Epstein Secrets

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

/2013 Page 5 of 12 connection with the specific representation." Id. at 619. The Seventh Circuit found this letter brought the case squarely within Upjohn Co. v. United States 449 U.S. 383 (1981), "which explained that factual investigations performed by attorneys as attorneys fall comfortably within the

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

_00059577 CONFIDENTIAL - PURSUANT TO FED. R.CCIN(F IDENTIAL DB-SONY-0022401 EFTA 00170127 EFTA01296795 Page 71 2015 U.S. Dist. LEXIS 87203, * Upjohn Co. v. United States, 449 U.S. 383, 402, 101 S. Ct. 677, 66 L. Ed. 2d 584 (1981)); see also In re Doe, 662 F.2d 1073, 1080 (4th Cir. 1981) (even under c

ANDER ACOSTA UNITED STATES ATTORNEY By: A. MA VILLAFANA on ea Bar o. 500 South Austra ian Avenue, Suite

tates respectfully requests that the aforementioned documents be sealed. Respectfully submitted, R. ALEXANDER ACOSTA UNITED STATES ATTORNEY By: A. MA VILLAFANA on ea Bar o. 500 South Austra ian Avenue, Suite 400 West Palm Beach. FL 33401 Telephone; Facsimile: U CERTIFICATE OF SERVICE I HEREBY CERTIFY

tions, but does not prevent disclosure from the client's records the underlying factual information included in attorney-client communications. See Upjohn Co. v. United States, 449 U.S. 383, 395 (1981). For this reason, putting otherwise non-privileged business records ... in the hands of an attorney—or p

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

enabling the client to conform his conduct to the dictates of the law and to present le- gitimate claims and dt enses f if litigation ensues. See Upjohn Co. I United States, O 2011 Thomson Reuters. No Claim to Orig. US Gov. Works. https://web2.westlaw.com/print/printstream.aspx?vi-2.0&mt=EleventhCircuit