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n agreement. At this point it is clear that AUSA Villafana was restricted in what she was being permitted to
/07 letters from A. Acosta to K. Starr and from J. Sloman to J. Lefkowitz re performance and victim notification with handwritten notes and edits by A. Marie Villafafla." Again, these materials are central to the dispute in this case, as they involve discussions between the U.S. Attorney's Office and defense attorne
prosecutors working on the case (including, but not limited to, federal prosecutors Alexander Acosta, Jeffrey H. Sloman, Matt Menchel, Andy Lourie, Ann Marie Villafana, Dexter Lee, and Bruce Reinhart and state prosecutors Dahlia Weiss, Lana Belolovek, and others involved in the Epstein investigation) and defense a
tionships" and that "[t]his principle has been applied to fiduciary relationships beyond the traditional trust context"); see also In re Grand Jury Subpoena Duces Tecum, 112 F.3d 910, 919-21 (8th Cir. 1997) (government attorneys have duty to report wrongdoing). Communications Facilitating Crime-Fraud-Misconduct Not
nited States of America, Respondent: Ann Marie C. Villafana, LEAD ATTORNEY, United States Attorney's Office,
ay C. Howell, PRO HAC VICE, Jay Howell & Associates PA, Jacksonville, FL; Paul G. Cassell, PRO HAC VICE. For United States of America, Respondent: Ann Marie C. Villafana, LEAD ATTORNEY, United States Attorney's Office, West Palm Beach. FL; Dexter Lee, LEAD ATTORNEY, United States Attorney's Office, Miami, FL. For R
documents that "might allow them to protect those very rights." (Id. at 15). By way of illustration, Petitioners offer the case of In re Grand Jury Subpoena Duces Tecum, where the Eighth Circuit broadly stated that "the general duty of public service calls upon government employees and agencies to favor disclosure
ned by Judge Kenneth A. Marra on 5/28/2009. Associated Cases: 9:08-cv-80119-KAM et al. (Ic3) (Entered: 05/28/2009) NOTICE of Attorney Appearance by Ann Marie C. Villafana on behalf of United States of America Associated Cases: 9:08-cv-80119-KAM et al.(Villafana, Ann Marie) (Entered: 05/29/2009) RESPONSE to Motion re
2009 13 05/14/2009 05/14/2009 14 Ann Marie C Villafana [COR LD NTC] United States Attorney's Office 5
orowitz, Adam) (Entered: 12/21/2009) 12/29/2009 443 RESPONSE/REPLY to 442 Response to Motion to Compel Presidential Women's Center to Comply with Subpoena Duces Tecum and Incorporated Motion to Compel Presidential Women's Center to Comply with Subpoena Duces Tecum Regarding Jane Doe 4 by Jeffrey Epstein. (Attachme
tour, P.C. A PROFESSIONAL CORPORATION NEW YORK, NEW YORK 10021 CERAM LEF URT SHERYL E. REICH RENAT C. STABILE FAITH A. FRIEDMAN VIA E-MAIL A. Marie Villafafia, Esq. Assistant United States Attorney Office of the United States Attorney Southern District of Florida 500 South Australian Avenue, Suite 400
e of the United States Attorney Southern District of Florida 500 South Australian Avenue, Suite 400 West Palm Beach, Florida 33401 July 18, 2007 Subpoena Duces Tecum dated June 18, 2007, to Custodian of Records, NES, LLC Dear Ms. Villafafia: I write concerning the grand jury subpoena duces tecum dated June 18, 2
I HEREBY CERTIFY that on July 17, 2007, a true and correct copy of the forging motion was furnished by facsimile (561) 802-1787, and U.S. mail to: Maria Villifana, Esq., U.S. Attorney's Office, 500 uth Australian Avenue, Suite 400, West Palm Beach, FL 33401. By: ROY BLACK, ESQ: Counsel for Jeffrey Epstein
ry Subpoena dated April 9, 1996, 87 F.3d 1198, 1200 (11th Cir. 1996); United States v. Gecas, 50 F.3d 1549, 1566 (11th Cir. 1995); In re Grand Jury Subpoena Duces Tecum, 754 F.2d 918, 921 (11th Cir. 1985) ("the act of production alone can constitute self-incriminating testimony); In re Grand Jury 83-8, 611 F. Supp.
merica Associated Cases: 9:08-cv-80119-KAM et al.(Villafana, Ann Marie) (Entered: 05/29/2009) 121 RESPONSE
Exhibit A)(Horowitz, Adam) (Entered: 12/21/2009) 443 RESPONSE/REPLY to 442 Response to Motion to Compel Presidential Women's Center to Comply with Subpoena Duces Tecum and Incorporated Motion to Compel Presidential Women's Center to Comply with Subpoena Duces Tecum Regarding Jane Doe 4 by Jeffrey Epstein. (Attachm
Entities connected to both A. Marie Villafana and Subpoena Duces Tecum

Jeffrey Epstein
PERSON
Alexander Acosta
PERSON
Kenneth Marra
PERSON
Dexter Lee
PERSON
Bradley Edwards
PERSONJack Goldberger
PERSONJane Doe
PERSON
Jay Lefkowitz
PERSONLeon Black
PERSON
United States
LOCATIONRoy Black
PERSON
Prince Andrew
PERSONKuyrkendall
PERSON
Department of Justice
ORGANIZATIONthe Southern District
LOCATION
George W. Bush
PERSON
Bill Richardson
PERSONSouthern District
LOCATION
Paul Cassell
PERSON
Alan Dershowitz
PERSON