Epstein Secrets

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

shonest. But, while the chase is on, it does not shock us to have it extended beyond the time first set, or, if it does, the stake forgives it. 16 The First Circuit has similarly considered this issue in the context of an ineffective assistance of counsel claim, and declined to reach the issue of whether Section

ANDER ACOSTA UNITED STATES ATTORNEY By: A. MA VILLAFANA on ea Bar o. 500 South Austra ian Avenue, Suite

tates respectfully requests that the aforementioned documents be sealed. Respectfully submitted, R. ALEXANDER ACOSTA UNITED STATES ATTORNEY By: A. MA VILLAFANA on ea Bar o. 500 South Austra ian Avenue, Suite 400 West Palm Beach. FL 33401 Telephone; Facsimile: U CERTIFICATE OF SERVICE I HEREBY CERTIFY

g the entrails of a goat, we are left to scour the record for indications of what these documents might be and what they might contain. Id. at 569. The First Circuit affirmed the district court's denial of the litigants' motion to quash because of their failure "to present sufficient information with respect to t

he Clerk of the Court using CM/ECF. According to the Court’s website, counsel for all parties are able to receive notice via the CM/ECF system. s/A. Marie Villafaña A. MARIE VILLAFAÑA Assistant United States Attorney Case 9:08-cv-80119-KAM Document 121 Entered on FLSD Docket

o obtain the “extraordinary” remedy of a stay is inevitably much reduced. Sterling Nat’l Bank, 175 F. Supp. 2d at 577 (internal citations omitted). The First Circuit has noted that the decision whether to grant a stay “is highly nuanced . . . [and] involves competing interests. Balancing these interests is a situ

ble to receive notice via the CM/ECF system. s/A. Marie Villafaña A. MARIE VILLAF

F. Supp. 2d at 577 (internal citations omitted). The First Circuit has noted that the decision whether to grant a st

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

ess: Certainly it is one thing to revive a prosecution already dead, and another to give it a longer lease of life. The question turns upon how 16 The First Circuit has similarly considered this issue in the context of an ineffective assistance of counsel claim and declined to reach the issue of whether Section

Page 1 of 56 Westlaw Delivery Summary Report for VILLAFANA,MARIE 3563006 Date/Time of Request: Wednesday,

its position clear that no reduction was warranted, adding that it could not present "a more vigorous argument" because of the plea agreement. Id. The First Circuit held that although the Government did not formally oppose the reduc- tion, it effectively opposed it in the memorandum. Id. Clark has no bearing on

Facsimi FACSIMILE COVER SHEET TO: JIM EISENBERG, ESQ. DATE: FAX NO. # OF PAGES: PHONE NO. RE: February 5, 2007 FROM: A. PHONE NO. VILLAFARA, ASSISTANT U.S. ATTORNEY COMMENTS: al 37rVi-- th at_ jala Catut .bint 1/4131A,Vt a att °t(6 - I I hake, apul h4s -Gr chger u wahocteitz.

obtain the "extraordinary" remedy of a stay is inevitably much reduced. Sterling Nat'l Bank, 175 F. Supp. 2d at 577 (internal citations omitted). The First Circuit has noted that the decision whether to grant a stay "is highly nuanced ... [and] involves competing interests. Balancing these interests is a situat

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

ess: Certainly it is one thing to revive a prosecution already dead, and another to give it a longer lease of life. The question turns upon how to The First Circuit has similarly considered this issue in the context of an ineffective assistance of counsel claim and declined to reach the issue of whether Section

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

95-98 (3d Cir. 2006); United States v. Walker, 447 F.3d 999, 1006-07 (7th Cir. 2006); United States v. Egenberger, 424 F.3d 803, 805 (Sth Cir. 2005). The First Circuit has held only that the failure to provide notice does not constitute plain error. See United States v. Mateo, No. 06-1805, 2006 WL 1195676, at 1 (1st