Epstein Secrets

gainst disclosure are beside the point.") (citing Douglas Oil Co. of Calif. v. Petrol Stops Nw., 441 U.S.

In October 2007, shortly after the agreement was signed, four victims were contacted and these provisions were discussed. One of those victims was C.W. who at the time was not represented, and she was given notice of the agreement. Notice was also provided of an expected change of plea in October 2

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. 11. Your Affiant's letter to T.M. was hand-delivered by myself to T.M. at the time that she was interviewed (Ex. 2).2

8, 1994. William H. Ogle, Ormond Beach, FL. W. Douglas Childs, Jacksonville, FL. Jonathan D. Kaney Jr.,

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

gainst disclosure are beside the point.") (citing Douglas Oil Co. of Calif. I Petrol Stops Nw., 441 U.S. 2

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).2

. on May 30, 2008 (Ex. 5). 4. Throughout the investigation, the FBI agents, the FBI's Victim-Witness Specialist, and your A Mani 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

gainst disclosure are beside the point.") (citing Douglas Oil Co. of Calif, Petrol Stops Nw., 441 U.S. 211

on May 30, 2008 (Ex. 5). 4. Throughout the investigation, the FBI agents, the FBI's Victim-Witness Specialist, and your A (tient had contact with C.W. and II Attorney Edwards' other client, was represented by counsel and, accordingly, all contact with MB was made through that attorney. That attor

nds upon the secrecy of grand jury proceedings," Douglas Oil Co. v. Petrol Stops Northwest, 441 U.S. 211,

r victims [including C.W.J 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 above

nds upon the secrecy of grand jury proceedings," Douglas Oil Co. I. Petrol Stops Northwest, 441 U.S. 211,

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 above