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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
position would create the perception that either the earlier or later court was misled." DE 401-2 at 25 (emphasis added) (citing Tampa Bay Water v. HDR Engineering, Inc., 731 F.3d 1171, 1182 (11th Cir. 2013)). In this case, even treating the state court proceedings as the "earlier" proceedings, the Government does n
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
stoppel does not apply to them because the government has not established one of the elements of the three-part test examined in Tampa Bay Water v. HDR Engineering, Inc., 731 F.3d 1171 (11th Cir. 2013). D.E. 416 at 60. Specifically, petitioners contend the government has not demonstrated the second factor, that petit
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
stoppel does not apply to them because the government has not established one of the elements of the three-part test examined in Tampa Bay Water v. HDR Engineering, Inc., 731 F.3d 1171 (11th Cir. 2013). D.E. 416 at 60. Specifically, petitioners contend the government has not demonstrated the second factor, that petit
Entities connected to both Ann Marie C. Villafafia and HDR Engineering, Inc.

Jeffrey Epstein
PERSON
A. Marie Villafana
PERSON
United States
LOCATION
Department of Justice
ORGANIZATION
Alexander Acosta
PERSONJane Doe
PERSON
Kenneth Marra
PERSON
Bradley Edwards
PERSONLeon Black
PERSON
George W. Bush
PERSON
Paul Cassell
PERSON
Dexter Lee
PERSONMaria Farmer
PERSON
Jeffrey Sloman
PERSON
Harvey Weinstein
PERSON
the University of Utah
ORGANIZATIONthe Eleventh Circuit
ORGANIZATIONGarcia
PERSON
S.J. Quinney College of Law
ORGANIZATION
Salt Lake City
LOCATION