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FBI VOL00009
EFTA00193954
651 sivua
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Villafana, Ann Marie C. (USAFLS) From: Lee, Dexter (USAFLS) Sent: Wednesday, July 09, 2008 11:53 AM To: Villafana, Ann Marie C. (USAFLS); Acosta, Alex (USAFLS); Sloman, Jeff (USAFLS) Cc: Jacobus, Wendy (USAFLS) Subject: Brad Edwards' End Game Marie, Alex and Jeff, I have just spoken with Kim Herd at EOUSA regarding clearance to argue that no rights to consultation accrue until after charges have been filed. The argument is being considered by Criminal Division and OLP. Kim wanted to know what Edwards' objective in this case is, and whether he would agree to meet and try to resolve this. I told Kim that the only way to avoid our filing at 5:00 p.m. today is if Edwards' agree to a joint enlargement of time. How reasonable do you think Edwards is? Dexter 622 EFTA00194394
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Villafana, Ann Marie C. (USAFLS) From: Acosta, Alex (USAFLS) Sent: Wednesday, July 09, 2008 11:56 AM To: Lee, Dexter (USAFLS); Villafana, Ann Marie C. (USAFLS); Sloman, Jeff (USAFLS) Cc: Jacobus, Wendy (USAFLS) Subject: Re: Brad Edwards' End Game Not at all. We need to file today. Original Message From: Lee, Dexter (USAFLS) To: Villafana, Ann Marie C. (USAFLS); Acosta, Alex (USAFLS); Sloman, Jeff (USAFLS) Cc: Jacobus, Wendy (USAFLS) Sent: Wed Jul 09 11:52:46 2008 Subject: Brad Edwards' End Game Marie, Alex and Jeff, I have just spoken with Kim Herd at EOUSA regarding clearance to argue that no rights to consultation accrue until after charges have been filed. The argument is being considered by Criminal Division and OLP. Kim wanted to know what Edwards' objective in this case is, and whether he would agree to meet and try to resolve this. I told Kim that the only way to avoid our filing at 5:00 p.m. today is if Edwards' agree to a joint enlargement of time. How reasonable do you think Edwards is? Dexter 621 EFTA00194395
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Recipient Read Acosta, Alex (USAFLS) Read: 7/9/200812:01 PM Lee, Dexter (USAFLS) Read: 7/9/2008 12:01 PM Sloman, Jeff (USAFLS) Read: 7/9/2008 12:00 PM Jacobus, Wendy (USAFLS) Read: 719/2008 12:12 PM 620 EFTA00194396
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How reasonable do you think Edwards is? Dexter Tracking: 619 EFTA00194397
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Villafana, Ann Marie C. (USAFLS) From: Villafana, Ann Marie C. (USAFLS) Sent: Wednesday, July 09, 2008 12:00 PM To: Acosta, Alex (USAFLS); Lee, Dexter (USAFLS); Sloman, Jeff (USAFLS) Cc: Jacobus, Wendy (USAFLS) Subject: RE: Brad Edwards' End Game I have talked to Brad and his heart seems to be in the right place, he just has gotten himself a bit too worked up over this. The agents and I (and Karen, I think) would be happy to meet with him and his clients. The problem is that there is nothing to discuss -- the agreement has already been signed and our investigation is closed. In light of that, I don't think a meeting would satisfy him because he seems to believe that his petition can undo what has been done. A. Marie Villafaha Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 Phone 561 209-1047 Fax 561 820-8777 Original Message From: Acosta, Alex (USAFLS) Sent: Wednesday, July 09, 2008 11:56 AM To: Lee, Dexter (USAFLS); Villafana, Ann Marie C. (USAFLS); Sloman, Jeff (USAFLS) Cc: Jacobus, Wendy (USAFLS) Subject: Re: Brad Edwards' End Game Not at all. We need to file today. Original Message From: Lee, Dexter (USAFLS) To: Villafana, Ann Marie C. (USAFLS); Acosta, Alex (USAFLS); Sloman, Jeff (USAF LS) Cc: Jacobus, Wendy (USAFLS) Sent: Wed Jul 09 11:52:46 2008 Subject: Brad Edwards' End Game Marie, Alex and Jeff, I have just spoken with Kim Herd at EOUSA regarding clearance to argue that no rights to consultation accrue until after charges have been filed. The argument is being considered by Criminal Division and OLP. Kim wanted to know what Edwards' objective in this case is, and whether he would agree to meet and try to resolve this. I told Kim that the only way to avoid our filing at 5:00 p.m. today is if Edwards' agree to a joint enlargement of time. 618 EFTA00194398
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Villafana, Ann Marie C. (USAFLS) From: Lee, Dexter (USAFLS) Sent: Wednesday, July 09, 200812:08 PM To: Villafana, Ann Marie C. (USAFLS); Acosta, Alex (USAFLS); Sloman, Jeff (USAFLS) Cc: Jacobus, Wendy (USAFLS) Subject: Latest Version Colleagues, Attached please find the latest version of the government's response. I have added a new Section III, which details the efforts made by Marie in maintaining contact with T.M., C.W., and S.R. Dexter victim_resp_USA rev corrected (... 617 EFTA00194399
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Villafana, Ann Marie C. (USAFLS) From: Villafana, Ann Marie C. (USAFLS) Sent: Wednesday, July 09, 2008 12:15 PM To: Lee, Dexter (USAFLS) Subject: Emailing: victim_resp_USArev corrected (3).wpd Attachments: victim_resp_USArev corrected (3).wpd Hi Dexter -- I caught one date error and an important "not" in the last section - - as far as I know, Edwards did NOT make contact with the State Attorney's Office. The message is ready to be sent with the following file or link attachments: victim_resp_USArev corrected (3).wpd Note: To protect against computer viruses, e-mail programs may prevent sending or receiving certain types of file attachments. Check your e-mail security settings to determine how attachments are handled. 616 EFTA00194400
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Recipient Road Acosta, Alex (USAFLS) Read: 719/20081:25 PM Lee, Dexter (USAFLS) Read: 7/9/2008 12:22 PM Sloman, Jeff (USAFLS) Read: 7/9/2008 2:05 PM Atkinson, Karen (USAFLS) 615 EFTA00194401
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Villafana, Ann Marie C. (USAFLS) From: Villatana, Ann Marie C. (USAFLS) Sent: Wednesday, July 09, 2008 12:22 PM To: Acosta, Alex (USAFLS); Lee, Dexter (USAFLS) Cc: Sloman, Jeff (USAFLS); Atkinson, Karen (USAFLS) Subject: Revised Declaration I removed the sentence about why the Palm Beach Police contacted FBI for assistance. I notice that the language regarding my securing pro bono counsel for C.W. was removed. I think it shows how far we went out of our way to protect the victims, especially Mr. Edwards' clients. Is it alright to put it back in? A. Marie Villafana Assistant U.S. Attorney 561 209-1047 Tracking: 614 EFTA00194402
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so.uu rnA poloODU640 USAO WPB CONFRM TRANSMISSION OK ********************* *** TX REPORT *** *Its*************ssxs* TX/RX NO. 0708 CONNECTION TEL. 19549241530. SUBADDRESS CONNECTION ID ST. TIME 07/09 14:59 USAGE T 01'11 PGS. SENT 5 RESULT OK United States Attorney's Office Southern District of Florida 500 S. Australian Ave.; Suite 400 West Paint Beach,.FL 33401-6235 • DATE: r TO: (3pa_awarol ORGANIZATION: FAX #: SUBJECT: FROM: MarcA IA/ (561) 820;8711 (561) 820-8777 (Fax) 4. NUMBER OF PAGES. INCLUDING THIS PAGE: COMMENTS: si EFTA00194403
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rah DOLOUOUBVI USXO WPB CONFRM TRANSMISSION OK ***************t4.4*** It** TX REPORT *** ********************* TX/RX NO 0708 CONNECTION TEL 19549241530 SUBADDRESS CONNECTION ID ST. TIME 07/09 14:59 USAGE T 01'11 PGS. SENT RESULT OK United. States Attorney's Office Srill &ern District of Florida 5011 S. Australian Ave., Suite 400 West ?atm Beach, FL 33401-6235 . DATE. —ilgior 1O. rtkot-chuyan ORGANIZATION: • • - @jolt: rt FAY, #- SUBJECT: FROM: Matiat VII (561) 820-8711 (561) 820-8777 (Fax) NUMBER OF PAGES. INCLUDING THIS PAGE: COMMENTS: 1. 'C 4. EFTA00194404
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U.S. Department of Justice United States Attorney Southern District of Florida 500 South Australian Ave., Suite 400 West Palm Beach, FL 33401 (561)820-8711 Facsimile: (561) 820-8777 July 9, 2008 VIA FACSIMILE Brad Edwards, Esq. The Law Offices of Brad Edwards & Associates, LLC 2028 Street, Suite 202 Hollywood, Florida 33020. Re: Jeffrey Epstein/MEM NOTIFICATION OF IDENTIFIED VICTIM Dear Mr. Edwards: By virtue of this letter, the United States Attorney's Office for the Southern District of Florida asks that you provide the following notice to your client, On June 30, 2008, Jeffrey Epstein (hereinafter referred to as "Epstein) entered a plea of guilty to violations of Florida Statutes Sections 796.07 (felony solicitation of prostitution) and 796.03 (procurement of minors to engage in prostitution), in the 15th Judicial Circuit in and for Palm Beach County (Case Nos. 2006-cf-009454AXXXMB and 2008-cf- 009381=O(MB) and was sentenced to a term of twelve months' imprisonment to be followed by an additional six months' imprisonment, followed by twelve months of 1 Community Control 1, with conditions of community confinement imposed by the Court. • In light of the entry of the guilty plea and sentence, the United States has agreed to defer federal prosecution in favor of this state plea and sentence, subject to certain conditions. One such condition to which Epstein has agreed is the following: "Any person, who while a minor, was a victim of a violation of an offense enumerated in Title 18, United States Code, Section 2255, will have the same rights to proceed under Section 2255 as she would have had, if Mr. Epstein EFTA00194405
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BRAD EDWARDS, ESQ. NOTIFICATION OF IDENTIFIED VICTIM JULY 9, 2008 PAGE 2 OF 2 had been tried federally and convicted of an enumerated offense. For purposes of implementing this paragraph, the United States shall provide Mr. Epstein's attorneys with a list of individuals whom it was prepared to name in an Indictment as victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this provision, including any authority determining which evidentiary burdens if any a plaintiff must meet, shall consider that it is the intent of the parties to place these identified victims in the same position as they would have been had Mr. Epstein been convicted at trial. No more; no less." Through this letter, this Office hereby provides Notice that your client, is an individual whom the United States was prepared to name as a victim of an enumerated offense. Should your client decide to file a claim against Jeffrey Epstein, his attorney, Jack Goldberger, asks that you contact him at Atterbury Goldberger and Weiss, 250 Australian Avenue South, Suite 1400, West Palm Beach, FL 33401, (561) 659-8300. Please understand that neither the U.S. Attorney's Office nor the Federal Bureau of Investigation can take part in or otherwise assist in civil litigation; however, if you do file a claim under 18 U.S.C. § 2255 and Mr. Epstein denies that your client is a victim of an enumerated offense, please provide notice of that denial to the undersigned. Please thank your client for all of her assistance during the course of this examination and express the heartfelt regards ofSt self and Special Agents Kuyrkendall and Richards for the health and well-being of Ms. M. R. ALEXANDER ACOSTA UNITED STATES ATTORNEY By: A. MARIE VILLAFANA ASSISTANT U.S. ATTORNEY cc: • Jack Goldberger, Esq. EFTA00194406
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U.S. Department of Justice United States Attorney Southern District of Florida 500 South Australian Ave, Suite 400 West Palm Beach, FL 3340! (561)820-8711 Facsimile: (561)8204777 July 9, 2008 VIA FACSIMILE Brad Edwards, Esq. The Law Offices of Brad Edwards & Associates, LLC 2028 MIEStreet, Suite 202 Hollywood, Florida 33020. Re: jeffreLS'IN OF IDENTIFIED VICTIM Dear Mr. Edwards: By virtue of this letter, the United States Attorney's Office fo istrict of Florida asks that you provide the following notice to your client, On June 30, 2008, Jeffrey Epstein (hereinafter referred to as "Epstein) entered a plea of guilty to violations of Florida Statutes Sections 796.07 (felony solicitation of prostitution) and 796.03 (procurement of minors to engage in prostitution), in the 15th Judicial Circuit in and for Palm Beach County (Case Nos. 2006-cf-009454AXXXMB and 2008-cf- 009381AXXXMB) and was sentenced to a term of twelve months' imprisonment to be followed by an additional six months' imprisonment, followed by twelve months of Community Control 1, with conditions of community confinement imposed by the Court. In light of the entry of the guilty plea and sentence, the United States has agreed to defer federal prosecution in favor of this state plea and sentence, subject to certain conditions. One such condition to which Epstein has agreed is the following: "Any person, who while a minor, was a victim of a violation of an offense enumerated in Title 18, United States Code, Section 2255, will have the same rights to proceed under Section 2255 as she would have had, if Mr. Epstein EFTA00194407
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BRAD EDWARDS, ESQ. NOTIFICATION OF IDENTIFIED VICTIM...BM JULY 9, 2008 PAGE 2 OF 2 had been tried federally and convicted of an enumerated offense. For purposes of implementing this paragraph, the United States shall provide Mr. Epstein's attorneys with a list of individuals whom it was prepared to name in an Indictment as victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this provision, including any authority determining which evidentiary burdens if any a plaintiff must meet, shall consider that it is the intent of the parties to place these identified victims in the same position as they would have been had Mr. Epstein been convicted at trial. No more; no less." Through this letter, this Office hereby provides Notice that your client, MIS is an individual whom the United States was prepared to name as a victim of an enumerated offense. Should your client decide to file a claim against Jeffrey Epstein, his attorney, Jack Goldberger, asks that you contact him at Atterbuty Goldberger and Weiss, 250 Australian Avenue South, Suite 1400, West Palm Beach, FL 33401, (561) 659-8300. Please understand that neither the U.S. Attorney's Office nor the Federal Bureau of Investigation can take part in or otherwise assist in civil litigation; however, if you do file a claim under 18 U.S.C. § 2255 and Mr. Epstein denies that your client is a victim of an enumerated offense, please provide notice of that denial to the undersigned. Please thank your client for all of her assistance during the course of this examination and express the heartfelt regards of Special Agents Kuyrkendall and Richards for the health and well-being of Ms. IL ALEXANDER ACOSTA UNITED STATES ATTORNEY By: A. MARIE VTLLAFAICIA ASSISTANT U.S. ATTORNEY ec: Jack Goldberger, Esq. EFTA00194408
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U.S. Department of Justice ftE COB United States Attorney Southern District of Florida SOO South Australian Ave.. Suite 400 West Palm Beach FL 33401 (561) 820-8711 Facsimile: (561) 8204777 July 9, 2008 VIA FACSIMILE Brad Edwards, Esq. The Law Offices of Brad Edwards & Associates, LLC 2028 ME Street, Suite 202 Hollywood, Florida 33020. Re: Jeffrey Epstein/ NOTIFICATION OF IDENTIFIED VICTIM Dear Mr. Edwards: By virtue of this letter, the United States Attorney's Office for the Southern District of Florida asks that you provide the following notice to your client, On June 30, 2008, Jeffrey Epstein (hereinafter referred to as "Epstein) entered a plea of guilty to violations of Florida Statutes Sections 796.07 (felony solicitation of prostitution) and 796.03 (procurement of minors to engage in prostitution), in the 15th Judicial Circuit in and for Palm Beach County (Case Nos. 2006-cf-009454AXXXMB and 2008-cf- 009381AXXXMB) and was sentenced to a term of twelve months' imprisonment to be followed by an additional six months' imprisonment, followed by twelve months of Community Control 1, with conditions of community confinement imposed by the Court. In light of the entry of the guilty plea and sentence, the United States has agreed to defer federal prosecution in favor of this state plea and sentence, subject to certain conditions. One such condition to which Epstein has agreed is the following: "Any person, who while a minor, was a victim of a violation of an offense enumerated in Title 18, United States Code, Section 2255, will have the same rights to proceed under Section 2255 as she would have had, if Mr. Epstein EFTA00194409
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BRAD EDWARDS; ESQ. NOTIFICATION OF IDENTIFIED VICTIM AAA 9, 2008 PAGE 2 OF 2 had been tried federally and convicted of an enumerated offense. For purposes of implementing this paragraph, the United States shall provide Mr. Epstein's attorneys with a list of individuals whom it was prepared to name in an Indictment as victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this provision, including any authority determining which evidentiary burdens if any a plaintiff must meet, shall consider that it is the intent of the parties to place these identified victims in the same position as they would have been had Mr. Epstein been convicted at trial. No more; no less." Through this letter, this Office hereby provides Notice that your client, is an individual whom the United States was prepared to name as a victim of an enumerate offense. Should your client decide to file a claim against Jeffrey Epstein, his attorney, Jack Goldberger, asks that you contact him at Atterbury Goldberger and Weiss, 250 Australian Avenue South, Suite 1400, West Palm Beach, FL 33401, (561) 659-8300. Please understand that neither the U.S. Attorney's Office nor the Federal Bureau of Investigation can take part in or otherwise assist in civil litigation; however, if you do file a claim under 18 U.S.C. § 2255 and Mr. Epstein denies that your client is a victim of an enumerated offense, please provide notice of that denial to the undersigned. Please thank your client for all of her assistance during the course of this examination and express the heartfelt regards of self and Special Agents Kuyrkendall and Richards for the health and well-being of Ms. R. ALEXANDER ACOSTA UNITED STATES ATTORNEY By: cc: Jack Goldberger, Esq. CSA1) A. MARIE VILLAFARA ASSISTANT U.S. ATTORNEY EFTA00194410
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U.S. Department of Justice United States Attorney Southern District of Florida 500 South Australian Ave., Suite 400 West Palm Beach, FL 33401 (561) 820-8711 Facsimile: (561) 820-8777 July 9, 2008 VIA FACSIMILE Brad Edwards, Esq. The Law Offices of Brad Edwards & Associates, LLC 2028 Street, Suite 202 Hollywood, Florida 33020. Re: Jeffrey Epstein : NOTIFICATION OF IDENTIFIED VICTIM Dear Mr. Edwards: By virtue of this letter, the United States Attorney's Office f District of Florida asks that you provide the following notice to your client, On June 30, 2008, Jeffrey Epstein (hereinafter referred to as "Epstein) entered a plea .of guilty to violations of Florida Statutes Sections 796.07 (felony solicitation of prostitution) and 796.03 (procurement of minors to engage in prostitution), in the 15th Judicial Circuit in and for Palm Beach County (Case Nos. 2006-cf-009454AXXXMB and 2008-cf- 00938 1 AXXXMB) and was sentenced to a term of twelve months' imprisonment to be followed by an additional six months' imprisonment, followed by twelve months of Community Control 1, with conditions of community confinement imposed by the Court. In light of the entry of the guilty plea and sentence, the United States has agreed to defer federal prosecution in favor of this state plea and sentence, subject to certain conditions. One such condition to which Epstein has agreed is the following: "Any person, who while a minor, was a victim of a violation of an offense enumerated in Title 18, United States Code, Section 2255, will have the same rights to proceed under Section 2255 as she would have had, if Mr. Epstein EFTA00194411
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BRAD EDWARDS, ESQ. NOTIFICATION OF IDENTIFIED VICTIM JULY 9, 2008 PAGE 2 OF 2 had been tried federally and convicted of an enumerated offense. For purposes of implementing this paragraph, the United States shall provide Mr. Epstein's attorneys with a list of individuals whom it was prepared to name in an Indictment as victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this provision, including any authority determining which evidentiary burdens if any a plaintiff must meet, shall consider that it is the intent of the parties to place these identified victims in the same position as they would have been had Mr. Epstein been convicted at trial. No more; no less." Through this letter, this Office hereby provides Notice that your client, is an individual whom the United States was prepared to name as a victim of an enumerated offense. Should your client decide to file a claim against Jeffrey Epstein, his attorney, Jack Goldberger, asks that you contact him at Atterbury Goldberger and Weiss, 250 Australian Avenue South, Suite 1400, West Palm Beach, FL 33401, (561) 659-8300. Please understand that neither the U.S. Attorney's Office nor the Federal Bureau of Investigation can take part in or otherwise assist in civil litigation; however, if you do file a claim under 18 U.S.C. § 2255 and Mr. Epstein denies that your client is a victim of an enumerated offense, please provide notice of that denial to the undersigned. Please thank your client for all of her assistance during the course of this examination and express the heartfelt regards of m self and Special Agents Kuyrkendall and Richards for the health and well-being of Ms. R. ALEXANDER ACOSTA UNITED STATES ATTORNEY By: A. MARIE VILLAFARA ASSISTANT U.S. ATTORNEY cc: Jack Goldberger, Esq. EFTA00194412
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July 9, 2008 "Agri:, eat ',cwt/ Ale ite.41: : att Acts:- • J ,i 44, .,keei-St. ft ,4”-'1,i•Avir 11.: , r ,ity. - ,..≥r..•4 .” •I tic. t. :. Asfo, ,. k .v ...t .r.4., ,:-...• lio.. ,„„,taia . IY9;-:. £ $: . - ..• 'c.c.s!, Ct. .til 'A'17, *.- , ,i i . • ittk ef kg: •"'""41,0:14..tic• •:;p:..,-;:titi •-••,,,,,.., , • .....• ° etzt.::-ele:t..,-.M.N `strVv-)..); 7-e- .• • i , ,..•::1* ;fr.: • • JOSEPH R.ATTERBURY •t JACK A.GOLDBERGER JASON S.WEISS "Board Certified Criminal Trial Attorney Member of New Jersey & Florida Bars A. Marie C. Villafana, Esq. Assistant United States Attorney United States Attorney's Office 500 South Australian Avenue 4th Floor, Suite 400 West Palm Beach, Florida 33401 SENT VIA E-MAIL & FACSIMILE (561) 820-8777 Re: Jeffrey E. Epstein Dear Ms. Villafana: Thank you for your letter to me dated July 8, 2008 and the draft document dated, e-mailed and faxed to me at my office on June 30, 2008, styled "Notification of Identified Victims." I would like to address a few related issues. First, please note that we have several requests concerning any such notification. Specifically, we request that: (a) Any notification be sent to any individual by mail (or served upon their attorney, to the extent known), and we respectfully object to any service by hand, a method of service which carries the concomitant risk of conversations regarding the notification that potentially would place the federal authorities in a position of being advocates for civil litigation; (b) Any notification be effectuated by a separate mailing to each individual without the inclusion of any language that appeared on the second page of your June 30, 2008 memorandum; i.e. rather than including in each notification a large section listing "identified individuals" with redactions other than the name of the recipient (which we contend would be a clear and impermissible signal to any individual that the notification is a broad notification to numerous other alleged victims). Rather, a simple one page notification directed only to the recipient, and limited to the information currently on the first page of your draft memorandum would suffice. One Clearlake Centre, Suite 1400 250 Australian Avenue South West Palm Beach, EL 33401 p 561.659.8300 f 561.835.8691 www.agwpa.com EFTA00194413