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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
system: Dexter Lee A. Marie Villafafia 500 S. Australian Ave., Suite 400 West Palm Beach, FL 33401 Attorneys for the Government Roy Eric Black Jacqueline Perczek Black Srebnick Komspan & Stumpf 201 S Biscayne Boulevard Suite 1300 Attorneys for Jeffrey Epstein /5/ twee, j2. £doonee4 65 EFTA00799952 Cas
ent and learned that Epstein's state court change of plea hearing was scheduled for 8:30 a.m., Monday, June 30, 2008. D.E. 403-19 at 21, 1 38. AUSA Villafafia called attorney Edwards, told him of the June 30, 2008 hearing, and stressed the importance of the hearing.2 Thus, the government provided petitione
o pursue and foist himself upon those victims who have never reached out and asked to confer. Neither Jane Doe 1 nor Jane Doe 2 ever contacted AUSA Villafafia or FBI Special Agent Kuyrkendall regarding the case, despite being provided their phone numbers and addresses. D.E. 403-19,915. Since the Court's s
Paul G. Cassell Pro Hac Vice S.J. Quinney College of Law at the University of Utah 332 S. 1400 E. el.I.LULLICyJ LU1 J CMG LUC tuna Janc A-ivy Jacqueline Perczek BLACK SREBNICK KORNSPAN & STUMPF 201 S. Biscayne Boulevard, Suite 1300 Roy E. Black BLACK SREBNICK KORNSPAN & STUMPF 201 S. Biscayne Boulevard,
ent and learned that Epstein's state court change of plea hearing was scheduled for 8:30 a.m., Monday, June 30, 2008. D.E. 403-19 at 21, 1 38. AUSA Villafafia called attorney Edwards, told him of the June 30, 2008 hearing, and stressed the importance of the hearing.2 Thus, the government provided petitione
o pursue and foist himself upon those victims who have never reached out and asked to confer. Neither Jane Doe 1 nor Jane Doe 2 ever contacted AUSA Villafafia or FBI Special Agent Kuyrkendall regarding the case, despite being provided their phone numbers and addresses. D.E. 403-19,915. Since the Court's s
ac Vice S.J. Quinney College of Law at the University of Utah 332 S. 1400 E. Salt Lake City, Utah 84112 Attorneys for Jane Doe 1 and Jane Doe 2 Jacqueline Perczek BLACK SREBNICK KORNSPAN & STUMPF 201 S. Biscayne Boulevard, Suite 1300 If • • TV 11. Roy E. Black BLACK SREBNICK KORNSPAN & STUMPF 201 S. Bi
ame internal deliberations — representations that it now argues should lead the Court to grant summary judgment in this case. See, e.g., DE 403-19 (Villafafia affidavit — filed June 2, 2017). The Government cannot simultaneously assert work product protection over relevant documents concerning its internal
ng the Court's CM/ECF system: Dexter Lee A. Marie Villafafia 500 S. Australian Ave., Suite 400 ISM Attorneys for the Government Roy Eric Black Jacqueline Perczek Black Srebnick Komspan & Stumpf 201 S Biscayne Boulevard Suite 1300 Miami, FL 33131 Email: Attorneys for Jeffrey Epstein /s/ Sualey Edeualua
Entities connected to both Ann Marie C. Villafafia and Jacqueline Perczek

Jeffrey Epstein
PERSON
Bradley Edwards
PERSONLeon Black
PERSON
Paul Cassell
PERSON
A. Marie Villafana
PERSON
United States
LOCATION
Kenneth Marra
PERSONJane Doe
PERSON
Jay Lefkowitz
PERSON
Dexter Lee
PERSON
Department of Justice
ORGANIZATION
Alexander Acosta
PERSONMaria Farmer
PERSON
Eric Trump
PERSONMartin Weinberg
PERSONthe Southern District
LOCATIONRoy Black
PERSONSouthern District
LOCATION
the University of Utah
ORGANIZATIONRoy Eric Black
PERSON