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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
st efforts turns out to be an exercise in internal government finger pointing. Specifically, the Government in this case (i.e., the U.S. Attorney's Office for the Southern District of Florida) argues that the Office complied with the Attorney General Guidelines for Victim and Witness Assistance (May 2005) and, accordingly, the Office use
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
rights under the CVRA. 79. In October 2007, shortly after the initial non-prosecution agreement was signed between Epstein and the U.S. Attorney's Office for the Southern District of Florida, Jane Doe No. 1 was contacted to be advised regarding the investigation. On October 26, 2007, Special Agents E. Nesbitt Kuyrkendall and Jason Richa
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
d on FLSD Docket 08/C )8 Page 6 of 16 Following the signing of the Non-Prosecution Agreement and the modifications thereto by the U.S. Attorney's Office for the Southern District of Florida, Epstein received an unusual benefit that the Government does not ordinarily provide to other criminal defendants: his performance was delayed whil
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
rights under the CVRA. 79. In October 2007, shortly after the initial non-prosecution agreement was signed between Epstein and the U.S. Attorney's Office for the Southern District of Florida, Jane Doe No. I was contacted to be advised regarding the investigation. On October 26, 2007, Special Agents E. Nesbitt Kuyrkendall and Jason Richa
d jury necessary to: (a) allow respond to OPR's written questions; (b) prepare for OPR's interview of (c) participate fully in OPR's interview of AUSA Villafafia. Disclosure shall be limited as set forth in the attached Protective Order. To the extent that 10, 2019 Response to OPR's written questions and a
continued secrecy; and (5) the request is structured to cover only the needed materials. EFTA00225040 Accordingly, the United States Attorney's Office for the Southern District of Florida, including Assistant United States Attorney A. Marie Villafaila, and the Justice Department's Office of Professional Responsibility may disclose to
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
on FLSD Docket 08/01/2008 Page 6 of 16 Following the signing of the Non-Prosecution Agreement and the modifications thereto by the U.S. Attorney's Office for the Southern District of Florida, Epstein received an unusual benefit that the Government does not ordinarily provide to other criminal defendants: his performance was delayed whil
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
rights under the CVRA. 79. In October 2007, shortly after the initial non-prosecution agreement was signed between Epstein and the U.S. Attorney's Office for the Southern District of Florida, Jane Doe No. 1 was contacted to be advised regardin the vestigation. On October 26, 2007, Special Agents E. and Jason met in person with Jane Do
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
between the ages of thirteen and seventeen to engage in prostitution, among other offenses. The case was presented to the United States Attorney's Office for the Southern District of Florida, which accepted the case for investigation. The Palm Beach County State Attorney's Office was EFTA00191264 also investigating the-ease Epstein. S
Entities connected to both AUSA Villafafia and Office for the Southern District of Florida

Jeffrey Epstein
PERSON
United States
LOCATION
Kenneth Marra
PERSONthe Southern District
LOCATION
Department of Justice
ORGANIZATIONJane Doe
PERSON
Bradley Edwards
PERSON
Alexander Acosta
PERSONFBI
ORGANIZATION
Jay Lefkowitz
PERSON
A. Marie Villafana
PERSON
Scarlett Johansson
PERSONJack Goldberger
PERSONLeon Black
PERSON
George W. Bush
PERSON
Paul Cassell
PERSONMaria Farmer
PERSON
Alan Dershowitz
PERSON
Virginia Giuffre
PERSON
Palm Beach County
LOCATION