This is an FBI investigation document from the Epstein Files collection (FBI VOL00009). Text has been machine-extracted from the original PDF file. Search more documents →
FBI VOL00009
EFTA00193954
651 pages
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Villafana, Ann Marie C. (USAFLS) From: Villafana, Ann Marie C. (USAFLS) Sent: Tuesday, July 08, 2008 5:37 PM To: Acosta, Alex (USAFLS); Lee, Dexter (USAFLS) Subject: Victim Notification Hi Alex and Dexter —Here is the proposed notification that was provided to Epstein's counsel last week. Victim lineation and Nc Assuming that they don't sign it tomorrow, I would remove the bottom portion that calls for Epstein's signature and incorporate some instructional language along with notice that Jack Goldberger is the contact person for any civil litigation. 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 Tracking: 692 EFTA00194374
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Villafana, Ann Marie C. (USAFLS) From: Villafana, Ann Marie C. (USAFLS) Sent: Tuesday, July 08, 2008 5:43 PM To: Lee, Dexter (USAFLS); Acosta, Alex (USAFLS); Sloman, Jeff (USAFLS) Subject: FW: Epstein: Victim Notification Letter Alex, Dexter, and Jeff — in my draft declaration I 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 I forward the victim notification letter to you. It is attached. Thank you. Victim lotification Ltr.pd A. Marie Vil!aloha Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 Phone 561 209-1047 Fax 561 820-8777 641 EFTA00194375
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Villafana, Ann Marie C. (USAFLS) From: Acosta, Alex (USAFLS) 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 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 » 640 EFTA00194376
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Villafana, Ann Marie C. (USAFLS) From: Lee, Dexter (USAFLS) Sent: Tuesday, July 08, 2008 7:42 PM To: Villafana, Ann Marie C. (USAFLS) Subject: Revised Declaration & Response 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 victim_resp_USA Villafana rev.wpd ieclaration-v2.wp 639 EFTA00194377
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Villafana, Ann Marie C. (USAFLS) From: Villafana, Ann Marie C. (USAFLS) Sent: Tuesday, July 08, 2008 8:04 PM To: Lee, Dexter (USAFLS); Acosta, Alex (USAFLS); Sloman, Jeff (USAFLS) Subject: Re: Revised Declaration & Response Hi Dexter and Alex. Changes look good. I have to correct one paragraph tomorrow morning and it should be good to go as soon as we send out the notifications. Thank you. Original Message From: Lee, Dexter (USAFLS) To: Villafana, Ann Marie C. (USAFLS) Sent: Tue Jul 08 19:41:56 2008 Subject: Revised Declaration & Response 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. both to ensure they are accurate. Thanks. Dexter «victim_resp_USArev.wpd» «Villafana Declaration-v2.wpd» Please review 638 EFTA00194378
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Recipient Read Lee. Dexter (USAFLS) Read: 7/9/2008 9:18 AM Acosta. Alex (USAFLS) Read: 7/9/2008 9:33 AM Atkinson. Karen (USAFLS) Read: 7/9/2008 9:20 AM Stomas). Jeff (USAFLS) Read: 7/9/2008 9:13 AM Kuyrkendall. E N. (FBI) Richards. Jason R. (FBI) 637 EFTA00194379
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Villafana, Ann Marie C. (USAFLS) 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 Attachments: 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 e-mail security settings to determine how attachments are handled. Tracking: 636 EFTA00194380
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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 e-mail security settings to determine how attachments are handled. 635 EFTA00194381
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Villafana, Ann Marie C. (USAFLS) From: Villafana, Ann Marie C. (USAFLS) Sent: Wednesday, July 09, 2008 9:19 AM To: Richards, Jason R. (FBI) Subject: RE: Emailing: victim_resp_USArev corrected.wpd Thank you. A. Marie Villafaha Assistant U.S. Attorney 561 209-1047 Original Message From: Richards, Jason R. (FBI) Sent: Wednesday, July 09, 2008 9:14 AM To: Villafana, Ann Marie C. (USAFLS) Subject: Re: Emailing: victim_resp_USArev corrected.wpd Hi Marie, We interviewed TM on 4/24/2007. Original Message From: Villafana, Ann Marie C. (USAFLS) <[email protected]> To: Lee, Dexter (USAFLS); Acosta, Alex (USAFLS) Cc: Atkinson, Karen (USAFLS); Sloman, Jeff (USAFLS) Sent: Wed Jul 09 09:10:39 2008 Subject: Emailing: victim_resp_USArev corrected.wpd «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. 634 EFTA00194382
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Villafana, Ann Marie C. (USAFLS) 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 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. 633 EFTA00194383
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Villafana, Ann Marie C. (USAFLS) From: Villafana, Ann Marie C. (USAFLS) Sent: Wednesday, July 09, 2008 9:22 AM To: Acosta, Alex (USAFLS); Lee, Dexter (USAFLS) Cc: Atkinson, Karen (USAFLS); Sloman, Jeff (USAFLS) Subject: Emaiting: Villafana Declaration-v2 final.wpd Attachments: 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 11:30. Thank you. The message is ready to be sent with the following file or link attachments: Villafana Declaration-v2 final.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. 632 EFTA00194384
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Recipient Read Lee, Dexter (USAFLS) Read: 7/9/2008 9:30 AM Acosta, Alex (USAFLS) Atkinson, Karen (USAFLS) Read: 7/912008 9:30 AM Sloman, Jeff (USAFLS) Read: 7/9/2008 9:25 AM Jacobus, Wendy (USAFLS) Read: 7/9120089:53 AM 631 EFTA00194385
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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 e-mail security settings to determine how attachments are handled. Tracking: 630 EFTA00194386
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Villafana, Ann Marie C. (USAFLS) From: Villafana, Ann Marie C. (USAFLS) Sent: Wednesday, July 09, 2008 9:23 AM 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 Villafaha 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 629 EFTA00194387
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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 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. 628 EFTA00194388
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Villafana, Ann Marie C. (USAFLS) From: Stamen, Jeff (USAFLS) Sent: Wednesday, July 09,2008 9:57 AM To: Lee, Dexter (USAFLS); Villatana, 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: Emailing: 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 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 Villafana 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) 627 EFTA00194389
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Villafana, Ann Marie C. (USAFLS) From: Acosta, Alex (USAFLS) Sent: Wednesday, July 09, 2008 10:38 AM To: Villafana, Ann Marie C. (USAFLS); Lee, Dexter (USAFLS) Cc: Atkinson, Karen (USAFLS); Sloman, Jeff (USAFLS) Subject: RE: Emailing: Villafana Declaration-v2 final.wpd A few thoughts: 1. bottom of page 5/ top of page 6 -- were we talk about the "Throughout the negotiations, ... recompense." Should we cite to Decl para 8? 2. Next para -- cite to para 8 should be cite to para 10. 3. Right before the next para starting with On Friday, should we discuss the content of para 9, where the same attorney that now complains had an opportunity to communicate with our office and didn't. What I find particularly compelling about that point is that Edwards had, or should have had, knowledge of this agreement because his clients were told of the agreement previously. Cite para 8. In fact, maybe this should be a separate argument III -- he, or his clients, had prior knowledge and didn't complain until now. Thoughts? 4. In para 2 of the declaration, do we need the last sentence hitting the State Attorney? Original Message From: Villafana, Ann Marie C. (USAFLS) 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 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 11:30. Thank you. The message is ready to be sent with the following file or link attachments: Villafana Declaration-v2 final.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. 626 EFTA00194390
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Recipient Read &omen, Jeff (USAFLS) Read: 7/9/2008 11:49 AM Lee, Dexter (USAFLS) Read: 7/9/2008 11:49 AM Acosta, Alex (USAFLS) Read: 7/9/2008 11:55 AM Atkinson, Karen (USAFLS) Jacobus, Wendy (USAFLS) Read: 7/9/200812:29 PM 625 EFTA00194391
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From: Villafana, Ann Marie C. (USAFLS) Sent: Wednesday, July 09, 2008 9:23 AM 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 Villafafia 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 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. Tracking: 624 EFTA00194392
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Villafana, Ann Marie C. (USAFLS) From: Villafana, Ann Marie C. (USAFLS) Sent: Wednesday, July OS, 200811:49 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 Attachments: image001.png 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 othenvise. The parties anticipate that this agreement will not be made p public record. If the United States receives a Freedom of In Act request or any compulsory process commanding the dis the agreement, it will provide notice to Epstein before mi disclosure. A. Marie Villafafia 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: Emailing: 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----- 623 EFTA00194393