Epstein Secrets

lm Beach, FL 33401 (561) 820-8711 Facsimile: (56!) 820-8777 July 10, 2008 NOTIFICATION OF IDENTIFIED VICTIM NOTICE: IN ACCORDANCE WITH TITLE 18, UNITED STATES CODE, SECTION 3509(d) AND FLORIDA LAW, THE ATTACHED DOCUMENT IS TO BE TREATED AS CONFIDENTIAL AND SHALL NOT BE DISCLOSED EXCEPT IN CONNECTION WITH

e victim all asked to address the Court. I cited the CVRA and other statutes to support the Court's authority to hear from them. The second case was United States' Oliver, which was the Office's first case seeking the appointment of a guardian ad litem (GAL). Through these cases, I researched statutes, cases,

, and London, England. Ms. Villafafia remained in civil practice, specializing in intellectual property litigation until 2001, when she was hired by the United States Attorney's Office in Miami. While she enjoyed civil practice, Ms. Villafafia for many years had wanted to be an Assistant United States Attorney. T

ms against me was because he disliked my insistence on pushing the case forward. After the NPA was signed, USA Acosta recommended that I transfer to the Civil Division. I agreed to meet with them and talk about their work. Despite USA Acosta's recommendation, I decided not to follow his recommendation, and I staye

ning why those categories of records do not contain reasonably segregable non-exempt information. See, e.g., Robbins, Geller, Rudman & Dowd, LLP v. United States Sec. & Exch. Comm 'n, No. 3:14-CV-2197, 2016 WL 950995, at *9 (M.D. Tenn. Mar. 12, 2016) (citing examples). Moreover, nonexempt portions of documents m

by the attorney-client privilege, as indicated on the FBI index. This group of emails consists of communications between FBI employees and Assistant United States Attorneys in the Civil Division of the USAO-SDNY, which provided details the AUSA could use in the indictment of Jeffrey Epstein. Seidel Decl. . As

lege, as indicated on the FBI index. This group of emails consists of communications between FBI employees and Assistant United States Attorneys in the Civil Division of the USAO-SDNY, which provided details the AUSA could use in the indictment of Jeffrey Epstein. Seidel Decl. . As confidential communications be

p. 2d 423 (S.D.N.Y. 2008) 7, 8 Renegotiation Bd. v. Grumman Aircraft Eng'g Corp., 421 U.S. 168 (1975) 13 Robbins, Geller, Rudman & Dowd, LLP v. United States Sec. & Exch. Comm'n, No. 3:14-CV-2197, 2016 WL 950995 (M.D. Tenn. Mar. 12, 2016) 22 SafeCard Sens., Inc. v. S.E.C., 926 F.2d 1197 (D.C. Cir. 1991) 5

61 Case 1:20-cv-00833-PAE Document 25 Filed 08/05/20 Page 9 of 30 night, Noel and Thomas have been charged with one count of conspiring to defraud the United States and to make or use a false writing or document, and five counts of making or using a false writing or document. See Capone DecL ¶ 9; Noel Indictment

lege, as indicated on the BOP index. This group of emails consists of communications between BOP employees and Assistant United States Attorneys in the Civil Division of the USAO-SDNY, which represented BOP in connection with litigation requests for documents related to Epstein, and how to respond to these reques

p. 2d 423 (S.D.N.Y. 2008) 7, 8 Renegotiation Bd. v. Grumman Aircraft Eng'g Corp., 421 U.S. 168 (1975) 13 Robbins, Geller, Rudman & Dowd, LLP v. United States Sec. & Exch. Comm'n, No. 3:14-CV-2197, 2016 WL 950995 (M.D. Tenn. Mar. 12, 2016) 22 SafeCard Sens., Inc. v. S.E.C., 926 F.2d 1197 (D.C. Cir. 1991) 5

44 Case 1:20-cv-00833-PAE Document 25 Filed 08/05/20 Page 9 of 30 night, Noel and Thomas have been charged with one count of conspiring to defraud the United States and to make or use a false writing or document, and five counts of making or using a false writing or document. See Capone DecL ¶ 9; Noel Indictment

lege, as indicated on the BOP index. This group of emails consists of communications between BOP employees and Assistant United States Attorneys in the Civil Division of the USAO-SDNY, which represented BOP in connection with litigation requests for documents related to Epstein, and how to respond to these reques

p. 2d 423 (S.D.N.Y. 2008) 7, 8 Renegotiation Bd. v. Grumman Aircraft Eng'g Corp., 421 U.S. 168 (1975) 13 Robbins, Geller, Rudman & Dowd, LLP v. United States Sec. & Exch. Comm'n, No. 3:14-CV-2197, 2016 WL 950995 (M.D. Tenn. Mar. 12, 2016) 22 SafeCard Sens., Inc. v. S.E.C., 926 F.2d 1197 (D.C. Cir. 1991) 5

78 Case 1:20-cv-00833-PAE Document 25 Filed 08/05/20 Page 9 of 30 night, Noel and Thomas have been charged with one count of conspiring to defraud the United States and to make or use a false writing or document, and five counts of making or using a false writing or document. See Capone DecL ¶ 9; Noel Indictment

lege, as indicated on the BOP index. This group of emails consists of communications between BOP employees and Assistant United States Attorneys in the Civil Division of the USAO-SDNY, which represented BOP in connection with litigation requests for documents related to Epstein, and how to respond to these reques

the interest of fair and effective law enforcement within their individual judicial districts. USAM §§ 9-2.001, 9-27.140. As stated in the USAM, “[t]he United States Attorney is invested by statute and delegation from the Attorney General with the broadest discretion in the exercise of such [prosecutive] authorit

the anonymity of his clients by preventing disclosure of their identities to the CVRA petitioners. See Response to Court Order of July 6, 2015 and United States’ Notice of Partial Compliance (July 24, 2015). It is noteworthy that in 2020, when OPR attempted to contact victims, through their counsel, for inte

nguage that he proposed including in a revision to the NPA’s § 2255 implementation section. Mandelker forwarded the language to her counterpart in the Civil Division, who responded to Mandelker and Acosta that he did not have “any insight” to offer. On December 19, 2007, after Acosta and Sloman had a phone conv

, which includes the listing of remedies. Our response is due on Tuesday, January 24, and we are on our second extension of time. My trial in M.C. I United States will begin on Monday, January 23, so I don't have much time to devote to this other litigation. Can you assign someone to assist • and on the issu

remedies they claim are available to them (pages 14-15). prepared the motion to dismiss for lack of standing. He needs assistance from someone in the Civil Division to specifically address the issue of the availability of remedies specified by the victims. I have attached the victims' response to our motion to

Subject: Availability of Civil Remedies - Crime Victims Rights Act Suit, Jane Does I and 2 1 United States Date: Tue, 17 Jan 2012 15:51:34 +0000 Importance: Normal Attachments: 127_pet_opp_MTD.pdf In July 2008, two victims of Jeffrey Epstein filed an a

remedies they claim are available to them (pages 14-15). prepared the motion to dismiss for lack of standing. He needs assistance from someone in the Civil Division to specifically address the issue of the availability of remedies specified by the victims. I have attached the victims' response to our motion to d

nd date a copy of this letter in the space provided below as an acknowledgment that you have received, read, EFTA00206895 Re: Jane Does #1 and #2 I. United States Case No.: 9:08-cv-80736-KAM November 2, 2010 Page -4- Privileged Communication and agree to comply with the preservation instructions contained i

ow-up to your recent meeting concerning the above-referenced case, I write this letter in my capacity as the Electronic Discovery Coordinator within the Civil Division of the United States Attorney's Office for the Southern District of Florida (1JSAO-SDFLA). 1 write to advise you of the USAO-SDFLA's legal obligati

of Litigation Hold Letter: I acknowledge that I have received and read the Litigation Hold letter dated November 2, 2010 regarding Jane Does #1 and Itli United States, Case No.: 08-80736-CP/-MARRA/Johnson and I have taken and agree to continue to take all reasonable steps necessary to preserve the documents and da

ow-up to your recent meeting concerning the above-referenced case, I write this letter in my capacity as the Electronic Discovery Coordinator within the Civil Division of the United States Attorney's Office for the Southern District of Florida (1JSAO-SDFLA). 1 write to advise you of the USAO-SDFLA's legal obligati