Epstein Secrets

AM Document 13 Entered on FLSD Docket 07/' )8 Page 8 of 8 to her any information that he wished her to consider. Nothing was provided. Id. AUSA Villafafia also told Mr. Edwards he could contact the State Attorney's Office, if he wished. To her knowledge, Mr. Edwards did not make the contact. The Gover

d to Bradley Edwards' three clients, T.M., C.W., and S.R.' Your Affiant's letter to C.W. was provided by the FBI. (Ex. 1). Your Affiant's letter to T.M. was hand-delivered by myself to T.M. at the time that she was interviewed (Ex. 2).? Both C.W. and T.M. also received letters from the FBI's Victim-

se the U.S. Attorney's modification limited Epstein's liability to victims whom the United States was prepared to name in an indictment. In light of T.M.'s prior statements to law enforcement, your Affiant could not in good faith include T.M. as a victim in an indictment and, accordingly, could not i

victim by both the FBI Victim-Witness Specialist and AUSA Villafafia. Id., 3. Petitioner's counsel, Brad Edwards, Esq., currently represents C.W., T.M., and S.R. The U.S. Attorney's Office victim notification letter to C.W. was provided by the FBI. and the letter to T.M. was hand-delivered by AUSA V

m to Alex Acosta, Work Product Deliberative Process and regarding state cases mentioned by Epstein's counsel P-014443 12/14/2007 email from Villafafia to Alex Acosta, , and with draft letters to State Attome 's Office and victims Work Product Deliberative Process P-014444 12/17/2007 email fr

t response to Jay Leflcowitz and victim notification letters Work Product Deliberative Process P414355 thru P-014361 12/3/2007 emails between Villafafia, Alex Acosta, and Work Product Deliberative Process regarding history of plea negotiations and drafting response to correspondence from Jay Lekow

with Ken Starr P-014440 12/11/2007 email from to and Alex Acosta Work Product Deliberative Process regarding call with lawyer for Jane Doe #2 (T.M.) P-014441 12/12/2007 emails between and Work Product Deliberative Process 6(e) regarding planning indictment review P-014442 12/14/2007 em

of these 39 pages is: "File folder entitled 'CORR RE GJ SUBPOENAS' containing correspondence related to various grand jury subpoenas and attorney (Villafafia) handwritten notes." 64. Another good illustration of the inadequacies of the privilege log is provided on page 20 of the first privilege log, with

to Bradley Edwards' three clients, T.M.. C.W., and S.R.' Your Affiant's letter to C.W. was provided by the FBI. (Ex. I ). Your Affiant's letter to T.M. was hand-delivered by myself to T.M. at the time that she was interviewed (Ex. 2).= Both C.W. and T.M. also received letters from the FBI's Victim-

se the U.S. Attorney's modification limited Epstein's liability to victims whom the United States was prepared to name in an indictment. In light of T.M.'s prior statements to law enforcement, your Affiant could not in good faith include T.M. as a victim in an indictment and, accordingly, could not i

to this litigation Box #1 P-001008 thru P-001056 File folder entitled "Notes from Fed Ex Records" containing handwritten and typed attorney (Villafafia) notes and screen shots of FedEx subpoena response electronic file Work Product 6(e) Contains information subject to investigative privilege. A

parties to this litigation 59 12/11/2007 email from Marie Villafafia to Jeff Sloman and Alex Acosta regarding call with lawyer for Jane Doe #2 (T.M.) Work Product Deliberative Process 60 12/3/2007 emails between Marie Villafatta, Alex Acosta, and Jeff Sloman regarding history of plea negotia

the victims $50,000 damages under § 2255? Thank you for any clarification you can provide on these questions. Sincerely, BE/sg Brad Edwards cc: Ann Marie C. Villafafia, AUSA United States Attorney's Office 500 South Australian Avenue West Palm Beach, Florida 33401 2028 HARRISON 8TREXT,SUITE 202, HOLLYWOOD, FLORI

n conviction, would not require sex offender registration. 3. Jane Doe #1 is a woman with initials C.W., and Jane Doe #2 is a woman with initials T.M. Both were victims of Epstein's while they were minors beginning when they were fifteen years old. Both Jane Does were identified through the Palm Be

edi-te-disesss what-I-may-diselese-to,the-gek-regarding-the-agreemenWl-U:SrAnemeyls-Cerrespondenee at-1-56: 13. On about September 26, 2007, AUSA. Villafafia sent an e-mail to Lefkowitz, a copy of which is attached hereto as Exhibit in-whielt-she-etatedailiay—Can-you-give-me-a-eall at-564-209--Enentl-th

upon conviction, did not require sex offender registration. 3. Jane Doe #1 is a woman with initials C.W., and Jane Doe #2 is a woman with initials T.M. Both were victims of Epstein's while they were minors beginning when they were fifteen years old. Both Jane Does were identified through the Palm Be