefkowitz, dated October 5, 2007 7:49 p.m., RE: Proposed Letter to Special Master (2 pages)

E-mail, Jay Lefkowitz to Marie Villafana, dated October 5, 2007 11:04 a.m., RE: Proposed Letter to Special Master (3 pages with 4 page letter from Jay Lefkowitz to Marie Villafana attached)

Letter to Jeffrey Sloman, dated October 8, 2007, RE: Jeffrey Epstein (3 pages), Author: Lilly Ann Sanchez

E-mail, Marie Villafana to Lilly Ann Sanchez, October 9, 2007 5:09 p.m., RE: Jeffrey Epstein (1 page with two page letter to Lilly Ann Sanchez attached)

E-mail, Jeff Sloman to Jay Lefkowitz, dated October 22, 2007 4:41 p.m., RE: Epstein (3 pages with 4 page draft letter to Hon. Edward B. , and 2 page Addendum to the Non-Prosecution Agreement, attached)

E-mail, Jay Lefkowitz to Jeff Sloman, dated October 22, 2007 5:10 p.m., RE: Epstein (3 pages)

E-mail, Jeff Sloman to Jay Lefkowitz, dated October 24, 2007 3:45 p.m., RE: Epstein – Addendum and Letter to Judge (2 page Addendum to the Non-Prosecution Agreement, and 4 page draft letter to Hon. Edward B. , attached)

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E-mail, Jeff Sloman to Jay Lefkowitz, dated October 24, 2007 5:30 p.m., RE: Epstein – Letter to Judge (1 page with 4 page letter to Hon. Edward B. attached)

Letter to Hon. Edward B. Akerman Senterfitt, dated October 25, 2007, RE: Service as a Special Master (4 pages); Author: Jeff Sloman

E-mail, Jeff Sloman to Jay Lefkowitz, dated October 31, 2007 11:51 a.m., RE: Epstein (2 pages)

E-mail, Jay Lefkowitz to Jeff Sloman, dated November 8, 2007 1:24 p.m., RE: No subject(1 page)

E-mail, Jay Lefkowitz to Jeff Sloman, dated November 16, 2007 2:00 p.m., RE: No subject(1 page)

E-mail, Jeff Sloman to Jay Lefkowitz, dated November 27, 2007 1:55 p.m., RE: Epstein (1 page)

Letter to Jeffrey Sloman, dated December 7, 2007, RE: Jeffrey Epstein, Author: Lilly Ann Sanchez (1 page Affirmation signed by Jeffrey E. Epstein, 1 page Notice of Hearing, and 1 page fax transmittal sheet, attached)

E-mail, Marie Villafana to Jack Goldberger, dated June 28, 2008 11:31 a.m., RE: Notice of Non-Compliance (1 page)

## Request for Production No. 8 (Lobbying efforts at DOJ)

E-mail, Jeff Sloman to Jay Lefkowitz, dated February 25, 2008 7:43 p.m., RE: Epstein (1 page)

E-mail, Jeff Sloman to Jay Lefkowitz, dated February 27, 2008 9:45 p.m., RE: Fw: Epstein (2 pages)

Letter to Jay Lefkowitz, Esq., dated May 15, 2008, RE: Investigation of Jeffery Epstein (5 pages), Author: Andrew G. Oosterbaan, Chief, Child Exploitation and Obscenity Section, Criminal Division, U.S. Department of Justice

E-mail, Jay Lefkowitz to Alex Acosta, dated May 19, 2008 10:54 a.m., RE: confidential communication (3 pages)

Letter to Honorable Mark Filip, Deputy Attorney General, dated May 19, 2008, No Subject (8 pages), Authors: Kenneth W. Starr, Kirkland & Ellis, and Joe D. Whitley, Alston & Bird

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Letter to Honorable Mark Filip, Deputy Attorney General, dated May 27, 2008, No Subject (2 pages), Authors: Kenneth W. Starr, Kirkland & Ellis, and Joe D. Whitley, Alston & Bird

E-mail, Jeff Sloman to Jay Lefkowtiz, dated May 28, 2008 4:51 p.m., RE: Jeffrey Epstein (1 page)

Letter to Kenneth Starr and Joe D. Whitley, dated June 3, 2008, No Subject (1 page), Author: John Roth, Senior Associate Deputy Attorney General

Letter to John Roth, Senior Associate Deputy Attorney General, dated June 19, 2008, No Subject (14 pages), Author: Stephanie D. Thacker, Allen Guthrie McHugh & Thomas, Charleston, West

Letter to Jay Lefkowitz and Kennth Starr, dated June 23, 2008, No Subject (1 page), Author: John Roth, Senior Associate Deputy Attorney General

Request for Production No. 19: (prosecutor misconduct)

Letter to R. Alexander Acosta, dated December 11, 2007, RE: Jeffrey Epstein (20 pages); Author: Jay Lefkowitz

Letter to Jay P. Lefkowitz, Esq., dated December 13, 2007, RE: Jeffrey Epstein (5 pages); Author: A. Marie Villafana.

E-mail, Jay Lefkowitz to Alex Acosta, dated February 29, 2008 3:11 p.m., RE: Fw Epstein (1 page)

Letter to Office of Professional Responsibility, U.S. Department of Justice, dated April 21, 2008, RE: Self Reporting – Jeffrey H. Sloman, FAUSA S.D.F.L. (3 pages, with 5 pages of attachments); Author: Jeffrey H. Sloman (P)

Letter to Office of Professional Responsibility, U.S. Department of Justice, dated April 22, 2008, RE: Self-Report of Allegation of Conflict of Interest (9 pages); Author: A. Marie Villafana (P)

Memorandum to Office of Professional Responsibility, dated April 23, 2008, Subject: Self Reporting – Jeffrey H. Sloman, Corrected Version of the previously submitted April 21, 2008 letter to OPR (1 page, with 3 page letter attached); Author: Jeffrey H. Sloman (P)

Letter to Deputy Attorney General Mark Filip, dated May 19, 2008, No Subject, Authors: Kenneth W. Starr and Joe D. Whitley, attachment entitled “Summary of Misconduct Issues in the Matter of Jeffrey Epstein”

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