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ion. Pro bono counsel was able to assist Jane Doe No. I in avoiding the improper deposition. AUSA Villafafla secured pro bono counsel by contacting Meg Garvin, Esq. of the the National Crime Victims' Law Center in Portland, Oregon, which is based in the Lewis & Clark College of Law. During the call, Ms. G
n, Esq. of the the National Crime Victims' Law Center in Portland, Oregon, which is based in the Lewis & Clark College of Law. During the call, Ms. Garvin was not advised that a non-prosecution agreement had been reached in this matter. 87. On May 30, 2008, another one of my clients who was recognized
on May 30, 2008 (Ex. 5). 4. Throughout the investigation, the Fill agents, the FBI's Victim-Witness Specialist, and your A ffiant had contact with C.W. and S.R. Attorney Edwards' other client. T.M., was represented by counsel and, accordingly. all contact with T.M. was made through that attorney. T
ss Specialist. Attached hereto arc copies of the letters provided 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).
al investigation. Pro bono counsel was able to assist Jane Doe #1 in avoiding the improper deposition. AUSA secured pro bono counsel by contacting Meg Garvin, Esq. of the the National Crime Victims' Law Center in Portland, Oregon, which is based in the Lewis & Clark College of Law. During the call, Ms. G
n, Esq. of the the National Crime Victims' Law Center in Portland, Oregon, which is based in the Lewis & Clark College of Law. During the call, Ms. Garvin was not advised that a non-prosecution agreement had been reached in this matter. 34. In mid-June 2008, Mr. Edwards contacted AUSA to inform her t
f Epstein's attorneys (and apparently acceded to by the U.S. Attorney's Office). Second, Ms. had EFTA00206710 said that "four victims [including C.W. — i.e., Jane Doe #1] were contacted and these provisions were discussed," it was not clear what provisions had in fact been discussed. 46. On Decem
al investigation. Pro bono counsel was able to assist Jane Doe #1 in avoiding the improper deposition. AUSA secured pro bono counsel by contacting Meg Garvin, Esq. of the the National Crime Victims' Law Center in Portland, Oregon, which is based in the Lewis & Clark College of Law. During the call, Ms. G
n, Esq. of the the National Crime Victims' Law Center in Portland, Oregon, which is based in the Lewis & Clark College of Law. During the call, Ms. Garvin was not advised that a non-prosecution agreement had been reached in this matter. 34. In mid-June 2008, Mr. Edwards contacted AUSA to inform her t
f Epstein's attorneys (and apparently acceded to by the U.S. Attorney's Office). Second, Ms. had EFTA00206747 said that "four victims [including C.W. — i.e., Jane Doe #1] were contacted and these provisions were discussed," it was not clear what provisions had in fact been discussed. 46. On Decem
ncluding the October and December addenda; copies of any FBI 302 prepared after the CW meeting; and the substance of the conversation Marie had with Meg Garvin, Esq., who she asked to assist one of victims who was being harassed by Epstein's attorneys. Rather than engage in a point by point response to Edw
regard to C.W., FBI Special Agents Kuyrkendall and Richardson met with her in September 2007 to advise her of the agreement reached in state court. C.W. claims she understood them to mean the federal proceeding was still a possibility. I think we have little to gain by trying to reach an agreement o
n evidentiary hearing is necessary. We don't dispute that none of the victims were notified of the impending agreement with Epstein. With regard to C.W., FBI Special Agents Kuyrkendall and Richardson met with her in September 2007 to advise her of the agreement reached in state court. C.W. claims she
in, Esq. of the National Crime Victims' Law Institute in Portland, Oregon, which is based in the Lewis & Clark College of Law. During the call, Ms. Garvin was not advised about the Non-Prosecution Agreement. In mid-June 2008, Mr. Edwards contacted Assistant U.S. Attorney Villafafia to inform her that
n FLSD Docket 08/C i8 Page 7 of 16 assist Jane Doe #1 in avoiding the improper deposition. AUSA Villafafia secured pro bono counsel by contacting Meg Garvin, Esq. of the National Crime Victims' Law Institute in Portland, Oregon, which is based in the Lewis & Clark College of Law. During the call, Ms. Ga
r victims [including C.W.] were contacted and these provisions were discussed" (emphasis added). Similarly at page 5, the declaration states: "After C.W. had been notified of the terms of the agreement ....." (emphasis added). I write to inquire whether, in view of the fact that the provision noted a
n, Esq. of the the National Crime Victims' Law Center in Portland, Oregon, which is based in the Lewis & Clark College of Law. During the call, Ms. Garvin was not advised that a non-prosecution agreement had been reached. 35. On May 30, 2008, another of Mr. Edwards's clients who was recognized as an a
Doe #1. Pro bono counsel was able to assist Jane Doe #1 in avoiding the improper deposition. AUSA Villafaila secured pro bono counsel by contacting Meg Garvin, Esq. of the the National Crime Victims' Law Center in Portland, Oregon, which is based in the Lewis & Clark College of Law. During the call, Ms. G
eference to the ages of the minor victims and, 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. Bo
Entities connected to both Meg Garvin and C.W.

Bradley Edwards
PERSON
George W. Bush
PERSON
A. Marie Villafana
PERSON
Jeffrey Epstein
PERSON
Dexter Lee
PERSON
Alexander Acosta
PERSONT.M.
PERSON
Kenneth Marra
PERSONJane Doe
PERSONJack Goldberger
PERSONS.R.
PERSON
Jeffrey Sloman
PERSONMarie
PERSONthe Southern District
LOCATION
Scarlett Johansson
PERSON
United States
LOCATION
Department of Justice
ORGANIZATIONFBI
ORGANIZATION
Paul Cassell
PERSON
Karen Atkinson
PERSON