solved by the non-prosecution agreement entered into by Epstein and the U.S. Attorney's Office in September 2007. 88. In mid-June 2008, I contacted AUSA Villafafia to inform her that I represented Jane Doe No. 1 and, later, Jane Doe No. 2. I asked to meet to provide information about the federal crimes committ

ified victims in connection with the criminal investigation. Pro bono counsel was able to assist Jane Doe No. 1 in avoiding the improper deposition. AUSA Villafafia secured pro bono counsel by contacting Meg Garvin, Esq. of the the National Crime Victims' Law Center in Portland, Oregon, which is based in the Le

ters provided the name of the FBI agent handling the Epstein investigation (Nesbitt Kurykendall), her phone number, the identity of the prosecutor (AUSA Villafafia), and her phone number. Although Jane Doe No. I and Jane Doe No. 2 had been furnished the means to contact the FBI agent and the prosecutor regardi

never. Jeffrey is an awesome man, no. Id. at 22. At the end of her interview, Jane Doe No. 2 was asked if she had any questions for the agents or AUSA Villafafia. Id. at 57. Jane Doe No. 2 responded: A. No, but I hope — I hope Jeffrey, nothing happens to Jeffrey because he's an awesome man and it would real

t. Next, you assert that our letter mischaractcrizes Mr. Epstein's obligation to pay damages to the victims. To avoid that suggestion, I have asked AUSA Villafafia to simply quote the terms of the Agreement directly into the Notification Letter. We also have no objection to referring to Mr. Epstein as a "sexua

hment, not the civil litigation. Those questions are appropriately directed to law enforcement. If questions arise related to the civil litigation, AUSA Villafafia and Special Agent ICuyrkendall will recommend that the victims direct those questions to Mr. Josefsberg. I have attached a revised letter incorpora

and federal attorneys or agents. We have no objection to sending the letters through the mail' but we will not remove the language about contacting AUSA Villafafia or Special Agent Kuyrkendall with questions or concerns. Again, federal law requires that victims have the "reasonable right to confer with the att

ng suit. A violation of this provision, by contesting jurisdiction or otherwise, will be considered a material breach. It had been my suggestion to AUSA Villafafia that we simply quote the terms of the Agreement directly into the Notification Letter or include a photocopy of the relevant sections. If you would

ecl. at 6-14, 31. The second sentence in paragraph 96 is denied as Jane Doe 1 and Jane Doe 2 never asked to confer or consult with the FBI or with AUSA Villafafia about the prosecution of Epstein despite having been informed of a victim's right to confer and having been provided with contact information for S

's crimes against them, remained on-going in the first half of 2008; and (c) Jane Doe 1 and Jane Doe 2 had been provided information for contacting AUSA Villafafia if they wanted to confer. See Villafafia Decl. at 115, 35-36. 97. The Government denies that Jane Doe 1 met with multiple AUSAs from the U.S. Atto

riminal case against Jeffrey Epstein and she wanted my assistance in getting some answers. 11. In mid-June 2008, I had several telephone calls with AUSA Villafafia. In her affidavit, Villafafia only recounts certain fragments of these calls. (See DE 403-19, para. 37-38). However, to the extent the substance o

and growing number of identified victims and sentencing guidelines if found guilty of committing a sex- trafficking offense against just one victim. AUSA Villafafia would not provide many answers or comments to any of my direct questions and, in fact, expressed that while she wished she could answer my question

on to be resolved without charges being filed against Epstein. Several months after that videotaped interview, Attorney Eisenberg was asked whether AUSA Villafafia could contact Jane Doe No. 2 directly and was told that contact had to occur via Mr. Eisenberg. Ex. S. 1 14. In seeking summary judgment, Jane Doe

No. 2 refused to be interviewed by the FBI and U.S. Attorney's Office unless she was granted immunity. Ex. A, Sept. 21, 2006 Ltr. from Eisenberg to AUSA Villafafia; Ex. S, 6-12. Thus, she was unwilling to provide any information regarding her encounters with Epstein unless she was assured her statements would

No. 2 refused to be interviewed by the FBI and U.S. Attorney's Office unless she was granted immunity. Ex. A, Sept. 21, 2006 Is. from Eisenberg to AUSA Villafafia; Ex. S, ¶16-12. Thus, she was unwilling to provide any information regarding her encounters with Epstein unless she was assured her statements would

on to be resolved without charges being filed against Epstein. Several months after that videotaped interview, Attorney Eisenberg was asked whether AUSA Villafafia could contact Jane Doe No. 2 directly and was told that contact had to occur via Mr. Eisenberg. Ex. S,1 14. In seeking summary judgment, Jane Doe N

A00177258 Case 9:08-cv-8 •KAM Document 19 Entered on FLSD Docket 08/C i8 Page 7 of 16 assist Jane Doe #1 in avoiding the improper deposition. AUSA Villafafia secured pro bono counsel by contacting Meg Garvin, Esq. of the National Crime Victims' Law Institute in Portland, Oregon, which is based in the Lew

ed to meet to provide information about the federal crimes committed by Epstein, hoping to secure a significant federal indictment against Epstein. AUSA Villafafia and Mr. Edwards discussed the possibility of federal charges being filed. At the end of the call, AUSA Villafafia asked Mr. Edwards to send any inf

solved by the non-prosecution agreement entered into by Epstein and the U.S. Attorney's Office in September 2007. 88. In mid-June 2008, I contacted AUSA Villafafia to inform her that I represented Jane Doe No. 1 and, later, Jane Doe No. 2. I asked to meet to provide information about the federal crimes committ

ified victims in connection with the criminal investigation. Pro bono counsel was able to assist Jane Doe No. I in avoiding the improper deposition. AUSA Villafafia secured pro bono counsel by contacting Meg Garvin, Esq. of the the National Crime Victims' Law Center in Portland, Oregon, which is based in the Le

's crimes against them, remained on-going in the first half of 2008; and (c) Jane Doe 1 and Jane Doe 2 had been provided information for contacting AUSA Villafafia if they wanted to confer. See Villafafia Decl. at 115, 35-36. 97. The Government denies that Jane Doe 1 met with multiple AUSAs from the U.S. Atto

ecl. at 6-14, 31. The second sentence in paragraph 96 is denied as Jane Doe 1 and Jane Doe 2 never asked to confer or consult with the FBI or with AUSA Villafafia about the prosecution of Epstein despite having been informed of a victim's right to confer and having been provided with contact information for S

red on FLSD Docket 07)15/2008 Page 4 of 8 %se January 10, 2008, and to S.R. on May 30, 2008. Villafafia Decl., 1 3. Throughout the investigation, AUSA Villafafia and the FBI's Victim-Witness Specialist had contact with C.W. Villafafia Decl., 1 4. Earlier in the investigation, T.M. was represented by James Ei

deral indictment against Epstein. AUSA Villafafia and Mr. Edwards discussed the possibility of federal charges being filed. At the end of the call, AUSA Villafafia asked Mr. Edwards to send any information that he wanted considered by the U.S. Attorney's Office in determining whether to file federal charges. B

later than January 25, 2007, so that we may review them in advance of the meeting on February 1st. If you have any other questions, please contact AUSA Villafafia directly at Sincerely, R. Alexander Acosta United States Attorney By: Assistant United States Attorney Enclosure cc: A. Marie Villafaila EFTA

ng suit. A violation of this provision, by contesting jurisdiction or otherwise, will be considered a material breach. It had been my suggestion to AUSA Villafafia that we simply quote the terms of the Agreement directly into the Notification Letter or include a photocopy of the relevant sections. If you would

hment, not the civil litigation. Those questions are appropriately directed to law enforcement. If questions arise related to the civil litigation, AUSA Villafafia and Special Agent Kuyrkendall will recommend that the victims direct those questions to Mr. Josefsberg. I have attached a revised letter incorporat

Award. He also pointed out that the parents of the victim in the Texas man’s case wrote a letter thanking Villafana at the conclusion of the case. “AUSA Villafafia has spent her 18-year career advocating tirelessly on behalf of victims of some of the most serious crimes in Florida, and has received numerous awar

arie Villafafia to inform her that I represented Jane Doe #1.) and, later, Jane Doe #2@@M). I asked to meet to provide information regarding Epstein. AUSA Villafafia did not advise me that a plea agreement had already been negotiated with Epstein’s attomeys that would block federal prosecution. AUSA Villafafia did

t the United States Attorney's Office prepared negotiated plea agreements containing these charges. For example, in a September 18, 2007, email from AUSA Villafafia to Lefkowitz (attached hereto as Exhibit "H"), she attached the proposed plea agreement describing Epstein's witness tampering as follows: "UNITED

plained that the Government was incentivizing the victims to overstate their involvement with Epstein in order to increase their damage claims. Id. AUSA Villafafia and the FBI agents concluded that informing additional victims could compromise both the witnesses' credibility and the agents' credibility at a la