Epstein Secrets

M Document 9 Entered on FLSD Docket 07/1' 3 Page 13 of 17 some right to specific performance of an illegal non-prosecution agreement. See Saner. Garcia, 582 N.W.2d 879 (Minn. 1998) (plea agreement for 81 months sentence, but court added 10-year conditional release term because, under facts of case,

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

Entered on FLSD Docket 02/10/2016 Page 2 of 2 (USAFLS) From: (USAFLS) Sent: on ay, september 1 , 2007 1:09 PM To: [email protected] Cc: Garcia, Rolando (USAFLS) Subject: My whereabouts Hi Jay — I am headed home. If a document is ready to be reviewed later today, can you send a copy to me

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

874 Through P-013875 Inadvertently marked as privileged, will be produced Suppl. Box 3 P-013876 Thru P-013877 E-mail, Villafana to Louric, Garcia, and Atkinson, September 19, 2007, 4:33 p.m., RE: Draft Plea Agreement, with e-mail from Lefkowitz to Villafana (September 19, 2007, 3:44 p.m

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

n Marie C. (USAFLS) Sent: Monday, July 14, 2008 8:57 AM To: [email protected] Subject: Inquiry regarding one of your clients Dear Mr. Garcia — I saw reported in the news that you arc representing one or more victims who are filing suit against Jeffrey Epstein. Can you contact me at your

torneys and the confidentiality clause in the Agreement. Edwards waived any protection for his clients, two of whom were present in court (C.W. and T.M.) As to the confidentiality, the court found that the discussions regarding the potential impeachment of the victims because of the availability of

Villafana, Ann Marie C. (USAFLS) From: Villafana, Ann Marie C. (USAFLS) Sent: Wednesday, September 19, 2007 4:33 PM To: Lourie, Andrew; Garcia, Rolando (USAFLS) Cc: Atkinson, Karen (USAFLS) Subject: RE: Draft Plea Agreement Importance: High Andy and Rolando -- This is my proposed resp

o. 2: (a) Letter to Miss C.W., dated June 7, 2007, RE: Crime Victims' and Witnesses' Rights (2 pages); Author: A. Marie Villafana. Letter to Miss T.M., dated August 11, 2006, RE: Crime Victims' and Witnesses' 1 EFTA00191186 Rights (2 pages); Author: A. Marie Villafana. Letter to C.W., dated Jan