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

ered on FLSD Docket 08/12/2008 Page 3 of 13 "agreed to defer federal prosecution in favor of prosecution by the State of Florida .... " See In re. Jane Doe, Case No. 08-80736-CIV-Marra/Johnson (S.D. Fla.) (DE 14), Deel. of AUSA Villafana, 07/09/08, ,i 5, attached hereto as Exhibit "A" (emphasis added).

ael Tein, former counsel for Defendant, along with Mr. Jack Goldberger, who still represents Defendant, entered into a verbal agreement at the time AUSA Villafana provided the USAO List to them, whereby neither Defendant, Jeffrey Epstein, nor his agents would have any direct or indirect contact with the victi

e 9:08-cv-80119-KAM Document 113 Entered on FLSD Docket 05/22/2009 Page 1 of 12 JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. JANE DOE NO. 3, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. JANE DOE NO. 4, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. UNITED STATES DISTRICT COURT

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

had drafted an 82-page prosecution memorandum outlining federal offenses committed by Epstein (including offenses committed against Jane Doe #1 and Jane Doe 2), as well as a 53-page draft indictment. 9. During the plea discussions, AUSA wrote in an e-mail to defense counsel: "On an 'avoid the press' not

n the West Palm Beach office of the U.S. Attorney's Office, and supervised portions of the criminal investigation of Jeffrey Epstein. 8. assisted AUSA Villafana during the criminal investigation of.leffrey Epstein. 9. In his revious capacity as Deputy Chief of the Criminal Division, U.S. Attorney's Office

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 08-80736-CIV-MARRA JANE DOE #1 and JANE DOE #2, Petitioners, vs. UNITED STATES OF AMERICA, Respondent. RESPONDENT'S INITIAL DISCLOSURES Respondent United States of America, by and through

To the extent that the Government is going to rely on representations about its internal motivations in making certain decisions (i.e., what things AUSA Villafana and the FBI agents "concluded" as part of making decisions), the victims respectfully request an opportunity to depose or cross-examine the relevan

Document 415 Entered on FLSD Docket 08/11/2017 Page 1 of 14 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 9:08-ev-80736-ICAM JANE DOE 1 AND JANE DOE 2, Petitioners, v. UNITED STATES, Respondent. JANE DOE 1 AND JANE DOE 2'S RESPONSE TO GOVERNMENT'S STATEMENT OF UNDISPUTED MATERIA

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

ction. Introduction This lawsuit arises from a pending federal criminal action concerning, among other things, an alleged assault of the plaintiff Jane Doe, who, according to her complaint, on "numerous occasions" provided "massages" to Epstein with "no credentials to provide massage therapy" and was "

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

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 08-80736-CIV-MARRA JANE DOE 1 AND JANE DOE 2, Petitioners, vs UNITED STATES OF AMERICA, Respondent. I JEFFREY EPSTEIN, Intervenor. I INTERVENOR JEFFREY EPSTEIN'S BRIEF IN OPPOSITION TO

never, ever, ever, no, never. Jeffrey is an awesome man, no. At the end of her interview, [LM] was asked if she had any questions for the agents or AUSA Villafana. [LM] responded: A. No, but I hope — I hope Jeffrey, nothing happens to Jeffrey because he's an awesome man and it would really be a shame. It's a

ck Funding, LLC, et aL v. Scott W. Rothstein, et aL, Case No. 09-062943(19); Deposition Transcript of Jeffrey Epstein. 502008CA028058XXXXMB AB; and Jane Doe v. Jeffrey Epstein, 08-80893- CIV Marra/Johnson. Rothstein returned to South Florida in November 2009 to face federal criminal charges and civil cl

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

ction. Introduction This lawsuit arises from a pending federal criminal action concerning, among other things, an alleged assault of the plaintiff Jane Doe, who, according to her complaint, on "numerous occasions" provided "massages" to Epstein with "no credentials to provide massage therapy" and was "

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

in the former firm of Herman, Sloman, & Mermelstein, filed five lawsuits, each asking for $50 million, against Mr. Epstein. Each lawsuit is entitled “Jane Doe # vs. Jeffrey Epstein,” despite the fact that each of the plaintiffs is an adult and not entitled to plead anonymously. See Tab 32, Examples of Feder