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informed me that any resolution of the criminal matter was imminent at that time, nor even that such a resolution was being contemplated. In fact, Villafafia gave me the impression that the Federal investigation was on-going, very expansive, and continuously growing, both in the number of identified vict
Florida. Neither Doe 1 nor Doe 2 had any reason to believe that they were victims of a state crime that was being prosecuted. Based on everything Villafafia said, and could not say, there was no possible way I could have believed that this state plea could affect the federal investigation or the rights
se calls, the line prosecutor continually created the impression that no resolution of the case was imminent: During the telephone calls I had with Villafafia between mid and late June 2008, she never informed me that previously, in September 2007, the U.S. Attorney's Office had reached a non-prosecution
in avoiding the improper deposition. Villafafia secured pro bono counsel by contacting Meg Garvin, Esq. of the National Crime Victims' Law Center in Portland, Oregon, which is based in the Lewis & Clark College of Law. Ms. Garvin was not advised that a non- prosecution agreement had been reached in this m
w. During the call, Ms. Garvin was not advised about the Non-Prosecution Agreement. In mid-June 2008, Mr. Edwards contacted Assistant U.S. Attorney Villafafia to inform her that he represented Jane Doe #1 and, later, Jane Doe #2. Mr. Edwards asked to meet to provide information about the federal crimes co
Page: EFTA00013932 →ing the improper deposition. AUSA Villafana secured pro bono counsel by contacting Meg Garvin, Esq. of the National Crime Victims' Law Institute in Portland, Oregon, which is based in the Lewis & Clark College of Law. During the call, Ms. Garvin was not advised about the Non-Prosecution Agreement. In mi
Page: EFTA00013932 →49, 58. Through diligent efforts, counsel for Jane Doe #1 and Jane Doe #2 received copies of half of the e-mail correspondence (the half reflecting Villafafia's communications to defense counsel) on about June 30, 2010. See Edwards Declaration at & &20-22. 5 EFTA00206839 10. The correspondence also sh
in avoiding the improper deposition. AUSA secured pro bono counsel by contacting Meg Garvin, Esq. of the the National Crime Victims' Law Center in Portland, Oregon, which is based in the Lewis & Clark College of Law. During the call, Ms. Garvin was not advised that a non-prosecution agreement had been r
of these 39 pages is: "File folder entitled 'CORR RE GJ SUBPOENAS' containing correspondence related to various grand jury subpoenas and attorney (Villafafia) handwritten notes." 64. Another good illustration of the inadequacies of the privilege log is provided on page 20 of the first privilege log, with
o. 1 in avoiding the improper deposition. secured pro bono counsel by contacting Meg Garvin, Esq. of the the National Crime Victims' Law Center in Portland, Oregon, which is based in the Lewis & Clark College of Law. During the call, Ms. Garvin was not advised that a non-prosecution agreement had been r
th Australian Avenue, Suite 400 West Palm Beach, Florida 33401 VL4 HAND-DELIVERY JEGE, Inc. ("JEGE") and Hyperion Ait; Inc. ("Hyperion') Dear Ms. Villafafia: I write as counsel to the above noted entities to respond to the subpoenas dated April 24, 2007, served, respectively, on those entities. I unders
188151 e EFTA00188152 1 0 0 0 0 0 0 5 8 3 6 AIRCRAFT SECURITY AGREEMENT . Debtor: Real Estate Exchange, Inc. 900 SW 5ih Avenue Mezz. Level Portland, Oregon 97204 Secured Party: Limited Service Corporation do Timothy P. Stehle The Limited, Inc. 4387 International Gateway Columbus, Ohio 4321
w. During the call, Ms. Garvin was not advised about the Non-Prosecution Agreement. In mid-June 2008, Mr. Edwards contacted Assistant U.S. Attorney Villafafia to inform her that he represented Jane Doe #1 and, later, Jane Doe #2. Mr. Edwards asked to meet to provide information about the federal crimes co
ng the improper deposition. AUSA Villafafla secured pro bono counsel by contacting Meg Garvin, Esq. of the National Crime Victims' Law Institute in Portland, Oregon, which is based in the Lewis & Clark College of Law. During the call, Ms. Garvin was not advised about the Non-Prosecution Agreement. In mi
the victims $50,000 damages under § 2255? Thank you for any clarification you can provide on these questions. Sincerely, BE/sg Brad Edwards cc: Ann Marie C. Villafafia, AUSA United States Attorney's Office 500 South Australian Avenue West Palm Beach, Florida 33401 2028 HARRISON 8TREXT,SUITE 202, HOLLYWOOD, FLORI
ng the improper deposition. AUSA Villafafia secured pro bono counsel by contacting Meg Garvin, Esq. of the National Crime Victims' Law Institute in Portland, Oregon, which is based in the Lewis & Clark College of Law. During the call, Ms. Garvin was not advised about the Non-Prosecution Agreement. In mi
edi-te-disesss what-I-may-diselese-to,the-gek-regarding-the-agreemenWl-U:SrAnemeyls-Cerrespondenee at-1-56: 13. On about September 26, 2007, AUSA. Villafafia sent an e-mail to Lefkowitz, a copy of which is attached hereto as Exhibit in-whielt-she-etatedailiay—Can-you-give-me-a-eall at-564-209--Enentl-th
g the improper deposition. AUSA Villafaila secured pro bono counsel by contacting Meg Garvin, Esq. of the the National Crime Victims' Law Center in Portland, Oregon, which is based in the Lewis & Clark College of Law. During the call, Ms. Garvin was not advised that a non-prosecution agreement had been r
of these 39 pages is: "File folder entitled 'CORR RE GJ SUBPOENAS' containing correspondence related to various grand jury subpoenas and attorney (Villafafia) handwritten notes." 64. Another good illustration of the inadequacies of the privilege log is provided on page 20 of the first privilege log, with
g the improper deposition. AUSA Villafafla secured pro bono counsel by contacting Meg Garvin, Esq. of the the National Crime Victims' Law Center in Portland, Oregon, which is based in the Lewis & Clark College of Law. During the call, Ms. Garvin was not advised that a non-prosecution agreement had been r
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