EFTA00193598

Villafana, Ann Marie C. (USAFLS)

<table><thead><tr><th>From:</th></tr></thead><tbody><tr><td>Sent:</td></tr><tr><td>To:</td></tr><tr><td>Subject:</td></tr></tbody></table>

Villafana, Ann Marie C. (USAFLS)

Thursday, July 31, 2008 9:20 AM

Lee, Dexter (USAFLS)

Re: Got your message

Hi Dexter. I thought Judge Marra required it to be filed but it has not been filed so they may have just "produced" it in discovery. Tein filed something under seal a couple of days ago but obviously I don't know what it was. A different plaintiff's attorney called me on Tuesday and asked if he could get a copy and I said no. I would ask Jeff how he wants to handle.

<table><tr><td>----- Original Message -----</td></tr><tr><td>From: Lee, Dexter (USAFLS)</td></tr><tr><td>To: Villafana, Ann Marie C. (USAFLS)</td></tr><tr><td>Cc: Acosta, Alex (USAFLS); Sloman, Jeff (USAFLS); Jacobus, Wendy (USAFLS)</td></tr><tr><td>Sent: Wed Jul 30 21:29:23 2008</td></tr><tr><td>Subject: RE: Got your message</td></tr></table>

Marie,

As I understand it, the USAO-Epstein agreement has a confidentiality provision. It was filed under seal in state court. I seem to recall you telling me that Judge Marra ordered Michael Tein to file the agreement in the pending federal court civil actions under 18 U.S.C. 2255. Is that not correct? My impression from speaking with Edwards is that, if he is satisfied the agreement adequately punishes Epstein and protects his clients, then he will withdraw his lawsuit. If we are not in a position to produce the agreement, then we won’t be able to adequately address his concerns.

I filed our notice to court on Tuesday night. Edwards is in a real hurry to try to resolve this matter before the court acts on the notice. I wonder if he thinks Judge Marra will not hold another hearing and rule on the papers.

I will call you tomorrow morning. Thanks.

Dexter

<table><tr><td>From: Villafana, Ann Marie C. (USAFLS)</td></tr><tr><td>Sent: Wednesday, July 30, 2008 1:53 PM</td></tr><tr><td>To: Lee, Dexter (USAFLS)</td></tr><tr><td>Subject: Got your message</td></tr></table>

Hi Dexter - As far as I know, the only place where the agreement has been filed is under seal in the state court. I don’t think we could provide it without a subpoena or court order.

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