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r. Epstein's attorneys, including Roy Black, Gerald Lefcourt, Alan Dershowitz, Alan Dershowitz's brother, Nat Dershowitz, Ken Starr, Jay Lefkowitz, Lilly Sanchez, Jack Goldberger, Bruce Lyons, Martin Weinberg, Stephanie Thacker, Guy Lewis, Mike Tein, Joe Whitley and Herb Rosen, have expressed sincere outrage
establishes that nothing about interaction with Mr. Epstein constituted a federal offense. It as against this factual background that Special Agent Kuyrkendall repeatedly contacted to persuade that she was a victim of federal crimes. According to sworn testimony, the FBI rsonally met with 5 or 6 time
a victim, offering counseling, and providing victim's rights information to Not su risingly, as a result of this constant barrage by Special Agent Kuyrkendall, engaged the attorney representative, Mr. Josefsberg, to obtain a settlement payment from Mr. Epstein under the NPA. On October 31, 2007, First AU
n at least as early as 2001, so all of the victims were minors at the time of the offense." (DE 407 at ¶ 83.) On December 7, 2007, defense attorney Lilly Ann Sanchez sent a letter to AUSA Sloman, requesting "that the Office hold off on sending any victim notification letters." No letters were sent in December of
l. ¶ 5, DE 361-26.) Jane Doe 1's understanding was that the federal investigation would continue. (Jane Doe 1 Decl. 16.) In contrast, Special Agent Kuyrkendall stated that the meeting with Jane Doe 1 was to advise her of the main terms of the NPA.2 (Kuykendall Decl. ¶ 8, DE 403-18.) After the meeting, Speci
he provision about monetary damages could be grounds for impeachment of the victims and herself. (Kuykendall Decl. ¶ 9.) According to Special Agent Kuyrkendall, the investigation of Epstein continued through 2008. (Kuykendall Decl. ¶ 11.) In addition to Jane Doe I, FBI agents only talked to two other victim
torney's Office and Epstein was subsequently modified by an October 2007 Addendum and a December 19, 2007, letter from the U.S. Attorney to Attorney Lilly Ann Sanchez. The U.S. Attorney's Office did not confer with any of the victims about these modifications of the agreement (or even notify them of the existence
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
nce of a September 2007 Non-Prosecution Agreement, an October 2007 Addendum and a letter dated December 19, 2007 from the U.S. Attorney to Attorney Lilly Ann Sanchez , Counsel to Jeffrey Epstein (DE 35 at ¶3).' I I assume those involved in the above-referenced litigation, have copies of the relevant court filin
el, Bradley J. Edwards, Esq. DE 14. Special Agent Nesbitt Kuyrkendall, F.B.I. is copied on AUSA Villafafia's letters and Special Agent Richards and Kuyrkendall are referenced in certain letters to Mr. Edwards. DE 14. Moreover, Epstein's counsel, Jack Goldberger, Esq. is copied on letters to Mr. Edwards. I a
Prosecution Agreement ("Part I"); (2) an October 2007 Addendum ("Pan 2"): and (3)a letter dated December19,2007, from the U.S. Attorney to Attorney Lilly Ann Sanchez, counsel to Jeffrey Epstein ("Part 3"). EFTA00184218 Case 9:08•cv-80736•KAM Document 35 Entered on FLSD Docket 12/22/2008 Page 2 of 4 4. On July
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 the targets of the investigation may contact you. Such contact does not vio
torney's Office and Epstein was subsequently modified by an October 2007 Addendum and a December 19, 2007, letter from the U.S. Attorney to Attorney Lilly Ann Sanchez. The US. Attorney's Office did not confer with any of the victims about these modifiCations of the agreement (or even notify them of the existence
iders 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 the targets of the investigation may contact you. Such cdntact does not vio
Andrew Lourie, overruled us. b. AUSA McMillan and I did not want to have a subsequent meeting with another set of attorneys for Epstein, including Lilly Ann Sanchez, Gerald Lefcourt, Alan Dershowitz, and Roy Black, that would also include Criminal Chief Matt Menchel. Over my objections, Mr. Menchel also instruc
auger stopped by to see Karen Atkinson on another matter, he told her that Epstein had been on work release for the past few weeks (Exhibit 82). S/A Kuyrkendall spoke with the work release coordinator who told her that he was led to believe that the USAO and FBI knew that Epstein had applied for the program
secution Agreement ("Part I"); (2) an October 2007 Addendum ("Part 2"); and (3)a letter dated December 19, 2007, from the U.S. Attorney to Attorney Lilly Ann Sanchez, counsel to Jeffrey Epstein ("Part 3"). EFTA00234649 Case 9:08-cv-80736-KAM Document 35 Entered on FLSD Docket 12/22/2008 Page 2 of 4 4. On J
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
Entities connected to both Lilly Ann Sanchez and Kuyrkendall

Jeffrey Epstein
PERSON
A. Marie Villafana
PERSON
Bill Richardson
PERSON
Alexander Acosta
PERSON
Kenneth Marra
PERSONJack Goldberger
PERSON
Jeffrey Sloman
PERSONKaren
PERSON
Bradley Edwards
PERSON
Karen Atkinson
PERSON
United States
LOCATIONJane Doe
PERSON
Department of Justice
ORGANIZATION
Dexter Lee
PERSONJoseph L. Ackerman
PERSONDarren Indyke
PERSON
Joe Biden
PERSON
George W. Bush
PERSONLeon Black
PERSONMarie
PERSON