Epstein Secrets

'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

under the NPA. See id. at 91 35-36. 100. Admitted to the extent that the Government assumes that "Jane Doe 5" refers to an individual with initials S.R. and with the qualification that Jane Doe 1 and two other victims had been informed in October 2007 about the NPA. See id. at II 32-33; 2d Kuyrkendal

'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

under the NPA. See id. at 91 35-36. 100. Admitted to the extent that the Government assumes that "Jane Doe 5" refers to an individual with initials S.R. and with the qualification that Jane Doe 1 and two other victims had been informed in October 2007 about the NPA. See id. at II 32-33; 2d Kuyrkendal

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

ormation), I represented four victims of Epstein's sex offenses in Federal Court — Jane Doe No. 1, Jane Doe No. 2, and a victim I will refer to as "S.R." and "M.J.", and other victims of Jeffrey Epstein's abuse as well. If further information is disclosed about this case, that will not discourage the

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

ormation), I represented four victims of Epstein's sex offenses in Federal Court — Jane Doe No. 1, Jane Doe No. 2, and a victim I will refer to as "S.R." and "M.J.", and other victims of Jeffrey Epstein's abuse as well. If further information is disclosed about this case, that will not discourage the

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

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 AUSA Villafaiia

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

ttorney's Office. She provided additional details of Epstein's sexual abuse of her." (DE48 at 17.) And, one of Petitioners' counsel's other clients, S.R., was originally interviewed in October 2007 and refused to provide information regarding Epstein. (DEI4 at ¶ 7.) During the time that Epstein was c

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

ormation), I represented four victims of Epstein's sex offenses in Federal Court — Jane Doe No. 1, Jane Doe No. 2, and a victim I will refer to as "S.R." and "M.J.", and other victims of Jeffrey Epstein's abuse as well. If further information is disclosed about this case, that will not discourage the

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

and from the FBI's Victim-Witness 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

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

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 by AUSA UMto her