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Case 1:20-cr-00330-PAE Document 204-3 Filed 04/16/21 Page 262 of 348 civil suits that were pending against Epstein.*® Villafafia also emailed one of the pro bono attorneys she had engaged to help victims avoid defense harassment, informing him that the federal investigation had been resolved through a state plea and that Epstein had an “agreement” with the USAO “requir[ing] him to make certain concessions regarding possible civil suits brought by the victims.” Villafafia advised Goldberger: “The FBI has received several calls regarding the [NPA]. I do not know whether the title of the document was disclosed when the [NPA] was filed under seal, but the FBI and our Office are declining comment if asked.” B. July 7, 2008: The CVRA Litigation Is Initiated On July 3, 2008, victims’ attorney Edwards spoke to Villafafia by telephone about the resolution of the state case against Epstein “and the next stage of the federal prosecution.”*°’ In his 2017 affidavit filed in the CVRA litigation, Edwards asserted that during this conversation, Villafafia did not inform him of the NPA, but that during the call, he sensed that the USAO “was beginning to negotiate with Epstein concerning the federally identified crimes.” However, in an email Villafafia sent after the call, she informed Sloman that during the call, Edwards stated that “his clients can name many more victims and wanted to know if we can get out of the deal.” Villafafia told Sloman that after she told Edwards that the government was bound by the agreement, assuming Epstein completed it, Edwards asked that “if there is the slightest bit of hesitation on Epstein’s part of completing his performance, that he and his [three] clients be allowed to consult with [the USAO] before making a decision.”*°° That same day, Edwards wrote a letter to Villafafia, complaining that Epstein’s state court sentence was “grossly inadequate for a predator of this magnitude” and urged Villafafia to “move forward with the traditional indictments and criminal prosecution commensurate with the crimes Mr. Epstein has committed.” On July 7, 2008, Edwards filed his emergency petition in the U.S. District Court for the Southern District of Florida on behalf of Courtney Wild, who was then identified only as “Jane Doe.” She was soon joined by a second petitioner, and they were respectively referred to as “Jane Doe 1” and “Jane Doe 2.”3°? Edwards claimed that the government had violated his clients’ rights under the CVRA by negotiating to resolve the federal investigation of Epstein without consulting with the victims. The petition requested that the court order the United States to comply with the CVRA. The USAO opposed the petition, arguing that the CVRA did not apply because there were 206 According to Villafafia’s handwritten notes from June 30, 2008, Villafafia left a message for two of the attorneys. 367 In his 2017 affidavit filed in the CVRA case, Edwards recalled that his telephone conversation occurred on June 30, 2008, but noted that it could possibly have occurred on July 3, 2008. 468 Sloman responded, “Thanks.” 369 Later attempts by two additional victims to join the ongoing CVRA litigation were denied by the court. 236 DOJ-OGR- 00003438