EFTA00190318

Case 1:08-cv-80736-KAM 
Document 1 
Entered on FLSD Docket 07/07/2008 
Page 8 of 10 
crime victim is afforded the rights described in [the CVRA]." 18 U.S.C. § 3771(b)(1). The 
CVRA also confers on crime victims the right to "assert the rights described in [the CVRA]." 18 
U.S.C. § 3771(d)(1). Therefore, this Court has its own independent obligation to intercede and 
ensure that the Government respects the rights of Petitioner under the CVRA. 
CONCLUSION 
The Petitioner requests the intervention of this Court to ensure that her rights are 
respected and accorded, as promised in the Crime Victims' Rights Act. 
DATED this 7th day of July, 2008. 
Respectfully Submitted, 
THE LAW OFFICE OF BRAD EDWARDS & 
ASSOCIATES, LLC 
Brad Edwards, Esquire 
Attorney for Petitioner 
Florida Bar #542075 
2028 
Street 
Suite 202 
Hollywood, Florida 33020 
Telephone: 
954-414-8033 
Facsimile: 
954-924-1530 
8 
ono 
EFTA00190518

Case 1:08-cv-80736-KAM 
Document 1 
Entered on FLSD Docket 07/07/2008 
Page 9 of 10 
CERTIFICATE OF SERVICE 
I HEREBY CERTIFY that a true and correct copy of the above and foregoing has been 
provided by United States mail and via facsimile to: ANN MARIE C. VILLAFANA, AUSA, 
United States Attorney's Office, 500 South Australian Avenue, Suite 400, West Palm Beach, 
Florida 33401, this 7th day of July, 2008. 
Brad Edwards, Esquire 
Attorney for Petitioner 
Florida Bar No. 542075 
9 
9 of 10 
EFTA00190519

08 -89DOSSINA/rIPAPP 
NEntered on FLSD Docket 07/07/2008 
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EFTA00190520

Villafana, Ann Marie C. (USAFLS) 
From: 
Villafana, Ann Marie C. (USAFIS) <[email protected]> 
Sent: 
Tuesday, July 08, 2008 5:43 PM 
To: 
Lee, Dexter (USAFLS); Acosta, Alex (USAFLS); Sloman, Jeff (USAFIS) 
Subject: 
FW: Epstein: Victim Notification Letter 
Attachments: 
Victim Notification Ltr.pdf 
Alex, Dexter, and Jeff — in my draft declarationl reference the original victim notification letter that was 
objected to by the defense. Here it is as it was sent to Jay Lefkowitz on November 28, 2007. 
Thanks. 
From: Villafana, Ann Marie C. (USAFLS) 
Sent: Wednesday, November 28, 2007 4:47 PM 
To: Jay Lefkowitz 
Cc: Sloman, Jeff (USAFLS); Acosta, Alex (USAFLS) 
Subject: Epstein: Victim Notification Letter 
Dear Jay: 
Jeff asked that 1 forward the victim notification letter to you. It is attached. 
Thank you. 
«Victim Notification Ltr.pdf» 
A. Marie Villafana 
Assistant U.S. Attorney 
500 S. Australian Ave, Suite 400 
West Palm Beach, FL 33401 
Phone 561 209-1047 
Fax 561 820-8777 
1 
39 
EFTA00190521

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 
November 29, 2007 
DELIVERY BY HAND 
Miss 
Re: 
Crime Victims' Rights — Notification of Resolution of Epstein Investigation 
Dear Miss 
Several months ago, I provided you with a letter notifying you of your rights as a victim 
pursuant to the Justice for All Act of 2004 and other federal legislation, including: 
(I) 
The right to be reasonably protected from the accused. 
(2) 
The right to reasonable, accurate, and timely notice of any public court proceeding 
involving the crime or of any release or escape of the accused. 
(3) 
The right not to be excluded from any public court proceeding, unless the court 
determines that your testimony may be materially altered if you are present for other 
portions of a proceeding. 
(4) 
The right to be reasonably heard at any public proceeding in the district court 
involving release, plea, or sentencing. 
(5) 
The reasonable right to confer with the attorney for the United States in the case. 
(6) 
The right to full and timely restitution as provided in law. 
(7) 
The right to proceedings free from unreasonable delay. 
(8) 
The right to be treated with fairness and with respect for the victim's dignity and 
privacy. 
I am writing to inform you that the federal investigation of Jeffrey Epstein has been 
completed, and Mr. Epstein and the U.S. Attorney's Office have reached an agreement containing 
the following terms. 
First, Mr. Epstein agrees that he will plead guilty to two state offenses, including the offense 
of soliciting minors to engage in prostitution, which will require him to register as a sexual predator 
for the remainder of his life. 
EFTA00190522

MISS 
NOVEMBER 29,2007 
PAGE 2 
Second, Mr. Epstein has agreed to make a binding recommendation of 18 months' 
imprisonment to the state court judge who sentences him. Mr. Epstein will serve that sentence of 
imprisonment at the Palm Beach County Jail. 
Third, Mr. Epstein has agreed that he will not contest jurisdiction or liability if you elect to 
seek damages from him because the United States has identified you as a minor victim of certain 
federal offenses, including travel in interstate commerce to engage in prostitution with minors and 
the use of facilities of interstate commerce to induce minors to engage in prostitution. To assist you 
in making such a claim, the U.S. Attorney's Office has asked an independent Special Master to 
select attorneys to represent you. Those attorneys are Aaron Podhurst and Robert ("Bob") 
Josefsberg with the law firm of Podhurst Orseck, P.A. They can be reached at (305) 358-2800. 1 
anticipate that someone from their law firm will be contacting you shortly. I must also advise you 
!hat you are not obligated to use these attorneys. In fact, you have the absolute right to select your 
own attorney. so you can decide not to speak with Mssrs. Podhurst/ Josefsberg at all. or you can 
speak with them and decide at any time to use a different attorney. I f you do decide to seek damages 
from Mr. Epstein and you decide to use Messrs. Podhurst / Josefsberg as your attorneys, Mr. Epstein 
will be responsible for paying attorney's fees incurred during the time spent trying to negotiate a 
settlement. If you are unable to reach a settlement with Mr. Epstein, you and Mr. Josefsberg can 
discuss how best to proceed. 
As I mentioned above, as part of the resolution of the federal investigation, Mr. Epstein has 
agreed to plead guilty to state charges. Mr. Epstein's change of plea and sentencing will occur on 
December 14, 2007, at 
a.m., before Judge Sandra K. McSorley, in Courtroom 11F at the Palm 
Beach County Courthouse, 205 North Dixie Highway, West Palm Beach, Florida. Pursuant to 
Florida Statutes Sections 960.001(1Xk) and 921.143(1), you are entitled to be present and to make 
a statement under oath. If you choose, you can submit a written statement under oath, which will 
be filed by the State Attorney's Office on your behalf. If you elect to prepare a written statement, 
it should address the following: 
the facts of the case and the extent of any harm, including social, psychological, or 
physical harm, financial losses, loss of earnings directly or indirectly resulting from 
the crime for which the defendant is being sentenced, and any matter relevant to an 
appropriate disposition and sentence. Fl. Stat. 921.143(2). 
You also are entitled to notification when Mr. Epstein is released from imprisonment at the 
end of his prison term and/or if he is allowed to participate in a work release program. To receive 
such notification, please provide the State Attorney's Office with the following information: 
I . 
Your name 
2. 
Your address 
3. 
Your home, work, and/or cell phone numbers 
EFTA00190523

Miss 
NOVEMBER 29, 2007 
PAGE 3 
4. 
Your e-mail address 
5. 
A notation of whether you would like to participate in the "VINE system," which 
provides automated notification calls any time an inmate is moved. (To use this 
system, your calls must go to you directly, not through a switchboard.) 
Thank you for all of your help during the course of the investigation. If you have any 
questions or concerns, please do not hesitate to contact me or Special Agent Nesbitt Kuyrkendall 
at (561) 822-5946. 
Sincerely, 
R. Alexander Acosta 
United States Attorney 
By: 
A. Marie Villafaha 
Assistant United States Attorney 
cc: 
Special Agent Nesbitt Kuyrkendall, F.B.I. 
Ms. Clearetha Wright, Victim-Witness Coordinator, U.S. Attorney's Office 
EFTA00190524

Villafana, Ann Marie C. (USAFLS) 
From: 
Villafana, Ann Marie C. (USAFLS) <[email protected]> 
Sent: 
Monday, July 07, 2008 7:23 PM 
To: 
Lee, Dexter (USAFLS) 
Cc: 
Sloman, Jeff (USAFLS) 
Subject: 
Re: CVRA Suit 
Hi dexter. Yes an agreement has been signed and has already been partially performed. The agreement is confidential and has been 
filed under seal in the state court proceedings. 
I-le could be filing his motion on behalf of 3 different jane does. S.R. Was not fully identified until after the agreement was signed. 
T.M. was notified and her notification resulted in claims of prosecutorial misconduct by Epstein's lawyers. I am checking to see if the 
third, C.W., was notified prior to the signing of the agreement. 
 
Original Message 
From: Lee, Dexter (USAFLS) 
To: Villafana, Ann Marie C. (USAFLS) 
Sent: Mon Jul 07 18:52:42 2008 
Subject: CVRA Suit 
Ann Marie, 
The Attorney General Guidelines for Victim and Witness Assistance (May 2005) provides that "responsible officials should make 
reasonable efforts to notify identified victims of, and consider victims' views about, prospective plea negotiations." Article IV, 
Services to Victims and Witnesses, p. 30. 
Has an agreement been signed with Epstein? Did we notify Jane Doe that an agreement was about to be negotiated, and the outlines 
of that proposed agreement? Thanks. 
Dexter 
183 
EFTA00190525

Villafana, Ann Marie C. (USAFLS) 
From: 
Villafana, Ann Marie C. (USAFLS) <[email protected]> 
Sent: 
Tuesday, July 08, 2008 10:17 AM 
To: 
Lee, Dexter (USAFLS) 
Subject: 
Emailing: Villafana Declaration re victim notification.wpd 
Attachments: 
Villafana Declaration re victim notification.wpd 
<<V i I la fana Declaration re victim notification.wpd>> Hi Dexter -- I am still working on it, but thought this would help 
with background. When I finish, I will send to you, Jeff, and Alex. 
Thanks. 
The message is ready to be sent with the following file or link attachments: 
Villafana Declaration re victim notification.wpd 
Note: To protect against computer viruses, e-mail programs may prevent sending or receiving certain types of file attachments. Check 
your c-mail security settings to determine how attachments arc handled. 
184 
EFTA00190526

Villafana, Ann Marie C. (USAFLS) 
From: 
Villafana, Ann Marie C. (USAFLS) <[email protected]> 
Sent: 
Tuesday, July 08, 2008 12:15 PM 
To: 
Lee, Dexter (USAFLS) 
Subject: 
FW: Epstein 
Attachments: 
Conf Plea Negotiations final.wpd 
Dexter - Please see below. 
A. Marie Villafalia 
Assistant U.S. Attorney 
500 S. Australian Ave, Suite 400 
West Palm Beach, FL 33401 
Phone 561 209-1047 
Fax 561 820-8777 
From: Villafana, Ann Marie C. (USAFLS) 
Sent: Thursday, September 06, 2007 5:47 PM 
To: Sloman, Jeff (USAFLS) 
Subject: RE: Epstein 
Hi Jeff— Funny you should ask. I have been wondering the same thing. Here is the term sheet and guidelines 
calculation that we provided at the last meeting. You and Matt and I had also discussed a possible federal plea 
to an Information charging a 371 conspiracy, with a Rule 11 plea with a two-year cap, but I think Matt must 
have asked Alex about it and it was nixed. Just to be prepared for tomorrow, I was just starting to draft a Rule 
1 I plea agreement in case Alex changes his mind and a formal non-prosecution agreement containing the state 
plea terms. As soon as those are ready, I will e-mail them to you. 
«Conf Plea Negotiations final.wpd» 
There are three concerns that I hope we can address tomorrow. First, that there is an absolute drop-dead date 
for accepting or rejecting because it is strategically important that we indict before the end of September, which 
means presenting the indictment on September 25th. Second, the agents and I have not reached out to the 
victims to get their approval, which as Drew politely reminded me, is required under the law. And third, I do 
not want to make any promises about allowing Epstein to self-surrender because I still believe that we have a 
good chance of getting him detained. 
On another note, Junior got a call today from the Palm Beach Police Chief because he got information that there 
will be an article released tomorrow about our meeting and that Epstein is going to plead to a state charge and 
the Chief wanted to know if the victims had been consulted about the deal. There has been some coverage in 
the New York press about Ken Starr, but I haven't seen anything local yet. 
A. Marie Villafafia 
185 
EFTA00190527

Assistant U.S. Attorney 
561 209-1047 
From: Sloman, Jeff (USAFLS) 
Sent: Thursday, September 06, 2007 5:35 PM 
To: Villafana, Ann Marie C. (USAFLS) 
Subject: Epstein 
Please refresh my recollection. What is the "deal" on the table? 
186 
EFTA00190528

Villafana, Ann Marie C. (USAFLS) 
From: 
Villafana, Ann Marie C. (USAFLS) <[email protected]> 
Sent: 
Tuesday, July 08, 2008 12:17 PM 
To: 
Lee, Dexter (USAFLS) 
Subject: 
RE: Factors in Not Disclosing Plea Agreement Terms 
Hi Dexter — I will forward to you an e-mail that I sent to Jeff and Alex about victim notification during the 
negotiations. The terms of the agreement were proposed by Matt Menchel, and I worked on drafting an 
agreement in accordance with those terms. 
I think the Office's position is that the number of victims, timing, and the confidentiality provisions included in 
the agreement made victim notification impossible. I would add that, after seeing how the defense twisted the 
disclosure of the terms to the first few victims, premature notification of them would have compromised their 
trial testimony. 
A. Made Villerfatia 
Assistant U.S. Attorney 
500 S. Australian Ave, Suite 400 
West Palm Beach, FL 33401 
Phone 561 209-1047 
Fax 561 820-8777 
From: Lee, Dexter (USAFLS) 
Sent: Tuesday, July 08, 2008 12:09 PM 
To: Villafana, Ann Marie C. (USAFLS) 
Subject: Factors in Not Disclosing Plea Agreement Terms 
Marie, 
The Attorney General's Guidelines lists several factors in determining whether to notify a victim of a proposed 
plea agreement: 
(3) Proposed Plea Agreements. Responsible officials should make reasonable efforts to notify identified victims 
of, and consider victims' views about, prospective plea negotiations. In determining what is reasonable, the 
responsible official should consider factors relevant to the wisdom and practicality of giving notice and 
considering views in the context of the particular case, including, but not limited to, the following factors: 
(a) The impact on public safety and risks to personal safety. 
(b) The number of victims. 
(c) Whether time is of the essence in negotiating or entering a proposed plea. 
187 
EFTA00190529

(d) Whether the proposed plea involves confidential information or conditions. 
(e) Whether there is another need for confidentiality. 
(f) Whether the victim is a possible witness in the case and the effect that relaying any information may have 
on the defendant's right to a fair trial. 
When we spoke this morning, you told me that the initial agreement with Epstein was reached in September 
2007. 
An addendum was negotiated in October 2007. Finally, an additional portion of the agreement was 
signed in December 2007. 
Did we consider these, or any other factors, in deciding not to advise the victims of the plea negotiations, 
which appeared to have commenced in mid-2007? Thanks. 
Dexter 
188 
EFTA00190530

Villafana, Ann Marie C. (USAFLS) 
From: 
Villafana, Ann Marie C. (USAFLS) <[email protected]> 
Sent: 
Wednesday, July 09, 2008 11:49 AM 
To: 
Sloman, Jeff (USAFLS); Lee, Dexter (USAFLS); Acosta, Alex (USAFLS) 
Cc: 
Atkinson, Karen (USAFLS); Jacobus, Wendy (USAFLS) 
Subject: 
RE: Emailing: victim_resp_USArev corrected.wpd 
Here is the language from the Agreement. I will leave it to you to interpret whether disclosing part of the substance of the 
Agreement requires sealing or otherwise. 
The parties anticipate that this agreement will not be made part of any 
public record. If the United States receives a Freedom of Information 
Act request or any compulsory process commanding the disclosure of 
the agreement, it will provide notice to Epstein before making that 
disclosure. 
A. Marie Villafaiia 
Assistant U.S. Attorney 
561 209-1047 
 
Original Message 
From: Sloman, Jeff (USAFLS) 
Sent: Wednesday, July 09, 2008 9:57 AM 
To: Lee, Dexter (USAFLS); Villafana, Ann Marie C. (USAFLS); Acosta, Alex (USAFLS) 
Cc: Atkinson, Karen (USAFLS); Jacobus, Wendy (USAFLS) 
Subject RE: Emailing: victim_resp_USArev corrected.wpd 
Doesn't the confidentiality provision obligate us to file it under seal? 
 
Original Message 
From: Lee, Dexter (USAFLS) 
Sent: Wednesday, July 09, 2008 9:53 AM 
To: Villafana, Ann Marie C. (USAFLS); Acosta, Alex (USAFLS) 
Cc: Atkinson, Karen (USAFLS); Sloman, Jeff (USAFLS); Jacobus, Wendy (USAFLS) 
Subject: RE: Entailing: victim_resp_USArev corrected.wpd 
Alex and Jeff, 
Do you have any preference for filing under seal or a public filing? If we can protect the identities of the minor victims in a 
public filing, that is one less reason to file it under seal. The other considerations are the government's confirmation that 
Epstein was under federal investigation, and the confidentiality provision in the deferral of prosecution agreement with Epstein. 
It's actually easier to file it electronically, and the general policy is that documents filed in court are public. 
Dexter 
 
Original Message 
From: Villafana, Ann Marie C. (USAFLS) 
Sent: Wednesday, July 09, 2008 9:23 AM 
37 
EFTA00190531

To: Lee, Dexter (USAFLS); Acosta, Alex (USAFLS) 
Cc: Atkinson, Karen (USAFLS); Sloman, Jeff (USAFLS); Jacobus, Wendy (USAFLS) 
Subject: RE: Emailing: victim_resp_USArev corrected.wpd 
I was planning to redact all of that information prior to scanning it and attaching Exhibit Stickers. I think we should do so even 
if this is filed under seal. 
A. Marie Villafafla 
Assistant U.S. Attorney 
561 209-1047 
----Original Message----
From: Lee, Dexter (USAFLS) 
Sent: Wednesday, July 09, 2008 9:22 AM 
To: Villafana, Ann Marie C. (USAFLS); Acosta, Alex (USAFLS) 
Cc: Atkinson, Karen (USAFLS); Sloman, Jeff (USAFLS); Jacobus, Wendy (USAFLS) 
Subject: RE: Emailing: victim_resp USArev corrected.wpd 
Marie, 
I will sign the response. Since this case involves girls who were minors when the crimes were committed, and there is a 
confidentiality provision in the deferral of prosecution agreement with Epstein, I believe this should be filed under 
seal. Otherwise, we'll have to go through each letter and excise the names, addresses, and other identifying information on the 
three girls. 
Dexter 
-----Original Message----
From: Villafana, Ann Marie C. (USAFLS) 
Sent: Wednesday, July 09, 2008 9:11 AM 
To: Lee, Dexter (USAFLS); Acosta, Alex (USAFLS) 
Cc: Atkinson, Karen (USAFLS); Sloman, Jeff (USAFLS) 
Subject: Emailing: victim_resp_USArev corrected.wpd 
Dexter and Alex -- I fixed a couple of typos and entered the correct information about the dates when the letters were sent. I 
also included the information about all three of Edwards' clients, T.M., C.W., and S.R. 
At the end, I also corrected the information regarding the notifications of the victims about the change of plea. I called Edwards 
on Friday, but I'm not sure whether we spoke that day or if he called me over the weekend. And the agents and I didn't start 
making calls together until Monday after the hearing. So I notified Edwards to inform his three clients, and PBPD tried to 
notify six victims, I think. I didn't want the court to think that we tried to notify all 33 girls. 
I will make similar changes to my declaration and send that to you shortly. 
Also, I notice there is no signature block. Do you want me to sign and file? Or will you do that, Dexter? Thanks. 
The message is ready to be sent with the following file or link attachments: 
victim_resp_USArev corrected.wpd 
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38 
EFTA00190532

Villafana, Ann Marie C. (USAFLS) 
From: 
Villafana, Ann Marie C. (USAFLS) <[email protected]> 
Sent: 
Tuesday, July 08, 2008 5:24 PM 
To: 
Sloman, Jeff (USAFLS); Lee, Dexter (USAFLS) 
Cc: 
Kuyrkendall, E N. (MM) (FBI); Richards, Jason R. (MM) (FBI); Atkinson, Karen (USAFLS) 
Subject: 
Emailing: Villafana Declaration re victim notification.wpd 
Attachments: 
Villafana Declaration re victim notification.wpd 
<<Villafana Declaration re victim notification.wpd>> I haven't proofed it yet, and Nesbitt and Jason need to double-check 
me on the facts, but I wanted to get it to you as soon as I could in case the Office wants to do major revisions. 
The air conditioning in my office is broken, so I am going to head home. I will have access to e-mail and the document at home, if we 
want to make changes tonight. Otherwise I will be back early tomorrow. If you do want to make changes, please just call me on my 
cell, 561 601-2301, and then I can sign on to the computer at home. 
Thanks. 
The message is ready to be sent with the following file or link attachments: 
Villafana Declaration re victim notification.wpd 
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189 
EFTA00190533

Villafana, Ann Marie C. (USAFLS) 
From: 
Acosta, Alex (USAFLS) <[email protected]> 
Sent: 
Tuesday, July 08, 2008 6:17 PM 
To: 
Lee, Dexter (USAFLS); Sloman, Jeff (USAFLS) 
Cc: 
Villafana, Ann Marie C. (USAFLS); Jacobus, Wendy (USAFLS) 
Subject: 
RE: Draft Response in Jane Doe 
Attachments: 
victim_resp.wpd 
Here is a second draft, with small rewrites 
I reduced the discussion of negotiations. The agreement has a confidentiality clause. I note this, because if 
we disclose too much, then we will be sued by the other side for breach of that clause. 
In other words, we need to disclose and discuss without going too far — unless ordered to do so by the court. 
«victim_resp.wpd» : 
From: Lee, Dexter (USAFLS) 
Sent: Tuesday, July 08, 2008 5:29 PM 
To: Acosta, Alex (USAFLS); Sloman, Jeff (USAFLS) 
Cc: Villafana, Ann Marie C. (USAFLS); Jacobus, Wendy (USAFLS) 
Subject: Draft Response In Jane Doe 
Alex and Jeff, 
Here is a draft response to the emergency petition filed by Jane Doe in the Epstein case. Our first argument is 
that Doe had no rights under 18 U.S.C. 3177(a)(5) since that provision does not apply where there are no 
"court proceedings" in federal court, and none were contemplated, as long as Epstein complied with the non-
prosecution agreement. 
The second argument is that the government used its best efforts to comply, since 
the A/G guidelines permitted us to not notify victims of the proposed plea negotiations if the proposed plea 
involved confidential information or conditions, or there is another need for confidentiality. Article IV, 
Section B(2)(C)(3). 
The government exercised its discretion and determined that keeping the terms 
confidential was necessary in order to obtain the best agreement. 
In particular, the government wanted 
Epstein to make a significant concession on one of the elements in 18 U.S.C. 2255. 
I am speaking with Kim Herd at EOUSA regarding the government's position. In particular, the first argument 
will have to be cleared by DOJ before I can assert it. Please feel free to make any comments. Thanks. 
Dexter 
« File: victim_resp.wpd » 
190 
EFTA00190534

Villafana, Ann Marie C. (USAFLS) 
From: 
Lee, Dexter (USAFLS) <[email protected]> 
Sent: 
Tuesday, July 08, 2008 7:42 PM 
To: 
Villafana, Ann Marie C. (USAFLS) 
Subject: 
Revised Declaration & Response 
Attachments: 
victim_resp_USArev.wpd; Villafana Declaration-v2.wpd 
Marie, 
Alex has reviewed my draft response and your final declaration. He wanted to leave out specific details 
regarding the plea negotiations, since plea discussions are normally held in confidence. Also, he wanted to 
leave out Epstein's attorneys' undue haste in hurling accusations of misconduct at the prosecution, since that 
does not address the claims presented by petitioner. 
I have revised the response and your declaration accordingly. Please review both to ensure they are 
accurate. Thanks. 
Dexter 
«victintresp_USArev.wpd» «Villafana Declaration-v2.wpd» 
191 
EFTA00190535

Villafana, Ann Marie C. (USAFLS) 
From: 
Lee, Dexter (USAFLS) <[email protected]> 
Sent: 
Wednesday, July 09, 2008 9:22 AM 
To: 
Villafana, Ann Marie C. (USAFLS); Acosta, Alex (USAFLS) 
Cc: 
Atkinson, Karen (USAFLS); Sloman, Jeff (USAFLS); Jacobus, Wendy (USAFLS) 
Subject: 
RE: Emailing: victim_resp_USArev corrected.wpd 
Marie, 
I will sign the response. Since this case involves girls who were minors when the crimes were committed, and there is a 
confidentiality provision in the deferral of prosecution agreement with Epstein, I believe this should be filed under seal. Otherwise, 
we'll have to go through each letter and excise the names, addresses, and other identifying information on the three girls. 
Dexter 
 
Original Message 
Front: Villafana, Ann Marie C. (USAFLS) 
Sent: Wednesday, July 09, 2008 9:1 I AM 
To: Lee, Dexter (USAFLS); Acosta, Alex (USA ELS) 
Cc: Atkinson, Karen (USAFLS); Sloman, Jeff (USAFLS) 
Subject: Emailing: victim_resp_USArev corrected.wpd 
Dexter and Alex -- I fixed a couple of typos and entered the correct information about the dates when the letters were sent. I also 
included the information about all three of Edwards' clients, T.M., C.W., and S.R. 
At the end, I also corrected the information regarding the notifications of the victims about the change of plea. I called Edwards on 
Friday, but I'm not sure whether we spoke that day or if he called me over the weekend. And the agents and I didn't start making calls 
together until Monday after the hearing. So I notified Edwards to inform his three clients, and PBPD tried to notify six victims, I 
think. I didn't want the court to think that we tried to notify all 33 girls. 
I will make similar changes to my declaration and send that to you shortly. 
Also, I notice there is no signature block. Do you want me to sign and file? Or will you do that, Dexter? Thanks. 
The message is ready to be sent with the following file or link attachments: 
victim_resp_USArev corrected.wpd 
Note: To protect against computer viruses, e-mail programs may prevent sending or receiving certain types of file attachments. Check 
your c-mail security settings to determine how attachments are handled. 
192 
EFTA00190536

Villafana, Ann Marie C. (USAFLS) 
From: 
Villafana, Ann Marie C. (USAFLS) <[email protected] 
Sent: 
Wednesday, July 09, 2008 9:22 AM 
To: 
Acosta, Alex (USAFLS); Lee, Dexter (USAFLS) 
Cc: 
Atkinson, Karen (USAFLS); Sloman, Jeff (USAFLS) 
Subject: 
Emailing: Villafana Declaration-v2 final.wpd 
Attachments: 
Villafana Declaration-v2 final.wpd 
<<Villafana Declaration-v2 final.wpd>> Attached is the revised declaration. Please let me know if any other changes are 
required. I am off to Court but should be back by I I:30. 
Thank you. 
The message is ready to be sent with the following file or link attachments: 
Villafana Declaration-v2 final.wpd 
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193 
EFTA00190537