Epstein Secrets

32211 Email: [email protected] PRO HAC VICE ATTORNEY TO BE NOTICED Paul G. Cassell Email: PRO HAC VICE ATTORNEY TO BE NOTICED represented by Ann Marie C. Villafana United States Attorney's Office 500 South Australian Ave Suite 400 West Palm Beach, FL 33401 561—820-8711 Fax: 820-8777 Email: mm,marie.c.vill

red: 09/25/2008) 10/08/2008 2s RESPONSE in Opposition rela MOTION to Unseal Document Non—Prosecution Agreement filed by United States of America. (Villafana, Ann Marie) (Entered: 10/08/2008) 10/16/2008 11 RESPONSE/REPLY toj2 Response in Opposition to Motion to Unseal Non—Prosecution Agreement filed by

/09/2008 1.4 UNSEALED DECLARATION signed by : A. Marie Villafana. re1.1 Response to Victim's Emergency Petition b

substantial likelihood that the Eleventh Circuit will agree. Indeed, the Court's opinion creates an incentive for attorneys not to do precisely what Hickman v. Taylor, 329 U.S. 495 (1947), was intended to encourage attorneys to do: reduce facts, ideas, and opinions to writing. A return to the days of se

/2011 Page 10 of 10 CERTIFICATE OF SERVICE The foregoing document was served on March 21, 2011. on the following using the Court's CM/ECF system: A. Marie Villafafia Assistant U.S. Attorney 500 S. Australian Ave., Suite 400 West Palm Beach, FL 33401 (561) 820-8711 Fax: (561) 820-8777 E-mail: ann.marie.c.lill

ave placed victims of Epstein's sexual abuse in "the same position as they would have been had Mr. Epstein been convicted at trial." Declaration of Marie Villafana, July 9, 2008 (doc. #14) at 3-4. The affidavit also goes on to say that "these provisions were discussed," id. at 4, apparently referring to this

e of the unfounded allegations made against AUSA Villafana by Epstcin's counsel during the "higher level re

f litigation.' United States' Nobles, 422 U.S. 225, 238 (1975). The work-product doctrine applies in civil and criminal litigation. Id. at 236. In Hickman' Taylor, the Supreme Court described the policy behind the doctrine protecting the opinion work-product of lawyers. The Court explained that a lawye

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

t from and broader than the attorney-client privilege." United States v. Nobles, 422 U.S. 225, 238, 95 S. Ct. 2160, 45 L. Ed. 2d 141 (1975) (citing Hickman, 329 U.S. at 508). In fact, the Eighth Circuit went on to consider the application of the work product doctrine and concluded that it did not apply

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

notes had in the first place before reaching the `waiver' issue. Accordingly, and because I do not believe that the ork-product *243 doctrine of Hickman Taylor, 329 U.S. 495, 67 S.Ct. 385, 91 L. . 451 (1947), can be extended wholesale from its historic role as a limita- tion on the nonevidentiary m

tions that someone would ordinarily do in the course of defending a civil case would constitute a violation of the agreement? (Ex. "A," p.34). Ms. Villafana: No, your honor. I mean, civil litigation is civil litigation, and being able to take discovery is part of what civil litigation is all about ....

; Lake Shore Radiator, Inc. v. Radiator Express Warehouse, 2008 WL 842989 (M.D. Fla. 2007)(protecting investigative materials as work-product); and Hickman v. Taylor, 329 U.S. 495, 508, 67 S.Ct. 385, 91 L.Ed. 451 (1947)(noting, among other things and subject to exception, that work-product includes inf