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

ss Specialist. Attached hereto arc 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. I ). Your Affiant's letter to T.M. was hand-delivered by myself to T.M. at the time that she was interviewed (Ex. 2).

r coercion and specifically states that he never pulled her close to him in a sexual way, p. 21. As to the other girls that were brought, including C.W., L.M. said that some of the girls were topless, and some were not and Epstein didn't mind, p. 23; she admits having brought approximately 30 plus g

ls were topless, and some were not and Epstein didn't mind, p. 23; she admits having brought approximately 30 plus girls to Epstein; she admits that C.W. was her baby's father's girlfriend at the time that she met her. She testified that "None of my girls ever had a problem and they call me. They'd b

use we did not believe the Crime Victims Rights Act applied. They also still want a free transcript and any FBI 302's prepared for the meeting with C.W. I intend to call Edwards on Monday and tell him we cannot produce the agreement due to the confidentiality provision (and not due to a lack of cour

ding until there was an actual agreement. My understanding is that the victims were not consulted (with the exception of the FBI agents meeting with C.W. in September 2007), because we did not believe the Crime Victims Rights Act applied. They also still want a free transcript and any FBI 302's prepa

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).?

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

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

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

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

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

regard to C.W., FBI Special Agents Kuyrkendall and Richardson met with her in September 2007 to advise her of the agreement reached in state court. C.W. claims she understood them to mean the federal proceeding was still a possibility. I think we have little to gain by trying to reach an agreement o

n evidentiary hearing is necessary. We don't dispute that none of the victims were notified of the impending agreement with Epstein. With regard to C.W., FBI Special Agents Kuyrkendall and Richardson met with her in September 2007 to advise her of the agreement reached in state court. C.W. claims she

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

. 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

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

ent, none of Mr. Edwards' clients had expressed a desire to be consulted prior to the resolution of the federal investigation. Id. In October 2007, C.W. was not represented by counsel. a. y 8. She was given telephonic notice of the agreement, as were three other victims. Id. These four individuals we

ed to the victim by both the FBI Victim-Witness Specialist and AUSA Villafafa. ILI 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 FBI. and the letter to T.M. was hand-delivered by

were provided to the victim by both the FBI Victim-Witness Specialist and AUSA al 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 FBI. and the letter to T.M. was hand-delivered by

ent, none of Mr. Edwards' clients had expressed a desire to be consulted prior to the resolution of the federal investigation. Id. In October 2007, C.W. was not represented by counsel. Id.. $ 8. She was given telephonic notice of the agreement, as were three other victims. Id. These four individuals

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

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

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

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

ess Specialist. Attached hereto are copies of the letters provided to Bradley Edwards' three clients, T.M., C.W., and S.R.' Your A Mantis letter to C.W. was provided by the FBI. (Ex. I ). Your Affiant's letter to T.M. was hand-delivered by myself to T.M. at the time that she was interviewed (Ex. 2).

eference to the ages of the minor victims and, upon conviction, did not require sex offender registration. 3. Jane Doe #1 is a woman with initials C.W., and Jane Doe #2 is a woman with initials T.M. Both were victims of Epstein=s while they were minors beginning when they were fifteen years old.

eems to assert that Petitioner was given some sort of notice about tl-e plea agreement about nine months ago. Gov't Response at 7 ("In October 2007, C.W. was not represented by counsel. . . . She was given telephonic notice of the agreement, as were three other 10 EFTA00235258 Case 9:08-cv-80736-K

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

f Epstein's attorneys (and apparently acceded to by the U.S. Attorney's Office). Second, Ms. had EFTA00206747 said that "four victims [including C.W. — i.e., Jane Doe #1] were contacted and these provisions were discussed," it was not clear what provisions had in fact been discussed. 46. On Decem

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