Epstein Secrets

nI--- Chief United States District Judge Copies furnished: R. Alexander Acosta, Esq. United States Attorney for the Southern District of Florida Ann Marie C. Villafana, Esq., For Plaintiff AUSA Patrick M. Hunt, Esq., AFPD Robin F. Farnsworth, Esq., AFPD For Defendant 15 EFTA01657887

tered on FLSD Docket 01/16/2007 Page 8 of 15 MS. VILLAFANA: You Honor, there are two other minor girls that

mined under the United States Sentencing Guidelines Manual. Cognizant that said sentence will be reviewed for reasonableness, see United States v. Owens, 464 F.3d 1252, 1254 (11th Cir. September 15, 2006), the Court enters this Order for the purpose of setting forth its reasoning in imposing the sam

on, Inc. Page 46 1 A. No, sir. 2 MR. LEOPOLD: Objection. Asked and 3 answered. 4 BY MR. TEIN: 5 Q. So if I say the name to you Marie 6 Villafona, you don't know who that is? 7 A. No, sir. 8 Q. How many women and how many men came to 9 your house? 10 A. I want to say two ladies and t

r. 13 Q. Does it refresh your recollection that he's 14 the number two prosecutor at the U.S. Attorney's Office? 15 A. No. 16 Q. That he's Marie Villafona's boss? 17 A. No. 18 Q. Does it refresh your memory that he's the 19 ex-partner of Jeff Herman, the first lawyer who sued 20 you -- sued Mr.

hasis added). In this case, the plaintiffs have tried to whip Jane Doe's original, one- defendant complaint into a froth that looks non-federal. Cf. Owens v. Swan, 962 F. Supp. 1436, 1439 (D. Utah 1997) (noting that "although plaintiffs' amended 12 Lewis.Teinii. 3039Gamy Avinim, Sun 340, COCOMUIGNOW,

tors also acknowledged the application of the Petite Policy in drafts of the Deferred Prosecution Agreement. See e.g., September 17, 2007 email from M. Villafana to J. Leflcowitz attaching draft Deferred Prosecution Agreement, Exhibit 32. 17 While federal prosecutors once suggested that Mr. Epstein's retenti

Petite policy will be served by the following procedure [contained in the Deferred Prosecution Agreement)." See e.g., September 17, 2007 email from M. Villafana to J. Lefkowitz attaching draft Deferred Prosecution Agreement, Exhibit 32. The draft agreement further stated: "Epstein understands that it is hi

rnment had to show that Sims benefited financially from Owen's sexual activity and that Sims knew that (a) force or coercion would be used to cause Owens to engage in a criminal sex act or (b) that Owens was under the age of 18." (emphasis added). The Eleventh Circuit's interpretation of the statute

if she had any questions for the agents or AUSA Villafana. [LM] responded: A. No, but I hope — I hope Jeff

be determined by the court under the facts and circumstances 16 EFTA00583967 of each case.'" Id. (citations omitted) (citing City of Pensacola v. Owens, 369 So.2d 328 (Fla.1979)). UNDISPUTED GROUNDS FOR SUMMARY JUDGMENT The reasonable suspicion that gives rise to probable cause for Epstein's suit

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.”

tion in favor of the state. Although Mr. Epstein and the State Attorney’s Office had already reached a plea agreement, in August 2007, Mr. Sloman and AUSA Marie Villafana warned that they intended to prosecute Epstein federally unless his counsel (i.e., not the U.S. Attorney’s Office) sought more stringent conditions t