Epstein Secrets

y, and, at a minimum, provided the victims with Belohlavek’s contact information. Acosta could have interacted with the State Attorney, or instructed Villafana or others to do so, to ensure the state intended to make notifications in a way that reached the most possible victims and that it had the informatio

ons leading to the agreement: former U.S. Attorney R. Alexander Acosta, and former AUSAs Jeffrey H. Sloman, Matthew I. Menchel, Andrew C. Lourie, and Ann Marie C. Villafana. Each subject submitted written responses detailing their involvement in the federal investigation of Epstein, the drafting and execution of the NPA,

is,~ on~ ~roscclilion_.Agrccmcnt and agrees to somrly. with. thcrp. By; CA/ Aronberg-000777 R:. AtEXANDERACOSTA UNITED s:r'.iTESATI◊R.NEY • A. :MARIE VILLAFANA AssfsTANT fos .• ATTQ~N-tY ·OERALi;:>.L13FCbUJ{t;:ESQ: C0VNSELTQ JEFFREY EJJ,SJEJN LiLLY ANN'SANCIJ~Z; isQ'. NFTORNEY FQR J½FFREY EPSTEIN FILED

.that he understands the clarifications to the Non- Prosecution Agreement and agrees to comply with them. R. ALEXANDER ACOSTA UNITED STATES ATTORNEY A. MARIE VILLAFASA ASSISTANT U.S. ATTORNEY Dated: JEFFREY EPSTEIN GERALD LEFCOURT, ESQ. COUNSEL TO JEFFREY EPSTEIN Dated: LILLY ANN'SANCHEZ, BS' ATTORNEY FOR JEFFREY EP

prosecutors, such consultations may be limited to gathering information from victims and conveying only nonsensitive data and public information.”443 Villafaha’s concern about generating potential impeachment evidence by informing victims of their potential to recover monetary damages from Epstein was not un

ates v. Annabi, 771 F.2d 670, 672 (2d Cir. 1985) (per curiam)). This is true even if the text of the agreement purports to bind “the Government.” See Annabi, Tl\ F.2d at 672. This analysis similarly extends to a non-prosecution agreement. See United States v. Laskow, 688 F. Supp. 851, 854 (E.D.N.Y. 1988)

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

irmatively establish that a more expansive interpretation was contemplated." United States v. Laskow, 688 F. Supp. 851, 854 (E.D.N.Y. 1988) (citing Annabi, 771 F.2d at 672), ard, 867 F.2d 1425 (2d Cir. 1988). To meet this burden, a defendant must establish that either the text of the agreement or the "

h Cir. 2020). Discovery has revealed that during these negotiations, several drafts of the NPA were exchanged. See, e.g., Exh. C (9/17/07 email from Villafana to Lefkowitz attaching draft NPA); Exh. D (9/21/07 email from Villafana to Lefkowitz attaching draft NPA). In addition, the parties exchanged sever

ecution of Potential Co-Conspirators Is Not Limited to the SDFL. 18 1. The NPA is binding on the USAO in this District 18 2. United States v. Annabi does not alter the analysis. 19 a. There is an "affirmative appearance" that the co-conspirator immunity provision was intended to apply outsid

h Cir. 2020). Discovery has revealed that during these negotiations, several drafts of the NPA were exchanged. See, e.g., Exh. C (9/17/07 email from Villafana to Lefkowitz attaching draft NPA); Exh. D (9/21/07 email from Villafana to Lefkowitz attaching draft NPA). In addition, the parties exchanged sever

ecution of Potential Co-Conspirators Is Not Limited to the SDFL. 18 1. The NPA is binding on the USAO in this District 18 2. United States v. Annabi does not alter the analysis. 19 1. There is an "affirmative appearance" that the co-conspirator immunity provision was intended to apply outsid

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

irmatively establish that a more expansive interpretation was contemplated." United States v. Laskow, 688 F. Supp. 851, 854 (E.D.N.Y. 1988) (citing Annabi, 771 F.2d at 672), aff'd, 867 F.2d 1425 (2d Cir. 1988)(tbl.). To meet this burden, a defendant must establish that either the text of the agreement

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

irmatively establish that a more expansive interpretation was contemplated." United States v. Laskow, 688 F. Supp. 851, 854 (E.D.N.Y. 1988) (citing Annabi, 771 F.2d at 672), aff'd, 867 F.2d 1425 (2d Cir. 1988)(tbl.). To meet this burden, a defendant must establish that either the text of the agreement