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Case 1:20-cr-00330-PAE Document 204-3 Filed 04/16/21 Page 202 of 348 search warrant was executed on that property, the computer equipment associated with those cameras had been removed. Villafafia knew who had possession of the computer equipment. Surveillance images might have shown the victims’ visits, and photographic evidence of their appearance at the time of their encounters with Epstein could have countered the anticipated argument that Epstein was unaware these girls were minors. The surveillance video might have shown additional victims the investigators had not yet identified. Such images could have been powerful visual evidence of the large number of girls Epstein victimized and the frequency of their visits to his home, potentially persuasive proof to a jury that this was not a simple “solicitation” case. Epstein’s personal computers possibly contained even more damning evidence. Villafafia told OPR that the FBI had information that Epstein used hidden cameras in his New York residence to record his sexual encounters, and one victim told agents that Epstein’s assistant photographed her in the nude. Based on this evidence, and experience in other sex cases involving minors, Villafafia and several other witnesses opined to OPR that the computers might have contained child pornography. Moreover, Epstein lived a multi-state lifestyle; it was reasonable to assume that he may have transmitted still images or videos taken at his Florida residence over the internet to be accessed while at one of his other homes or while traveling. The interstate transmission of child pornography was a separate, and serious, federal crime that could have changed the entire complexion of the case against Epstein.*°? Villafafia told OPR, “[I]f the evidence had been what we suspected it was . . . [i]t would have put this case completely to bed. It also would have completely defeated all of these arguments about interstate nexus.” Because she recognized the potential significance of this evidence, Villafafia attempted to obtain the missing computers. After Villafafia learned that an individual associated with one of Epstein’s attorneys had possession of the computer equipment that was removed from Epstein’s home, she consulted with Department subject matter experts to determine how best to obtain the evidence. Following the advice she received and after notifying her supervisors, Villafafia took legal steps to obtain the computer equipment. Epstein’s team sought to postpone compliance with the USAO’s demand for the equipment. In late June 2007, defense attorney Sanchez requested an extension of time to comply; in informing Sloman, Menchel, and Lourie of the request, Villafafia stressed that ““we want to get the computer equipment that was removed from Epstein’s home prior to the state search warrant as soon as possible.” She agreed to extend the date for producing the computer equipment by one week until July 17, 2007. On that day, Epstein initiated litigation regarding the computer equipment. That litigation was still pending at the end of July, when Acosta decided to resolve 2 18 U.S.C. § 2251(a) provides, in pertinent part: Any person who .. . induces . . . any minor to engage in. . . any sexually explicit conduct for the purpose of producing any visual depiction of such conduct, shall be punished . . . if such person knows or has reason to know that such visual depiction will be . . . transmitted using any means or facility of interstate .. . commerce or in or affecting interstate ... commerce . . . [or] if that visual depiction was produced or transmitted using materials that have been mailed, shipped, or transported in or affecting interstate or .. . commerce by any means, including by computer. 176 DOJ-OGR- 00003378