Epstein Secrets

dgment should be denied. DATED: August 11, 2017 Respectfully Submitted. /s/ &alai 9. Same Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L. 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 And Paul G. Cassell Pro Hac Vice S.J. Quinney College of Law at the Uni

informed me that any resolution of the criminal matter was imminent at that time, nor even that such a resolution was being contemplated. In fact, Villafafia gave me the impression that the Federal investigation was on-going, very expansive, and continuously growing, both in the number of identified vict

Florida. Neither Doe 1 nor Doe 2 had any reason to believe that they were victims of a state crime that was being prosecuted. Based on everything Villafafia said, and could not say, there was no possible way I could have believed that this state plea could affect the federal investigation or the rights

se calls, the line prosecutor continually created the impression that no resolution of the case was imminent: During the telephone calls I had with Villafafia between mid and late June 2008, she never informed me that previously, in September 2007, the U.S. Attorney's Office had reached a non-prosecution

FLSD Docket 10/10/2017 Page 31 of 32 Attorneys for Intervenor Jeffrey Epstein SERVICE LIST Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, ■. 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 Paul G. Cassell Pro Hac Vice S.J. Quinney College of Law at the University

ent and learned that Epstein's state court change of plea hearing was scheduled for 8:30 a.m., Monday, June 30, 2008. D.E. 403-19 at 21, 1 38. AUSA Villafafia called attorney Edwards, told him of the June 30, 2008 hearing, and stressed the importance of the hearing.2 Thus, the government provided petitione

o pursue and foist himself upon 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 s

08-cv-80736-KAM Document 425-1 Entered on FLSD Docket 10/06/2017 Page 32 of 33 SERVICE LIST Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, 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

ent and learned that Epstein's state court change of plea hearing was scheduled for 8:30 a.m., Monday, June 30, 2008. D.E. 403-19 at 21, 1 38. AUSA Villafafia called attorney Edwards, told him of the June 30, 2008 hearing, and stressed the importance of the hearing.2 Thus, the government provided petitione

o pursue and foist himself upon 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 s

ered on FLSD Docket 08/11/2017 Page 10 of 11 Respectfully Submitted, /5/ Sal, P. Eeitualua Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L. 425 North Andrews Avenue, Suite 2 Fort Lauderdale. Florida 33301 Telephon Facsimile E-mail: And Paul G. Cassell Pro Hac Vice S.J. Quin

ame internal deliberations — representations that it now argues should lead the Court to grant summary judgment in this case. See, e.g., DE 403-19 (Villafafia affidavit — filed June 2, 2017). The Government cannot simultaneously assert work product protection over relevant documents concerning its internal

eys for Proposed Intervenors Roy Black et al. Respectfully Submitted, S/ Bradley J. Edwards Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, EFTA00615906 Case 9:00-cv-80736-KAM Document 205-1 Entered on FLSD Docket 10120/2014 Page 39 of 64 EXHIBIT 2 To Brad Edwards Affidavit EFTA0

of these 39 pages is: "File folder entitled 'CORR RE GJ SUBPOENAS' containing correspondence related to various grand jury subpoenas and attorney (Villafafia) handwritten notes." 64. Another good illustration of the inadequacies of the privilege log is provided on page 20 of the first privilege log, with

keted as of today's date, as timely filed. DATED: January 21, 2015. Respectfully Submitted, Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L. 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 Telephone (954) 524-2820 Facsimile (954) 524-2822 E-mail: brad(gpathtojus

of Florida 500 South Australian Avenue, Suite-400 West Palm Beach, Florida 33401 Jeffrey Epstein Dear Messrs. Sloman, Menchel and Lourie and Ms. Villafafia: We write as counsel to Jeffrey Epstein to follow-up on our meeting on June 26, 2007. We thought the meeting was extremely productive and appreciat

o. 08-80736-CIV-MARRA/MATTHEWMAN United States District Court, Southern District of Florida Brad Edwards, Esq., Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, P.L. 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 (954)524-2820 Fax: (954) 524-2822 E-mail: [email protected] Paul G.

to this litigation Box #1 P-001008 thru P-001056 File folder entitled "Notes from Fed Ex Records" containing handwritten and typed attorney (Villafafia) notes and screen shots of FedEx subpoena response electronic file Work Product 6(e) Contains information subject to investigative privilege. A

e materials at issue. DATED: August 16.2013 Respectfully Submitted, /s/ Bradley J. Edwards Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L. 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 Telephone (954) 524-2820 Facsimile (954) 524-2822 Florida Bar No.: 542075

hru summary chart, witness/victim names and Contains information and Anticipation of Litigation; Improper P-002386 contact list, attorney (Villafafia) documents subject to Invocation; Overriding Need; Claims Against handwritten notes, 302s, portions of state investigative privilege. Public Pro

ex offenses he committed against many children," said Bradley Edwards, the women's trial counsel and a partner at Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman in Fort Lauderdale. Edwards said the documents at this point will be disclosed only to the plaintiffs and will not become part of the public record

edi-te-disesss what-I-may-diselese-to,the-gek-regarding-the-agreemenWl-U:SrAnemeyls-Cerrespondenee at-1-56: 13. On about September 26, 2007, AUSA. Villafafia sent an e-mail to Lefkowitz, a copy of which is attached hereto as Exhibit in-whielt-she-etatedailiay—Can-you-give-me-a-eall at-564-209--Enentl-th

08-80736-CIV-MARRA/JOHNSON United States District Court, Southern District of Florida Bradley J. Edwards, Esq., Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, P.L. 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 (954) 524-2820 Fax: (954) 524-2822 E-mail: bradarloathtoiustice.com Paul

t position in this case, it is that this provision is not in fact part of the plea agreement in this case. If our understanding is correct, then Ms. Villafafia has filed a false affidavit with the court, albeit inadvertently. We respectfidly request that she file a new affidavit that corrects this false in