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ters provided the name of the FBI agent handling the Epstein investigation (Nesbitt Kurykendall), her phone number, the identity of the prosecutor (AUSA Villafafia), and her phone number. Although Jane Doe No. I and Jane Doe No. 2 had been furnished the means to contact the FBI agent and the prosecutor regardi
never. Jeffrey is an awesome man, no. Id. at 22. At the end of her interview, Jane Doe No. 2 was asked if she had any questions for the agents or AUSA Villafafia. Id. at 57. Jane Doe No. 2 responded: A. No, but I hope — I hope Jeffrey, nothing happens to Jeffrey because he's an awesome man and it would real
WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L. 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 mart: Paul G. Cassell Pro Hac Vice S.J. Quinney College of Law at the University of Utah 332 S. 1400 E. T fNe•• T Tt.A. 4A 1 11 Attorneys or Jane Doe 1 and Jane Doe 2 Jacqueline Perczek BLACK SREBNICK KORN
's crimes against them, remained on-going in the first half of 2008; and (c) Jane Doe 1 and Jane Doe 2 had been provided information for contacting AUSA Villafafia if they wanted to confer. See Villafafia Decl. at 115, 35-36. 97. The Government denies that Jane Doe 1 met with multiple AUSAs from the U.S. Atto
ecl. at 6-14, 31. The second sentence in paragraph 96 is denied as Jane Doe 1 and Jane Doe 2 never asked to confer or consult with the FBI or with AUSA Villafafia about the prosecution of Epstein despite having been informed of a victim's right to confer and having been provided with contact information for S
IST Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L. 425 North Andrews Avenue, Suite 2 Paul G. Cassell Pro Hac Vice S.J. Quinney College of Law at the University of Utah 332 S. 1400 E. Attorneys for Jane Doe 1 and Jane Doe 2 Jacqueline Perczek BLACK SREBNICK KORNSPAN & STUMPF 201 S. Bi
and growing number of identified victims and sentencing guidelines if found guilty of committing a sex- trafficking offense against just one victim. AUSA Villafafia would not provide many answers or comments to any of my direct questions and, in fact, expressed that while she wished she could answer my question
riminal case against Jeffrey Epstein and she wanted my assistance in getting some answers. 11. In mid-June 2008, I had several telephone calls with AUSA Villafafia. In her affidavit, Villafafia only recounts certain fragments of these calls. (See DE 403-19, para. 37-38). However, to the extent the substance o
E, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L. 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 And Paul G. Cassell Pro Hac Vice S.J. Quinney College of Law at the University of Utah' 332 S. 1400 E. This daytime business address is provided for identification and correspondence purposes only and is not
's crimes against them, remained on-going in the first half of 2008; and (c) Jane Doe 1 and Jane Doe 2 had been provided information for contacting AUSA Villafafia if they wanted to confer. See Villafafia Decl. at 115, 35-36. 97. The Government denies that Jane Doe 1 met with multiple AUSAs from the U.S. Atto
ecl. at 6-14, 31. The second sentence in paragraph 96 is denied as Jane Doe 1 and Jane Doe 2 never asked to confer or consult with the FBI or with AUSA Villafafia about the prosecution of Epstein despite having been informed of a victim's right to confer and having been provided with contact information for S
JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L. 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 Paul G. Cassell Pro Hac Vice S.J. Quinney College of Law at the University of Utah 332 S. 1400 E. Attorneys for Jane Doe 1 and Jane Doe 2 Jacqueline Perczek BLACK SREBNICK KORNSPAN & STUMPF 201 S. Bi
on to be resolved without charges being filed against Epstein. Several months after that videotaped interview, Attorney Eisenberg was asked whether AUSA Villafafia could contact Jane Doe No. 2 directly and was told that contact had to occur via Mr. Eisenberg. Ex. S. 1 14. In seeking summary judgment, Jane Doe
No. 2 refused to be interviewed by the FBI and U.S. Attorney's Office unless she was granted immunity. Ex. A, Sept. 21, 2006 Ltr. from Eisenberg to AUSA Villafafia; Ex. S, 6-12. Thus, she was unwilling to provide any information regarding her encounters with Epstein unless she was assured her statements would
JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L. 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 Paul G. Cassell Pro Hac Vice S.J. Quinney College of Law at the University of Utah 332 S. 1400 E. Attorneys for Jane Doe 1 and Jane Doe 2 Jacqueline Perczek BLACK SREBNICK KORNSPAN & STUMPF 201 S. Bi
on to be resolved without charges being filed against Epstein. Several months after that videotaped interview, Attorney Eisenberg was asked whether AUSA Villafafia could contact Jane Doe No. 2 directly and was told that contact had to occur via Mr. Eisenberg. Ex. S,1 14. In seeking summary judgment, Jane Doe N
No. 2 refused to be interviewed by the FBI and U.S. Attorney's Office unless she was granted immunity. Ex. A, Sept. 21, 2006 Is. from Eisenberg to AUSA Villafafia; Ex. S, ¶16-12. Thus, she was unwilling to provide any information regarding her encounters with Epstein unless she was assured her statements would
EHRMAN, P.L. 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 Tel: E-mail: [email protected] Paul G. Cassell Pro Hac Vice S.J. Quinney College of Law at the University of Utah 332 S. 1400 E. Salt Lake City, Utah 84112 Tel: E-mail: [email protected] Attorneys for Jane Doe 1 and Jane Doe 2
solved by the non-prosecution agreement entered into by Epstein and the U.S. Attorney's Office in September 2007. 88. In mid-June 2008, I contacted AUSA Villafafia to inform her that I represented Jane Doe No. 1 and, later, Jane Doe No. 2. I asked to meet to provide information about the federal crimes committ
ified victims in connection with the criminal investigation. Pro bono counsel was able to assist Jane Doe No. 1 in avoiding the improper deposition. AUSA Villafafia secured pro bono counsel by contacting Meg Garvin, Esq. of the the National Crime Victims' Law Center in Portland, Oregon, which is based in the Le
stice.com EFTA00081152 Case 9:08-cv-80736-KAM Document 225-1 Entered on FLSD Docket 08/16/2013 Page 38 of 64 and Paul G. Cassell Pro Hac Vice S.J. Quinney College of Law at the University of Utah 332 S. 1400 E. Salt Lake City, UT 84112 Telephone: 801-585-5202 Facsimile: 801-585-6833 E-Mail: [email protected]
solved by the non-prosecution agreement entered into by Epstein and the U.S. Attorney's Office in September 2007. 88. In mid-June 2008, I contacted AUSA Villafafia to inform her that I represented Jane Doe No. 1 and, later, Jane Doe No. 2. I asked to meet to provide information about the federal crimes committ
ified victims in connection with the criminal investigation. Pro bono counsel was able to assist Jane Doe No. I in avoiding the improper deposition. AUSA Villafafia secured pro bono counsel by contacting Meg Garvin, Esq. of the the National Crime Victims' Law Center in Portland, Oregon, which is based in the Le
stice.com EFTA00179735 Case 9:08-cv-80736-KAM Document 225-1 Entered on FLSD Docket 08/16/2013 Page 38 of 64 and Paul G. Cassell Pro Hac Vice S.J. Quinney College of Law at the University of Utah 332 S. 1400 E. Salt Lake City, UT 84112 Telephone: 801-585-5202 Facsimile: 801-585-6833 E-Mail: [email protected]
plained that the Government was incentivizing the victims to overstate their involvement with Epstein in order to increase their damage claims. Id. AUSA Villafafia and the FBI agents concluded that informing additional victims could compromise both the witnesses' credibility and the agents' credibility at a la
& LEHRMAN, P.L. 425 North Andrews Avenue, Suite 2 Fort Lauderdale. Florida 33301 Telephon Facsimile E-mail: And Paul G. Cassell Pro Hac Vice S.J. Quinney College of Law at the University of Utah' 332 S. 1400 E. Salt Lake it T 4112 Telephon Facsi E-Mai Attorneys for Jane Does 1 and 2 'This daytime business ad
tters in approximately June 2007 [Jane 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
Jaffe, Weissing, Edwards, Fistos & Lehrman, P.L. 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 Fax: E-mail: Paul G. Cassell S.J. Quinney College of Law at the University of Utah 332 S. 1400 E. Salt Lake City, Utah 84112 Fax: E-mail: Attorneys for Jane Doe # 1 and Jane Doe # 2 54 EFTA00078888
Entities connected to both AUSA Villafafia and S.J. Quinney College of Law

Paul Cassell
PERSON
Bradley Edwards
PERSON
Jeffrey Epstein
PERSONJane Doe
PERSON
the University of Utah
ORGANIZATION
Kenneth Marra
PERSONMaria Farmer
PERSON
Salt Lake City
LOCATIONFISTOS & LEHRMAN
ORGANIZATION
Scarlett Johansson
PERSON
United States
LOCATIONthe Southern District
LOCATIONLeon Black
PERSON
Department of Justice
ORGANIZATION
Dexter Lee
PERSON
A. Marie Villafana
PERSON
Jay Lefkowitz
PERSONJack Goldberger
PERSON
Alexander Acosta
PERSONRoy Black
PERSON