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Case 1:20-cr-00330-PAE Document 204-3 Filed 04/16/21 Page 258 of 348 Villafafia told OPR that before the state plea hearing, she sent Reiter a list of the victims, including their telephone numbers, to notify and asked him to destroy the list. Villafafia recalled that Reiter told her that he would “try to contact as many as he could” and that he would destroy the list afterwards. Villafafia did not recall being “asked [to] provide a list of all our victims to the State Attorney’s Office.” In his 2009 deposition, Reiter stated that Villafafia sent him a letter “around the time of sentencing,” listing the victims in the federal investigation, and that she asked him to destroy the letter after he reviewed it. Reiter recalled that he requested the list because he was aware that the state grand jury’s indictment of Epstein did not include all of the victims that the PBPD had identified and he “wanted to make sure that some prosecution body had considered all of our victims.”?* In her 2017 declaration in the CVRA litigation, Villafafia stated that she and the PBPD “attempted to notify the victims about [the June 30] hearing in the short time available to us.”°>* In her 2008 declaration, however, Villafafia conceded that “all known victims were not notified.” Villafafia told OPR that Edwards was the only victim attorney she was authorized to contact—she thought probably by Sloman—about the June 30, 2008 plea hearing because Edwards “had expressed a specific interest in the outcome.” Villafafia recalled, “I was told that I could inform [Edwards] of [the plea date], but I still couldn’t inform him of the NPA.”** In her 2008 declaration in the CVRA litigation, Villafafia stated that she called Edwards and informed him of the plea hearing scheduled for Monday; Villafafia stated that Edwards told her that he could not attend the hearing but “someone” would be present. In a later filing in the CVRA litigation, however, Edwards asserted that Villafafia told him only that “Epstein was pleading guilty to state solicitation of prostitution charges involving other victims—not Mr. Edwards’ clients nor any of the federally-identified victims.”*°° Edwards further claimed that because Villafafia failed to inform him that the “guilty pleas in state court would bring an end to the possibility of federal prosecution pursuant to the plea agreement,” his clients did not attend the hearing. Villafafia told OPR that her expectation was that the state plea proceeding would allow Edwards and his clients the ability to comment on the resolution: 453 Reiter showed the letter to the lead Detective so he could “confirm that all of the victims that we had for the state case were included on that.” The Detective “looked at it and he said they’re all there and then [Reiter] destroyed it.” The Detective recalled viewing the list in Reiter’s office, but he could not recall when Reiter showed it to him. 354 The FBI co-case agent told OPR that “I don’t think the [FBI] reached out to anyone.” A008 Villafafia told OPR that she thought that it was Sloman who gave her the instructions, but she could not “remember the specifics of the conversation.” 356 Villafafia stated that she “never told Attorney Edwards that the state charges involved ‘other victims,’ and neither the state court charging instrument nor the factual proffer limited the procurement of prostitution charge to a specific victim.” Although Edwards criticized Villafafia’s conduct in his CVRA filings, in his recently published book, Edwards described Villafafia as a “kindhearted prosecutor who tried to do right,” noting that she “believ[ed] in the victims and tr[ied] ... to bring down Jeffrey Epstein.” Bradley J. Edwards with Brittany Henderson, Relentless Pursuit at 380 (Gallery Books 2020). 232 DOJ-OGR- 00003434