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e 9:08-cv-80736-KAM •ument 416-1 Entered on FLSD Dirt 08/11/2017 Page 10 of LA141)FFICE I • (Aetti( tre/reildi • ; AND ASSOCIATES July 3, 2008 Ann Marie C. Villafana, AUSA United States Attorney's Office 500 South Australian Avenue West Palm Beach, Florida 33401 Dear Ms. Villafana: VIA CERTIFIED MAIL RETURN
S July 3, 2008 Ann Marie C. Villafana, AUSA United States Attorney's Office 500 South Australian Avenue West Palm Beach, Florida 33401 Dear Ms. Villafana: VIA CERTIFIED MAIL RETURN RECEIPT REQUESTED 7007 2680 0002 5519 8503 As you are aware, we represent several of the young girls that were victimi
was relieved of its CVRA obligations. Of course, an agency's own "'interpretation' of the statute cannot supersede the language chosen by Congress." Mohasco Corp. v. Silver, 447 U.S. 807, 825 (1980). Whatever the Attorney General may have said in his Guideline, the ultimate issue in this case remains what the
Attorney ("AUSA") assigned to the case, A. Marie Villafana, sent a letter telling the victim that she was p
the two-year investigation, once a victim of Epstein's sexual abuse was identified, the lead Assistant U.S. Attorney ("AUSA") assigned to the case, A. Marie Villafana, sent a letter telling the victim that she was protected by the CVRA and explaining her statutory rights under the CVRA. For example, in 2006 and
on, like the change of position by the Justice Department's local U.S. Attorney's Office, came only after Epstein's victims filed this lawsuit. See Mohasco Corp. v. Silver, 447 U.S. 807, 825, 100 S. Ct. 2486, 2497, 65 L.Ed.2d 532 (1980) (holding that an agency's "interpretation' of a statute cannot supersede
Florida accepted the case for prosecution and assigned specific federal prosecutors to handle the case. The lead Assistant U.S. Attorney ("AUSA"), A. Marie Villafaita, sent a letter to the identified victims, informing each victim that she was protected by, and had rights under, the CVRA. For example, in 2006, t
d, Epstein's attorney Jay Lefkowitz e-mailed AUSA Villafana, requesting: "Marie - Please do whatever you can
eading Law: The Interpretation of Legal Texts 170 (2012) ("A word or phrase is presumed to bear the same meaning throughout a text ...."); cf. also Mohasco Corp. v. Silver. 447 U.S. 807, 826, 100 S.Ct. 2486.65 L.Ed.2d 532 (1980) (rejecting interpretation that would "giv[e] the word 'filed' two different mean
ing the time period where Jane Doe 2 had obtained counsel paid for by Epstein. (Jane Doe 2 Decl. ¶¶ 5-7.) Assistant United States Attorney ("AUSA") A. Marie Villafafia ("line prosecutor" "Villafaiia") testified that both Jane Doe 1 and Jane Doe 2 received letters describing their rights under the CVRA. Although Ja
obligations to notify the victims. In any event, an agency's own "'interpretation' of a statute cannot supersede the language chosen by Congress." Mohasco Corp. v. Silver, 447 U.S. 807, 825 (1980). Next, the Court rejects the Government's contention that Jane Doe 2 is not protected by 31 EFTA00794152 Cas
Entities connected to both A. Marie Villafana and Mohasco Corp.

Jeffrey Epstein
PERSON
Jeffrey Sloman
PERSON
Alexander Acosta
PERSON
Kenneth Marra
PERSON
Bradley Edwards
PERSONMarie
PERSON
Jay Lefkowitz
PERSONJane Doe
PERSONLeon Black
PERSON
United States
LOCATION
Prince Andrew
PERSONKuyrkendall
PERSON
Department of Justice
ORGANIZATIONthe Southern District
LOCATION
Paul Cassell
PERSON
Alan Dershowitz
PERSONFBI
ORGANIZATIONRolando Garcia
PERSONGarcia
PERSON
Scarlett Johansson
PERSON