| From: | Villafana, Ann Marie C.(USAFLS) <AVillafana@usa.doj.gov> |
| 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 Villafaña
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?
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
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EFTA00190531
| -----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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