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e plaintiffs claim is reproduced in the lead 3 The ordinary meaning of the adjective --pending" is ''[r]emaining undecided; awaiting decision .... " Black's Law Dictiona,y 1154 (8th ed. 2004 ). The United States Court of Appeals for the Eleventh Circuit routinely relies on Black's Law Dictionary for t
Epstein denies that your client is a victim of an enumerated offense, please provide notice of that denial to the undersigned [AUSA]." See Deel. of AUSA Villafana, Exhs. 6 & 7, at 2 (July 9, 2008). The clear implication of the USAO's request (by which the USAO appears to involve itself in the instant litigati
stigation conducted by the U.S. Attorney's Office and the resolution of that investigation 21. Roy Black Black, Srebnick, Komspan and Stumpf Mr. Black represented Jeffrey Epstein concerning the criminal investigation conducted by the U.S. Attorney's Office and the resolution of that investigation.
n the West Palm Beach office of the U.S. Attorney's Office, and supervised portions of the criminal investigation of Jeffrey Epstein. 8. assisted AUSA Villafana during the criminal investigation of.leffrey Epstein. 9. In his revious capacity as Deputy Chief of the Criminal Division, U.S. Attorney's Office
400 ISO Attorneys for the Government Roy Eric Black Jacqueline Perczek Black Srebnick Komspan & Stu
To the extent that the Government is going to rely on representations about its internal motivations in making certain decisions (i.e., what things AUSA Villafana and the FBI agents "concluded" as part of making decisions), the victims respectfully request an opportunity to depose or cross-examine the relevan
iew of the case, demanded to meet with U.S. Attorney Acosta and to have the opportunity to meet with someone in Washington, D.C. To accommodate Mr. Black, the meeting was put off until September 7, 2007, despite the fact that the indictment was ready for presentation to the grand jury. In the interim,
component was involved in the process. For example, at the end of 2006, former SDFL U.S. Attorney and EOUSA Executive Director Guy Lewis contacted AUSA Villafana when he learned that she was handling the federal investigation of Epstein. He asked to meet with her but she said that she believed such a meeting
iew of the case, demanded to meet with U.S. Attorney Acosta and to have the opportunity to meet with someone in Washington, D.C. To accommodate Mr. Black, the meeting was put off until September 7, 2007, despite the fact that the indictment was ready for presentation to the grand jury. In the interim,
component was involved in the process. For example, at the end of 2006, former SDFL U.S. Attorney and EOUSA Executive Director Guy Lewis contacted AUSA Villafana when he learned that she was handling the federal investigation of Epstein. He asked to meet with her but she said that she believed such a meeting
"Memaining undecided; awaiting decision . . . ." Black's Law Dictionary 1154 (8th ed. 2004).3 See also
in favor of prosecution by the State of Florida . . . ." See In re: Jane Doe, Case No. 08- 80736-CIV-Marra/Johnson (S.D. Fla.) (D.E. 14), Decl. of AUSA Villafana, 07/09/08, ¶ 5, attached hereto as Exhibit "A" (emphasis added). Under the Agreement, the USAO presently retains the continuing right to indict Mr
49 placing of the parties to it in status quo." Black's Law Dictionary (4th ed. 1968). "The effect of
r legal positions, the risk of litigation, and the government's desire to minimize damaging impeachment evidence of its witnesses. As summarized by AUSA Villafana, the USAO-SDFL made the decision to enter the NPA out of a desire to obtain a guaranteed sentence of incarceration, the equivalent of uncontested r
review of the case, demanded to meet with U.S. Attorney Acosta and to have the opportunity to meet with someone in Washington, • To accommodate Mr. Black, the meeting was put off until September 7, 2007, despite the act• that the indictment was ready for presentation to the grand jury. In the interim,
component was involved in the process. For example, at the end of 2006, former SDFL U.S. Attorney and EOUSA Executive Director Guy Lewis contacted AUSA Villafana when he learned that she was handling the federal investigation of Epstein. He asked to meet with her but she said that she believed such a meeting
r]emaining undecided; awaiting decision . . . ." Black's Law Dictionary 1154 (8th ed. 2004)2 See also W
in favor of prosecution by the State of Florida . . . ." See In re: Jane Doe, Case No. 08- 80736-CIV-Marra/Johnson (S.D. Fla.) (D.E. 14), Decl. of AUSA Villafana, 07/09/08, ¶ 5, attached hereto as Exhibit "A" (emphasis added). Under the Agreement, the USAO presently retains the continuing right to indict Mr
Entities connected to both Leon Black and AUSA Villafana

Jeffrey Epstein
PERSON
Lesley Groff
PERSON
Marc Rich
PERSONRoy Black
PERSON
Prince Andrew
PERSON
Alan Dershowitz
PERSON
Woody Allen
PERSON
United States
LOCATION
George W. Bush
PERSON
Barry Diller
PERSONJack Goldberger
PERSON
Department of Justice
ORGANIZATIONMartin Weinberg
PERSON
Joe Biden
PERSON
Alexander Acosta
PERSON
Julie K. Brown
PERSON
Bradley Edwards
PERSON
Jay Lefkowitz
PERSON
Kenneth Marra
PERSON
Bill Clinton
PERSON