Epstein Secrets

ttorney's Office—regarding the subject of the lawsuit or Jeffrey Epstein? A. Same objection and instruction. Q. All right. Did you ever speak with Marie Villafana during the pendency of that litigation which is still pending today? SCAROLA: Are you asking whether such conversations occurred that were relevan

re. SCAROLA: Then the instruction remains the same. The objection remains the same. Q. So, even if, do you - even if you talked about it with Mrs. Villafana, even if your client Mr. Edwards spoke with Mrs. Villafana about a scheduling issue, it's your position that its what, work-product? A. SCAROLA: T

EFTA00606629 1.) For example, Edwards's attorney instructed him when Edwards was asked how one plaintiff, E.W., came to contact referring attorney Howell. Id. at 89, lines 9-19. Edward's attorney told him he could not even answer the threshold "yes" or "no" question: Did [Mr. Howell] ever relate that

referring attorney Howell. Id. at 89, lines 9-19. Edward's attorney told him he could not even answer the threshold "yes" or "no" question: Did [Mr. Howell] ever relate that to you." Id. 9. Edwards in one instance when asked what his client E.W. told him on the phone, himself claimed privilege. Id. a

Jeffrey Epstein? Id. at page 101-102; line 24-6. MR. SCAROLA: Same objection and instruction. Id. at page 102; line?-8. Q: Did you ever speak with Marie Villafana during, during the pendency of that litigation which is still pending today? Transcript of Deposition dated March 23, 2010, page 102-03; line 24-1.

dad, P.A. • 315 SE 7'h Street, Fort Lauderdale, FL 3330I• 954.467.1223 EFTA00799406 Q: So, even if; do you — even if you talked about it with Mrs. Villafana, even if your client Mr. Edwards spoke with Mrs. Villafana about a scheduling issue, it's your position that that is what, work-product? Id. at pag

nswering. Id. at page 89; lines 4-8. Q: With regard to E.W. you filed a case — well, let me ask you this: Do you know how E.W. come to contact Mr. Howell? Did he ever relate that to you? Id. at page 89; lines 9 -12. MR. SCAROLA: If it's in information that you obtained from your client, I instruct y

R. SCAROLA: If it's in information that you obtained from your client, I instruct you not to answer. If it's information that you obtained from Mr. Howell, I also instruct you not to answer. Both instructions are on the basis of attorney-client and work-product privileges. Id. at page 89; lines 3-19.

Jeffrey Epstein? Id. at page 101-102; line 24-6. MR. SCAROLA: Same objection and instruction. Id. at page 102; line?-8. Q: Did you ever speak with Marie Villafana during, during the pendency of that litigation which is still pending today? Transcript of Deposition dated March 23, 2010, page 102-03; line 24-1.

ction remains the same. The objection remains the same. Id. at page 103; line 14-16.4 Q: So, even if; do you — even if you talked about it with Mrs. Villafana, even if 'The objection is: "If that is information that you obtained in the course of your responsibilities in representation of any client I woul

nswering. Id. at page 89; lines 4-8. Q: With regard to E.W. you filed a case — well, let me ask you this: Do you know how E.W. come to contact Mr. Howell? Did he ever relate that to you? Id. at page 89; lines 9 -12. MR. SCAROLA: If it's in information that you obtained from your client, I instruct y

R. SCAROLA: If it's in information that you obtained from your client, I instruct you not to answer. If it's information that you obtained from Mr. Howell, I also instruct you not to answer. Both instructions are on the basis of attorney-client and work-product privileges. Id. at page 89; lines 3-19.

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-

stake. It also took the position that the Crime Victims Right Act did not apply unless federal charges were filed against Epstein. Victims' Rights Howell said the decision indicates how courts have come around to the victim's point of view. He said as a state prosecutor in 1978, victims' rights were n

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

tes, 418 U.S. 87 (1974) 150, 151 Hemphill v. United States, 392 F.2d 45 (8th Cir. 1968) 176 Herring v. United States, 555 U.S. 135 (2009) 87 Howell v. Superintendent Rockview SCI, 939 F.3d 260 (2d Cir. 2019) 210 Huddleston v. United States, 485 U.S. 681 (1988) 166 In re Enter. Mort. Accepta

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

74) 225, 227 vi EFTA00099947 Hemphill v. United States, 392 F.2d 45 (8th Cir. 1968) 268 Herring v. United States, 555 U.S. 135 (2009) 123 Howell v. Superintendent Rockview SCI, 939 F.3d 260 (2d Cir. 2019) 302 Huddleston v. United States, 485 U.S. 681 (1988) 254 In re Enter. Mort. Accepta

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

974) 225, 227 vi EFTA00103005 Hemphill v. United States, 392 F.2d 45 (8th Cir. 1968) 268 Herring v. United States, 555 U.S. 135 (2009) 123 Howell v. Superintendent Rockview Sc!, 939 F.3d 260 (2d Cir. 2019) 302 Huddleston v. United States, 485 U.S. 681 (1988) 254 In re Enter. Mort. Accepta