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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
f Florida, the District of EFTA00081158 Case 9:08-cv-80736-KAM Document 225-1 Entered on FLSD Docket 08/16/2013 Page 44 of 64 New Jersey, and/or the District of Columbia. For this one discovery request only, please include all relevant grand jury transcripts and evidence collected by the grand jury. DEFINITIONS For
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
numerated in article 1.B, a victim is "a person directly and proximately harmed as a result of the commission of a Federal offense or an offense in the District of Columbia" (18 U.S.C. § 3771(e)), if the offense is charged in Federal district court. If a victim is under 18 years of age, incompetent, incapacitated, or
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
(2)(A) ("The term `crime victim' means a person directly and proximately harmed as a result of the commission of a Federal offense or an offense in the District of Columbia."). The only provisions of the CVRA that even address state criminal proceedings are found in 18 U.S.C. § 3771(b)(2)—a provision that addresses col
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
(2)(A) ("The term `crime victim' means a person directly and proximately harmed as a result of the commission of a Federal offense or an offense in the District of Columbia."). The only provisions of the CVRA that even address state criminal proceedings are found in 18 U.S.C. § 3771(b)(2)—a provision that addresses col
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
f Florida, the District of EFTA00179741 Case 9:08-cv-80736-KAM Document 225-1 Entered on FLSD Docket 08/16/2013 Page 44 of 64 New Jersey, and/or the District of Columbia. For this one discovery request only, please include all relevant grand jury transcripts and evidence collected by the grand jury. DEFINITIONS For
efkowitz e-mailed AUSA Villafana, requesting: "Marie - Please do whatever you can to keep this [Agreement] from becoming public." (emphasis added). AUSA Villafafia assured Lefkowitz that the Agreement would be kept confidential. 7 For example, in a December 6, 2007 letter, AUSA Villafana informed Lefkowitz tha
states: -The term 'crime victim' means a person directly and proximately harmed as a result of the commission of a Federal offense or an offense in the District of Columbia." 18 U.S.C. § 3771(e)(2)(A). 5 The crime victim's complaint and the United States Attorney's answer—along with any accompanying discovery—would pr
Entities connected to both AUSA Villafafia and the District of Columbia

United States
LOCATION
Jeffrey Epstein
PERSON
Department of Justice
ORGANIZATION
Virginia Giuffre
PERSONLeon Black
PERSON
George W. Bush
PERSON
Donald Trump
PERSON
Prince Andrew
PERSON
Ghislaine Maxwell
PERSON
Bradley Edwards
PERSON
Julie K. Brown
PERSON
Prince Charles
PERSON
Joe Biden
PERSON
Scarlett Johansson
PERSON
Michael Jackson
PERSON
Kenneth Marra
PERSON
Bill Clinton
PERSONFBI
ORGANIZATION
Samantha Power
PERSON
New York
LOCATION