Epstein Secrets

32211 Email: [email protected] PRO HAC VICE ATTORNEY TO BE NOTICED Paul G. Cassell Email: PRO HAC VICE ATTORNEY TO BE NOTICED represented by Ann Marie C. Villafana United States Attorney's Office 500 South Australian Ave Suite 400 West Palm Beach, FL 33401 561—820-8711 Fax: 820-8777 Email: mm,marie.c.vill

red: 09/25/2008) 10/08/2008 2s RESPONSE in Opposition rela MOTION to Unseal Document Non—Prosecution Agreement filed by United States of America. (Villafana, Ann Marie) (Entered: 10/08/2008) 10/16/2008 11 RESPONSE/REPLY toj2 Response in Opposition to Motion to Unseal Non—Prosecution Agreement filed by

/09/2008 1.4 UNSEALED DECLARATION signed by : A. Marie Villafana. re1.1 Response to Victim's Emergency Petition b

state commerce to entice minors to engage in unlawful sexual activity would not be granted until government consulted with victim); United States v. Ingrassia, 2005 WL 2875220 at *17 n. 11 (Senate Debate supports view that contemplated mechanism for victims to obtain information on which to base their inp

/2011 Page 10 of 10 CERTIFICATE OF SERVICE The foregoing document was served on March 21, 2011. on the following using the Court's CM/ECF system: A. Marie Villafafia Assistant U.S. Attorney 500 S. Australian Ave., Suite 400 West Palm Beach, FL 33401 (561) 820-8711 Fax: (561) 820-8777 E-mail: ann.marie.c.lill

ave placed victims of Epstein's sexual abuse in "the same position as they would have been had Mr. Epstein been convicted at trial." Declaration of Marie Villafana, July 9, 2008 (doc. #14) at 3-4. The affidavit also goes on to say that "these provisions were discussed," id. at 4, apparently referring to this

e of the unfounded allegations made against AUSA Villafana by Epstcin's counsel during the "higher level re

t 2 EFTA00177148 Case 9:08-cv-80736-KAM Document 59 Entered on FLSD Docket 04/07/2011 Page 3 of 9 plea proceedings. Id., citing United States,. Ingrassia, 2005 WL 2875220 at •17 (E.D.N.Y. Sep. 7, 2005). The district court concluded, "[t]he CVRA, therefore, dots not authorize an unbridled gallop to an

13) (citing Declaration of Asst. U.S. 5 EFTA00230177 Case 9:08-cv-80736-KAM Document 51 Entered on FLSD Docket 03/21/2011 Page 6 of 10 Attorney Marie Villafafia). These same subjects were also discussed at length at the Court's July 11, 2008, hearing on the matter. See, e.g., Tr. July 11, 2008, at 3-4, 18-1

n been convicted at trial." Declaration of Marie Villafana, July 9, 2008 (doe. #14) at 3-4. The affidavit

t 2 EFTA00230165 Case 9:08-cv-80736-KAM Document 59 Entered on FLSD Docket 04/07/2011 Page 3 of 9 plea proceedings. 111, citing United States v. Ingrassia, 2005 WL 2875220 at •17 (B.D.N.Y. Sep. 7, 2005). The district court concluded, "[t]he CVRA, therefore, does not authorize an unbridled gallop to an

ing the time period where Jane Doe 2 had obtained counsel paid for by Epstein. (Jane Doe 2 Decl. ¶¶ 5-7.) Assistant United States Attorney ("AUSA") A. Marie Villafafia ("line prosecutor" "Villafaiia") testified that both Jane Doe 1 and Jane Doe 2 received letters describing their rights under the CVRA. Although Ja

state commerce to entice minors to engage in unlawful sexual activity would not be granted until government consulted with victim); United States v. Ingrassia, No. CR-04-0455ADSJO, 2005 WL 2875220, at *17 n. 11 (E.D.N.Y. Sept. 7, 2005) (Senate debate supports the view that the contemplated mechanism for v

e Department of Justice, for example, has used websites to provide notice in terrorism cases to large numbers of victims. See, e.g., United States v. Ingrassia, No. CR-04-0455ADSJO, 2005 WL 2875220, at 4 (E.D.N.Y. Sept. 7, 2005); Criminal Division's Victim Notification Program, U.S. Dep't of Justice, hittp:/

(1), (5), (8), (c)(1) (2012). 213 See 42 U.S.C. § 10607(c)(2) (2006). 214 See Attorney General Guidelines, supra note 52, at 41-42. 215 Letter from A. Marie Villafana, Assistant U.S. Att'y, to Jane Doe #1 (June 7, 2007), reprinted in Jane Doe Motion, supra note 40, at ex. C. 216 Td, 217 Td, 218 See Victims' Right

upra note 52, at 41-42. 215 Letter from A. Marie Villafana, Assistant U.S. Att'y, to Jane Doe #1 (June 7, 20

e Department of Justice, for example, has used websites to provide notice in terrorism cases to large numbers of victims. See, e.g., United States v. Ingrassia, No. CR-04-0455ADSJO, 2005 WL 2875220, at *4 (E.D.N.Y. Sept. 7, 2005); Criminal Division’s Victim Notification Program, U.S. DEP’T OF Justice, http:/

in state criminal justice systems. Nearly two-thirds of states have adopted constitutional provisions to protect victims throughout 715 Letter from A. Marie Villafafia, Assistant U.S. Att’y, to Jane Doe #1 (June 7, 2007), reprinted in Jane Doe Motion, supra note 40, at ex. C. HOUSE_OVERSIGHT_014076 --- PAGE BREAK

enfuegos, 462 F.3d 1160, 1165 (9th Cir. 2006) (same); United States v. Degenhardt, 405 F. Supp. 2d 1341, 1344 (D. Utah 2006) (same); United States v. Ingrassia, 2005 WE 2875220 (E.D.N_Y. 2005) (same). 94 28 U.S.C. § 2072(b) (2006). °° CVRA Subcommittee Memo, supra note 66, at 1. DAVID SCHOEN HOUSE_OVERSI

phasis added). Courts have held that Brady obligations extend only to prosecutors, because the Supreme Court has not imposed this duty on others. See Villasana v. Wilhoit, 368 F.3d 976, 979 (8th Cir. 2004). w 4 See Brady, 373 U.S. at 88. w > 162 F.3d 937 (7th Cir. 1998). DAVID SCHOEN HOUSE_OVERSIGHT_01