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

plaining that the right to confer was "intended to be expansive," applying to "any critical state or disposition of the case") and United States v. Heaton, 458 F. Supp. 2d 1272 (D. Utah 2006)(government motion to dismiss charge of using facility of interstate commerce to entice minors to engage in unla

, 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

f law and as a measure of respect that we have for the victims' difficult decisions to come forward in this matter. In a case called United States v. Heaton, H-e-a-t-o-n-, the government filed a Rule 48 motion for leave to dismiss a charge against a defendant who allegedly committed a sexual offense again

Rule 48. I completely share that viewpoint in these circumstances, even though the facts of our case, as I said, are somewhat different from those in Heaton. I believe it is SOUTHERN DISTRICT REPORTERS, P.O. (212) 805-0300 i i CA/Aronberg-000926 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/20

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

In re Richards, 213 F.3d 773, 787 (3d Cir. 2000); see also United States v. Hamm, 659 F.2d 624, 629-30 (Sth Cir. 1981). 417 Accord United States v. Heaton, 458 F. Supp. 2d 1271, 1272 (D. Utah 2006). 478 Black's Law Dictionary 633 (Bryan A. Garner ed., 8th ed. 2004) (defining the adjective "fair"). 479