Epstein Secrets

In October 2007, shortly after the agreement was signed, four victims were contacted and these provisions were discussed. One of those victims was C.W. who at the time was not represented, and she was given notice of the agreement. Notice was also provided of an expected change of plea in October 2

ss Specialist. Attached hereto are 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. 11. Your Affiant's letter to T.M. was hand-delivered by myself to T.M. at the time that she was interviewed (Ex. 2).2

ively by the Federal Rules of Criminal Procedure, the USAO would not be entitled to compel pre-trial production of any of this information. See Fed. R. Cr. P. 16(b)(1)(A), (C), and 16(bX2); United States v. Argomaniz, 925 F.2d 1349, 1355-56 (11th Cir. 1991) (explaining act-of-production privilege). T

ss Specialist. Attached hereto are 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. 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).2

. on May 30, 2008 (Ex. 5). 4. Throughout the investigation, the FBI agents, the FBI's Victim-Witness Specialist, and your A Mani 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

ively by the Federal Rules of Criminal Procedure, the USAO would not be entitled to compel pre-trial production of any of this information. See Fed. R. Cr. P. 16(b)(1)(A), (C), and 16(b)(2); United States I Argomaniz, 925 F.2d 1349, 1355-56 (11th Cir. 1991) (explaining act-of-production privilege). T

on May 30, 2008 (Ex. 5). 4. Throughout the investigation, the FBI agents, the FBI's Victim-Witness Specialist, and your A (tient had contact with C.W. and II Attorney Edwards' other client, was represented by counsel and, accordingly, all contact with MB was made through that attorney. That attor

ively by the Federal Rules of Criminal Procedure, the USAO would not be entitled to compel pre-trial production of any of this information. See Fed. R. Cr. P. 16(b)(1)(A), (C), and 16(b)(2); United States Argomaniz, 925 F.2d 1349, 1355-56 (11th Cir. 1991) (explaining act-of-production privilege). Th