Epstein Secrets

Epstein denies that your client is a victim of an enumerated offense, please provide notice of that denial to the undersigned [AUSA]." See Deel. of AUSA Villafana, Exhs. 6 & 7, at 2 (July 9, 2008). The clear implication of the USAO's request (by which the USAO appears to involve itself in the instant litigati

--pending" is ''[r]emaining undecided; awaiting decision .... " Black's Law Dictiona,y 1154 (8th ed. 2004 ). The United States Court of Appeals for the Eleventh Circuit routinely relies on Black's Law Dictionary for the definition of statutory terms, including in criminal cases. See e.g., United States , •. Young,

pulate that this correspondence accurately reflects communications between Epstein and the Justice Department. 8. At the time of plea discussions, AUSA Villafana had drafted an 82-page prosecution memorandum outlining federal offenses committed by Epstein (including offenses committed against Jane Doe #1 and

ase, the CVRA did not apply. The EFTA00207822 question of application of the CVRA to this situation appears to be an issue of first impression in the Eleventh Circuit. The parties jointly propose a briefing schedule to present that legal issue to the Court for resolution. Once the Court resolves that legal issue

in favor of prosecution by the State of Florida . . . ." See In re: Jane Doe, Case No. 08- 80736-CIV-Marra/Johnson (S.D. Fla.) (D.E. 14), Decl. of AUSA Villafana, 07/09/08, ¶ 5, attached hereto as Exhibit "A" (emphasis added). Under the Agreement, the USAO presently retains the continuing right to indict Mr

njoin the stay. And we conclude that this provision does not violate separation of powers principles.") (emphasis added). One District Court within the Eleventh Circuit recently construed "the plain language of § 3509(k)" as "regaining" a stay in a case . . . where . . a parallel criminal action [is] pending." Doe

r legal positions, the risk of litigation, and the government's desire to minimize damaging impeachment evidence of its witnesses. As summarized by AUSA Villafana, the USAO-SDFL made the decision to enter the NPA out of a desire to obtain a guaranteed sentence of incarceration, the equivalent of uncontested r

ed Mr. Epstein's rights and privileges, Mr. Epstein and his counsel intervened to assert their rights, both in the district court, and on appeal to the Eleventh Circuit. See Doe No. 1, supra. That there would be no judgment against Mr. Epstein at the end of this CVRA litigation, however, was understood throughout t

in favor of prosecution by the State of Florida . . . ." See In re: Jane Doe, Case No. 08- 80736-CIV-Marra/Johnson (S.D. Fla.) (D.E. 14), Decl. of AUSA Villafana, 07/09/08, ¶ 5, attached hereto as Exhibit "A" (emphasis added). Under the Agreement, the USAO presently retains the continuing right to indict Mr

njoin the stay. And we conclude that this provision does not violate separation of powers principles.") (emphasis added). One District Court within the Eleventh Circuit recently construed "the plain language of § 3509(k)" as "requirfing/ a stay in a case . . . where . . . a parallel criminal action [is] pending." D

n of the parties’ Non Prosecution Agreement—and issued yet another subpoena seeking evidence in this case. See Tab 19, Subpoena to | In the subpoena, AUSA Villafana directs MMMto appear on July 1, 2008 to give testimony and produce documents to FGJ 07-103 West Palm Beach. The attachment to the subpoena seeks docu

s to engage in a criminal sex act or (b) that Owens was under the age of 18.) (emphasis added). Again, none of these factors is present in this case. The Eleventh Circuit’s interpretation of the statute makes perfect sense: were § 1591 not limited in this fashion, it would threaten to criminalize a host of localized beha