Epstein Secrets

nue, Suite 2 Fort Lauderdale, Florida 33301 Fax: E-mail: Paul G. Cassell S.J. Quinney College of Law at the University of Utah 332 S. 1400 E. Salt Lake City, Utah 84112 Fax: E-mail: Attorneys for Jane Doe # 1 and Jane Doe # 2 54 EFTA00078888

rime. The letters specifically advised that if the Petitioners felt that they were "being threatened or harassed, then please contact Special Agent Kuyrkendall or [AUSA Villafaiia]. (See DE14, Exs. 1 and 2.) It is further undisputed that Jane Doe #1 actually took advantage of the offer of protection when E

ane 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 felt that they were "being threa

: 542075 E-mail: [email protected] and Paul G. Cassell Pro Hac Vice S.J. Quinney College of Law at the University of Utah 332 S. 1400 E. Salt Lake City, UT 84112 Telephone: 801-585-5202 Facsimile: 801-585-6833 E-Mail: [email protected] Attorneys for Jane Doe #1 and Jane Doe #2 41 EFTA001770

rime. The letters specifically advised that if the Petitioners felt that they were "being threatened or harassed, then please contact Special Agent Kuyrkendall or [AUSA Villafaiial. (See DE14, Exs. I and 2.) It is further undisputed that Jane Doe ttl actually took advantage of the offer of protection when

ane 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 felt that they were "being threa

RMAN, P.L. 425 North Andrews Avenue, Suite 2 Paul G. Cassell Pro Hac Vice S.J. Quinney College of Law at the University of Utah 332 S. 1400 E. Salt Lake City, Utah 84112 Attorneys for Jane Doe 1 and Jane Doe 2 Jacqueline Perczek BLACK SREBNICK KORNSPAN & STUMPF 201 S. Biscayne Boulevard, Suite 1300 If

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

cket 02/01/2016 Page 11 of 11 Fax: (954) 524-2822 E-mail: Paul G. Cassell S.J. Quinney College of Law at the University of Utah 332 S. 1400 E. Salt Lake City, Utah 84112 (801) 585-5202 Fax: (801) 585-6833 E-mail: [email protected] Attorneys for Jane Doe # 1 and Jane Doe # 2 11 EFTA00618032

nging a search has no right to depose the testifying government agents prior to the evidentiary hearing, petitioners have no right to depose Agents Kuyrkendall and Richards. Petitioners should not have more rights in the absence of a criminal prosecution against Epstein than they would have had he been for

ail:[email protected] Paul G Cassell [ATTORNEY TO BE NOTICED] S.J. Quinney College of Law At The University of Utah 383 S. University Street Salt Lake City, UT, USA 84112-0730 (801)-585-5202 Fax: (801)-585-2750 Email:[email protected] DEFENDANT ATTORNEY(S): John E. Stephenson, Jr. [ATTORNEY TO BE

tive-process privilege that may apply. It not protected by the attorney-client privilege, as the Government has not demonstrated that FBI agent Kuyrkendall provided this information in an attempt to secure legal advice or a legal opinion from the United States Attorney's Office. The correspondence

a 33301 Tel: E-mail: [email protected] Paul G. Cassell Pro Hac Vice S.J. Quinney College of Law at the University of Utah 332 S. 1400 E. Salt Lake City, Utah 84112 Tel: E-mail: [email protected] Attorneys for Jane Doe 1 and Jane Doe 2 Jacqueline Perczek BLACK SREBNICK KORNSPAN & STUMPF 201

o obtain information from Jane Doe No. 2. Ex. B; Ex. S,11[6-12. On April 24, 2007, Jane Doe No. 2 was interviewed by FBI Special Agents E. Nesbitt Kuyrkendall and Jason Richards and AUSA Marie Villafafia, in the presence of her attorney, James Eisenberg, Esq. Ex. C; Ex. R, 15; Ex. S, ¶ 12. Jane Doe No. 2 d

2820 Facsimile (954) 524-2822 E-mail: And Paul G. Cassell Pro Hac Vice S.J. Quinney College of Law at the University of Utah' 332 S. 1400 E. Salt Lake City, UT 84112 Telephone:801-585-5202 Facsimile:801-585-6833 [email protected] Attorneys for Jane Does 1 and 2 This daytime business addres

cription of the meeting, but 8 EFTA00597325 Case 9:08-cv-80736-KAM Document 417 Entered on FLSD Docket 08/11/2017 Page 9 of 33 citing only Agent Kuyrkendall's declaration recounting what he said, not what understanding Jane Doe I had). The parties agree that, during the time period before Epstein's entr

cognition of the constitutional principle of separation of powers. Attorneys and Law Firms *1198 Paul Cassell, University of Utah College of Law, SALT LAKE CITY, UT, Bradley James Edwards, EdwardsPottinger, LLC, FORT LAUDERDALE, FL, for Petitioner. Richard Christian Komando, Bradley Garrison & Komando, OR

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

4-2820 Fax: (954) 524-2822 E-mail: [email protected] Paul G. Cassell S.J. Quinney College of Law at the University of Utah 332 S. 1400 E. Salt Lake City, Utah 84112 (801) 585-5202 Fax: (801) 585-6833 E-mail: [email protected] Attorneys for Jane Doe # 1 and Jane Doe # 2 Roy Black, Esq. Jackie

viders can be provided to you, if you so desire. If you or your family is subjected to any intimidation or harassment, please contact Special Agent Kuyrkendall or myself immediately. It is possible that someone working on behalf of thc targets of the investigation may contact you. Such contact does not vio

4-2820 Fax: (954) 524-2822 E-mail: [email protected] Paul G. Cassell S.J. Quinney College of Law at the University of Utah 332 S. 1400 E. Salt Lake City, Utah 84112 (801) 585-5202 Fax: (801) 585-6833 E-mail: casselp(alaw.utah.edu Attorneys for Jane Doe # 1 and Jane Doe # 2 15 EFTA00184858 Case

ct me or Special Agen Kuyrkendall Sincerely, R. Alexandea United States Attorney By: A. Assistant United States Attorney cc: Special Agent.. Kuyrkendall, F.B.I. Ms. Clearetha Wright, Victim-Witness Coordinator, U.S. Attorney's Office US_Atty_Cor_00262 EFTA00184869 Case 9:08-cv-80736-KAM Document