Epstein Secrets

P-003634 Thru P-003646 File folder bearing victim name containing FBI interview report from May 2008, telephone activity report with attorney (Villafanafia) handwritten notes, related grand jury material Work product Attorney-client privilege 6(e) Investigative privilege Also contains information

08/16/2013 Page 30 of 70 Bates Range Description Privilege(s) Asserted Victims' Objections Box #2 P409114 Tint P-009115 7/3/2008 Email from A. Marie Villafafia to Col. M. Gauger at PBSO re Epstein work release with attachment [not being withheld as privileged — produced to opposing counsel] N/A Box

Underpinnings; Fiduciary Duty; Court Compelled Disclosure; Factual Materials; Waiver Box #3 P-013231 Thai P-013239 April 22, 2008 Letter from A. Marie Villafafia to Office of Professional Responsibility re Self-Report of Allegation of Conflict of Interest Privacy Act Inadequate Log; No Factual Underpinni

aiver; Claims Against Public Prosecutor, Overriding Need; Attorney Conduct at Issue Epstein, with e- mail from Menchel (July 5, 2007, 3:30 p.m.), Villafana to Menchel (July 4, 2007, 5:16 p.m.), and Sloman to Villafana (July 3, 2007, 1:47 p.m.), attached Suppl. Box 3 P-013866 E-mail, Marie Villafana

y's Conduct is at Issue — If the attorney's conduct is a central issue in the case, the work-production protection does not apply. See, e.g., In re John Doe, 662 F.2d 1073, 1080 (4th Cir. 1981); Charlotte Moto• Speedway, Inc. v. International Ins. Co., 125 F.R.D. 127, 130 (M.D.N.C. 1989). E Rule 6(c) —

tigative information and may not be permitted access to grand jury information" (id. at 4). 12. To assist in responding to the OPR investigation, Villafana secured the representation of Jonathan Biran, a partner at Baker Donelson in Washington, DC. Mr. Biran graduated from Stanford Law School in 1993 a

ive order attached hereto. a. Disclosure shall be limited to grand jury material relevant to Mr. Biran's representation of Assistant U.S. Attorney A. Marie Villafafia that are necessary to: (a) allow Villafafia to respond to OPR's written questions; (b) prepare for OPR's interview of Villafaila; and (c) partici

ie the policy of grand jury secrecy are implicated to a much lesser extent when the disclosure merely involves Government attorneys." United States. John Doe, Inc. I, 481 U.S. 102, 112 (1987). Nothing in Douglas Oil, however, requires a district court to pretend that there are no differences between gov

ber Seven. A GRAND JUROR: Jane Doe Number? MS. VILLAFANA: Seven. BY MS. VILLAFANA: Q Who is Jane Doe Nu

a sexual activity for which a person can be charged with an offense? A Yes. Q How many telephone calls have you been able to document between John Doe Number 14 and A We have approximately 70 phone calls between and Jane Doe Number 14. Q And what about with A Approximately seven. Q And bec

Page 1 of 56 Westlaw Delivery Summary Report for VILLAFANA,MARIE 3563006 Date/Time of Request: Wednesday,

y requirements. Sec. 607. Safe ID Act. Sec. 608. Illicit Drug Anti-Proliferation Act. Sec. 609. Definition of vehicle. Sec. 610. Authorization of John Doe DNA indictments. Sec. 611. Transitional housing assistance grants for child victims of domestic violence, stalking, or sexual as- Copr. C West 2008