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ment 54 Entered on FLSD Docket 02/12/2009 Page 10 of 12 In its opposition, Plaintiff improperly seeks to rely upon a July 10, 2008 letter from A. 3 Marie Villafana, Assistant U.S. Attorney to Plaintiff’s counsel. This letter was not referenced in nor attached to the Amended Complaint. It is axiomatic that, at
rely upon a July 10, 2008 letter from A. 3 Marie Villafana, Assistant U.S. Attorney to Plaintiff’s counsel.
s stage, the Court must consider well-pled allegations of the complaint as true and must limit its examination to the four corners of the complaint. Grossman v. Nationsbank, N.A., 225 F.3d 1228, 1231 (11th Cir. 2000). Thus, the Court will not consider the letter in ruling on the instant motion. 11 what i
Viltafana, Ann Marie C. (USAFLS) From: Peters, Jim (USAID) Sent: Wednesday, March 12, 2008 10:39 AM To: Villafana, Ann Marie C. (USAFLS) Subject: RE: Appointment of counsel for victims? We have had GAL's appointed pre-indictment. Here are a couple of examples.
seems to be limited to situations where there is a strong possibility of flight. Any help and samples would be greatly appreciated. Thank you all. A. Marie Villafatia Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 Phone 561 209-1047 Fax 561 820-8777 1 EFTA00192258 Harold
ormed before and was existing j at the time of the commies' of the overt act or acts. Dahly United States, 8 Cir., 60 F.2d 8 United States v. Grossman, D.C, 55 F.2d 408. There must be proof of the unlawful agreement, either expressed or implied, in and participation with owledge of the agreeme
Villafana, Ann Marie C. (USAFLS) From: Villafana, Ann Marie C. (USAFLS) Sent: Thursday, July 26, 2007 8:49 AM To: Menthe', Matthew (USAFLS) Cc: Lourie,
ment. 5. I will add oven acts and counts related to two additional girls who have been identified and interviewed. I will sec you at 2:00. Thanks. A. Marie Villafafla Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 Phone 561 209-1047 Fax 561 820-8777 Tracking: 45 Exhibit 3
ted his 135 month sentence. Court affirmed sentence. 56 EFTA00226340 COURT CASES FACILITY FACTS/COMMUNICATICi. " - a iICHAItGE to U.S. I Grossman, 2007 U.S. App. LEXIS 12500 (11" Cir. 2007) Unpublished Internet Internet chat room "preteen, baby and toddler sex"; initiated communications
smissed because of prosecutorial misconduct. 2422(b) Not Consummated Sting S.D. Fla. U.S. I McDaniel, 470 F. Supp. 2d 1372 (S.D. Fla. 2007) (Villafana case) Internet 19 yr-old contacted 12 yr-old & communicated for 18 months; believed to be in love; traveled to meet girl who was 14 yrs-old by
ot Consummated Appealed 120 month sentence. Showed up for meeting Affirmed. 54 EFTA00224188 COURT CASES FACILITY FACfS/COMMUNICATrIn U.S I Grossman, 2007 U.S. App. LEXIS 12500 (11" Cir. 2007) Unpublished Internet Internet chat room "preteen, baby and toddler sex"; initiated communications
FTA01729544 COURT CoS S i' 6.CIO - :- :SYCO NPOWNI4 CT ION I% ' t S.D. Fla. U.S. v. McDaniel, 470 F. Supp. 2d 1372 (S.D. Fla. 2007) (Villafana case) Internet • 19 yr-old contacted 12 yr-old & communicated for 18 months; believed to be in love; traveled to meet girl who was 14 yrs-old
nce. Showed up for meeting Affirmed. 52 EFTA01729536 COURT : . . . CASES - . ti80.00Y ..;c `.F,AACT'S/CoMMUNIGATION • : :CHARGE U.S. v. Grossman, 2007 U.S. App. LEXIS 12500 (11th Cir. 2007) Unpublished Internet Internet chat room "preteen, baby and toddler sex"; initiated communications
ting 60 EFTA00079473 COURT CASES EACH ITV FACTS/COMNIUNICATION CHARGE S.D. Fla. U.S. v. McDaniel, 470 F. Supp. 2d 1372 (S.D. Fla. 2007) (Villafana case) Internet 19 yr-old contacted 12 yr-old & communicated for 18 months; believed to be in love; traveled to meet girl who was 14 yrs-old by
Appealed 120 month sentence. Showed up for meeting Affirmed. 52 EFTA00079465 O ia riolafi t. FACILITY FACTS/COMMUNICATION Cl LARGE U.S. v. Grossman, 2007 U.S. App. LEXIS 12500 (11th Cir. 2007) Unpublished Internet Internet chat room "preteen, baby and toddler sex"; initiated communications
Entities connected to both A. Marie Villafana and Grossman

Jeffrey Epstein
PERSON
Kenneth Marra
PERSON
Bradley Edwards
PERSONJack Goldberger
PERSONJane Doe
PERSONLeon Black
PERSON
United States
LOCATION
Prince Andrew
PERSON
Department of Justice
ORGANIZATION
George W. Bush
PERSONSouthern District
LOCATION
Bill Richardson
PERSONthe Southern District
LOCATION
Alan Dershowitz
PERSONFBI
ORGANIZATIONGerald Lefcourt
PERSONGarcia
PERSONMartin Weinberg
PERSONMaria Farmer
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Scarlett Johansson
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