Epstein Secrets

ttorney's Office—regarding the subject of the lawsuit or Jeffrey Epstein? A. Same objection and instruction. Q. All right. Did you ever speak with Marie Villafana during the pendency of that litigation which is still pending today? SCAROLA: Are you asking whether such conversations occurred that were relevan

re. SCAROLA: Then the instruction remains the same. The objection remains the same. Q. So, even if, do you - even if you talked about it with Mrs. Villafana, even if your client Mr. Edwards spoke with Mrs. Villafana about a scheduling issue, it's your position that its what, work-product? A. SCAROLA: T

m the communication is made. Section 90.502 (2), Fla. Stat.; State v. Rabin, 475 So. 2d 257, 260 (Fla. 3d DCA 1986); see Hoch v. Rissman, Weisberg, Barrett, 742 So. 2d 451 (Fla. 5th DCA 1999. Therefore, if the answer was evident from the complaint eventually filed by Edwards ("to seek redress from Jeffr

ANDER ACOSTA UNITED STATES ATTORNEY By: A. MA VILLAFANA on ea Bar o. 500 South Austra ian Avenue, Suite

tates respectfully requests that the aforementioned documents be sealed. Respectfully submitted, R. ALEXANDER ACOSTA UNITED STATES ATTORNEY By: A. MA VILLAFANA on ea Bar o. 500 South Austra ian Avenue, Suite 400 West Palm Beach. FL 33401 Telephone; Facsimile: U CERTIFICATE OF SERVICE I HEREBY CERTIFY

); In re Grand Jury Subpoena Duces Tecutn, 1 F.3d 87, 90 (2d Cir. 1993) (defendant's personal calendar not protected because voluntarily prepared); Barrett v. Acevedo, 169 F.3d 1155, 1168 (8th Cir. 1999) (defendant's journal not protected because voluntarily written); United States v. Wuykowski, 929 F.2

I HEREBY CERTIFY that on July 17, 2007, a true and correct copy of the forging motion was furnished by facsimile (561) 802-1787, and U.S. mail to: Maria Villifana, Esq., U.S. Attorney's Office, 500 uth Australian Avenue, Suite 400, West Palm Beach, FL 33401. By: ROY BLACK, ESQ: Counsel for Jeffrey Epstein

the continued vitality of Boyd with respect to personal documents. In re Grand Jury Investigation, 921 F.2d 1184, 1187 n.6 (11'h Or. 1991). And see Barrett v. Acevedo, 169 F.3d 1155, 1167 (8th Cir. 1999) ("whether Doe's rationale extends to purely personal papers in a defendant's possession is still op

s and the United States Prosecutors in a jgint attempt to minimize Epstein's civil exposure. For example, on October 3, 2007, Assistant U.S. Attorney Marie Villafafia sent an email (attached hereto as Exhibit “D’’) to Jay Lefkowitz, counsel for Epstein, with attached proposed letter to special master regarding hand

id. The litigation privilege applies in all causes of action, whether for common- law torts or statutory violations. See Echevarria, McCalla, Raymer, Barrett & Frappier v. Cole, 950 So. 2d 380 (Fla. 2007). Defamatory statements made by lawyer while interviewing a witness in preparation for and connected to