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of a federal case, but I don't recall discussing that at the time. 35 I had never before used a non-prosecution 34 As I noted in my filings in the Jane Doe' United States litigation, I had concerns about informing the victims that part of the negotiations involved securing for them the right to obtain d
he West Palm Beach Office and is now the liaison to the Greater Palm Beach County Health Care Fraud Task Force. Since returning to West Palm Beach, AUSA Villafafia's caseload has shifted more towards economic crimes, but she has worked on a wide array of cases including insurance fraud, varying types of health c
ow if there are any other names that should be identified. Please let me knos. first name. I will also need the names of the victims that would be Jane Doe # 1 and Jane Doe #2 for preservation purposes. This information will be kept confidential. If the USAO-SDFLA Lit Hold efforts are ever the subject o
ential. If the USAO-SDFLA Lit Hold efforts are ever the subject of discovery, we can redact the victim names...as was done in the letters filed with AUSA Villafafia's first declaration. Also, I will need your assistance in preparing letters to the FBI and Palm Beach P.D. to urge them to place a Hold on any docum
n the originals of both documents to me by November 9, 2010. With respect to the claims asserted in the litigation, in the Victim's Petition (DE I), Jane Doe # I brought claims against the United States for alleged violation of her rights under the Crime Victim's Rights Act ("CVRA"). The Jane Doe #1 petit
ration are AUSA Villafaila's letters to the victim's counsel, Bradley J. Edwards, Esq. DE 14. Special Agent Nesbitt Kuyrkendall, F.B.I. is copied on AUSA Villafafia's letters and Special Agent Richards and Kuyrkendall are referenced in certain letters to Mr. Edwards. DE 14. Moreover, Epstein's counsel, Jack Goldb
tered on FLSD Docket 08/25/2017 Page 1 of 11 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 08-80736-CIV-MARRA JANE DOE 1 AND JANE DOE 2, Petitioners, vs. UNITED STATES OF AMERICA, Respondent. GOVERNMENT'S RESPONSE AND OPPOSITION TO PETITIONERS' MOTION FOR FINDING OF WAIVER OF WO
would impeach the victims and my credibility by asserting that I told victims they could receive money for implicating Epstein." Id. The basis for AUSA Villafafia's decision was offered to demonstrate that it was the 2 EFTA00601683 Case 9:08-cv-80736-KAM Document 421 Entered on FLSD Docket 08/25/2017 Page 3 o
tered on FLSD Docket 08/25/2017 Page 1 of 11 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 08-80736-CIV-MARRA JANE DOE 1 AND JANE DOE 2, Petitioners, vs. UNITED STATES OF AMERICA, Respondent. GOVERNMENT'S RESPONSE AND OPPOSITION TO PETITIONERS' MOTION FOR FINDING OF WAIVER OF WO
would impeach the victims and my credibility by asserting that I told victims they could receive money for implicating Epstein." Id. The basis for AUSA Villafafia's decision was offered to demonstrate that it was the 2 EFTA00799965 Case 9:08-cv-80736-KAM Document 421 Entered on FLSD Docket 08/25/2017 Page 3 o
ed to include Jane Doe #2 among the list of Epstein's victims. Ironically, these same attempts to protect Jane Doe #2's rights are now being used by Jane Doe #2 to allege violations of the CVRA. Petitioners also allege that the letters sent to Jane Doe #1 and Jane Doe #2 during the period when Epstein wa
a plea resolution. The inclusion of a Section 2255 remedy was specifically raised and discussed at the September 7th meeting. Indeed, according to AUSA Villafafia's notes, you thanked her for bringing it to your attention. Again, no objection to the Section 2255 issue was raised. After considering the arguments
ttorney Edwards who was informed of these developments and who received both the initial and corrected victim notification letters that were sent to Jane Doe #1. 12. In accordance with the Court's instructions at the status conference of August 14, 2008 and the terms of the Protective Order entered by t
a plea resolution. The inclusion of a Section 2255 remedy was specifically raised and discussed at the September 7t° meeting. Indeed, according to AUSA Villafafia's notes, you thanked her for bringing it to your attention. Again, no objection to the Section 2255 issue was raised. After considering the arguments
ttorney Edwards who was informed of these developments and who received both the initial and corrected victim notification letters that were sent to Jane Doe #1. 12. In accordance with the Court's instructions at the status conference of August 14, 2008 and the terms of the Protective Order entered by t
a plea resolution. The inclusion of a Section 2255 remedy was specifically raised and discussed at the September 7t° meeting. Indeed, according to AUSA Villafafia's notes, you thanked her for bringing it to your attention. Again, no objection to the Section 2255 issue was raised. After considering the ar ems r
Entities connected to both Jane Doe and AUSA Villafafia's

Jeffrey Epstein
PERSON
Bradley Edwards
PERSON
Kenneth Marra
PERSON
Paul Cassell
PERSONJack Goldberger
PERSON
Scarlett Johansson
PERSON
United States
LOCATION
Alan Dershowitz
PERSONthe Southern District
LOCATIONMaria Farmer
PERSON
George W. Bush
PERSONMichael J. Pike
PERSONLeon Black
PERSONSouthern District
LOCATION
Salt Lake City
LOCATION
Alexander Acosta
PERSON
A. Marie Villafana
PERSONRobert C. Josefsberg
PERSON
Department of Justice
ORGANIZATION
Prince Andrew
PERSON