Epstein Secrets

in favor of prosecution by the State of Florida . . . ." See In re: Jane Doe, Case No. 08- 80736-CIV-Marra/Johnson (S.D. Fla.) (D.E. 14), Decl. of AUSA Villafana, 07/09/08, ¶ 5, attached hereto as Exhibit "A" (emphasis added). Under the Agreement, the USAO presently retains the continuing right to indict Mr

would have had, if Mr. Epstein 'The undersigned does not know when Mr. Edwards began representing T.M. or whether T.M. ever formally terminated Mr. Eisenberg's representation. -3- EFTA00233853 Case 9:08-cv-80811-KAM Document 33 Entered on FLSD Docket 01/07/2009 Page 24 of 41 Case 9:08-cv-80736-KAM

y Edwards' other client, T.M., was represented by counsel and, accordingly, all contact with T.M. was made through that attorney. That attorney was James Eisenberg, and his fees were paid by Jeffrey Epstein, the target of the investigation.' 5. In the summer of 2007, Mr. Epstein and the U.S. Attorney's Office

To the extent that the Government is going to rely on representations about its internal motivations in making certain decisions (i.e., what things AUSA Villafana and the FBI agents "concluded" as part of making decisions), the victims respectfully request an opportunity to depose or cross-examine the relevan

nment's non- prosecution agreement with Epstein and the Government does not cite any evidence suggesting otherwise. 13. Admitted to the extent that James Eisenberg, Esq., represented Jane Doe 2 during a specific time during part of the federal criminal investigation of Epstein, and otherwise denied. 3 EFTA007

in favor of prosecution by the State of Florida . . . ." See In re: Jane Doe, Case No. 08- 80736-CIV-Marra/Johnson (S.D. Fla.) (D.E. 14), Decl. of AUSA Villafana, 07/09/08, ¶ 5, attached hereto as Exhibit "A" (emphasis added). Under the Agreement, the USAO presently retains the continuing right to indict Mr

would have had, if Mr. Epstein 'The undersigned does not know when Mr. Edwards began representing T.M. or whether T.M. ever formally terminated Mr. Eisenberg's representation. 09112/2019 CONFIDENTIAL Agency to Agency Requet: 19-011 SDNY_GM_00331560 EFTA_00204286 EFTA02729277 Case 9:08-cv-80811-KAM