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6/30/08 BSI 6/27/2008 AUSA Villafafia notifies Attorney Edwards of upcoming change of plea and urges his clients
#33, #37 (via Michael E. Dutko), #38, #44 biaJeffni Herman) 8-90 9/W2008 Victim notification letters to #36, #35 (via Brad Edwards), #42, #43 (via Brad Edwards) B-9I 9/12/2008 Notification of Identified Victim letter #39 B-92 9/15/2008 Mailed victim notification letters for #I8 and #32 15-93 9/17/2008-
77 6/27/2008 Counsel for Epstein advise USAO of Epstein state court change of plea on 6/30/08 BSI 6/27/2008 AUSA Villafafia notifies Attorney Edwards of upcoming change of plea and urges his clients to attend 6/27/2008 USAO notifies Palm Beach Police Chief Reiter of upcoming change of plea. He
9 Villafafia Roy Black Letter in response to 11/02/09 letter re Epstein's place of employment with attached Complaint against Scott Rothstein and Bradley J. Edwards 1/4/2010 Villafafia Spencer Kuvin Letter re computer seized by FBI 1/20/2010 Villafalia Roy Black Letter re attorney's fees 1/21/2010 Villaf
person. and assisted in finding counseling and other services for them. Justice Denar ment Personnel CEOS Deputy Chief Gelber (still at DOJ): Ms. Gelber was part of the team that reviewed the case and the NPA when Epstein "appealed" to DOJ. Ms. Gelber also is familiar with my work from a prior case
victims, met with them in person. and assisted in finding counseling and other services for them. Justice Denar ment Personnel CEOS Deputy Chief Gelber (still at DOJ): Ms. Gelber was part of the team that reviewed the case and the NPA when Epstein "appealed" to DOJ. Ms. Gelber also is familiar with
cedures. I don't remember saying anything different in this case. I did not see any FBI letters in this case prior to collecting the FBI letters to Brad Edwards' clients in connection with the Jane Doe I United States litigation. I did not instruct the FBI to include the language about the case being under in
y Circuit Court (Exhibit B-41). I responded, acknowledging his representation (Exhibit B-42). On June 18, 2008, I liv received a call from attorney Brad ards, who told me that he represented Individual #43, who is also Jane Doe #1 in the Jane Doe United States lawsuit. Mr. Edwards expressed an interest
a call from attorney Brad ards, who told me that he represented Individual #43, who is also Jane Doe #1 in the Jane Doe United States lawsuit. Mr. Edwards expressed an interest in assisting with the case. We were still waiting to hear about whether we would be moving " On the State side, Lefkowitz has
y. Now, victims from many child pornography "series" have been identified and have attorney contact information for purposes of restitution. CEOS' Gelber is the national expert in this area. To summarize, my understanding of my obligation was: to do my best to notify victims of upcoming court proceed
already entered a binding non-prosecution agreement with Jeffrey Epstein. The government is without 6 EFTA00191204 knowledge of precisely when "Bradley J. Edwards was working on a letter to the U.S. Attorney's Office concerning the need to federally prosecute Epstein for sex offenses committed against Jane Do
rally prosecute Epstein for sex offenses committed against Jane Doe #1 and Jane Doe #2," and, accordingly, the government denies the assertion that Edwards worked on that letter on July 3, 2008. Except as otherwise admitted above, the government denies Request No. 12. 13. (a) The government admits that
on Deliberative Process Work Product Attorney-Client Privilege 30 3/19/2008-3/21/2008 emails between Marie Villafafia, Drew Oosterbaan (CEOS), Gelber (CEOS), Jeff Sloman, and Robert Senior about meeting between Esptein counsel and CEOS and follow-up questions Work Product 6(e) Deliberative Pr
Entities connected to both Bradley Edwards and Gelber

Jeffrey Epstein
PERSONJane Doe
PERSONJack Goldberger
PERSON
Kenneth Marra
PERSON
Alan Dershowitz
PERSON
George W. Bush
PERSON
United States
LOCATION
Prince Andrew
PERSONLeon Black
PERSONthe Southern District
LOCATION
A. Marie Villafana
PERSON
Department of Justice
ORGANIZATION
Alexander Acosta
PERSONMartin Weinberg
PERSONRichard Horace Willits
PERSONRobert C. Josefsberg
PERSON
Virginia Giuffre
PERSON
Dexter Lee
PERSONRoy Black
PERSONFBI
ORGANIZATION