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n agreement. At this point it is clear that AUSA Villafana was restricted in what she was being permitted to
/07 letters from A. Acosta to K. Starr and from J. Sloman to J. Lefkowitz re performance and victim notification with handwritten notes and edits by A. Marie Villafafla." Again, these materials are central to the dispute in this case, as they involve discussions between the U.S. Attorney's Office and defense attorne
prosecutors working on the case (including, but not limited to, federal prosecutors Alexander Acosta, Jeffrey H. Sloman, Matt Menchel, Andy Lourie, Ann Marie Villafana, Dexter Lee, and Bruce Reinhart and state prosecutors Dahlia Weiss, Lana Belolovek, and others involved in the Epstein investigation) and defense a
e, liberty, or property interest implicated in the CVRA, and courts are hesitant to find that a substantive due process right has been created. Site Collins v. City of Harker Heights. Texas, 503 U.S. 115, 125 (1992X"As a general matter, the Court has always been reluctant to expand the concept of substa
/2011 Page 10 of 10 CERTIFICATE OF SERVICE The foregoing document was served on March 21, 2011. on the following using the Court's CM/ECF system: A. Marie Villafafia Assistant U.S. Attorney 500 S. Australian Ave., Suite 400 West Palm Beach, FL 33401 (561) 820-8711 Fax: (561) 820-8777 E-mail: ann.marie.c.lill
ave placed victims of Epstein's sexual abuse in "the same position as they would have been had Mr. Epstein been convicted at trial." Declaration of Marie Villafana, July 9, 2008 (doc. #14) at 3-4. The affidavit also goes on to say that "these provisions were discussed," id. at 4, apparently referring to this
e of the unfounded allegations made against AUSA Villafana by Epstcin's counsel during the "higher level re
, liberty, or property interest implicated in the CVRA, and courts arc hesitant to find that a substantive due process right has been created. See Collins I. City of Harker Heights. Texas, 503 U.S. 115, 5 EFTA00177151 Case 9:08-cv-80736-KAM Document 59 Entered on FLSD Docket 04/07/2011 Page 6 of 9
/2011 Page 10 of 10 CERTIFICATE OF SERVICE The foregoing document was served on March 21, 2011, on the following using the Court's CM/ECF system: A. Marie Villafafla Assistant U.S. Attorney 500 S. Australian Ave., Suite 400 West Palm Beach, FL 33401 (561) 820-8711 Fax: (561) 820-8777 E mail: ann.marie.c.vill
office file a corrected declaration and accompanying explanation. The first statement is found at page 3 to 4 of the July 9th, 2008 declaration of Marie Villafafia. There a provision in a plea agreement with Mr. Jeffrey Epstein is recounted. As we understand the Government's current position in this case, it is
n been convicted at trial." Declaration of Marie Villafana, July 9, 2008 (doe. #14) at 3-4. The affidavit
, liberty, or property interest implicated in the CVRA, and courts are hesitant to find that a substantive due process right has been created. See Collins City of Harker FIeights. Texas, 503 U.S. 115, 5 08-80736-CV-MARRA 000922 EFTA00230746 Case 9:08-cv-80736-KAM Document 59 Entered on FLSD Docke
ovision expanded as [USAO-SDFL prosecutor Maria] Villafana and defense counsel exchanged drafts of, first,
edged that investigators were aware of Epstein's longtime relationship with a close female friend who was a well- known socialite, but, according to Villafaha, in 2007, they "didn't have any specific evidence against her." Accordingly, Villafaila believed that the only "co-conspirators" of Epstein who wou
F.2d 646 (2d Cir. 1990) 82 United States v. Coke, No. 07 Cr. 971 (RPP), 2011 WL 3738969 (S.D.N.Y. Aug. 22, 2011) 105, 109, 111 United States v. Collins, 409 F. Supp. 3d 228 (S.D.N.Y. 2019) 186 United States v. Concepcion, 983 F.2d 369 (2d Cir. 1992) 165 United States v. Coppa, 267 F.3d 132 (2d
13) (citing Declaration of Asst. U.S. 5 EFTA00230177 Case 9:08-cv-80736-KAM Document 51 Entered on FLSD Docket 03/21/2011 Page 6 of 10 Attorney Marie Villafafia). These same subjects were also discussed at length at the Court's July 11, 2008, hearing on the matter. See, e.g., Tr. July 11, 2008, at 3-4, 18-1
n been convicted at trial." Declaration of Marie Villafana, July 9, 2008 (doe. #14) at 3-4. The affidavit
, liberty, or property interest implicated in the CVRA, and courts are hesitant to find that a substantive due process right has been created. See Collins v. City of Harker FIeights. Texas, 503 U.S. 115, 5 EFTA00230168 Case 9:08-cv-80736-KAM Document 59 Entered on FLSD Docket 04/07/2011 Page 6 of 9
ment, the defendant asks the Court to order discovery and conduct a hearing. In short, 10 The OPR Report further reflects that in OPR's interview of Villafana, she reported that she did not have anyone in mind aside from the four individuals named in the "co-conspirator" provision: "Villafaiia told OPR th
2d 102 (E.D.N.Y. 2005) 228 United States v. Coke, No. 07 Cr. 971 (RPP), 201 1 WL 3738969 (S.D.N.Y. Aug. 22, 2011) 153, 160, 163 United States v. Collins, 409 F. Supp. 3d 228 (S.D.N.Y. 2019) 278 United States v. Concepcion, 983 F.2d 369 (2d Cir. 1992) 252 United States v. Coppa, 267 F.3d 132 (2d
Page 1 of 56 Westlaw Delivery Summary Report for VILLAFANA,MARIE 3563006 Date/Time of Request: Wednesday,
hek 406 F.3d 1012, 1016 (8th Cir.2005). The a post facto clause ) is violated when a law defining a crime increas- ing punishment for a crime, see Collins Young- blood. 497 U.S. 37, 43, 110 S.Ct. 2 15, III L.Ed.2d 30 (1990), is applied to events that tmei oc- curred before its enac t, to the "disad
edged that investigators were aware of Epstein's longtime relationship with a close female friend who was a well- known socialite, but, according to Villafana, in 2007, they "didn't have any specific evidence against her." Accordingly, Villafaila believed that the only "co-conspirators" of Epstein who wou
2d 102 (E.D.N.Y. 2005) 228 United States v. Coke, No. 07 Cr. 971 (RPP), 2011 WL 3738969 (S.D.N.Y. Aug. 22, 2011) 153, 160, 163 United States v. Collins, 409 F. Supp. 3d 228 (S.D.N.Y. 2019) 278 United States v. Concepcion, 983 F.2d 369 (2d Cir. 1992) 252 United States v. Coppa, 267 F.3d 132 (2d
Entities connected to both A. Marie Villafana and Collins

Jeffrey Epstein
PERSON
Alexander Acosta
PERSON
Kenneth Marra
PERSONKaren
PERSON
Dexter Lee
PERSON
Karen Atkinson
PERSON
Bradley Edwards
PERSONLeon Black
PERSONJack Goldberger
PERSON
United States
LOCATIONJane Doe
PERSON
Jay Lefkowitz
PERSON
Prince Andrew
PERSON
Department of Justice
ORGANIZATION
George W. Bush
PERSONRoy Black
PERSONthe Southern District
LOCATION
Bill Richardson
PERSONFBI
ORGANIZATION
Alan Dershowitz
PERSON