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Case 1:20-cr-00330-PAE Document 293-1 Filed 05/25/21 Page 83 of 349
Menchel made several substantive changes to Villafafia’s draft letter. He specified that “a
two-year term of state imprisonment” wa
Case 1:20-cr-00330-PAE Document 293-1 Filed 05/25/21 Page 76 of 349
Villafafia, Menchel left the meeting after almost no discussion, leaving Villafafia “shocked and
stunned.”
Menchel told OPR that h
Case 1:20-cr-00330-PAE Document 293-1 Filed 05/25/21 Page 75 of 349
D. Acosta Decides on a Resolution That Includes a Two-Year Term of
Incarceration
The next critical step in the development of the
Case 1:20-cr-00330-PAE Document 293-1 Filed 05/25/21 Page 74 of 349
equipment.” After further communications on this issue involving Black, Sanchez, Villafafia, and
Lourie, Black took legal action th
Case 1:20-cr-00330-PAE Document 293-1 Filed 05/25/21 Page 73 of 349
Early in the federal investigation, Villafafia recognized the potential significance of
obtaining the missing computer equipment. V
Case 1:20-cr-00330-PAE Document 293-1 Filed 05/25/21 Page 71 of 349
e-mail that I would like to address, and I also would like to address
where we are in the case.
First, I wanted to address the com
Case 1:20-cr-00330-PAE Document 293-1 Filed 05/25/21 Page 67 of 349
Menchel could not recall who initially suggested a state plea, but noted to OPR that his
own “emails . .. make clear that this cour
Menchel’s reply email began with a rebuke:
Both the tone and substance of your email are totally inappropriate
and, in combination with other matters in the past, it seriously calls
your judgment int
Case 1:20-cr-00330-PAE Document 293-1 Filed 05/25/21 Page 68 of 349
In light of these concerns, Villafafia emailed Menchel, expressing her strong disagreement
with the process:
[I]t is inappropriate
Case 1:20-cr-00330-PAE Document 293-1 Filed 05/25/21 Page 64 of 349
include concurrent time.” The email primarily concerned other issues, and Villafafia did not
explain what the resolution she had in
Case 1:20-cr-00330-PAE Document 293-1 Filed 05/25/21 Page 62 of 349
Lourie opined that the government could argue “that over time [Epstein] set up a network of illegal
high school massage recruits th
Case 1:20-cr-00330-PAE Document 293-1 Filed 05/25/21 Page 60 of 349
for meetings was to cause delay, but “the people in my office either couldn’t see that or didn’t
want to see that,” perhaps because
Case 1:20-cr-00330-PAE Document 293-1 Filed 05/25/21 Page 58 of 349
we are contemplating so Dershowitz can tell us why they don’t apply.”*’ Lourie told Menchel, “I
don’t see the downside,” but added,
Case 1:20-cr-00330-PAE Document 293-1 Filed 05/25/21 Page 59 of 349
opposition to these meetings, but we are simply looking at this case
as a violent crime prosecution involving stiff penalties rathe
Case 1:20-cr-00330-PAE Document 293-1 Filed 05/25/21 Page 5/7 of 349
he is comfortable before proceeding.” Menchel told Villafafia he had “trouble understanding” why
she was in a “rush” “given how lo
Case 1:20-cr-00330-PAE Document 293-1 Filed 05/25/21 Page 56 of 349
Lourie followed up his email to Villafafia with one to Menchel, in which Lourie reiterated
the potential benefits of a pre-indictme
Case 1:20-cr-00330-PAE Document 293-1 Filed 05/25/21 Page 52 of 349
of the state’s victim interviews and partial transcripts provided by defense counsel.** Villafafia
also pursued other investigative
Case 1:20-cr-00330-PAE Document 293-1 Filed 05/25/21 Page 51 of 349
disagreed with her position. Villafafia and a West Palm Beach AUSA with whom she was
consulting about the investigation, and who se
Case 1:20-cr-00330-PAE Document 293-1 Filed 05/25/21 Page 48 of 349
On July 24, 2006, Villafafia alerted Sloman, who informed Acosta, that the State Attorney’s
Office had charged and arrested Epstein
Case 1:20-cr-00330-PAE Document 293-1 Filed 05/25/21 Page 46 of 349
Epstein massages that were sexual in nature, and that Epstein had used “various types of pressure”
to avoid prosecution by the stat
Case 1:20-cr-00330-PAE Document 293-1 Filed 05/25/21 Page 45 of 349
2. May 2006: The USAO Accepts the Case and Opens a Case File
On May 23, 2006, Villafafia prepared the paperwork to open a USAO cas
Case 1:20-cr-00330-PAE Document 293-1 Filed 05/25/21 Page 43 of 349
other things, prohibit anyone from being present while grand jurors deliberate and vote, and
proscribe the release of the notes, re
Case 1:20-cr-00330-PAE Document 293-1 Filed 05/25/21 Page 41 of 349
they found computer monitors and keyboards in the home, as well as disconnected surveillance
cameras, but the computer equipment it
Timeline of Key Events for Federal Epstein Investigation — May 2006 through October 2008
Oo Sa
tT Acosta, Sloman, Villafaiia May 19 ~ Epstein’s counse! sends
~ +others] meet with Epstein’s counsel le
Case 1:20-cr-00330-PAE Document 293-1 Filed 05/25/21 Page 35 of 349
Wk. JEFFREY EPSTEIN AND HIS DEFENSE ATTORNEYS
A. Jeffrey Epstein
Jeffrey Epstein was born in Brooklyn, New York, in 1953.4 Althoug
Case 1:20-cr-00330-PAE Document 293-1 Filed 05/25/21 Page 37 of 349
[Page Intentionally Left Blank]
10
DOJ-OGR- 00004334
Page 34 of 349
Filed 05/25/21
Document 293-1
Case 1:20-cr-00330-PAE
United States Attorney
First Assistant
United States Attorney
Criminal Chief
Managing Assistant
United States Attorney
West P
Page 30 of 349
Filed 05/25/21
Document 293-1
Case 1:20-cr-00330-PAE
SOLICITOR
GENERAL
OFFICE OF THE
SOLICITOR
GENERAL
OFFICE OF
JUSTICE
PROGRAMS
OFFICE OF
INFORMATION
AND PRIVACY
EXECUTIVE
‘OF
Case 1:20-cr-00330-PAE Document 293-1 Filed 05/25/21 Page 25 of 349
B. July 7, 2008: The CVRA Litigation Is Initiated ......... eee eeceeeeeeeeeeeeeeeeeeeneeees 236
Cc. July 2008: Villafafia Prepares
Case 1:20-cr-00330-PAE Document 293-1 Filed 05/25/21 Page 27 of 349
[Page Intentionally Left Blank]
XXIV
DOJ-OGR- 00004324
Case 1:20-cr-00330-PAE Document 293-1 Filed 05/25/21 Page 23 of 349
CHAPTER THREE: ISSUES RELATING TO THE GOVERNMENT’S INTERACTIONS
AND COMMUNBTCATIONS WITTE VICTIMS ercnecnmares smmamescomsns sarmm
Case 1:20-cr-00330-PAE Document 293-1 Filed 05/25/21 Page 22 of 349
D. OPR Does Not Find That the Subjects’ Preexisting Relationships with
Defense Counsel, Decisions to Meet with Defense Counsel, and
Case 1:20-cr-00330-PAE Document 293-1 Filed 05/25/21 Page 17 of 349
I. THE FBI AND THE USAO INVESTIGATE EPSTEIN, AND THE
DEFENSE TEAM ENGAGES WITH THE USAO wesssosseses scsssesnsssneons senssounesat
Case 1:20-cr-00330-PAE Document 293-1 Filed 05/25/21 Page 13 of 349
initiate a federal prosecution of Epstein was within the scope of his authority, and OPR did not
find evidence that his decision wa
Case 1:20-cr-00330-PAE Document 293-1 Filed 05/25/21 Page 14 of 349
interactions with victims that ultimately led to public and court condemnation of the government’s
treatment of the victims, reflec
Case 1:20-cr-00330-PAE Document 293-1 Filed 05/25/21 Page 12 of 349
of immunity, or (6) the deportation of criminal aliens. The potentially applicable standards that
OPR considered as to each of thes
Case 1:20-cr-00330-PAE Document 293-1 Filed 05/25/21 Page 9 of 349
an investigation into the matter and would review the USAO’s decision to resolve the federal
investigation of Epstein through the NP
Case 1:20-cr-00330-PAE Document 293-1 Filed 05/25/21 Page 6 of 349
Soon after he was incarcerated, Epstein applied for the Palm Beach County Sheriff’s work
release program, and the Sheriff approved h
Case 1:20-cr-00330-PAE Document 293-1 Filed 05/25/21 Page 3 of 349
DOJ-OGR-00004300
Case 1:20-cr-00330-PAE Document 293-1 Filed 05/25/21 Page 1 of 349
Exhibit A
DOJ-OGR- 00004298
Case 1:20-cr-00330-PAE Document 293 Filed 05/25/21 Page 31 of 32
Bobbi C. Sternheim
Law Offices of Bobbi C. Sternheim
33 West 19th Street - 4th Floor
New York, NY 10011
Phone: 212-243-1100
Attorne
Case 1:20-cr-00330-PAE Document 293 Filed 05/25/21 Page 22 of 32
1994) (reversal of conviction may be required due to “prejudicial spillover” in cases in which the
jury relies on inadmissible evidenc
Case 1:20-cr-00330-PAE Document 293 Filed 05/25/21 Page 4 of 32
United States v. Lopez,
356 F.3d 463 (2d Cir, 2004). oo... cecccccecececcesceseeeseeeseceseenseeseeceeeeeesecnaeenaeeeeeseeneeseenaees
Case 1:20-cr-00330-PAE Document 293 Filed 05/25/21 Page 3 of 32
TABLE OF AUTHORITIES
Page(s)
Cases
Clemmons vy. Delo,
124 F.3d 944 (8th Cir, 1997) ooo. ccccecccesecesecesececseecsecseeesseecsesese
Case 1:20-cr-00330-PAE Document 292 Filed 05/25/21 Page2of2
Denver, Colorado 80203
Phone: 303-831-7364
Bobbi C. Sternheim
Law Offices of Bobbi C. Sternheim
33 West 19th Street - 4th Floor
New York,
Case 1:20-cr-00330-PAE Document 291 Filed 05/21/21 Page11of13
Page 11
conspirator statements when they are not produced until after the in limine deadline has
passed.
District judges in this Circui
Case 1:20-cr-00330-PAE Document 291 Filed 05/21/21 Page7of13
Page 7
“premature” because the defense had not yet decided whether to call the expert and explaining that
“Talllowing [the] defendant to
Case 1:20-cr-00330-PAE Document 291 Filed 05/21/21 Page4of13
Page 4
See, e.g., United States v. Kaufman, 19 Cr. 504 (LAK), Dkt. No. 175 (S.D.N.Y. Feb. 22, 2021)
(ordering Government disclosure of Je
Case 1:20-cr-00330-PAE Document 289 _ Filed 05/21/21 Page 2of2
The Honorable Alison J. Nathan
May 21, 2021
Page 2
the common law and First Amendment. Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110,
Case 1:20-cr-00330-PAE Document 287-1 Filed 05/20/21 Pageiof1
Exhibit A
(Filed Under Seal)
DOJ-OGR- 00004244