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Case 22-1426, Document 77, 06/29/2023, 3536038, Page236 of 258
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involved in such notifications. According to Villafaña, Sloman then directed her to have the case
agents make the victim notifications.

Accordingly, Villafaña directed the case agents to “meet with the victims to provide them
with information regarding the terms of the [NPA] and the conclusion of the federal investigation.”
The case agent told OPR, “[T]here was a discussion that Marie and I had as
to . . . how we would tell them, and what we would tell them, and what that was I don’t recall, but
it was the terms of the agreement.” Villafaña believed that if “victims were properly notified of
the terms [of the NPA] that applied to them, regarding their right to seek damages from [Epstein],
and he paid those damages, that the rest of the [NPA] doesn’t need to be disclosed.” Villafaña
“anticipated that [the case agents] would be able to inform the victims of the date of the state court
change of plea [hearing], but that date had not yet been set by state authorities at the time the first
victims were notified [by the FBI].” Villafaña told OPR that it was her belief that because the
USAO had agreed to a confidentiality clause, the government could not disclose the NPA to the
general public, but victims could be informed “because by its terms they needed to be told what
the agreement was about.” Villafaña told OPR that no one in her supervisory chain expressed a
concern that if victims learned of the NPA, they would try to prevent Epstein from entering a plea.

Within a week after the NPA was signed, news media began reporting that the parties had
reached a deal to resolve the Epstein case. For example, on October 1, 2007, the
New York Post reported that Epstein “has agreed to plead guilty to soliciting underage prostitutes
at his Florida mansion in a deal that will send him to prison for about 18 months,” and noted that
Epstein would plead guilty in state court and that “the feds have agreed to drop their probe into
possible federal criminal violations in exchange for the guilty plea to the new state charge.”301

The case agent recalled informing some victims that “there was an agreement reached” and
“we would not be pursuing this federally.” In October 2007, for example, the case agents met with
victim Courtney Wild, “to advise her of the main terms of the Non-Prosecution Agreement.”
According to the case agent, during that meeting, the case agents told Wild “that an agreement had
been reached, Mr. Epstein was going to plead guilty to two state charges, and there would not be
a federal prosecution.”302 However, in a declaration filed in 2015 in the CVRA litigation, Wild
described the conversation differently:

[T]he agents explained that Epstein was also being charged in State
court and may plea [sic] to state charges related to some of his other
victims. I knew that State charges had nothing to do with me.

301 Dan Mangan, “‘Unhappy Ending’ Plea Deal—Moneyman to Get Jail For Teen Sex Massages,” New York
Post, Oct. 1, 2007. See also “Model Shop Denies Epstein Tie,” New York Post, Oct. 6, 2007; “Andrew Pal Faces Sex
List Shame,” Mail on Sunday, Oct. 14, 2007; “Epstein Eyes Sex-Rap Relief,” New York Post, Oct. 9, 2007; “Sex Case
‘Victims’ Lining Up,” New York Post “Page Six,” Oct. 15, 2007; Dareh Gregorian and Mathew Nestel, “I Was Teen
Prey of Pervert Tycoon,” New York Post, Oct. 18, 2007. The following month, the Palm Beach Post reported the end
of the federal investigation as well. See “Epstein Has One Less Worry These Days,” Palm Beach Post, Nov. 9, 2007;
“How Will System Judge Palm Beach Predator?,” Palm Beach Post “Opinion,” Nov. 16, 2007.

302 The co-case agent recalled meeting with the victims about the resolution of the case, but could not recall the
specifics of the discussions.

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