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

the investigation and potential prosecution, relating to Jeffrey Epstein’s alleged sexual activities with minor females,” and assigned the matter to the Middle District of Florida U.S. Attorney’s Office for further consideration. The records included a declination of the matter due to the NPA. 7. U.S. Attorney’s Offi

ct of Florida Dexter A. Lee, Assistant U.S. Attorney 99 N.E. 4th Street Miami, Florida 33132 Telephone: 305-961-9320 Facsimile: 305-530-7139 Ann Marie C. Villafana, AUSA United States Attorney's Office 500 South Australian Avenue Suite 400 West Palm Beach, Florida 33401 s/ Brad Edwards Brad Edwards, Esquir

d: 09/25/2008) 10/08/2008 29 RESPONSE in Opposition re 28 MOTION to Unseal Document Non-Prosecution Agreement filed by United States of America. (Villafana, Ann Marie) (Entered: 10/08/2008) 10/16/2008 3Q RESPONSE/REPLY to 29 Response in Opposition to Motion to Unseal Non-Prosecution Agreement filed by

office file a corrected declaration and accompanying explanation. The first statement is found at page 3 to 4 of the July 916, 2008 declaration of Marie Villafafla. There a provision in a plea agreement with Mr. Jeffrey Epstein is recounted. As we understand the Government's current position in this case, it is

Notice, taken before Victoria Aiello, Court Reporter, pages 1-32. For the Plaintiff: Bradley Edwards, Esquire For the Defendant: Dexter Lee, AUSA Maria Villafana, AUSA STEVEN M. IARIM CLERK U. S. GIST. S. D. of FLA-MV GJT C. sedans ,v • •••I, • .hrt/...•0•1•••41•, OFFICIAL REPO NG SERVICES, LLC (954)

ct Court for the Southern District of Florida; and (2) I am a member in good standing of the Florida Bar and the bar for the U.S. District Court for the Middle District of Florida. EFTA00177249 Case 9:08-cv- 3-KAM Document 20 Entered on FLED Docket 08/ 08 Page 6 of 7 CERTIFICATE OF SERVICE 1 HEREBY CERTIFY

P-003634 Thru P-003646 File folder bearing victim name containing FBI interview report from May 2008, telephone activity report with attorney (Villafanafia) handwritten notes, related grand jury material Work product Attorney-client privilege 6(e) Investigative privilege Also contains information

08/16/2013 Page 30 of 70 Bates Range Description Privilege(s) Asserted Victims' Objections Box #2 P409114 Tint P-009115 7/3/2008 Email from A. Marie Villafafia to Col. M. Gauger at PBSO re Epstein work release with attachment [not being withheld as privileged — produced to opposing counsel] N/A Box

Underpinnings; Fiduciary Duty; Court Compelled Disclosure; Factual Materials; Waiver Box #3 P-013231 Thai P-013239 April 22, 2008 Letter from A. Marie Villafafia to Office of Professional Responsibility re Self-Report of Allegation of Conflict of Interest Privacy Act Inadequate Log; No Factual Underpinni

aiver; Claims Against Public Prosecutor, Overriding Need; Attorney Conduct at Issue Epstein, with e- mail from Menchel (July 5, 2007, 3:30 p.m.), Villafana to Menchel (July 4, 2007, 5:16 p.m.), and Sloman to Villafana (July 3, 2007, 1:47 p.m.), attached Suppl. Box 3 P-013866 E-mail, Marie Villafana

e documents being held by the U.S. Attorney's Office in the other district that is handling conflict matters. (It appears that this other office is the Middle District of Florida.) This appears to be improbable, because the conflict matters would presumably generate many documents covered by the victims' discovery

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

miss, page 8, n. 8][DE 119). However, it contends, without explanation, that the September 24, 2007 non-prosecution agreement would still constrain the Middle District of Florida United States Attorney's Office "due to that office's recusal- based derivative prosecutorial responsibilities in the Southern District of

ental box No. 3 (P-013504 to P-013507). The entry here reads: "File folder labeled `Mtg w/ Ken Starr, RAA, JS, Drew' containing handwritten notes by A. Marie Villafaiia." Kenn Staff, of course, is a defense attorney who represented defendant Epstein. Recording information provided by a defense attorney is not part o

mails) that were sent to. conied to, or sent by Reinhart in which the word "Epstein," _ ' "Morrison," "Visoki," "Rogers," "Hammond," Roxburgh," "Villafana, " "Florida Science Foundation," "Starr," "Black," "Goldberger," "Jeffrey," "Australian," "Lewis," "Sanchez," "358 El Brillo Way" appears and which

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

e documents being held by the U.S. Attorney's Office in the other district that is handling conflict matters. (It appears that this other office is the Middle District of Florida.) This appears to be improbable, because the conflict matters would presumably generate many documents covered by the victims' discovery

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

ive entity, and any grand jury investigating these (or releated) allegations, including any grand jury meeting in the Southern District of Florida, the Middle District of Florida, the District of EFTA00179741 Case 9:08-cv-80736-KAM Document 225-1 Entered on FLSD Docket 08/16/2013 Page 44 of 64 New Jersey, and/o

Negotiations" containing 9/17/07 e-mail from A. Villafana to J. N. it status update; undated and typed ha

f this Non- Prosecution Agreement and agrees to comply with them. R. ALEXANDER UNITED STATES ATTORNEY Dated: By: Dated: 77a, Dated: Dated: VILLAFARA ASSISTANT U.S. ATTORNEY GERALD LEFCOURT, ESQ. COUNSEL TO JEFFREY EPSTEIN LILLY ANN SANCHEZ, ESQ. ATTORNEY FOR JEFFREY EPSTEIN Page 7 of 7 EFTA

o supplemental box No. 3 (P-013644 through P-013653). The entry here "File folder e ' I "Notes Re Plea Negotiations" containing 9/17/07 e-mail from A. Villafana to J. N. it status update; undated and typed handwritten notes by A. Villafafia re items to be completed on case, strength of case, victim interv

e documents being held by the U.S. Attorney's Office in the other district that is handling conflict matters. (It appears that this other office is the Middle District of Florida.) This appears to be improbable, because the conflict matters would presumably generate many documents covered by the victims' discovery

sked whether she was concerned that failing to tell victims about the NPA when she was interviewing them would mislead victims, as previously noted, Villafaña told OPR that she believed she and the agents were conducting an investigation because they continued “interviewing witnesses” and “doing all these

Black, Esq. Counsel to Jeffrey Epstein R. ALEXANDER ACOSTA UNITED STATES ATTORNEY Dated: ___________ ____________________________________ By: A. Marie Villafaña Assistant United States Attorney (;+,%,7  6HSWHPEHU   1RQဨ3URVHFXWLRQ $JUHHPHQW [Page Intentionally Left Blank] INRE: INVESTIGATION

osecution Agreement and agrees to comply with them. Dated: ----- DatedM Dated: ----- Dated: ----- By: R. ALEXANDER ACOSTA UNITED STATES ATTORNEY A. MARIE VILLAFANA ASSISTANT U.S. ATTORNEY GERALD LEFCOURT, ESQ. COUNSEL TO JEFFREY EPSTEIN LILLY ANN SANCHEZ, ESQ. ATTORNEY FOR JEFFREY EPSTEIN Page 7 of 7 By

he investigation and potential prosecution, relating to Jeffrey Epstein’s alleged sexual activities with minor females,” and assigned the matter to the Middle District of Florida U.S. Attorney’s Office for further consideration. The records included a declination of the matter due to the NPA. 7. U.S. Attorney

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

. 1980); United States v. Landof, 591 F.2d 36, 38 (9th Cir. 1978); In re Grand Jury Proceedings, 73 F.R.D. 647, 651 (M.D. Fl. 1977)). In Blackburn, the Middle District of Florida applied the act of production privilege under the premise that Boyd was still binding precedent. Even applying Boyd, the court found that

o you want to try something today? Sent Thursday, December 08, 2011 3:39 PM Can all three of us get together on the phone tomorrow? Dismiss From: Vlllafana, Ann Marie C. (USAFLS) Sent: Thursday, December 08, 2011 11:47 AM To: Sanchez, Eduardo (USAFLS); Lee, Dexter (USAFLS) Subject: Jane Does I. US — S

ad no objection to the Motion to Seal. I stated that we had no objection. I am on vacation next week. We really HAVE to get this file transferred to the Middle District. «20111206 Sealed Response to Motn to Dismiss.pdf» EFTA00204923