Epstein Secrets

npersuaded by the letter and the presentation, but I agreed that I should carefully review transcripts of the recorded statements given to PBPD for Brady issues." Since witness credibility was clearly at the fore, I undertook efforts " The requested documents and items were never provided. 15 As the

afaita to Montan summarizing conversation with Goldberger that Epstein would serve sentence in confinement '24-bouts-a-day 80 6/29/2008 Email from Kuyrkendall to Villafana regarding work release 81 7/3/2008 Email from Villafiula to Sloman providing update on meeting with Col Gauger at PBSO regarding wor

e working on a number of different child exploitation matters at the time, along with ICE Special Agent David Malone. I remember generally that S/A Kuyrkendall mentioned an investigation of a wealthy man who lived on Palm Beach and recruited minors for sexual activity. During these casual conversations, I d

Soman, Villafana Atkinson Email chain regarding Epstein's request to do less time than 18 months 5/29/2008 Villafalia, Senior; cc: Atkinson, Kuyrkendall, Richards Sloman Email regarding DAG decision to consider Epstein's "appeal" and that GJ for Tuesday is off B-40 Privileged Confidential Page 3

each was astonished that any evidence Ms. Villafana purported to have was not shared with the State or made available to Mr Epstein's attorneys as Brady evidence. Ms. Villafana launched a totally unsupportable and vastly overreaching sex trafficking investigation without providing notification to th

establishes that nothing about interaction with Mr. Epstein constituted a federal offense. It as against this factual background that Special Agent Kuyrkendall repeatedly contacted to persuade that she was a victim of federal crimes. According to sworn testimony, the FBI rsonally met with 5 or 6 time

a victim, offering counseling, and providing victim's rights information to Not su risingly, as a result of this constant barrage by Special Agent Kuyrkendall, engaged the attorney representative, Mr. Josefsberg, to obtain a settlement payment from Mr. Epstein under the NPA. On October 31, 2007, First AU

ir statements, their credibility and the foundations, if any, for claiming person! injury. Also. Mr. Epstein would have received, pursuant to either Brady or Jencks, material in the tbnn of prior inconsistent statements made by these women before they learned of any financial benefit that may be avail

We have no objection to sending the letters through the mail' but we will not remove the language about contacting AUSA Villafafia or Special Agent Kuyrkendall with questions or concerns. Again, federal law requires that victims have the "reasonable right to confer with the attorney for the Government in t

hose questions are appropriately directed to law enforcement. If questions arise related to the civil litigation, AUSA Villafafla and Special Agent Kuyrkendall will recommend that the victims direct those questions to Mr. Josefsberg. I have attached a revised letter incorporating the changes on which we can

s regarding Epstein not wanting underage girls providing him massages would have been required to be disclosed to Epstein's defense attorneys under Brady v. Maryland 373 U.S. 83 (1963). If the government ever chose to call her as a prosecution witness, the government would have been obligated to discl

those victims who have never reached out and asked to confer. Neither Jane Doe 1 nor Jane Doe 2 ever contacted AUSA Villafafia or FBI Special Agent Kuyrkendall regarding the case, despite being provided their phone numbers and addresses. D.E. 403-19,915. Since the Court's statutory interpretation of the te

Jeopardy Clause's Protection Against Duplicative Punishments. 11 III. The Government Should Immediately Produce Accuser-4's Prior Statements as Brady Material. 14 IV. The Court Should Grant Ms. Maxwell's Other Requested Relief. 16 CONCLUSION 17 i EFTA00104412 TABLE OF AUTHORITIES Page

blunt the exculpatory significance of Accuser-4's omission; in fact, it underscores it. It is clear from the grand jury testimony of Special Agent Kuyrkendall that the FBI specifically asked Accuser-4 who scheduled her massage appointments 6 The government has provided only two quasi-Brady disclosures in t

it has identified. Because the information provided by these women goes directly to the question of Mr. Epstein's guilt or innocence, it is classic Brady information. We understand that the U.S. Attorney might not want to disclose impeachment information about their witnesses prior to a charge or dur

he Custodians of Records of the Corporations complete the Business Records Certifications and Inventory Forms and return everything to Special Agent Kuyrkendall at the Federal Bureau of Investigation, 505 South Flagler Drive, Suite 500, West Palm Beach, FL 33401- 5933. Thank you for your assistance with thi

s regarding Epstein not wanting underage girls providing him massages would have been required to be disclosed to Epstein's defense attorneys under Brady v. Maryland 373 U.S. 83 (1963). If the government ever chose to call her as a prosecution witness, the government would have been obligated to discl

those victims who have never reached out and asked to confer. Neither Jane Doe 1 nor Jane Doe 2 ever contacted AUSA Villafafia or FBI Special Agent Kuyrkendall regarding the case, despite being provided their phone numbers and addresses. D.E. 403-19,915. Since the Court's statutory interpretation of the te

reasonableness."); / Kyles v. Whitley, 514 U.S. 419, 432-33, 115 S. Ct. 1555, 1565, 131 L.Ed.2d 490 (1995) (under the Due Process Clause and 11 Brady v. Maryland, 373 U.S. 83, 83 S. Ct. 1194, 10 L.Ed.2d 215 (1963), prosecutors must disclose all evidence, upon request, that is favorable to the def

1232 language that demeans the harm they may have suffered." • "[W]e will not remove the language about contacting AUSA Villafana or Special Agent Kuyrkendall with questions or concerns. Again, federal law requires that victims have a 'reasonable right to confer with the attorney for the Government in th

mann v. Fla. Dep't of Colt, 940 F.3d 559, 580 (11th Cir. 2019) ("Although we conclude that the district court properly determined that Riechmann's Brady claim was procedurally defaulted, we will briefly address the substance of the underlying Brady claim, which we alternatively find lacks merit.");

tim Notification Letter. She stated that the U.S. Attorney's Office would "not remove the language about contacting AUSA Villafafia or Special Agent Kuyrkendall with questions or concerns." Again, AUSA Villafafia wrote that "federal law requires that victims have the `reasonable right to confer with the att

s representing criminals, your Office would promptly turn over to us all information in its possession that was helpful to these criminals under the Brady and Giglio decisions. We asked your Office to extend to the victims the same assistance that it would provide to criminals — i.e., we asked and t

By: Kuyrkendall B Nesbit Case ID #: 31E-MM-108062v/ Attn: SSA Date: 01/08/2010 From: Miami PB-1, Palm Beach County RA Contact: SA E. Nesb i ;tt Kuyrkendall, i----- Title: JEFFREY EPSTEIN; WSTA - CHILD PROSTITUTION Synopsis: To request transfer of above captioned case due to agent's transfer to anothe