Epstein Secrets

ed one. Epstein's attorneys actually made these baseless allegations in depositions and other court filings. (See, e.g., Jane Doe' Jeffrey Epstein, Haley Robson, and Sarah Kellen, Court File No. 08-80804-Civ- Marra/Johnson, DEl at 44-52.) 42 EFTA00177092 Case 9:08-cv-80736-KAM Document 62 Entered on FLSD

gs. (See, e.g., Jane Doe' Jeffrey Epstein, Haley Robson, and Sarah Kellen, Court File No. 08-80804-Civ- M

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

ed one. Epstein's attorneys actually made these baseless allegations in depositions and other court filings. (See, e.g., Jane Doei Jeffrey Epstein, Haley Robson, and Sarah Kellen, Court File No. 08-80804-Civ- Marra/Johnson, DEl at 44-52.) 42 08-80736-CV-MARRA 000861 EFTA00230685 fmney,'" Case 9:08-cv-8

gs. (See, e.g., Jane Doei Jeffrey Epstein, Haley Robson, and Sarah Kellen, Court File No. 08-80804-Civ- M

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

o have it recopied to have an original in evidence and a working copy with the file. Upon researching the file, it was discovered that the suspect, Haley Robson's cellular calls wer sub oenaed incorrectly. The suspect telephone number was and the original request was for . I requeste t e information through

lalliehinitially denied anything had happened, only admitting to going with Haley (later identif ed as Haley Robson) to Palm Beach to pick up money Robson was owed. identified Haley Robson as the cousin of her former boyfriend She ultimately admitted to knowing that Robson worked for a wealthy man an

viders can be provided to you, if you so desire. If you or your family is subjected to any intimidation or harassment, please contact Special Agent Kuyrkendall or myself immediately. It is possible that someone working on behalf of thc targets of the investigation may contact you. Such contact does not vio

telephone. computer or any other facility of interstate commerce, hut rather in a nate-to-face discussion with a third party who was her friend (Ms. Robson) and who told her to lie to Mr. Epstein about her age. As such, it is simply impassible to shoehorn this conduct into any of the above-discussed fe

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

6/06/2017 Page 26 of 32 unfairly prejudice the opposing party. Tampa Bay Water v. HDR Engineering. Inc. 731 F.3d 1171, 1182 (11th Cir. 2013) citing Robinson v. Tyson Foods. Inc., 595 F.3d 1269, 1273 (11th Cir. 2010). In their state court tort actions against Epstein, both petitioners invoked the provisi

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

/02/2017 Page 27 of 33 unfairly prejudice the opposing party. Tampa Bay Water v. HDR Engineering. Inc. 731 F.3d 1171, 1182 (11th Cir. 2013) citing Robinson v. Tyson Foods. Inc., 595 F.3d 1269, 1273 (11th Cir. 2010). In their state court tort actions against Epstein, both petitioners invoked the provisi

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

States v. St. Amour, 886 F.3d 1009, 1013 (11th Cir. 2018) (quoting United States v. Fisher, 289 F.3d 1329, 1337-38 (11th Cir. 2002)); see also ? Robinson g Shell Oil Co., 519 U.S. 337, 341, 117 S.Ct. 843, 136 L.Ed.2d 808 (1997) ("The plainness or ambiguity of WESTLAW @ 2021 Thomson Reuters. No claim

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