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

43 United States v. Henry, 861 F. Supp. 1190 (S.D.N.Y. 1994) 177 United States v. Herbert, 698 F.2d 981 (9th Cir. 1983) 200 United States v. Hernandez, 85 F.3d 1023 (2d Cir. 1996) 159 United States v. Heyward, No. 10 Cr. 84 (LTS), 2010 WL 4484642 (S.D.N.Y. Nov. 9, 2010) 106 United States v. Hi

8-cv-80119-KAM Document 49 Entered on FLSD Docket 10/31/2008 Page 7 of 11 convicted of an enumerated offense.” (See July 10, 2008 letter from A. Marie Villafaña, Assistant U.S. Attorney, attached hereto as Exhibit “A”). Defendant also attempts to make much of a typographical error that appears in Count II

v.P. 12(e) may only be granted “if a pleading is so vague or ambiguous that a party cannot reasonably be required to frame a responsive pleading.” Hernandez v. Two Brothers Farm, LLC, 2008 WL 4405409 *1 (S.D. Fla. 2008) (quoting Betancourt v. Marine Cargo Mgmt., 930 F. Supp. 606, 608 (S.D. Fla. 1996)).

Case 9:08-cv-80993-KAM Document 11 Entered on FLSD Docket 10/31:2008 Page 8 of 11 convicted of an enumerated offense." July 10, 2008 letter from A. Marie Villafafia, Assistant U.S. Attorney, attached hereto as Exhibit "A"). Defendant also attempts to make much of a typographical error that appears in Count III

iv.P. 12(e) may only be granted "if a pleading is so vague or ambiguous that a party cannot reasonably be required to frame a responsive pleading." Hernandez'. Two Brothers Farm, LLC, 2008 WL 4405409 *1 (S.D. Fla. 2008) (quoting Betancourt I. Marine Cargo Mgmt., 930 F. Supp. 606, 608 (S.D. Fla. 1996)). Fe

Case 9:08-cv-80119-KAM Document 49 Entered on FLSD Docket 10/31/2008 Page 8 of 11 convicted of an enumerated offense." July 10, 2008 letter from A. Marie Villafafia, Assistant U.S. Attorney, attached hereto as Exhibit "A"). Defendant also attempts to make much of a typographical error that appears in Count III

iv.P. 12(e) may only be granted "if a pleading is so vague or ambiguous that a party cannot reasonably be required to frame a responsive pleading." Hernandez'. Two Brothers Farm, LLC, 2008 WL 4405409 *1 (S.D. Fla. 2008) (quoting Betancourt I. Marine Cargo Mgmt., 930 F. Supp. 606, 608 (S.D. Fla. 1996)). Fe

Case 9:08-cv-80119-KAM Document 49 Entered on FLSD Docket 10/31/2008 Page 8 of 11 convicted of an enumerated offense." July 10, 2008 letter from A. Marie Villafafia, Assistant U.S. Attorney, attached hereto as Exhibit "A"). Defendant also attempts to make much of a typographical error that appears in Count III

iv.P. 12(e) may only be granted "if a pleading is so vague or ambiguous that a party cannot reasonably be required to frame a responsive pleading." Hernandez'. Two Brothers Farm, LLC, 2008 WL 4405409 *1 (S.D. Fla. 2008) (quoting Betancourt I. Marine Cargo Mgmt., 930 F. Supp. 606, 608 (S.D. Fla. 1996)). Fe

9:08-cv-80119-KAM Document 49 Entered on FLSD Docket 10/31/2008 Page 8 of 11 convicted of an enumerated offense." (See July 10, 2008 letter from A. Marie Villafafia, Assistant U.S. Attorney, attached hereto as Exhibit "A"). Defendant also attempts to make much of a typographical error that appears in Count III

iv.P. 12(e) may only be granted "if a pleading is so vague or ambiguous that a party cannot reasonably be required to frame a responsive pleading." Hernandez'. Two Brothers Farm, LLC 2008 WL 4405409 *1 (S.D. Ha. 2008) (quoting Betancourt I. Marine Cargo Mgmt., 930 F. Supp. 606, 608 (S.D. Fla. 1996)). Fede

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

, 62 United States v. Henry, 861 F. Supp. 1190 (S.D.N.Y. 1994) 269 United States v. Herbert, 698 F.2d 981 (9th Cir. 1983) 293 United States v. Hernandez, 85 F.3d 1023 (2d Cir. 1996) 242 United States v. Hester, No. 19 Cr. 324 (NSR), 2020 WL 3483702 (S.D.N.Y. June 26, 2020) 211 United States v. H

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

, 62 United States v. Henry, 861 F. Supp. 1190 (S.D.N.Y. 1994) 269 United States v. Herbert, 698 F.2d 981 (9th Cir. 1983) 293 United States v. Hernandez, 85 F.3d 1023 (2d Cir. 1996) 242 United States v. Hester, No. 19 Cr. 324 (NSR), 2020 WL 3483702 (S.D.N.Y. June 26, 2020) 211 United States v. H