Epstein Secrets

ale friend who was a well- known socialite, but, according to Villafaha, in 2007, they "didn't have any specific evidence against her." Accordingly, Villafaila believed that the only "co-conspirators" of Epstein who would benefit from the provision were the four female assistants identified by name. 20

complying with certain parts of the NPA. OPR Report at 95. According to the report: At the same time, at [USAO-SDFL supervisor] Lourie's request, Villafafta sent the NPA and its addendum to Lourie and Oosterbaan. Oosterbaan responded to Lourie that he was "not thrilled" about the NPA; described Epstein'

t position in this case, it is that this provision is not in fact part of the plea agreement in this case. If our understanding is correct, then Ms. Villafaila has filed a false affidavit with the court, albeit inadvertently. We respectfully request that she file a new affidavit that corrects this false in

seek for violations of their rights in this case. The second statement may or may not be false, but may need some clarification. At page 4 of Ms. Villafafta declaration, she states that "[i]n October 2007, shortly after the agreement was signed, four victims [including C.W.] were contacted and these prov

Objections Box #1 P-000983 thru P-001007 File folder entitled "Attorney Notes from Document Review" containing typed and handwritten attorney (Villafaila) notes, target letters, correspondence re grand jury subpoena Work product 6(e) Contains information subject to investigative privilege. Also

176 Draft of September 2009 letter from Marie Villafalia to Roy Black regarding breach of Non Prosecution Agreement with handwritten attorney (Villafafta) notes Work Product Attorney-Client Privilege Deliberative Process Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Not in Anticipation