Epstein Secrets

, Suite 1300 • Miami. Florida 33131 • Phone: 305.371.6421 • Fax: 305-358-2006 • www.RoyBlaciccom EFTA00213246 Jeff Sloman, Esq. Bob Senior, Esq. A. Marie Villafana, Esq. March 29, 2010 Page 2 Declaratory Judgment action asking the Court presiding over the Jane Doe 103 lawsuit to determine whether the raising

6 Jeff Sloman, Esq. Bob Senior, Esq. A. Marie Villafana, Esq. March 29, 2010 Page 2 Declaratory Judgme

and the rule of lenity applied in construing a statute, Defendant's position as to the meaning of the statute would prevail. See United States v. Santos 128 S.Ct. 2020, 2025 (2008). As summarized by the United States Supreme Court in Santos, supra, at 2025: 5 See argument in sections (2) and (3) t

eaning of the statute would prevail. See United States v. Santos 128 S.Ct. 2020, 2025 (2008). As summarized by the United States Supreme Court in Santos, supra, at 2025: 5 See argument in sections (2) and (3) that follow which represent the predicate for the rule of lenity issue discussed in B. 9

Villafana, Ann Marie C. (USAFLS) From: Roy BLACK [[email protected] Sent: Thursday, January 21, 2010 2:59 PM To: Villafana, Ann Marie C. (USAFLS) Cc:

evard, Suite 1300. Miami. Florida 33131. Phone: 305-371-6421• Fax: 30S-1M-2DM • mw.RoyBlack.coni EFTA00194793 Jeff Sloman, Esq. Bob Senior, Esq. A. Marie Villafana, Esq. March 29, 2010 Page 2 Declaratory Judgment action asking the Court presiding over the Jane Doe 103 lawsuit to determine whether the raising

, and the rule of lenity applied in construing a statute, Defendant's position as to the meaning of the statute would prevail. See United States'. Santos 128 S.Ct. 2020, 2025 (2008). As summarized by the United States Supreme Court in Santos, supra, at 2025: 5 See argument in sections (2) and (3) t

meaning of the statute would prevail. See United States'. Santos 128 S.Ct. 2020, 2025 (2008). As summarized by the United States Supreme Court in Santos, supra, at 2025: 5 See argument in sections (2) and (3) that follow which represent the predicate for the rule of lenity issue discussed in B. 9

involvement in this matter, and return responsibility for this case to the State of Florida. 17 08-80736-CV-MARRA RFP WPB 001686 EFTA00209865 Villafana, Ann Marie C. (USAFLS) From: Jay Lefkowitz [[email protected]] Sent: y, September 27, 2007 2:53 PM To: , Ann Marie C. (USAFLS) Subject:

500, West Palm Beach, FL 33401- 5933. Thank you for your assistance with this matter. Sincerely, R. ALEXANDER ACOSTA UNITED STATES ATTORNEY By: A. MARIE VILLAFASIA Assistant United States Attorney Enclosures cc: Special Agent E. Nesbitt Kuyrkendall, FBI 08-80736-CV-MARRA RFP WPB 001701 EFTA00209880 Atter

ecution is to the facts in this case. Importantly, we note that the CEOS review was conducted prior to the Supreme Court's very recent decisions in Santos and Cuellar, which we believe—illuminating as they do the Court's interpretive methodology when it comes to federal criminal law—powerfully demonst

in order to convict Mr. Epstein. Indeed, just this week (and after two years of federal involvement in this matter), Assistant United States Attorney Villafana re-initiated the federal grand jury investigation—in direct contravention of the parties’ Non Prosecution Agreement—and issued yet another subpoena s

secution is to the facts in this case. Importantly, we note that the CEOS review was conducted prior to the Supreme Court’s very recent decisions in Santos and Cuellar, which we believe—illuminating as they do the Court’s interpretive methodology when it comes to federal criminal law—powerfully demonstra

y Southern District of Florida 500 E. Broward Blvd, 7th Floor Ft. Lauderdale. FL 33394 Re: B.B. JEFFREY EPSTEIN OUR FILE NO.: 080303 Dear Ms. Villafana: As you are aware, this firm represents Plaintiff, Jane Doe, a/k/a/ B.B. in the civil litigation against Jeffrey Epstein styled B.B. I Jeffrey Epst

, and the rule of lenity applied in construing a statute, Defendant's position as to the meaning of the statute would prevail. See United States'. Santos 128 S.Ct. 2020, 2025 (2008). As summarized by the United States Supreme Court in Santos supra, at 2025: 3 See argument in sections (2) and (3) th

secution is to the facts in this case. Importantly, we note that the CEOS review was conducted prior to the Supreme Court’s very recent decisions in Santos and Cuellar, which we believe—illuminating as they do the Court’s interpretive methodology when it comes to federal criminal law—powerfully demonstra

ase at the Earliest Stage 4, In early November of 2006, Epstein’s lawyers had their initial contact with the newly assigned line federal prosecutor, A. Marie Villafana. Although it is extremely unusual for a First Assistant United States Attorney to participate in such a communication, FAUSA Jeffrey Sloman was prese

proval because her subpoena was not directed to “an office physically located within an attorney’s office.” See Tab 18, December 13, 2007 Letter from M. Villafana at 4n.1. This answer clearly suggests that Ms. Villafana had intentionally misled the Department officials about the items that her subpoena sought.”