Epstein Secrets

red on FLSD Docket 07)15/2008 Page 4 of 8 %se January 10, 2008, and to S.R. on May 30, 2008. Villafafia Decl., 1 3. Throughout the investigation, AUSA Villafafia and the FBI's Victim-Witness Specialist had contact with C.W. Villafafia Decl., 1 4. Earlier in the investigation, T.M. was represented by James Ei

ent, none of Mr. Edwards' clients had expressed a desire to be consulted prior to the resolution of the federal investigation. Id. In October 2007, C.W. was not represented by counsel. a. y 8. She was given telephonic notice of the agreement, as were three other victims. Id. These four individuals we

ed to the victim by both the FBI Victim-Witness Specialist and AUSA Villafafa. ILI 3. Petitioner's counsel, Brad Edwards, Esq., currently represents C.W., T.M., and S.R. The U.S. Attorney's Office victim notification letter to C.W. was provided by the FBI. and the letter to T.M. was hand-delivered by

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

r victims [including C.W.] were contacted and these provisions were discussed" (emphasis added). Similarly at page 5, the declaration states: "After C.W. had been notified of the terms of the agreement ....." (emphasis added). I write to inquire whether, in view of the fact that the provision noted a

investigation, when a victim was identified, victim notification letters were provided to the victim by both the FBI Victim-Witness Specialist and AUSA Villafafia. Id., 3. Petitioner's counsel, Brad Edwards, Esq., currently represents C.W., T.M., and S.R. The U.S. Attorney's Office victim notification letter

on May 30, 2008 (Ex. 5). 4. Throughout the investigation, the FBI agents, the FBI's Victim-Witness Specialist, and your A ffiant had contact with C.W. and S.R. Attorney Edwards' other client, T.M., was represented by counsel and, accordingly, all contact with T.M. was made through that attorney. T

ss Specialist. Attached hereto are copies of the letters provided to Bradley Edwards' three clients, T.M., C.W., and S.R.' Your Affiant's letter to C.W. was provided by the FBI. (Ex. 1). Your Affiant's letter to T.M. was hand-delivered by myself to T.M. at the time that she was interviewed (Ex. 2).?

f the proposed state plea agreement, and learned that Epstein's state plea hearing was scheduled for Monday, June 30, 2008, at 8:30 a.m.-eel„ 1 10. AUSA Villafafia and the Palm Beach Police Department attempted to provide notification to victims in the short time that they had. jj Although all known victims we

were provided to the victim by both the FBI Victim-Witness Specialist and AUSA a¶ 3. Petitioner's counsel, Brad Edwards, Esq., currently represents C.W., T.M., and S.R. The U.S. Attorney's Office victim notification letter to C.W. was provided by the 1:131. and the letter to T.M. was hand-delivered

, and to S.R. on May 30, 2008. Villafafla Decl., ¶ 3. Throughout the investigation, AUSAInauld the FBI's Victim-Witness Specialist had contact with C.W. ¶ 4. Earlier in the investigation, T.M. was represented by James Eisenberg, E:sq. Consequently, all contact with T.M. was made through Mr. Eisenber

vestigation. Pro bono counsel was able to assist Jane Doe #1 in avoiding the improper deposition. 12. In mid-June 2008, Attorney Edwards contacted AUSA Villafafia to inform her that he represented Jane Doe #1 and, later, Jane Doe #2. Attorney Edwards asked to meet to provide information regarding Epstein. Att

eference to the ages of the minor victims and, upon conviction, did not require sex offender registration. 3. Jane Doe #1 is a woman with initials C.W., and Jane Doe #2 is a woman with initials T.M. Both were victims of Epstein's while they were minors beginning when they were fifteen years old. B

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

eference to the ages of the minor victims and, upon conviction, did not require sex offender registration. 3. Jane Doe #1 is a woman with initials C.W., and Jane Doe #2 is a woman with initials T.M. Both were victims of Epstein's while they were minors beginning when they were fifteen years old. Bo