Epstein Secrets

all of the victims." Id. 3. In addition, after Defendant entered into a non-prosecution agreement with the USAO, Assistant United States Attorney Marie Villafana provided Defendant's attorneys with a list of individuals whom the USAO had identified as victims of child sex exploitation as defined in 18 U.S.C.

the USAO, Assistant United States Attorney Marie Villafana provided Defendant's attorneys with a list of in

om Case 9:08-cv-80119-KAM Document 113 Entered on FLSD Docket 05/22/2009 Page 5 of 12 convicted at trial. Thus, upon information and belief, AUSA Marie Villafana and Mr. Michael Tein, former counsel for Defendant, along with Mr. Jack Goldberger, who still represents Defendant, entered into a verbal agreement

ve any contact, direct or indirect" with any victims. (Transcript of the Plea Conference at 20, relevant pages attached hereto as Exhibit A). Judge Dale Pucillo went on to clarify that, by "indirect," she meant that Defendant should not send any text messages, e-mails, Facebook contact, My Space contact, te

all of the victims." Id. 3. In addition, after Defendant entered into a non-prosecution agreement with the USAO, Assistant United States Attorney Marie Villafaila provided Defendant's attorneys with a list of individuals whom the USAO bad identified as victims of child sex exploitation as defined in 18 U.S.C.

stein's state plea. Ourtmdastanding is that AUSA Villafana and Messrs. Twin and Goldberger entered a verbal

s, e-mails, Facebook contact, My Space contact, telephone calls, voicemails, or messages through third parties to "any of these victims." Id. Judge Dale Pucillo expressly stated that the no-contact order should apply to "all of the victims." Id. 3. In addition, after Defendant entered into a non-prosecutio

Jury Matter. Pursuant to the Order regarding the disclosure of Grand Jury Information, a copy was not served upon the proposed intervenors. O, -O— Marie Villafatta Assistant United States Attorney SERVICE LIST Jane Does I and 2 v. United States, Case No. 08-80736-CIV-MARRA/JOHNSON United States District Cou

idenced by his statements to the Court during his State Plea colloquy on June 30, 2008, case number 06CF009454AMB, taken before the Honorable Judge Dale Pucillo, wherein he indicated that after his release from the Palm Beach County Jail he intends to reside permanently at his home at 358 El Brillo Way, West

f Grand Jury Matter. Pursuant to the Order regarding the disclosure of Grand Jury Information, a copy was not served upon the proposed intervenors. Marie Villafafta Assistant United States Attorney SERVICE LIST Jane Does I and 2 v. United States, Case No. 08-80736-CIV-MARRA/JOHNSON United States District Cou

idenced by his statements to the Court during his State Plea colloquy on June 30, 2008, case number 06CF009454AMB, taken before the Honorable Judge Dale Pucillo, wherein he indicated that after his release from the Palm Beach County Jail he intends to reside permanently at his home at 358 El Brillo Way, West