Epstein Secrets

ct of Florida Dexter A. Lee, Assistant U.S. Attorney 99 N.E. 4th Street Miami, Florida 33132 Telephone: 305-961-9320 Facsimile: 305-530-7139 Ann Marie C. Villafana, AUSA United States Attorney's Office 500 South Australian Avenue Suite 400 West Palm Beach, Florida 33401 s/ Brad Edwards Brad Edwards, Esquir

d: 09/25/2008) 10/08/2008 29 RESPONSE in Opposition re 28 MOTION to Unseal Document Non-Prosecution Agreement filed by United States of America. (Villafana, Ann Marie) (Entered: 10/08/2008) 10/16/2008 3Q RESPONSE/REPLY to 29 Response in Opposition to Motion to Unseal Non-Prosecution Agreement filed by

office file a corrected declaration and accompanying explanation. The first statement is found at page 3 to 4 of the July 916, 2008 declaration of Marie Villafafla. There a provision in a plea agreement with Mr. Jeffrey Epstein is recounted. As we understand the Government's current position in this case, it is

Notice, taken before Victoria Aiello, Court Reporter, pages 1-32. For the Plaintiff: Bradley Edwards, Esquire For the Defendant: Dexter Lee, AUSA Maria Villafana, AUSA STEVEN M. IARIM CLERK U. S. GIST. S. D. of FLA-MV GJT C. sedans ,v • •••I, • .hrt/...•0•1•••41•, OFFICIAL REPO NG SERVICES, LLC (954)

in, Esq. of the National Crime Victims' Law Institute in Portland, Oregon, which is based in the Lewis & Clark College of Law. During the call, Ms. Garvin was not advised about the Non-Prosecution Agreement. In mid-June 2008, Mr. Edwards contacted Assistant U.S. Attorney Villafafia to inform her that

n FLSD Docket 08/C i8 Page 7 of 16 assist Jane Doe #1 in avoiding the improper deposition. AUSA Villafafia secured pro bono counsel by contacting Meg Garvin, Esq. of the National Crime Victims' Law Institute in Portland, Oregon, which is based in the Lewis & Clark College of Law. During the call, Ms. Ga

ental box No. 3 (P-013504 to P-013507). The entry here reads: "File folder labeled `Mtg w/ Ken Starr, RAA, JS, Drew' containing handwritten notes by A. Marie Villafaiia." Kenn Staff, of course, is a defense attorney who represented defendant Epstein. Recording information provided by a defense attorney is not part o

mails) that were sent to. conied to, or sent by Reinhart in which the word "Epstein," _ ' "Morrison," "Visoki," "Rogers," "Hammond," Roxburgh," "Villafana, " "Florida Science Foundation," "Starr," "Black," "Goldberger," "Jeffrey," "Australian," "Lewis," "Sanchez," "358 El Brillo Way" appears and which

prosecutors working on the case (including, but not limited to, federal prosecutors Alexander Acosta, Jeffrey H. Sloman, Matt Menchel, Andy Lourie, Ann Marie Villafana, Dexter Lee, and Bruce Reinhart and state prosecutors Dahlia Weiss, Lana Belolovek, and others involved in the Epstein investigation) and defense a

ion. Pro bono counsel was able to assist Jane Doe No. 1 in avoiding the improper deposition. AUSA Villafafia secured pro bono counsel by contacting Meg Garvin, Esq. of the the National Crime Victims' Law Center in Portland, Oregon, which is based in the Lewis & Clark College of Law. During the call, Ms. G

n, Esq. of the the National Crime Victims' Law Center in Portland, Oregon, which is based in the Lewis & Clark College of Law. During the call, Ms. Garvin was not advised that a non-prosecution agreement had been reached in this matter. 87. On May 30, 2008, another one of my clients who was recognized

n agreement. At this point it is clear that AUSA Villafana was restricted in what she was being permitted to

/07 letters from A. Acosta to K. Starr and from J. Sloman to J. Lefkowitz re performance and victim notification with handwritten notes and edits by A. Marie Villafafla." Again, these materials are central to the dispute in this case, as they involve discussions between the U.S. Attorney's Office and defense attorne

prosecutors working on the case (including, but not limited to, federal prosecutors Alexander Acosta, Jeffrey H. Sloman, Matt Menchel, Andy Lourie, Ann Marie Villafana, Dexter Lee, and Bruce Reinhart and state prosecutors Dahlia Weiss, Lana Belolovek, and others involved in the Epstein investigation) and defense a

ion. Pro bono counsel was able to assist Jane Doe No. I in avoiding the improper deposition. AUSA Villafafia secured pro bono counsel by contacting Meg Garvin, Esq. of the the National Crime Victims' Law Center in Portland, Oregon, which is based in the Lewis & Clark College of Law. During the call, Ms. G

n, Esq. of the the National Crime Victims' Law Center in Portland, Oregon, which is based in the Lewis & Clark College of Law. During the call, Ms. Garvin was not advised that a non-prosecution agreement had been reached in this matter. 87. On May 30, 2008, another one of my clients who was recognized

sequen4-inention-was-made-to-the vietims-of-the-nen-pcoseeutien-agreement, EFTA00191268 -14 On about September 27, 2007, Assistant U.S. Attorney A. Marie Villafafia sent an e-mail to Leflcowitz regarding an attorney who was under discussion to be a representative of victims of Epstein civil litigation, a copy o

-preeeed-entsitte-the terns-of the pela agreement. (Sorry 1-jual-have-a-bies-against-ptaintiffsz-atterneysel.687 Attorney's Correspondence at 157. Villafana continued to push Oeariz as the best choice, in EFTA00191269 beeause4t-weukl-redttee-publiei ne-niee4hing-about-Beft-feeafi*is-that-he4s-in-Miatni

se statements-hael-been-made-te-thfrcetift2m-the-July-9th-swom-deeleration-of-ALISA-V4llefarlarigee Oetr9r a048r Letter from Bradley J. Edwards to Marie Villafafia at 1, Edwards Declaration, Atetelvinent -ir-str whi4e—Msr Wilefarla—liael—desevibetha—tenn—as-being-part-ef-the-plea agreeinesvith-Epsteiur that-

n, Esq. of the the National Crime Victims' Law Center in Portland, Oregon, which is based in the Lewis & Clark College of Law. During the call, Ms. Garvin was not advised that a non-prosecution agreement had been reached. 35. On May 30, 2008, another of Mr. Edwards's clients who was recognized as an a

Doe #1. Pro bono counsel was able to assist Jane Doe #1 in avoiding the improper deposition. AUSA Villafaila secured pro bono counsel by contacting Meg Garvin, Esq. of the the National Crime Victims' Law Center in Portland, Oregon, which is based in the Lewis & Clark College of Law. During the call, Ms. G

Negotiations" containing 9/17/07 e-mail from A. Villafana to J. N. it status update; undated and typed ha

f this Non- Prosecution Agreement and agrees to comply with them. R. ALEXANDER UNITED STATES ATTORNEY Dated: By: Dated: 77a, Dated: Dated: VILLAFARA ASSISTANT U.S. ATTORNEY GERALD LEFCOURT, ESQ. COUNSEL TO JEFFREY EPSTEIN LILLY ANN SANCHEZ, ESQ. ATTORNEY FOR JEFFREY EPSTEIN Page 7 of 7 EFTA

o supplemental box No. 3 (P-013644 through P-013653). The entry here "File folder e ' I "Notes Re Plea Negotiations" containing 9/17/07 e-mail from A. Villafana to J. N. it status update; undated and typed handwritten notes by A. Villafafia re items to be completed on case, strength of case, victim interv

ion. Pro bono counsel was able to assist Jane Doe No. I in avoiding the improper deposition. AUSA Villafafla secured pro bono counsel by contacting Meg Garvin, Esq. of the the National Crime Victims' Law Center in Portland, Oregon, which is based in the Lewis & Clark College of Law. During the call, Ms. G

n, Esq. of the the National Crime Victims' Law Center in Portland, Oregon, which is based in the Lewis & Clark College of Law. During the call, Ms. Garvin was not advised that a non-prosecution agreement had been reached in this matter. 87. On May 30, 2008, another one of my clients who was recognized

Villafana, Ann Marie C. (USAFLS) From: Villafana, Ann Marie C. (USAFLS) <AVillafana@usa.doj.gov> Sent: Saturday, August 02, 2008 5:34 PM To: villafana@ho

Office arranged to have victim notification letters sent to Jane Doe #1 and Jane Doe #2. For example, on about June 7, 2007, Assistant U.S. Attorney A. Marie Villafafia sent a letter to Jane Doe #1 that began: "Pursuant to the [CVRA], as a victim and/or witness of a federal offense, you have a number of rights." Th

in, Esq. of the National Crime Victims' Law Institute in Portland, Oregon, which is based in the Lewis & Clark College of Law. During the call, Ms. Garvin was not advised about the Non-Prosecution Agreement. In mid-June 2008, Mr. Edwards contacted Assistant U.S. Attorney Villafafia to inform her that

FLSD Docket 08/01O008 Page 7 of 16 assist Jane Doe #1 in avoiding the improper deposition. AUSA Villafafla secured pro bono counsel by contacting Meg Garvin, Esq. of the National Crime Victims' Law Institute in Portland, Oregon, which is based in the Lewis & Clark College of Law. During the call, Ms. Ga

e 9:08-cv-80736-KAM •ument 416-1 Entered on FLSD Dirt 08/11/2017 Page 10 of LA141)FFICE I • (Aetti( tre/reildi • ; AND ASSOCIATES July 3, 2008 Ann Marie C. Villafana, AUSA United States Attorney's Office 500 South Australian Avenue West Palm Beach, Florida 33401 Dear Ms. Villafana: VIA CERTIFIED MAIL RETURN

S July 3, 2008 Ann Marie C. Villafana, AUSA United States Attorney's Office 500 South Australian Avenue West Palm Beach, Florida 33401 Dear Ms. Villafana: VIA CERTIFIED MAIL RETURN RECEIPT REQUESTED 7007 2680 0002 5519 8503 As you are aware, we represent several of the young girls that were victimi

y contacting Meg Garvin, Esq. of the National Crime Victims' Law Center in Portland, Oregon, which is based in the Lewis & Clark College of Law. Ms. Garvin was not advised that a non- prosecution agreement had been reached in this matter or that any possible resolution of any kind had been reached. In f

tigation. Pro bono counsel was able to assist Jane Doe No. 1 in avoiding the improper deposition. Villafafia secured pro bono counsel by contacting Meg Garvin, Esq. of the National Crime Victims' Law Center in Portland, Oregon, which is based in the Lewis & Clark College of Law. Ms. Garvin was not advised

Office arranged to have victim notification letters sent to Jane Doe #1 and Jane Doe #2. For example, on about June 7, 2007, Assistant U.S. Attorney A. Marie Villafafia sent a letter to Jane Doe #1 that began: "Pursuant to the [CVRA), as a victim and/or witness of a federal offense, you have a number of rights." Th

Doe #1 in avoiding the improper deposition. AUSA Villafana secured pro bono counsel by contacting Meg Garvi

in, Esq. of the National Crime Victims' Law Institute in Portland, Oregon, which is based in the Lewis & Clark College of Law. During the call, Ms. Garvin was not advised about the Non-Prosecution Agreement. In mid-June 2008, Mr. Edwards contacted Assistant U.S. Attorney Villafafia to inform her that

ecord as to what your position is and the government's is as to what actions were taken. And I don't know if I have enough information, based on Ms. Villafana's affidavit or I need additional information. And because it is not an emergency, I don't have to do something quickly, we can play it b[y] ear and

al investigation. Pro bono counsel was able to assist Jane Doe #1 in avoiding the improper deposition. AUSA secured pro bono counsel by contacting Meg Garvin, Esq. of the the National Crime Victims' Law Center in Portland, Oregon, which is based in the Lewis & Clark College of Law. During the call, Ms. G

n, Esq. of the the National Crime Victims' Law Center in Portland, Oregon, which is based in the Lewis & Clark College of Law. During the call, Ms. Garvin was not advised that a non-prosecution agreement had been reached in this matter. 34. In mid-June 2008, Mr. Edwards contacted AUSA to inform her t

ecord as to what your position is and the government's is as to what actions were taken. And I don't know if I have enough information, based on Ms. Villafana's affidavit or I need additional information. And because it is not an emergency, I don't have to do something quickly, we can play it b[y] ear and

esent Jane Doe #1. Pro bono counsel was able to assist Jane Doe #1 in avoiding the improper deposition. AUSA secured pro bono counsel by contacting Meg Garvin, Esq. of the the National Crime Victims' Law Center in Portland, Oregon, which is based in the Lewis & Clark College of Law. During the call, Ms. G

n, Esq. of the the National Crime Victims' Law Center in Portland, Oregon, which is based in the Lewis & Clark College of Law. During the call, Ms. Garvin was not advised that a non-prosecution agreement had been reached. 35. On May 30, 2008, another of Mr. Edwards's clients who was recognized as an E