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wish farther clarification of our position or to discuss this matter in any way. Until then, I remain, • Very truly yours, Michael R. Thin cc; Jack Goldberger, Esq. 08-80736-CV-MARRA RFP WPB 000547 ••• • •I•MPISIM EFTA00185097 Case 9:08-cv-80736-KAM Document 362-52 Entered on FLSD Docket 02/10/2016
• Very truly yours, Michael R. Thin cc; Jack Goldberger, Esq. 08-80736-CV-MARRA RFP WPB 000547 ••• •
ed to meet to provide information about the federal crimes committed by Epstein, hoping to secure a significant federal indictment against Epstein. AUSA Villafafla and Mr. Edwards discussed the possibility of federal charges being filed. At the end of the call, AUSA Villafafla asked Mr. Edwards to send any inf
0ame93018faMECITZIEW0MI Clitaaurrenit3M-9EhteeteardgrEJELBMIS981017M3308016agefflgefatM 17 assist Jane Doe #1 in avoiding the improper deposition. AUSA Villafafla secured pro bono counsel by contacting Meg Garvin, Esq. of the National Crime Victims' Law Institute in Portland, Oregon, which is based in the Lew
ein's defense team, including yourself, Professor Dershowitz, former United States Attorney Guy Lewis, Ms. Lilly Ann Sanchez and Messrs. Roy Black, Jack Goldberger, Gerry Lefcourt and Jay Lefkowitz had the opportunity to review and raise objections to the terms of the Agreement. Again, no one raised objections
tember 12, 2007, counsel for the United States (AUSAs Lourie, Garcia, and Villafafla) and counsel for Mr. Epstein (Messrs. Lefcourt, Lefkowitz, and Goldberger) met with State Attorney Barry Krisher and Assistant State Attorney Lanna Belohlavek to discuss a plea to an Information in the state court that wo
ion 2255 provision issue was first discussed at a July 31, 2007, meeting between FAUSA Sloman, Criminal Chief Menchel, West Palm Beach Chief Lourie, AUSA Villafafla, and two FBI agents who met with Roy Black, Gerald Lefcourt, and Lilly Ann Sanchez. On that date, the prosecutors presented a written, four-bullet-
t, and on September 12, 2007, counsel for the SDFL (AUSAs Lourie, Garcia, and Villafafta) and counsel for Epstein (Messrs. Lefcourt, Lefkowitz, and Goldberger) met with Palm Beach County State Attorney Barry Krisher and Assistant State Attorney Lanna Belohlavek to discuss a plea to an Information in the s
stein's defense team included Ken Staff, Jay Lefkowitz, Lilly Ann Sanchez, Alan Dershowitz, Gerald Lefcourt, Roy Black, Guy Lewis, Martin Weinberg, Jack Goldberger, Stephanie Thacker*, and the associates at Kirkland & Ellis who conducted research on discrete issues. This impressive legal team reviewed the Agre
Attorney Acosta, Criminal Division Chiefs Menchel and, later Robert Senior, Deputy Criminal Division Chiefs Lourie, followed by Rolando Garcia, and AUSA Villafafla have somehow steered this investigation toward "an unprecedented extension of federal law"despite being simultaneously and/or subsequently reviewed
aiapplemelliox No. 3 (P-013284). The entry here reads: "7/10/08 emails between J. and A. Villafafla, K. Atkinson, and FBI re proposed response to Goldberger's letter re victim notification." The log then indicates that the Government is asserting attorney-client privilege, work product privilege, and del
solved by the non-prosecution agreement entered into by Epstein and the U.S. Attorney's Office in September 2007. 88. In mid-June 2008, I contacted AUSA Villafafla to inform her that I represented Jane Doe No. I and, later, Jane Doe No. 2. I asked to meet to provide information about the federal crimes committ
ified victims in connection with the criminal investigation. Pro bono counsel was able to assist Jane Doe No. I in avoiding the improper deposition. AUSA Villafafla secured pro bono counsel by contacting Meg Garvin, Esq. of the the National Crime Victims' Law Center in Portland, Oregon, which is based in the Le
Entities connected to both Jack Goldberger and AUSA Villafafla

Jeffrey Epstein
PERSON
Bradley Edwards
PERSONJane Doe
PERSON
Alan Dershowitz
PERSON
Paul Cassell
PERSON
Kenneth Marra
PERSONLeon Black
PERSON
George W. Bush
PERSON
Alexander Acosta
PERSONRoy Black
PERSON
United States
LOCATION
A. Marie Villafana
PERSON
Department of Justice
ORGANIZATION
Jay Lefkowitz
PERSON
Scarlett Johansson
PERSONthe Southern District
LOCATIONFBI
ORGANIZATION
Salt Lake City
LOCATION
Prince Andrew
PERSON
Palm Beach County
LOCATION