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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
Villafafia secured pro bono counsel by contacting Meg Garvin, Esq. of the National Crime Victims' Law Center in Portland, Oregon, which is based in the Lewis & Clark College of Law. Ms. Garvin was not advised that a non- prosecution agreement had been reached in this matter or that any possible resolution of any kind had been r
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
afafia 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 Lewis & Clark College of Law. During the call, Ms. Garvin was not advised that a non-prosecution agreement had been reached in this matter. 87. On May 30, 2008, another one of
A00177258 Case 9:08-cv-8 •KAM Document 19 Entered on FLSD Docket 08/C i8 Page 7 of 16 assist Jane Doe #1 in avoiding the improper deposition. AUSA Villafafia secured pro bono counsel by contacting Meg Garvin, Esq. of the National Crime Victims' Law Institute in Portland, Oregon, which is based in the Lew
ed to meet to provide information about the federal crimes committed by Epstein, hoping to secure a significant federal indictment against Epstein. AUSA Villafafia and Mr. Edwards discussed the possibility of federal charges being filed. At the end of the call, AUSA Villafafia asked Mr. Edwards to send any inf
lafafia secured pro bono counsel by contacting Meg Garvin, Esq. of the National Crime Victims' Law Institute in Portland, Oregon, which is based in the Lewis & Clark College of Law. During the call, Ms. Garvin was not advised about the Non-Prosecution Agreement. In mid-June 2008, Mr. Edwards contacted Assistant U.S. Attorney V
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
afafia 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 Lewis & Clark College of Law. During the call, Ms. Garvin was not advised that a non-prosecution agreement had been reached in this matter. 87. On May 30, 2008, another one of
deral indictment against Epstein. AUSA Villafafia and Mr. Edwards discussed the possibility of federal charges being filed. At the end of the call, AUSA Villafafia asked Mr. Edwards to send any information that he wanted considered by the U.S. Attorney's Office in determining whether to file federal charges. B
Page: EFTA00013932 →llafana secured pro bono counsel by contacting Meg Garvin, Esq. of the National Crime Victims' Law Institute in Portland, Oregon, which is based in the Lewis & Clark College of Law. During the call, Ms. Garvin was not advised about the Non-Prosecution Agreement. In mid-June 2008, Mr. Edwards contacted Assistant U.S. Attorney V
Page: EFTA00013932 →ed to meet to provide information about the federal crimes committed by Epstein, hoping to secure a significant federal indictment against Epstein. AUSA Villafafia and Mr. Edwards discussed the possibility of federal charges being filed. At the end of the call, AUSA Villafafia asked Mr. Edwards to send any inf
lafafla secured pro bono counsel by contacting Meg Garvin, Esq. of the National Crime Victims' Law Institute in Portland, Oregon, which is based in the Lewis & Clark College of Law. During the call, Ms. Garvin was not advised about the Non-Prosecution Agreement. In mid-June 2008, Mr. Edwards contacted Assistant U.S. Attorney V
secution agreement. At this point it is clear that AUSA was restricted in what she was being permitted to tell me. 89. On July 3, 2008, I sent to AUSA Villafafia a letter. In the letter, I indicated my client's desire that federal charges be filed against defendant Epstein. In particular, I wrote on behalf of
afafta 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 Lewis & Clark College of Law. During the call, Ms. Garvin was not advised that a non-prosecution agreement had been reached in this matter. 87. On May 30, 2008, another one of
de—rlet—knew whethee-the-title-ef-ttte-deooment-was-diselesed-when4he-Agreemem-was-filed-under-sealr but 39. On July 3, 2008, Mr. Edwards sent to AUSA Villafafia a letter. See Affidavit of Bradley J. Edwards, Esq., at 15 (attachment 2). In the letter, Mr. Edwards indicated his client's desire that federal ch
afaila 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 Lewis & Clark College of Law. During the call, Ms. Garvin was not advised that a non-prosecution agreement had been reached. 35. On May 30, 2008, another of Mr. Edwards's clie
Entities connected to both AUSA Villafafia and the Lewis & Clark College of Law

Jeffrey Epstein
PERSON
Bradley Edwards
PERSON
Kenneth Marra
PERSON
A. Marie Villafana
PERSON
United States
LOCATION
Department of Justice
ORGANIZATION
Alexander Acosta
PERSONJane Doe
PERSON
Jay Lefkowitz
PERSONJack Goldberger
PERSON
Paul Cassell
PERSONthe Southern District
LOCATIONFBI
ORGANIZATION
Scarlett Johansson
PERSON
Oregon
LOCATIONLeon Black
PERSON
Poland
LOCATION
Meg Garvin
PERSONMaria Farmer
PERSONOffice for the Southern District of Florida
ORGANIZATION