Epstein Secrets

afaita to Montan summarizing conversation with Goldberger that Epstein would serve sentence in confinement '24-bouts-a-day 80 6/29/2008 Email from Kuyrkendall to Villafana regarding work release 81 7/3/2008 Email from Villafiula to Sloman providing update on meeting with Col Gauger at PBSO regarding wor

e working on a number of different child exploitation matters at the time, along with ICE Special Agent David Malone. I remember generally that S/A Kuyrkendall mentioned an investigation of a wealthy man who lived on Palm Beach and recruited minors for sexual activity. During these casual conversations, I d

Soman, Villafana Atkinson Email chain regarding Epstein's request to do less time than 18 months 5/29/2008 Villafalia, Senior; cc: Atkinson, Kuyrkendall, Richards Sloman Email regarding DAG decision to consider Epstein's "appeal" and that GJ for Tuesday is off B-40 Privileged Confidential Page 3

e Dalton School (return date 9/29/09) 9/26/2006 Acosta, Mulvihill, Sloman, Noto, Waters, L°urie' Stefin, Atkinson, Garcia, Brown, Boscovich, Martinez Villafaila Memo regarding changes to Child Explotation Statutes in Tide 18 16 10/19/2006 Subpoena to Individual #28 (return date 10/27/06) 10/2

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

"encompass the entire criminal investigatory process," but rather "at the very least requires the initiation of legal proceedings." P M()Chavez it Martinez, 538 U.S. 760, 766, 123 S.Ct. 1994, 155 L.Ed.2d 984 (2003). Notably, in so holding, the Court drew on longstanding tradition, citing its now nearl

n legal parlance the judicial-case connotation is undoubtedly primary." Maj. Op. at 1207. As to the term "case," even the Majority cites Chavez v. Martinez, 538 U.S. 760, 766, 123 S. Ct. 1994, 2000-01, 155 L.Ed.2d 984 (2003), which supports my conclusion that the CVRA's conferral right attaches pre- cha

rime. The letters specifically advised that if the Petitioners felt that they were "being threatened or harassed, then please contact Special Agent Kuyrkendall or [AUSA Villafaiia]. (See DE14, Exs. 1 and 2.) It is further undisputed that Jane Doe #1 actually took advantage of the offer of protection when E

ane Doe #1] and August 2006 [Jane Doe #2] wherein they were advised of this right and given the phone numbers of AUSA Villafafia, FBI Special Agent Kuyrkendall, and the Justice Department's Office for Victims of Crime. The letters specifically advised that if the Petitioners felt that they were "being threa

"case" as "a question contested before a court of justice"). This general understanding is equally applicable to criminal proceedings. In Chavez v. Martinez, 538 U.S. 760 (2005), the Supreme Court held that a criminal "case" — as distinct from an investigation — "at the very least requires the initiation

rime. The letters specifically advised that if the Petitioners felt that they were "being threatened or harassed, then please contact Special Agent Kuyrkendall or [AUSA Villafaiial. (See DE14, Exs. I and 2.) It is further undisputed that Jane Doe ttl actually took advantage of the offer of protection when

ane Doe #1) and August 2006 [Jane Doe #2) wherein they were advised of this right and given the phone numbers of AUSA Villafafia, FBI Special Agent Kuyrkendall, and the Justice Department's Office for Victims of Crime. The letters specifically advised that if the Petitioners felt that they were "being threa

rc "merely a statement of assertion or concession made for some independent purpose," and may be controverted or explained by the party who made it. Martinez I Bally's Louisiana, Inc., 244 F.3d 474, 476-77 (51° Cir. 2001), citing McNamara v. Miller, 269 F.2d 511, 515 (D.C. Cir. 1959). In contrast, a judi

ane Doe #1] and August 2006 [Jane Doe #2) wherein they were advised of this right and given the phone numbers of AUSA Villafaila, FBI Special Agent Kuyrkendall, and the Justice Department's Office for Victims of Crime. The letters specifically advised that if the Petitioners felt that they were "being threa

rime. The letters specifically advised that if the Petitioners felt that they were "being threatened or harassed, then please contact Special Agent Kuyrkendall or [AUSA Villafafia]. (See DE14, Exs. 1 and 2.) It is further undisputed that Jane Doe #1 actually took advantage of the offer of protection when E

re "merely a statement of assertion or concession made for some independent purpose," and may be controverted or explained by the party who made it. Martinez I. Bally's Louisiana, Inc., 244 F.3d 474, 476-77 (V' Cir. 2001), citing McNamara'. Miller, 269 F.2d 511, 515 (D.C. Cir. 1959). In contrast, a judic

to obtain information from Jane Doe No. 2. Ex. B; Ex. S, 6-12. On April 24, 2007, Jane Doe No. 2 was interviewed by FBI Special Agents E. Nesbitt Kuyrkendall and Jason Richards and AUSA Marie Villafafia, in the presence of her attorney, James Eisenberg, Esq. Ex. C; Ex. R, I 5; Ex. S, q 12. Jane Doe No. 2

Q. 6 "A judicial admission is a formal concession in the pleadings or stipulations by a party or counsel that is binding on the party making them." Martinez v. Bally's Louisiana. Inc. 244 F.3d 474, 476-77 (5th Cir. 2001). 23 EFTA00799847 Case 9:08-cv-80736-KAM Document 408 Entered on FLSD Docket 06/0

o obtain information from Jane Doe No. 2. Ex. B; Ex. S,11[6-12. On April 24, 2007, Jane Doe No. 2 was interviewed by FBI Special Agents E. Nesbitt Kuyrkendall and Jason Richards and AUSA Marie Villafafia, in the presence of her attorney, James Eisenberg, Esq. Ex. C; Ex. R, 15; Ex. S, ¶ 12. Jane Doe No. 2 d

Q. 6 "A judicial admission is a formal concession in the pleadings or stipulations by a party or counsel that is binding on the party making them." Martinez v. Bally's Louisiana. Inc. 244 F.3d 474, 476-77 (5th Cir. 2001). 23 EFTA00591484 Case 9:08-cv-80736-KAM Document 401-2 Entered on FLSD Docket 06

tim Notification Letter. She stated that the U.S. Attorney's Office would "not remove the language about contacting AUSA Villafafia or Special Agent Kuyrkendall with questions or concerns." Again, AUSA Villafafia wrote that "federal law requires that victims have the `reasonable right to confer with the att

nal problems, the other should prevail—whether or not those constitutional problems pertain to the particular litigant before the Court." °Clad< v. Martinez. 543 U.S. 371. 380-81. 125 S. Ct. 716. 724. 160 L.Ed.2d 734 (2005). It is thus no answer to say that the separation of powers problems might not ap