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I hereby certify that the foregoing is true 
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and correct to the best of my ability. 
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Victoria Aiello, Court Reporter 
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OFFICIAL REPORTING SERVICES, LLC (954) 467-8204 
EFTA00184764

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EXHIBIT 
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UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT. OF FLORIDA 
Case No. 08-80736-Civ-Marra/Johnson 
IN RE: JANE DOE, 
Petitioner. 
FILED by 
D.0 
JUL 0 9 2008 
STEVEN M. tA.RIMORE 
C LERK U.S. DIST. CT. 
S O. OF FLA. • MM. 
DECLARATION OF A. 
VILLAFASIA 
IN SUPPORT OF UNITED STATES' RESPONSE 
TO yinints EMERGENCY PETITION FOR ENFORCEMENT 
OF CRIME VICTIM RIGHTS ACT. IS U.S.C. § 3771 
1. 
I. A. 
Villafafta, do hereby declare that I am a member in good standing 
ul'the Ilar of the State of Florida. 1 graduated from the University of California at Berkeley 
School of Law (Hoak Hall) in 1993. After serving as a judicial clerk to the Ilon. David F. 
Levi in Sacramento, California, 1 was admitted to practice in California in 1995. I also am 
admitted to practice in all courts of the states of Minnesota and Florida, the Eighth, Eleventh, 
and Federal Circuit Courts of Appeals. and the U.S. District Courts for the Southern District 
of Florida, the District of Minnesota, and the Northern District of California. My bar 
admission status in California and Minnesota is currently inactive. lam currently employed 
as an Assistant United States Attorney in the Southern District of Florida and was so 
employed during all of the events described herein. 
gie 
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2. 
1 am the Assistant United States Attorney assigned to the investigation of 
Jeffrey Epstein. The case was investigated by the Federal Bureau of Investigation ("FBI"). 
The federal investigation was initiated in 2006 at the request of the Palm Beach Police 
Department ("PBPD") into allegations that Jeffrey Epstein and his personal assistants had 
used facilities of interstate commerce to induce young girls between the ages of thirteen and 
seventeen to engage in prostitution. amongst other offenses. 
3. 
'Throughout the investigation, when a victim was identified, victim notification 
letters were provided to her both from your Milani and from the FBI's Victim-Witness 
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).= Both C.W. and T.M. also received letters from the FBI's Victim-
Witness Specialist, which were sent on January 10, 2008 (Exs. 3 & 4). S.R. was identified 
via the FBI's investigation in 2007, but she initially refused to speak with investigators. 
S.R.'s status as a victim of a federal offense was confirmed when she was interviewed by 
'Attorney Edwards filed his Motion on behalf of "Jane Doc," without identifying which of 
his clients is the purported victim. Accordingly. I will address facts related to C.W., T.M.. and S R. 
All three of those clients were victims of Jeffrey Epstein's while they were minors beginning when 
they were fifteen years old. 
Incase note that the dates on the U.S. Attorney's Office letters to C.W. and T.M. are not the 
dates that the letters were actually delivered. Letters to all known victims were prepared early in the 
investigation and delivered as each victim was contacted. 
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federal agents on May 28, 2008. The FBI's Victim-Witness Specialist sent a letter to S.R. 
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. That attorney was James Eisenberg. and his fees were paid by Jeffrey Epstein, 
the target of the investigation! 
5. 
In the summer of 2007. Mr. Epstein and the U.S. Attorney's Office for the 
Southern District of Florida ("the Office") entered into negotiations to resolve the 
investigation. At that time. Mr. Epstein had been charged by the State of Florida with 
solicitation of prostitution, in violation of Florida Statutes § 796.07. Mr. Epstein's attorneys 
sought a global resolution of the matter. The United States subsequently agreed to defer 
federal prosecution in favor of prosecution by the State of Florida, so long as certain basic 
preconditions were met. One of the key objectives for the Government was to preserve a 
federal remedy for the young girls whom Epstein had sexually exploited. Thus, one 
condition of that agreement, notice of which was provided to the victims on July 9. 2008. 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 
'The undersigned does not know when Mr. Edwards began representing T.M. or whether 
T.M. ever formally terminated Mr. Eisenberg's representation. 
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had been tried federally and convicted ofan enumerated olTense. 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." 
6. 
An agreement was reached in September 2007. The Agreement contained an 
express confidentiality provision. 
7. 
Although individual victims were not consulted regarding the agreement, 
several had expressed concerns regarding the exposure of their identities at trial and they 
desired a prompt resolution of the matter. At the time the agreement was signed in 
September 2007. T.M. was openly hostile to the prosecution of Epstein. The FRI attempted 
to interview S.R. in October 2007. at which time she refused to provide any information 
regarding Jeffrey Epstein. None of Attorney Edwards' clients had expressed a desire to be 
consulted prior to the resolution of the federal investigation. 
8. 
As explained above, one of the terms of the agreement deferring prosecution 
to the State of Florida was securing a federal remedy for the victims. In October 2007, 
shortly alter 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 2007. When Epstein's attorneys learned that some of the victims had been 
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notified, they complained that the victims were receiving an incentive to overstate their 
involvement with Mr. Epstein in order to increase their damages claims. While your Affiant 
knew that the victims' statements had been taken and corroborated with independent 
evidence well before they were informed of the potential for damages. the agents and I 
concluded that inlbrming additional victims could compromise the witnesses' credibility at 
trial if Epstein reneged on the agreement. 
9. 
Atter C.W. had been notified of the terms of the agreement, but before Epstein 
performed his obligations, C.W. contacted the P131 because Epstein's counsel was attempting 
to take her deposition and private investigators were harassing her. Your Affiant secured pro 
bono counsel to represent C.W. and several other identified victims. Pro bono counsel was 
able to assist C.W. in avoiding the improper deposition. 'that pro bono counsel did not 
express to your Milani that C.W. was dissatisfied with the resolution of the matter. 
10. 
In mid-June 2008. Attorney Edwards contacted your Affiant to inform me that 
he represented C.W. and Sit, and asked to meet to provide me with information regarding 
Epstein. I invited Attorney Edwards to send to me any information that he wanted me to 
consider. Nothing was provided. I also advised Attorney Edwards that he should consider 
contacting the State Attorney's Office, i f he so wished. I understand that no contact with that 
office was made. Attorney Edwards had alluded to T.M., so I advised him that, to my 
knowledge. T.M. was still represented by Attorney James Eisenberg. 
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I I. 
On Friday, June 27, 2008, at approximate 4:15 p.m., your Afliant received a 
copy of the proposed state plea agreement and learned that the plea was scheduled for 8:30 
a.m., Monday, June 30. 2008. Your Afliant and the Palm Beach Police Department 
attempted to provide notification to victims in the short time that Epstein's counsel had given 
us. Although all known victims were not notified, your A Iliant specifically called attorney 
Edwards to provide notice to his clients regarding the hearing. Your Milani believes that 
it was during this conversation that Attorney Edwards notified Inc that he represented T.M., 
and I assumed that he would pass on the notice to her, as well. Attorney Edwards informed 
your Afliant that he could not attend but that someone would be present at the hearing. Your 
Afliant attended the hearing, but none of Attorney Edwards' clients was present. 
12. 
On today's date, your Affiant provided the attached victim notifications to 
C.W. and S.R. via their attorney. Bradley Edwards (Exs. 6 & 7). A notification was not 
provided to T.M. because the U.S. Attorney's modification limited Epstein's liability to 
victims whom the United States was prepared to name in an indictment. In light of T.M.'s 
prior statements to law enforcement, your Affiant could not in good faith include T.M. as a 
victim in an indictment and, accordingly, could not include her in the list provided to 
Epstein's counsel. 
13. 
Furthermore, with respect to the Certification of Emergency. Attorney Edwards 
did not ever contact me prior to the filing of that Certification to demand the relief that he 
requests in his Emergency Petition. On the afternoon ofJuly 7. 2008, alter your Afliant had 
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already received the Certification of Emergency and Emergency Petition, I received a letter 
from Attorney Edwards that had been sent, via Certified Mail, on July 3,2008. While that 
letter urges the Attorney General and the United States Attorney to consider "vigorous 
enforcement" of federal laws with respect to Jeffrey Epstein, it contains no demand for the 
relief requested in the Emergency Petition. 
14. 
I declare under penalty of perjury, pursuant to 28 U.S.C. § 1746 that the 
foregoing is true and correct to the best of my knowledge and belief. 
Executed this 94_ 
day of July, 2008. 
A. Marie ViTlafahaU 
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EXHIBIT 
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UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
Case No. 08-80736-Civ-Marra/Johnson 
JANE DOE No. 1 and JANE DOE No. 2 
I 
UNITED STATES 
AFFIDAVIT OF BRADLEY J. EDWARDS, ESQ. REGARDING NEED FOR 
PRODUCTION OF DOCUMENTS 
1. I, Bradley J. Edwards, Esq., do hereby declare that I am a member in good standing of the Bar 
of the State of Florida. Along with co-counsel, I represent Jane Doe No. I and Jane Doe No. 2 
(as referred to as "the victims") in the above-listed action to enforce their rights under the Crime 
Victims Rights Act (CVRA). I also represented them (and several other victims) in civil suits 
against Jeffrey Epstein for sexually abusing them. I am also familiar with the criminal justice 
system, having served as state prosecutor in the Broward County State Attorney's Office. 
2. This affidavit covers factual issues regarding the Government's assertions of privilege to 
more than 13,000 pages of documents it has produced for in camera inspection in this case. This 
affidavit provides factual information demonstrating that the Government's assertions of 
privilege are not well founded. It further demonstrates that the victims have a compelling and 
substantial need for the information requested and have no other way of obtaining the 
information. 
Background Regarding Unsuccessful Efforts to Reach Stipulated Facts with the 
Government 
3. On July 7, 2008, I filed a petition to enforce the CVRA rights of Jane Doe No. 1 and Jane Doe 
No. 2 with regard to sex offenses committed against them by Jeffrey Epstein while they were 
minors. The course of the proceedings since then is well-known to the Court. For purposes of 
this affidavit regarding privileges, it is enough to briefly recount the efforts of the victims to 
reach a stipulated set of facts with the Government — efforts that the Government has blocked. 
4. The Court first held a hearing on victims' petition on July 11, 2008. The Court discussed a 
need to "hav[e] a complete record, and this is going to be an issue that's ... going to go to the 
Eleventh Circuit, [so it] may be better to have a complete record as to what your position is and 
the government's is as to what actions were taken." Tr. at 25-26. 
The Court concluded the 
hearing with the following instructions: "So I'll let both of you confer about whether there is a 
need for any additional evidence to be presented." Tr. at 32. 
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5. The victims and the U.S. Attorney's Office then attempted to reach a stipulated set of facts 
underlying the case. The U.S. Attorney's Office offered a very abbreviated set of proposed facts, 
and the victims responded with a detailed set of proposed facts. Rather than respond to the 
victims' specific facts, however, the U.S. Attorney's Office suddenly reversed course. On July 
29, 2008, it filed a Notice to Court Regarding Absence of Need for Evidentiary Hearing (DE 17). 
The U.S. Attorney's Office took the following position: "After consideration, the Government 
believes that an evidentiary hearing is not necessary" (DE 17 at 1). The Office asserted that the 
Court need only take judicial notice of the fact that no indictment had been filed against Epstein 
to resolve the case. 
6. On August 1, 2008, the victims filed a response to the Government's "Notice," giving a 
proposed statement of facts surrounding the case. DE 19 at 5. The victims' response also 
requested that the Court direct the Government to confer with the victims regarding the 
undisputed facts of the case, and produce the non-prosecution agreement and other information 
about the case. Id. at 14. On August 14, 2008, the Court held a hearing on the case regarding 
the confidentiality of the non-prosecution agreement. The Court ultimately ordered production 
of the agreement to the victims. 
7. After the U.S. Attorney's Office made the non-prosecution agreement available to the 
victims, the victims reviewed it and pursued further discussions with the U.S. Attorney's Office. 
Ultimately, however, the U.S. Attorney's Office declined to reach a stipulated set of facts with 
the victims and declined to provide further information about the case. 
8. With negotiations at an impasse, the victims attempted to learn the facts of the case in other 
ways. In approximately May 2009, counsel for the victims propounded discovery requests in 
both state and federal civil cases against Epstein, seeking to obtain correspondence between 
Epstein and prosecutors regarding his plea agreement — information that the U.S. Attorney's 
Office was unwilling to provide to the victims and information that was highly relevant both to 
the victims' civil suit and their CVRA enforcement action. Epstein refused to produce that 
information, and (as the Court is aware) extended litigation to obtain the materials followed. The 
Court rejected all of Epstein's objections to producing the materials. 
9. On June 30, 2010, counsel for Epstein sent to counsel for the victims approximately 358 
pages of e-mail correspondence between criminal defense counsel and the U.S. Attorney's Office 
regarding the plea agreement that had been negotiated between them. See DE48-Attachment 
1/Exhibit A. These e-mails began to disclose for the first time the extreme steps that had been 
taken by the U.S. Attorney's Office to avoid prosecuting Epstein and to avoid having the victims 
in the case learn about the non-prosecution agreement that had been reached between Epstein 
and the Government. 
While the Court ordered that all of the correspondence be turned over to 
the victims, Epstein chose to disobey that order and instead only produced the correspondence 
authored by the Government and redacted all correspondence authored by him or his attorneys. 
10. In mid-July 2010, Jane Doe No. 1 and Jane Doe No. 2 settled their civil lawsuits against 
Epstein. 
Then, armed with the new information, they turned to moving forward in the CVRA 
case. On September 13, 2010, the victims informed the Court that they were preparing new 
filings in the case. 
11. On October 12, 2010, the Court entered an order directing the victims to provide a status 
report on the case by October 27, 2010. That same day, counsel for the victims again contacted 
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the U.S. Attorney's Office about the possibility of reaching a stipulated set of facts in the case. 
That same day, the U.S. Attorney's Office responded: "We don't have any problem with 
agreeing that a factual assertion is correct if we agree that is what occurred" (DE 41 at 2). 
12. On October 23, 2010, the victims e-mailed to the U.S. Attorney's Office a detailed proposed 
statement of facts, with many of the facts now documented by the correspondence between the 
U.S. Attorney's Office and Epstein's counsel. The victims requested that the U.S. Attorney's 
Office identify which facts it would agree to. In a letter to the U.S. Attorney's Office, the victims 
stated: 
If you believe that any of the facts they propose are incorrect, Jane Doe No. 1 and 
Jane Doe No. 2 would reiterate their long-standing request that you work with us 
to arrive at a mutually-agreed statement of facts. As you know, in the summer of 
2008 Jane Doe No. 1 and Jane Doe No. 2 were working with you on a stipulation 
of facts when you reversed course and took that position that no recitation of the 
facts was necessary (see doe. No. 19 at 2)... . I hope that your e-mail means that 
you will at least look at our facts and propose any modifications that you deem 
appropriate. Having that evidence quickly available to the Court could well help 
move this case to a conclusion. 
That same day, the U.S. Attorney's Office agreed to forward the proposed statement of facts to 
the appropriate Assistant U.S. Attorney for review (DE 41 at 2-3). 
13. On October 26, 2010, rather than stipulate to undisputed facts, the U.S. Attorney's Office 
contacted the victims' attorneys and asked them to delay the filing of their motion for a two-
week period of time so that negotiations could be held between the Office and the victims in an 
attempt to narrow the range of disputes in the case and to hopefully reach a settlement resolution 
without the need for further litigation. Negotiations between the victims and the U.S. Attorney's 
Office then followed over the next two days. However, at 6:11 p.m. on October 27, 2010 — the 
date on which the victims' pleading was due — the U.S. Attorney's Office informed the victims 
that it did not believe that it had time to review the victims' proposed statement of facts and 
advise which were accurate and which were inaccurate. The Office further advised the victims 
that it believed that the victims did not have a right to confer with their Office under the CVRA 
in this case because in its view the case is "civil" litigation rather than "criminal" litigation (doc. 
No. 41 at 3).
14. As a result, purely as an accommodation to the U.S. Attorney's Office, on October 27, 2010, 
the victims filed a report with the Court in which they agreed to delay filing their motion and 
accompanying facts for up to two-weeks to see if negotiations can resolve (or narrow) the 
disputes with the U.S. Attorney's Office (DE 41 at 4). Discussions with the U.S. Attorney's 
Office dragged on, including a personal meeting between Jane Doe No. 1 and the U.S. Attorney 
in December 2010. 
In seeming contradiction to this position, on March 17, 2011, the U.S. Attorney's Office 
informed the victims that it would not be making any initial disclosures to the victims as required 
for civil cases by Fed. R. Civ. P. 26(a)(1). The U.S. Attorney's Office did not explain why they 
believe that this rule of civil procedure is inapplicable if they think this case is properly viewed 
as a "civil" case. 
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15. After further discussions failed to produce any agreement or other visible progress, the 
victims informed the U.S. Attorney's Office that they would file their "summary judgment" 
motion with the Court on March 18, 2011 and requested further cooperation from the Office on 
the facts. 
16. Ultimately, after months of discussion, the U.S. Attorney's Office informed counsel for the 
victims that — contrary to promises made earlier to stipulate to undisputed facts — no such 
stipulation would be forthcoming. Ins 
on March 15, 2011, the U.S. Attorney for the 
th
Souern District of Florida, Wifredo A. 
sent a letter to the victims declining to reach any 
agreement on the facts: 
Because, as a matter of law, the CVRA is inapplicable to this matter in which no 
federal criminal charges were ever filed, your requests for the government's 
agreement on a set of proposed stipulated facts is unnecessary and premature. 
That is, because whether the rights in 18 U.S.C. § 3771(a) attach prior to the filing 
of a charge in a federal court is a matter of statutory interpretation, resolution of 
that question is not dependent upon the existence of any certain set of facts, other 
than whether a charging document was ever filed against Jeffrey Epstein in the 
United States District Court for the Southern District of Florida. And while this 
Office remains willing to cooperate, cooperation does not mean agreeing to facts 
that are not relevant to the resolution of the legal dispute at issue .... 
Letter from Wifredo A. 
to Paul G. Cassell (March 15, 2011). 
17. Accordingly, unable to work with the Government to reach a resolution of the facts, on 
March 21, 2011, the victims filed a Motion for Summary Judgment, alleging 53 undisputed facts 
along with some evidentiary support for each of the facts. DE 48. The victims also filed a 
motion to have their facts accepted because of the Government's failure to contest their facts. 
DE 49. The victims also filed a motion to have the Court direct the Government to not withhold 
relevant evidence. DE 50. 
18. Following a hearing on the motions, on September 26, 2011, the Court rejected the 
Government's argument that the CVRA was inapplicable in this case because the Government 
had never filed charges against Epstein. DE 99. The Court, however, rejected the victims' 
argument that it should accept their facts because of the Government's failure to contest the 
facts. DE 99 at 11. Instead, the Court directed that discovery could proceed in the form of 
requests for admission and document production requests. Id. at 11. The Court reserved ruling 
on the victims' motion that the Government should be directed not to withhold evidence. 
19. In light of the Court's order, on October.3, 2011, the victims filed requests for production 
with the Government. The requests included 25 specific requests, each of which linked very 
directly to the facts that the victims were attempting to prove in this case. 
20. On November 7, 2011, the day when the Government's responses were due, rather than 
produce even a single page of discovery, the Government filed a motion to dismiss the victims' 
petitions. DE 119. On that same day, the Government filed a motion to stay discovery. DE 121. 
The victims filed a response, arguing that the Government's motion was a stall tactic. DE 129. 
The victims also filed a motion to compel production of all of their discovery requests. DE 130. 
The Government filed a reply, arguing that it was not stalling. Indeed, the Government told the 
Court that "the United States has agreed to provide some information to [the victims] even 
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during the pendency of the stay [of discovery] and is undertaking a search for that information." 
DE 140 at 4. Contrary to that representation, however, over the next seventeen months, the 
Government did not produce any information to the victims, despite the victims reminding the 
Government of that statement made to the court. 
21. Ultimately, after some additional motions and rulings, on June 19, 2013, the Court denied 
the Government's motion to dismiss and lifted any stay of discovery. DE 189. That same day, 
the Court entered an order granting the victims' motion to compel and directing the Government 
to produce (1) all correspondence between it and Epstein; (2) all communications between the 
Government and outside entities; and (3) every other document requested by the victims. DE 
190 at 2. With respect to the third item, the Court allowed the Government to assert privilege by 
producing the items in question for in camera inspection and filing a contemporaneous privilege 
log. Id. The Court required that the privilege log must "clearly identify[] each document[] by 
author(s), addressee(s), recipient(s), date, and general subject matter ...." DE 190 at 2. 
22. On July 19 and July 27, 2013, the Government made its production. With regard to item (1) 
— correspondence with Epstein, the Government withheld the correspondence pending a ruling 
from the Eleventh Circuit on Epstein's motion to stay production of these materials. With regard 
to the other items, the Government produced 14,825 pages of documents to the Court for in 
camera inspection, but turned over only 1,357 pages to the victims. Thus, the Government 
asserted privilege to more than 90% of the documents in question. The documents that the 
Government produced were almost worthless to the victims, as they included such things that the 
victims' own letters to the Government (Bates 0001-04), court pleadings filed by the victims 
themselves or other victims, by Epstein, or by news media organizations (e.g., Bates 00142-88, 
00229-31, 281-311, 00668-69), public court rulings on Epstein related matters (e.g., Bates 0008-
10, 0012-14. 0036-86, 00190-228), public newspaper articles (e.g., Bates 0011, 0030, 0032-33), 
and similar materials already available to the victims. It also included roughly four hundred 
pages of notices sent to the various other victims in this case — notices that were substantively 
indistinguishable from the notices the victims themselves in this case had already received. 
Almost without exception, the documents the Government produced do not go to the disputed 
issues in this case. 
23. The Government made one last production of materials in this case on August 6, 2013. This 
involved roughly 1,500 pages of documents that were largely meaningless in the context of the 
contested issues in the case. They included public documents in the case such the crime victims' 
own pleadings, see, e.g., Bates 000671-000711 (copy of the victims' redacted summary 
judgment motion). Curiously, while the Government has produced these documents that would 
likely fall into an "irrelevant" category of documents, they have simultaneously refused 
production of hundreds of other documents that arc responsive to our requests on the basis of 
relevance. 
24. The victims have tried to obtain information on all relevant subjects through requests for 
admission. The Government, however, has refused to admit many of the victims' central 
allegations in this case. A copy of the victims' requests for admissions and the Government's 
responses is attached to this affidavit so that the Court can see that the victims have diligently 
tried to pursue this avenue for developing the facts in this case. 
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25. The victims have also tried to obtain information on subjects related to their suit by 
voluntary requests for interview with persons who are no longer emilearilie Justice 
Department. For example, I have sent letters to both Bruce Reinhart and 
who both 
have information about the Epstein case, requesting an opportunity to discuss the case with them. 
Both of them have ignored my letters. 
The Need for the Materials Requested by the Victims 
26. The documents that the victims requested that the Government produce to them on October 
3, 2011, are all highly relevant to their CVRA enforcement action. We would not have requested 
them otherwise. The victims also have no other means of obtaining the requested material. This 
section of the affidavit explains why the materials are needed by the victims. 
For the 
convenience of the Court, the affidavit will proceed on a section-by-section basis concerning the 
need for the materials. Also for the convenience of the Court, a copy of the October 3, 2011, 
request for production is attached to this Affidavit. Also attached is the victims' supplemental 
discovery request of June 24, 2013. As the Court will note from reviewing the requests for 
production, most of the requests specifically recount the allegations that the requested documents 
would support, in an effort to eliminate any dispute from the Government that the documents 
were not relevant to the case. Many of the requests for production link directly to specific 
paragraphs in the victims' previously-filed summary judgment motion. Accordingly, the victims 
have a very specific need for these documents to support the allegations in the summary 
judgment motion found at DE 48 at 3-23. 
27. The Court has previously concluded that the victims' proof of their claims is, at this point in 
the case, inadequate. Instead, the Court has ruled: "Whether the evidentiary proofs will entitle 
[the victims] to that relief [of setting aside the non-prosecution agreement] is a question properly 
reserved for determination upon a fully developed evidentiary record." DE 189 at 11-12. The 
Court has further indicated that it will be considering an "estoppel" argument raised by the 
Government as a defense in this case. DE 189 at 12 n.6. The Court has noted that this argument 
"implicates a fact-sensitive equitable defense which must be considered in the historical factual 
context of the entire interface between Epstein, the relevant prosecutorial authorities and the 
federal offense victims — including an assessment of the allegation of a deliberate conspiracy 
between Epstein and federal prosecutors to keep the victims in the dark on the pendency of 
negotiations between Epstein and federal authorities until well after the fact and presentation of 
the non-prosecution agreement to them as a fait accompli." DE 189 at 12 n.6 (emphasis added). 
The victims have a compelling need for information about the Government's actions to show 
what the "entire interface" was and to respond to the Government's estoppel arguments, as well 
as other defenses that it appears to be preparing to raise. See, e.g., DE 62 (52-page response 
from the Government to the victim's summary judgment motion, raising numerous factually-
based and other arguments against the victim's position). 
28. 
Request for Production ("RFP") No. 1 requests information regarding the Epstein 
investigation. 
These documents are needed to support the victims' allegations that the 
Government had a viable criminal case for many federal sex offenses that it could have pursued 
against Epstein. See, e.g., DE 48 at 3-7. 
29. RFP No. 2 requests information regarding crime victim notifications in this case. These 
documents are needed to support the victims' allegations that their rights under the CVRA, their 
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right to notice and to confer with the Government, were violated in this case. In particular, these 
documents are needed to demonstrate that the victims were not properly notified about the non-
prosecution agreement (NPA) entered into by the Government and Jeffrey Epstein and that the 
Government did not confer with the victims about the agreement. See, e.g., DE 48 at 11-17. 
30. RFP No. 3 requests information about the NPA, including in particular its confidentiality 
provision. These documents are needed to demonstrate that the confidentiality provision 
precluded disclosing the agreement to Jane Doe No. 1 and Jane Doe No. 2, as well as to other 
victims. See, e.g., DE 48 at 10-17. These documents are further needed to demonstrate that 
Jeffrey Epstein specifically orchestrated the secrecy of the agreement, thereby deliberately 
causing the Government's CVRA violation in this case. See, e.g., DE 48 at 13. 
31. RFP No. 4 requests documents relating to negotiations between the Government and Jeffrey 
Epstein concerning the court and/or location in which Jeffrey Epstein would enter any guilty plea 
(including in particular any negotiations concerning concluding the plea in Miami or another 
location outside of West Palm Beach). These documents are relevant to the victims allegations 
that the Government was interested in finding a place to conclude any plea agreement that would 
effectively keep Epstein's victims (most of whom resided in or about West Palm Beach) from 
learning what was happening through the press. See, e.g., DE 48 at 7-8. 
32. RFP No. 5 requests documents pertaining to negotiations between the Government and 
Jeffrey Epstein regarding any legal representation of the victims in civil cases against Epstein. 
These documents are needed to prove the victims' allegation that part of the plea negotiations 
with Epstein involved Epstein's efforts to make sure that the victims would be represented in 
civil cases against Epstein by someone who was not an experienced personal injury lawyer or by 
someone familiar to Epstein or his legal team. See, e.g., DE 48 at 9. 
33. RFP No. 6 requests documents concerning the Government's and/or Epstein awareness or 
discussion of possible public criticism and/or victim objections to the non-prosecution agreement 
that they negotiated. The documents are needed to prove the victims' allegations that the 
Government wanted the non-prosecution agreement with Epstein concealed from public view 
because of the intense public criticism that would have resulted had the agreement been 
disclosed and/or the possibility that victims would have objected in court and convinced the 
judge not to accept the agreement. See, e.g., DE 48 at 7-8, II. They are also relevant to bias and 
motive by the authors or subjects of other documents in this case. 
34. RFP No. 7 requests documents regarding the Government's awareness of its potential 
CVRA obligations in this case and regarding any discussions between the Government and 
Epstein concerning these CVRA obligations in this case. These documents are needed to prove 
the victims' allegations that the Government was aware that it potentially had obligations under 
the CVRA to notify the victims about the non-prosecution agreement and any related state court 
plea agreement. See, e.g., DE 48 at 12-13. 
35. 
RFP No. 8 requests documents regarding Epstein's lobbying efforts to persuade the 
Government to give him a more favorable plea arrangement and/or non-prosecution agreement, 
including efforts on his behalf by former President Bill Clinton, Prince Andrew, and Harvard 
Law Professor Alan Dershowitz. These materials are needed to prove the victims allegation 
that, after Epstein signed the non-prosecution agreement, his performance was delayed while he 
used his significant social and political connections to lobby the Justice Department to obtain a 
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more favorable plea deal. See, e.g., DE 48 at 16-18. These materials also are needed to establish 
the course of the proceedings in this case, which is necessary in light of the Government's letters 
to the victims (discussed in the next paragraph) concerning the status of the case. 
36. RFP No. 9 requests documents regarding the letters sent to the victims by the FBI on 
January 10, 2008, Jane Doe No. 1 and Jane Doe No. 2 advising them that "this case is currently 
under investigation." These documents are needed to show that these letters were inaccurate or, 
at the very least, highly misleading, because they conveyed the impression that no plea 
arrangement (for example, a non-prosecution agreement) had been negotiated between Epstein 
and the Government. See, e.g., DE 48 at 16. These documents are also needed to respond to the 
Government's "estoppel" defense, as noted in the Court's order DE 189 at 12 n.6. 
37. RFP No. 10 requests documents regarding the victims' allegations that the FBI was led to 
believe that their investigation of Epstein was going to produce a federal criminal prosecution 
and that the FBI was also misled by the U.S. Attorney's office about the status of the case. The 
Government has argued that these documents are not relevant to the case, because the only issue 
is whether the Government misled the victims. But the Government fails to recognize that the 
victims received information about the case through the FBI. These documents are therefore 
needed to demonstrate that the victims received inaccurate information about the status of the 
case — inaccurate information caused by the U.S. Attorney's Office's negotiations with Epstein. 
If the FBI agents were not accurately informed about the progress of the cases, then they could 
not have accurately informed the victims about the progress of the case — a central point in the 
victims' argument. Moreover, these documents would show a common scheme or plan —
something made admissible in a trial by operation of Fed. R. Evid. 404(3). Of course, if the U.S. 
Attorney's Office was misleading the FBI about the NPA, it would have been part of the same 
scheme or plan to mislead the victims as well. The documents are also needed to support specific 
allegations in the victims' summary judgment motion. See, e.g., DE 48 at 16-17. 
38. RFP No. 11 requests documents regarding various meetings that the Government (including 
FBI agents) had with the victims. These documents are needed to prove that during those 
meetings the Government did not disclose to the victims (or to their attorneys) that a non-
prosecution agreement had been negotiated with Epstein, and even signed with Epstein, that 
related to their cases, allegations that the victims have advanced in their summary judgment 
motion. See, e.g., DE 48 at 16-18. 
39. RFP No. 12 requests all documents connected with a request from the U.S. Attorney's 
Office to me (Bradley J. Edwards) to write a letter concerning the need for filing federal charges 
against Epstein and follow-up to that letter. These documents are needed to show that this 
request was made to me without disclosing the existence of the non-prosecution agreement. 
Thus, just as Jane Doe No. I and Jane Doe No. 2 were deceived about the NPA, I was deceived 
as well. See, e.g., DE 48 at 18-19. It is also needed to contradict the Government's apparent 
position that it disclosed the "existence' of the NPA to me and to the victims. See, e..g., Gov't 
Answers to RFA 1 13(d) ("The government admits that, when Epstein was pleading guilty to the 
state charges discussed in the non-prosecution agreement, the USAO and Epstein's defense 
attorneys sought to keep the document memorializing the non-prosecution agreement 
confidential, but denies that they sought at that time to keep the existence of the non-prosecution 
agreement confidential."). 
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40. RFP No. 13 requests documents regarding how, on or about June 27, 2008, the Government 
learned that Epstein would be entering his plea to state charges on or about June 30, 2008. The 
documents are needed to describe the course of proceedings in this case and to prove both the 
Government's and Epstein's awareness that he would be entering a guilty plea (and thus 
blocking prosecution of other crimes) without the victims' full knowledge of what was 
happening. See, e.g., DE 48 at 19-20. 
41. 
RFP No. 14 requests documents relating to the Government and Epstein working together 
to keep the existence of the non-prosecution agreement secret, including declining comment 
about the existence of such an agreement when asked about it when his guilty plea in state court 
became public knowledge. These documents are needed to prove the victims' allegations that 
the Government concealed the NPA from them, see, e.g., DE 48 at I 4-18,and to contradict what 
appears to be the Government's position, namely that the victims were aware of the NPA shortly 
after it was negotiated, see, e.g., Gov't Answers to RFA 1 13(b) (claiming that "the USA() had 
communicated with Jane Doe #1 about the non-prosecution agreement prior to Epstein's June 30, 
2008 guilty plea."). 
These documents are also necessary to contradict the Government's 
apparent claim that the NPA did not bar discussions with crime victims. See, e.g., Gov't 
Answers to RFA 1 13(d) (Government denying request that it admit that "Epstein's defense 
attorneys had negotiated for a confidentiality provision in the non-prosecution agreement that 
barred conferring with victims about the agreement"). 
42. RFP No. 15 requests documents pertaining to the feasibility of notifying the victims about 
the NPA, along with information concerning how the victims came to receive a "corrected" 
notification letter on about September 3, 2008 — months after Epstein had pled guilty. These 
documents are needed to demonstrate that the Government had no valid reason for failing to 
provide notice to the victims. It is also needed to demonstrate why the victims at first received 
inaccurate information about the NPA, as well as Jeffrey Epstein's involvement in that 
inaccurate notice. See, e.g., DE 48 at 15-16. 
43. RFP No. 16 requests documents regarding Bruce Reinhart, a senior prosecutor who was 
present in the U.S. Attorney's Office during the time that the Office negotiated the NPA with 
Epstein, blocking his prosecution for federal crimes in the Southern Districdt of Florida. In RFP 
No. 16, the victims have sought documents showing that Reinhart learned confidential, non-
public information about Epstein matter. The Court will recall that Reinhart has filed a sworn 
affidavit with this Court, in which he flatly declared that while he was a prosecutor in the Office: 
"I never learned any confidential, non-public information about the Epstein matter." DE 79-1 at 
3 (¶ 12). When Reinhart made that statement, it seemed improbable to me, because Reinhart was 
in close contact with other prosecutors in the Office and would seem likely that he would have 
discussed the high-profile Epstein case with them. Additionally, I learned through public record 
that while still a prosecutor at the Office Mr. Reinhart established his criminal defense office at 
the exact address (and exact Suite number) as Jeffrey Epstein's personal business address. 
However, I did not have any direct way of contradicting Reinhart's sworn statement. Since then, 
however, in answering the victims' Requests for Admissions, the Government has admitted that 
it possesses information that Reinhart learned confidential, non-public information about the 
Epstein case and that he discussed the Epstein case with other prosecutors. Gov't Answers to 
RFA's 1 15(a) & (b). Of course, this means that the Government has documents that Reinhart 
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filed a false affidavit with this Court. This gives rise to the reasonable inference that, if Reinhart 
was willing to provide false information about this subject, he may have additional information 
about the case that is being concealed as well. 
44. Materials about Reinhart are also needed to support the victims' summary judgment motion. 
See, e.g., DE 48 at 22-23 (raising allegations about Reinhart). 
45. Reinhart's affidavit with the Court also states: "Because I did not have any, I did not share 
non-public confidential information about the Epstein investigation with any of Epstein's 
attorneys." DE 79-1 at 4 (¶ 17). Because the Government has information demonstrating that 
the first part of this statement is false, it may well be that the second part of the statement is false 
as well. Given that Mr. Reinhart established a business address identical to Epstein's business 
address, at a time while he was still working at the US Attorney's Office, and that Mr. Reinhart 
ultimately represented several of Epstein's co-conspirators, jet pilots, and staff, during the civil 
litigation, any involvement Mr. Reinhart had with the Epstein case while working at the Office is 
highly relevant. 
46. The Government has further admitted that it possesses documents reflecting contacts 
between Bruce Reinhart and persons/entities affiliated with Jeffrey Epstein before Reinhart left 
his job at the U.S. Attorney's Office. Gov't Answers to RFA's ¶ 16. As stated above, Reinhart 
left the U.S. Attorney's Office to start a private firm that was located in the same address as 
Epstein's personal business where he was daily. This would appear to be a violation of the 
Florida rules of ethics for attorneys. 
47. Information about Reinhart's connections to Epstein is critical to the victims' allegations in 
this case. If Reinhart was helping Epstein gain insight into the prosecutions efforts, that would 
provide a motive for Reinhart (and other prosecutors) not to properly notify the victims and not 
to confer with them. 
Also, if Epstein was improperly receiving information about the 
prosecution efforts against him (or lack thereof), that could be highly relevant to the remedies 
stage of this case, in which the victims will ask (among other things) to have the NPA agreement 
invalidated. Epstein has already indicated that he will raise a double jeopardy argument against 
that effort. However, double jeopardy considerations do not apply in situations where the 
defendant was not truly in jeopardy of prosecution. In addition, the Court may wish to consider, 
in crafting a remedy, Epstein's culpability for the violations of the NPA. Evidence that Epstein 
was improperly obtaining information about the prosecution efforts against him would be highly 
relevant to that culpability assessment. It is also relevant to the estoppel defense that the 
Government (and perhaps Epstein as well) intend to raise. 
48. Evidence concerning Reinhart's connections, including improper connections, to Epstein is 
also relevant to bias and motive in this case. It would show, for example, the Reinhart had a 
reason to encourage others in the U.S. Attorney's Office to give Epstein a more lenient deal than 
the one he was entitled to. 
49. RFP No. 16 requested information not only about improper connections between Epstein 
and Reinhart, but more broadly about such connections with any other prosecutors. Of course, if 
the Government possesses such information, it would be highly relevant to the victims' 
allegations for the reasons just discussed. In its answers to the victims' Requests for Admission, 
the Government admits that it has information about a personal or business relationship between 
Jeffrey Epstein and another prosecutor involved in the Epstein case, Matthew 
. Answers 
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