Epstein Secrets

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.

with the intent to cause such contact or the apprehension that such contact is imminent. Paul v. Holbrook, 696 So.2d 1311, 1312 (Fla. 5th DCA 1997); Sullivan v. Atlantic Fed. Sav. & Loan Ass'n, 454 So.2d 52, 54 (Fla. 4th DCA 1984), review denied, 461 So.2d 116 (Fla.1985). Defendant does not contend that

BY MR. CRITTCIN: 6 Q. Ms. Jane Doe, I have in front of you, I 7 think, Malt 4 what 1 know to be Exhibit 4, which 8 is the declaration of Ms. Villafana. Do you see that? 9 A. Yes. 10 Q. And I will represent to you, and I think you 11 told me you don't know who she is; correct? 12 A. Yes 13

s — let me have marked as Exhibit -- where 22 are we — 5. 23 (Discussion held off the record.) 24 MR. CRITION: Four was the declaration of 25 Marie Villafana. (561) 832-7500 PROSE COURT REPORTING AGENCY, 9 (Pages 159 to 162) INC. (561) 832-7506 Electronically signed by Pamela Sullivan (501-333-772-16

direct control and/or direction of the catlfiong reporter. 16 17 18 19 20 21 22 23 24 25' Doted this 13th day of October. 2009. Pamela/. Sullivan. RFR, FPR, CLIO 1 CERTIFICATE Page 258 2 3 THE STATE OF FLORIDA 4 COUNTY OF PALM BEACH 5 I hereby certify that I have read the foregoing 6

1 Is — lame have marked as Exhibit where 22 are we — 5. 23 (Discussion held off the record.) 24 MR. CRITTON: Four was the declaration of 25 Marie Villafana. (561) 832-7500 9 (Pages 159 to 162) PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Pamela Sullivan (501-3334724662)

. CRITTON: Four was the declaration of 25 Marie Villafana. (561) 832-7500 9 (Pages 159 to 162) PROSE COU

direct control and/or direction of the catlfiong reporter. 16 17 18 19 20 21 22 23 24 25' Doted this 13th day of October. 2009. Pamela/. Sullivan. RFR, FPR, CLIO 1 CERTIFICATE Page 258 2 3 THE STATE OF FLORIDA 4 COUNTY OF PALM BEACH 5 I hereby certify that I have read the foregoing 6

Villafana, Ann Marie C. (USAFLS) From: Senior, Robert (USAFLS) <[email protected]> Sent: Monday, December 15, 2008 10:55 AM To: Villafana, Ann Marie C.

s, please let me know. Please feel free to contact me with any questions or concerns. Sincerely, R. Alexander Acosta United States Attorney By: A. Marie Villafafia Assistant United States Attorney cc: Colonel Michael Gauger Karen Atkinson, Chief, Northern Division I EFTA00194081 . EFTA00194082 CAPTAIN

the telephone number of Atterbury, Goldberger and Weiss—one of the law firms representing Mr. Epstein. Richard Kahn is a partner at the law firm of Sullivan and Cromwell in New York and has no association with the Atterbury firm. Checking public records available on the internet, I located the IRS retur

, counsel in this matter.” Marra quoted an equally pleasant note then-Palm Beach County State Attorney Barry Krischer sent to Assistant U.S, Attorney Marie Villafana, who was the lead prosecutor in Epstein’s case. "Glad we could get this worked out for reasons I won't put in writing,” Krischer wrote, shortly after

at were exchanged dealt with prosecutors’ and Epstein's lawyers’ shared desire to keep the deal secret from Epstein's accusers. In a September email, Villafana asked Lefkowitz for guidance about what she should reveal. “And can We have a conference call to discuss what I may disclose to ...,the girls regardi

a situation where there was tremendous controversy over what happened in the case and whether or not the prosecutors went off the reservation. Judge Sullivan — and there were three or four independent — not independent, DOJ inquiries into the very same matter. But Judge Sullivan wanted his own opportunity

8-cv-80119-KAM Document 49 Entered on FLSD Docket 10/31/2008 Page 7 of 11 convicted of an enumerated offense.” (See July 10, 2008 letter from A. Marie Villafaña, Assistant U.S. Attorney, attached hereto as Exhibit “A”). Defendant also attempts to make much of a typographical error that appears in Count II

Herzfeld, 781 So.2d 1070 (Fla.2001) (noting that plaintiff alleged intentional tort of “assault and battery” based on allegations of sexual abuse); Sullivan v. Atlantic Federal Savings & Loan, 454 So.2d 52 (Fla. 4th DCA 1984) (holding that a cause of action for assault and battery cannot be based entire

need their addresses, please let me know. Please feel free to contact me with any questions or concerns. Sincerely, United States Attorney By: A. Marie Villafafia Assistant United States Attorney "le cc: Northern Division I EFTA00176906 EFTA00176907

the telephone number of Atterbury, Goldberger and Weiss-one of the law firms representing Mr. Epstein. Richard Kahn is a partner at the law firm of Sullivan and Cromwell in New York and has no association with the Atterbury firm. Checking public records available on the internet, I located the IRS return

9:08-cv-80119-KAM Document 49 Entered on FLSD Docket 10/31/2008 Page 8 of 11 convicted of an enumerated offense." (See July 10, 2008 letter from A. Marie Villafafia, Assistant U.S. Attorney, attached hereto as Exhibit "A"). Defendant also attempts to make much of a typographical error that appears in Count III

lerzfeld, 781 So.2d 1070 (Fla.200I) (noting that plaintiff alleged intentional tort of "assault and battery" based on allegations of sexual abuse); Sullivan'. Atlantic Federal Savings & Loan, 454 So.2d 52 (Fla. 4th DCA 1984) (holding that a cause of action for assault and battery cannot be based entirel

s, please let me know. Please feel free to contact me with any questions or concerns. Sincerely, R. Alexander Acosta United States Attorney By: A. Marie Villafafia Assistant United States Attorney cc: Colonel Michael Gauger Karen Atkinson, Chief, Northern Division I LI The returns are available online at the

the telephone number of Atterbury, Goldberger and Weiss—one of the law firms representing Mr. Epstein. Richard Kahn is a partner at the law firm of Sullivan and Cromwell in New York and has no association with the Atterbury firm. Checking public records available on the Internet, I located the IRS retur