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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
ed States v. Jones, 482 F.3d 60 (2d Cir. 2006) 169 United States v. Josephberg, 459 F.3d 350 (2d Cir. 2006) 169, 170, 172, 173 United States v. Kaplan, 758 F. App'x 34 (2d Cir. 2018) 121 United States v. Kenny, 883 F. Supp. 869 (E.D.N.Y. 1995) 202 United States v. Kidd, 386 F. Supp.3d 364 (S.
represented by Assistant U.S. Attorney A. Marie Villafana and others. The plea discussions generally began
th the investigation, you will he no', By: cc: Special Agent Nesbitt Kuyrkendall, F.B.I. Sincerely, R. Alexander Acosta United States Attorney A. Marie Villafafia Assistant United States Attorney f f 08-80736-CV-MARRA 000724 EFTA00230548 Case 9:08-cv-80736-KAM Document 48-5 Entered on FLSD Docket 03/21/2
identiary support after a reasonable opportunity for further investigation or discovery. Fed. R. Civ. P. 11(b). Rule 11 uses an objective standard. Kaplan'. Daimleravysler, A.G., 331 F.3d I251, 1255 (11th ar. 2003). The analysis is whether "a reasonable attorney in like circumstances could believe tha
es, the Office had approximately 20 Assistant U.S. Attorneys assigned to the West Palm Beach location. The prosecutor assigned to the Epstein case, Ann Marie Villafana, end I were assigned to different sections within the Office. We reported to different supervisors. 11. I did not participate in any way in the Of
osecutor assigned to the Epstein case, Ann Marie Villafana, end I were assigned to different sections withi
identiary support after a reasonable opportunity for further investigation or discovery. Fed. R. Civ. P. 11(b). Rule 11 uses an objective standard. Kaplan ! DaintlerChrysler, A.G., 331 F.3d 1251, .1255 (11th Cir. 2003). The analysis is whether "a reasonable • attorney in like circumstances could beli
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
294 United States v. Jones, 482 F.3d 60 (2d Cir. 2006) 259 United States v. Joseph berg, 459 F.3d 350 (2d Cir. 2006) passim United States v. Kaplan, 758 F. App'x 34 (2d Cir. 2018) 182 United States v. Kenny, 883 F. Supp. 869 (E.D.N.Y. 1995) 294 United States v. Kidd, 386 F. Supp.3d 364 (S
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
) 294 United States v. Jones, 482 F.3d 60 (2d Cir. 2006) 259 United States v. Josephberg, 459 F.3d 350 (2d Cir. 2006) passim United States v. Kaplan, 758 F. App'x 34 (2d Cir. 2018) 182 United States v. Kenny, 883 F. Supp. 869 (E.D.N.Y. 1995) 294 United States v. Kidd, 386 F. Supp.3d 364 (S
Entities connected to both A. Marie Villafana and Kaplan

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