Epstein Secrets

y as yet unnamed plaintiffs, and (3) the risk that the promise of uncontested damages may compromise so called "victim" testimony, all of which Mr. Whitley advised made it important that the NPA be reviewed at the highest levels of the Justice Department. See December 5, 2007 Memorandum of J. Whitley t

establishes that nothing about interaction with Mr. Epstein constituted a federal offense. It as against this factual background that Special Agent Kuyrkendall repeatedly contacted to persuade that she was a victim of federal crimes. According to sworn testimony, the FBI rsonally met with 5 or 6 time

a victim, offering counseling, and providing victim's rights information to Not su risingly, as a result of this constant barrage by Special Agent Kuyrkendall, engaged the attorney representative, Mr. Josefsberg, to obtain a settlement payment from Mr. Epstein under the NPA. On October 31, 2007, First AU

e Agreement, the SDFL unilaterally proposed to divest its right to select the attorney representative for the victims. Contrary to Messrs. Starr and Whitley's recent assertion that this was "engineered in a way that appears intended to profit particular lawyers in private practice in South Florida with

We have no objection to sending the letters through the mail' but we will not remove the language about contacting AUSA Villafafia or Special Agent Kuyrkendall with questions or concerns. Again, federal law requires that victims have the "reasonable right to confer with the attorney for the Government in t

hose questions are appropriately directed to law enforcement. If questions arise related to the civil litigation, AUSA Villafafla and Special Agent Kuyrkendall will recommend that the victims direct those questions to Mr. Josefsberg. I have attached a revised letter incorporating the changes on which we can

39, 117 S. Ct. 417, 421, 136 L.Ed.2d 347 (1996) ("We have long held that the 'touchstone of the Fourth Amendment is reasonableness."); / Kyles v. Whitley, 514 U.S. 419, 432-33, 115 S. Ct. 1555, 1565, 131 L.Ed.2d 490 (1995) (under the Due Process Clause and 11 Brady v. Maryland, 373 U.S. 83, 83 S. Ct

1232 language that demeans the harm they may have suffered." • "[W]e will not remove the language about contacting AUSA Villafana or Special Agent Kuyrkendall with questions or concerns. Again, federal law requires that victims have a 'reasonable right to confer with the attorney for the Government in th

r concerns on this matter. I respectfully request that you consider the issues I discuss below in conjunction with the ethics opinion of Mr. Joe I). Whitley that I faxed to your Office on December 7. Background of Negotiations believe it is important for you to be aware of the full scope and substance

ct me or Special Agen Kuyrkendall Sincerely, R. Alexandea United States Attorney By: A. Assistant United States Attorney cc: Special Agent.. Kuyrkendall, F.B.I. Ms. Clearetha Wright, Victim-Witness Coordinator, U.S. Attorney's Office US_Atty_Cor_00262 EFTA00184869 Case 9:08-cv-80736-KAM Document