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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 Dexter
effrey Epstein the sex offender, rather than the prosecutors who work for you. Today we had a telephone conference call with two of your attorneys, Dexter Lee and Marie Villafana, in which they told us that we would not be receiving any cooperation from your Office on our CVRA case and that, in short, we
ld, withhold from the victims information in your Office's possession that would support their claims under the CVRA. After receiving approval from Dexter and Marie, we wanted to write to you personally in one last effort to see if we can narrow our differences on these two issues and avoid a disappoin
e attorneys representing criminals, the Office would promptly turn over all information in its possession that was helpful to these criminals under Brady v. Maryland, 373 U.S. 83 (1963), and related decisions. Victims' counsel asked the Office to extend to the victims the same assistance that it would
on the case (including, but not limited to, federal prosecutors Alexander Acosta, Jeffrey H. Sloman, Matt Menchel, Andy Lourie, Ann Marie Villafana, Dexter Lee, and Bruce Reinhart and state prosecutors Dahlia Weiss, Lana Belolovek, and others involved in the Epstein investigation) and defense attorneys rep
system: Dexter Lee A. Marie Villafafla 500 S. Australian Ave., Suite 400 West Palm Beach, FL 33401 (561) 820-8711 Fax: (561) 820-8777 E-mail: Dexter.Lec(e)usdoj.gov E-mail: [email protected] Attorneys for the Government Roy Black, Esq. Jackie Perczek, Esq. Black, Srebnick, Korns
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
ana to request for conference call prior to call with Roy Black B-76 8/13/2008 Email from Bob Senior to Karen Atkinson, Alex Acosta, Jeff Montan, Dexter Lee, and Marie Villalatla regarding Epstein and call with Jay' Lefkowitz B-77 8/13/2008 Email response from Alex Acosta to Karen Atkinson, Bob Senior,
respondence and telephone conference with J. Lefkowitz B-79 8/14/2008 Villafana -;enior Email response to 8/14/08 email from Villafaiia advising Dexter disagrees with strategy 8/14/2008 Villafana, cc: Atkinson Lefkowitz Email re Follow up point regarding victims B-80 8/14/2008 Status Conf be
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
Y that on October 10, 2017, the foregoing was filed with the Clerk of the Court and served on counsel on the attached service list using CM/ECF. Is/Dexter A. Lee Dexter A. Lee Assistant United States Attorney 30 EFTA00800037 Case 9:08-cv-80736-KAM Document 427 Entered on FLSD Docket 10/10/2017 Page 31 of 3
under the CVRA, including the Government's obligation to treat the victim with fairness. Doc. #50. The victims also argued that the Government has "Brady" obligations to crime victims not less than criminal defendants that apply regardless of any discovery obligations. Id. This Court has reserved ruli
the following using the Court's CM/ECF system: Dexter Lee A. Marie Villafafia Assistant U.S. Attorneys 5
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
FY that on October 6, 2017, the foregoing was filed with the Clerk of the Court and served on counsel on the attached service list using CM/ECF. Is/Dexter A. Lee Dexter A. Lee Assistant United States Attorney 30 EFTA00800005 Case 9:08-cv-80736-KAM Document 425-1 Entered on FLSD Docket 10/06/2017 Page 32 of
ys representing criminals, your 0 ice 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 to vol
ld, withhold from the victims information in your Office's possession that would support their claims under the CVRA. After receiving approval from Dexter and Marie, we wanted to write to you personally in one last effort to see if we can narrow our differences on these two issues and avoid a disappoin
e attorneys representing criminals, the Office would promptly turn over all information in its possession that was helpful to these criminals under Brady. Maryland, 373 U.S. 83 (1963), and related decisions. Victims' counsel asked the Office to extend to the victims the same assistance that it would p
tr.if"'" • Case 9:08-cv-80736-KAM Docurnor450L1A w Eptyppeop FLSD Docket 03121/2011 Page 1 of 2 • aitadedataa% • AND ASSOCIATES October 9, 2008 Dexter Lee, AUSA United States Attorney's Office 99 N.E. 4th Street Miami, Florida 33132 Re: Jane Doe # and Jane Doe #2 United States of America Case No.
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
he asked of me. I immediately documented this conversation and informed the U.S. Attorney who informed Senior Litigation Counsel and Ethics Advisor Dexter Lee. AUSA Lee opined that he did not see a conflict. As soon as I -became aware of these allegations, I reported myself to the Office of Professional R
Entities connected to both Brady and Dexter Lee

Jeffrey Epstein
PERSON
A. Marie Villafana
PERSON
Bradley Edwards
PERSON
Alexander Acosta
PERSON
Jeffrey Sloman
PERSONJane Doe
PERSON
Kenneth Marra
PERSONKaren
PERSON
Karen Atkinson
PERSON
Paul Cassell
PERSONMarie
PERSON
United States
LOCATIONLeon Black
PERSONJack Goldberger
PERSON
George W. Bush
PERSONRoy Black
PERSONthe Southern District
LOCATION
Department of Justice
ORGANIZATION
Jay Lefkowitz
PERSONMaria Farmer
PERSON