Epstein Secrets

ant to 28 U.S.C. § 1746, that the foregoing is true and correct to the best of my knowledge and belief. Executed this2b, j day of December, 2008. A.A. Marie Villafafia, q. -4- EFTA00234652 Case 9:08-cv-80736-KAM Document 35-2 Entered on FLSD Docket 12/22/2008 Page 1 of 2 UNITED STATES DISTRICT COURT SOUTHER

Friday, June 27, 2008 10:00 AM To: Jack Goldberger Subject Have a great weekend! EFTA00234612 Exhibit 11 EFTA00234613 Jack Goldberger From: Villafana, Ann Marie C. (USAFLS) [Ann.Marie.C.Villafana@usdoj.gov] Sent: Saturday, June 28, 2008 11:31 AM To: Jack Goldberger Cc: Atkinson, Karen (USAFL

not hesitate to contact me or Special Agent Nesbitt Kuyrkendall at (561) 822-5946. Sincerely, R. Alexander Acosta United States Attorney By: A. Marie Villafala Assistant United States Attorney cc: Special Agent Nesbitt Kuyrkendall, F.B.I. Ms. Clearetha Wright, Victim-Witness Coordinator, U.S. Attorney's

ts, their credibility and the foundations, if any, for claiming personal injury. Also, Mr. Epstein would have received, pursuant to either Brady or Jencks, material in the form of prior inconsistent statements made by these women before they learned of any financial benefit that may be available to the

enue, 41h Floor West Palm Beach, FL 33401 Attn: A. Marie Villafana Re: FGJ 07-103(WPIH-Tues./No. OLY-71 Dear Ms.

Floor West Palm Beach, FL 33401 Attn: A. Marie Villafana Re: FGJ 07-103(WPIH-Tues./No. OLY-71 Dear Ms.

e's Ls"' .... - ........ -de.thr--/ .a..... .Sufi".:.._....... _ .. .. _ . ... 19. tennt• RESIDENCE ADDRESS IN FULL (Street No. and City) I Jencks declare that the foregoing statemen s arc true, and I hereby apply to lb Company fur a bond in my behalf oat such kind and in such amount as the emp

AL BUREAU OF INVESTIGATION Date of transcription 02/08/2008 On Thursday, January 31, 2008, COURTNEY WILD met with Assistant United States Attorney MARIE VILLAFANA, UNITED STATES ATTORNEY'S OFFICE (USAO) and Attorney MYESHA K. BRADEN, UNITED STATES DEPARTMENT OF(JUSTICE(DOJ), CRIMINAL DIVISION. Also present a

met with Assistant United States Attorney MARIE VILLAFANA, UNITED STATES ATTORNEY'S OFFICE (USAO) and Atto

statements of a witness on the subject of his testimony are the kind of evidentiary matter to which an adversary is entitled. F198. The Court in Jencks quoted the language of Mr. Clgef Justice Marshall in United State Burr, 25 Fed.Cas., No. 14,694, pp. 187, 191 (Va. 1807): "Now, if a paper be in

epresentative will be simultaneously representing parties that may be in conflict, in violation of Rule 1.7. For these reasons, we believe that Ms. Villafana's interpretation of the Agreement in connection with the attorney representative's role in the settlement process must be rejected. Second Issue: W

refer to the plea and sentencing as though it will be in January; Mr. Krisher's office has not confirmed any date; and Mr. Goldberger recently told Marie Villafafia that "there is no date." I must reiterate that a delayed guilty plea and sentencing — now more than two months beyond the original deadline — is un

ts, their credibility and the foundations, if any, for claiming personal injury. Also, Mr. Epstein would have received, pursuant to either Brady or Jencks, material in the form of prior inconsistent statements made by these women before they learned of any financial benefit that may be available to the

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

might aid in impeaching government witnesses at trial, "the legislative history expresses a much greater concern with limiting the application of the Jencks decision so that it would not hamper the workings of law enforcement by forcing wholesale disclosure of government materials and files." 33° The Jen

le of making their own decisions. llowever. the USA() included into the Agreement that we pay fir the attorney representative -- when originally Ms. Villafana stated that the representative could he paid for by us or the federal court. See e-mail from to Lelkowitz dated September 23. 2007. RFP MIA 000027

, their credibility and the foundations. il' any. for claiming personal istiory. Also. Mr. Epstein would have received, pursuant to either Brady or Jencks. material in the Ponta of prior inconsistent statements made by these women before they learned of any financial benefit that may be available to th

SERVICE LIST United States v. Adam G. McDaniel Case No. 06-80058-Cr-Zloch/Snow Andrew Lourie Assistant U.S. Attorney [email protected] A. Marie Villafaiia Assistant U.S. Attorney [email protected] U.S. Attorney's Office 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 Telep

Id.) McDaniel decided to plead guilty near the time of the interview of Melody; accordingly a report of Melody's interview was never prepared and a Jencks disclosure of the report of Amber's interview was never produced because there was no trial. (Id. at ¶¶ 15-17.) Following the change of plea, the P

8 To: Robert Senior, Chief, Criminal Division Rolando Garcia, Deputy Chief, Criminal Division Karen Atkinson, Chief, Northern Region From: cc: A. Marie Villafafia Drew Oosterbaan Myesha Braden INTRODUCTION This third supplement summarizes the changes to the indictment and prosecution memo since the first p

on probable cause, the court commonly will schedule a consolidated preliminary and detention hearing at which the prosecution must make available "Jencks" statements. If a hup://10.173.2.12/usao/cousa/olc/usaboolddrug/26drug.lum 4/10/2008 EFTA00191628 Federal Narcotics Prosecutions - Chapter 26 P

ge 3 was identified in previous correspondence as a person who remained on the Government's list of "victims" even after (at least according to Ms. Villufana's letter) the list was subjected to careful multi-party review. Ms.. Miller's sworn statement clearly reflects the fact that she is not a "victim'

nts, their credibility and the foundations, if any, for claiming person! injury. Also. Mr. Epstein would have received, pursuant to either Brady or Jencks, material in the tbnn of prior inconsistent statements made by these women before they learned of any financial benefit that may be available to the

007 Page 6 fictitious "rights" or invited to make sworn written or in-court testimonial statements against Mr. Epstein at such pmceedings. as Ms.. Villalana repeatedly maintained they had the right to do. Additionally, it was and remains our position that any notification should he by mail and that all

s. their, credibility and the foundations. if any. fir claiming personal injury. Also. Mr. Epstein would have received, pursuant to either Brady or Jencks. material in tlx: form of prior inconsistent statements made by these women before they learned of any financial benefit that may be available to th