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government about the investigation and potential prosecution of Epstein. At least one attorney for the government (Assistant United States Attorney Villafafia from the USAO-SDFL) had spoken to Petitioners about the offenses committed against them by Epstein prior to the signing of the Non-Prosecution Agre
-c‘O3O3B.49664-0CtailltdReta 2fft3eurfetteSCt off ikkElEgaltket (0748/S01315Page 5 of 20 obligations undertaken therein to be set aside.4 See, e.g., Santobello v. New York 404 U.S. 257, 262 (1971) ("[W]hen a plea rests in any significant degree on a promise or agreement of the prosecutor, so that it can be
greement, the United States would still be constitutionally required to adhere to the negotiated terms of the Non-Prosecution Agreement. See, e.g., Santobello, 404 U.S. at 262; Harvey, 869 F.2d at 1443. Due process considerations further bar this Court from setting aside a non-prosecution agreement that g
government about the investigation and potential prosecution of Epstein. At least one attorney for the government (Assistant United States Attorney Villafafia from the USAO-SDFL) had spoken to Petitioners about the offenses committed against them by Epstein prior to the signing of the Non-Prosecution Agre
-c‘O3O3B.49664-0CtailltdReta 2fft3eurfetteSCt off ikkElEgaltket (0748/S01315Page 5 of 20 obligations undertaken therein to be set aside.4 See, e.g., Santobello v. New York 404 U.S. 257, 262 (1971) ("[W]hen a plea rests in any significant degree on a promise or agreement of the prosecutor, so that it can be
greement, the United States would still be constitutionally required to adhere to the negotiated terms of the Non-Prosecution Agreement. See, e.g., Santobello, 404 U.S. at 262; Harvey, 869 F.2d at 1443. Due process considerations further bar this Court from setting aside a non-prosecution agreement that g
e NPA, the investigation had not developed evidence of `any other potential co-conspirators.'"); id. at 167 (with respect to Maxwell, "according to Villafafia, in 2007, they `didn't have any specific evidence against her.'"). 55 EFTA00100022 satisfied that he should prosecute and will be able promptly t
another individual's plea agreement. See Santobello v. United States, No. 94 Cr. 119 (RPP), 1998 WL 113950, at *3 (S.D.N.Y. Mar. 13, 1998) ("Even if Santobello could establish the existence of plea agreements between the Government and his co-defendants, there is little known authority that would allow him
ast one court in this Circuit has noted the absence of authority that a third party has standing to enforce another individual's plea agreement. See Santobello v. United States, No. 94 Cr. 119 (RPP), 1998 WL 113950, at *3 (S.D.N.Y. Mar. 13, 1998) ("Even if Santobello could establish the existence of plea a
edged that investigators were aware of Epstein's longtime relationship with a close female friend who was a well- known socialite, but, according to Villafafia, in 2007, they "didn't have any specific evidence against her." Accordingly, Villafaiia believed that the only "co-conspirators" of Epstein who wou
another individual's plea agreement. See Santobello v. United States, No. 94 Cr. 119 (RPP), 1998 WL 113950, at *3 (S.D.N.Y. Mar. 13, 1998) ("Even if Santobello could establish the existence of plea agreements between the Government and his co-defendants, there is little known authority that would allow him
United States, 369 U.S. 749 (1962) 229 Rutenberg v. United States, 245 U.S. 480 (1918) 292 Salinas v. United States, 522 U.S. 52 (1997) 245 Santobello v. United States, No. 94 Cr. (RPP), 1998 WL 113950 (S.D.N.Y. Mar. 13, 1998) 21 Sch. Dist. No. 7, 167 F.3d 784 (2d Cir. 1999) 61 SEC v. 71eStree
edged that investigators were aware of Epstein's longtime relationship with a close female friend who was a well- known socialite, but, according to Villafafia, in 2007, they "didn't have any specific evidence against her." Accordingly, Villafaiia believed that the only "co-conspirators" of Epstein who wou
another individual's plea agreement. See Santobello v. United States, No. 94 Cr. 119 (RPP), 1998 WL 113950, at *3 (S.D.N.Y. Mar. 13, 1998) ("Even if Santobello could establish the existence of plea agreements between the Government and his co-defendants, there is little known authority that would allow him
United States, 369 U.S. 749 (1962) 229 Rutenberg v. United States, 245 U.S. 480 (1918) 292 Salinas v. United States, 522 U.S. 52 (1997) 245 Santobello v. United States, No. 94 Cr. (RPP), 1998 WL 113950 (S.D.N.Y. Mar. 13, 1998) 21 Sch. Dist. No. 7, 167 F.3d 784 (2d Cir. 1999) 61 SEC v. 71eStree
, OPR concluded that "the evidence does not show that [Former USAO-SDFL U.S. Attorney Alex] Acosta, [Former USAO-SDFL supervisor Andrew] Lourie, or Villafafia agreed to the nonprosecution provision to protect any of Epstein's political, celebrity, or other influential associates." OPR Report at 168." In
another individual's plea agreement. See Santobello v. United States, No. 94 Cr. 119 (RPP), 1998 WL 113950, at *3 (S.D.N.Y. Mar. 13, 1998) ("Even if Santobello could establish the existence of plea agreements between the Government and his co-defendants, there is little known authority that would allow him
United States, 369 U.S. 749 (1962) 151 Rutenberg v. United States, 245 U.S. 480 (1918) 200 Salinas v. United States, 522 U.S. 52 (1997) 161 Santobello v. United States, No. 94 Cr. (RPP), 1998 WL 113950 (S.D.N.Y. Mar. 13, 1998) 18 Sch. Dist. No. 7, 167 F.3d 784 (2d Cir. 1999) 43 SEC v. TheStree
--- Case 9:08-cv-80736-KAM Document 205-2 Entered on FLSD Docket 07/05/2013 Page 5 of 20 obligations undertaken therein to be set aside! See, e.g., Santobello v. New York, 404 U.S. 257, 262 (1971) ("[W]hen a plea rests in any significant degree on a promise or agreement of the prosecutor, so that it can b
Page: EFTA00010478 →government about the investigation and potential prosecution of Epstein. At least one attorney for the government (Assistant United States Attorney Villafafia from the USAO-SDFL) had spoken to Petitioners about the offenses committed against them by Epstein prior to the signing of the Non-Prosecution Agre
Page: EFTA00010481 →Entities connected to both Ann Marie C. Villafafia and Santobello

Jeffrey Epstein
PERSON
United States
LOCATIONJane Doe
PERSON
Kenneth Marra
PERSONthe Southern District
LOCATION
A. Marie Villafana
PERSON
Alexander Acosta
PERSON
Scarlett Johansson
PERSON
Department of Justice
ORGANIZATION
Bradley Edwards
PERSONFBI
ORGANIZATIONLeon Black
PERSONEmmy Taylor
PERSON
George W. Bush
PERSONMartin Weinberg
PERSON
Paul Cassell
PERSON
Jay Lefkowitz
PERSONRoy Black
PERSON
Prince Andrew
PERSONJack Goldberger
PERSON