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Getting Epstein to agree to pay restitution to his victims and register as a sex offender were key, Villafana wrote. Prosecutors wanted to assure his victims that they would be compensated and that "other minors throughout the country" would be protected, she wrote.

But shortly after Epstein signed the agreement on Sept. 24, 2007, he began fighting it, she said. He and his legal team, including former U.S. Solicitor General Kenneth Starr, whose investigation led to President Bill Clinton's impeachment, contacted high-level justice department officials. They challenged the terms of the non-prosecution agreement.

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