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a and/or her supervisors advise him otherwise. Furthermore, you make reference to "our July 8 deadline." Respectfully, the United States Attorney's Office for the Southern District of Florida ("SDFL") has never agreed to any such deadline. Should you decide to provide the SDFL with any additional information, please do so through AUSA Vi
ee of Defendant JEFFREY EPSTEIN prepared a written telephoF message for Defendant JEFFREY EPSTEIN's review regarding a telephone call received from T.M. and Jane Doe #12 that stated: "They are available all weekend and maybe pane Doe #13] too". 20 EFTA00225764 (83) On or about December 30, 2004,
or more telephone calls to a telephone used by Jane Doe #7. (58) On or about July 16, 2004, Defendant placed a telephone call telephone used by T.M. (59) On or about July 17, 2004, one of Defendant JEFFREY EPSTEIN's employees prepared a written telephone message for Defendant JEFFREY EPSTEIN's
a telephone call to a telephone used by Jane Doe #8. D (56) On or about July 15, 2004, Defendant placed a telephone call to a telephone used by T.M. (57) On or about July 16, 2004, Defendant placed one or more telephone calls to a telephone used by Jane Doe #7. (58) On or about July 16, 2004
ing T.M. or whether T.M. ever formally terminated Mr. Eisenberg's representation. -2- EFTA00190507 S. In the summer of 2007, the U.S. Attorney's Office for the Southern District of Florida ("the Office") decided to enter into negotiations with Epstein to resolve the investigation. In September 2007, an agreement was reached. Pursuant
om your Affiant and from the FBI's Victim-Witness Specialist. Attached hereto are copies of the letters provided to two of Bradley Edwards clients, T.M. and C.W.' The letter to C.W. was hand-delivered by the FBI agents. The letter to T.M. was hand-delivered by myself to T.M. at the time that she wa
e from the Office had communicated the victim list to Epstein, attorneys for Epstein made contact with the Office complaining of the designation of T.M. as a victim. Epstein's attorneys used the designation of T.M. as a basis to allege prosecutorial misconduct against 3The indictment contained no re
rights under the CVRA. 79. In October 2007, shortly after the initial non-prosecution agreement was signed between Epstein and the U.S. Attorney's Office for the Southern District of Florida, Jane Doe No. I was contacted to be advised regardiniihkivestigation. On October 26, 2007, Special Agents E. and Jason met in person with Jane Doe
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
ferenced case, I write this letter in my capacity as the Electronic Discovery Coordinator within the Civil Division of the United States Attorney's Office for the Southern District of Florida (1JSAO-SDFLA). 1 write to advise you of the USAO-SDFLA's legal obligation to preserve documents and data relevant to the lawsuit and to enlist your
fied, including notification letters that were sent. DE 14. Attached to that Declaration are copies of redacted letters provided to victims "C.W.", "T.M.", and "S.R." by AUSA Villafatia and the FBI's Victim-Witness Specialist Twiller Smith. DE 14. In addition, appended to the Declaration are AUSA le
ferenced case, I write this letter in my capacity as the Electronic Discovery Coordinator within the Civil Division of the United States Attorney's Office for the Southern District of Florida (USAO-SDFLA). I write to advise you of the USAO-SDFLA's legal obligation to preserve documents and data relevant to the lawsuit and to enlist your
fied, including notification letters that were sent. DE 14. Attached to that Declaration are copies of redacted letters provided to victims "C.W.", "T.M.". and "S.R." by AUSA and the FBI's Victim-Witness S ecialist Twiller Smith. DE 14. In addition, appended to the Declaration are AUSA letters to th
ferenced case, I write this letter in my capacity as the Electronic Discovery Coordinator within the Civil Division of the United States Attorney's Office for the Southern District of Florida (1JSAO-SDFLA). 1 write to advise you of the USAO-SDFLA's legal obligation to preserve documents and data relevant to the lawsuit and to enlist your
fied, including notification letters that were sent. DE 14. Attached to that Declaration are copies of redacted letters provided to victims "C.W.", "T.M.", and "S.R." by AUSA Villafatia and the FBI's Victim-Witness Specialist Twiller Smith. DE 14. In addition, appended to the Declaration are AUSA Vil
ferenced case, I write this letter in my capacity as the Electronic Discovery Coordinator within the Civil Division of the United States Attorney's Office for the Southern District of Florida (USAO-SDFLA). 1 write to advise you of the USAO-SDFLA's legal obligation to preserve documents and data relevant to the lawsuit and to enlist your
fied, including notification letters that were sent. DE 14. Attached to that Declaration are copies of redacted letters provided to victims "C.W.", "T.M.", and "S.R." by AUSA and the FBI's Victim-Witness Specialist Twiller Smith, DE 14. In addition, appended to the Declaration are AUSA Villafana's le
d on FLSD Docket 08/C )8 Page 6 of 16 Following the signing of the Non-Prosecution Agreement and the modifications thereto by the U.S. Attorney's Office for the Southern District of Florida, Epstein received an unusual benefit that the Government does not ordinarily provide to other criminal defendants: his performance was delayed whil
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
between the ages of thirteen and seventeen to engage in prostitution, among other offenses. The case was presented to the United States Attorney's Office for the Southern District of Florida, which accepted the case for investigation. The Palm Beach County State Attorney's Office was EFTA00191264 also investigating the-ease Epstein. S
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
Entities connected to both Office for the Southern District of Florida and T.M.

Jeffrey Epstein
PERSON
Bradley Edwards
PERSON
Kenneth Marra
PERSONJane Doe
PERSON
George W. Bush
PERSONthe Southern District
LOCATION
United States
LOCATION
Alexander Acosta
PERSON
Department of Justice
ORGANIZATION
A. Marie Villafana
PERSONFBI
ORGANIZATIONJack Goldberger
PERSON
Scarlett Johansson
PERSON
Dexter Lee
PERSON
Jay Lefkowitz
PERSON
C.W.
PERSONLeon Black
PERSON
Paul Cassell
PERSON
Jeffrey Sloman
PERSONMaria Farmer
PERSON