Epstein Secrets

ess as a witness for the prosecution of Epstein. Villafana Decl, 1 14. Her exculpatory statements regarding

nt United States Attorney 99 ■. 4th Street, Suite 300 Miami, Florida 33132 Tel: (305) 961-9320; Fax: (305) 530-7139 E-mail: [email protected] A. Marie Villafafia Assistant United States Attorney 500 S. Australian Avenue, Suite 400 West Palm Beach, Florida 33401 Tel: (561) 820-8711; Fax: (561) 820-8777 E-m

stoppel does not apply to them because the government has not established one of the elements of the three-part test examined in Tampa Bay Water v. HDR Engineering, Inc., 731 F.3d 1171 (11th Cir. 2013). D.E. 416 at 60. Specifically, petitioners contend the government has not demonstrated the second factor, that petit

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

position would create the perception that either the earlier or later court was misled." DE 401-2 at 25 (emphasis added) (citing Tampa Bay Water v. HDR Engineering, Inc., 731 F.3d 1171, 1182 (11th Cir. 2013)). In this case, even treating the state court proceedings as the "earlier" proceedings, the Government does n

puty Chief, Northern Region), and AUSA Anna Marie Villafana. Mr. Epstein retained counsel with expertise in

Jeffrey Sloman (First Assistant U.S. Attorney), Matthew Menchel (Chief, Criminal Division), Andrew Lourie (Deputy Chief, Northern Region), and AUSA Anna Marie Villafana. Mr. Epstein retained counsel with expertise in federal law and federal jurisdiction, including a former federal appellate judge, a former United S

F.2d 1324, 20 EFTA00299040 1325 (9th Cir. 1975). As this Court has recognized, "a contracting party is the paradigm of an indispensable party." HDR Engineering, Inc. v. R.C.T. Engineering, Inc., No. 08- 81040-CIV-ICAM, 2010 WL 2402908, *2 (S.D.Fla. June 15, 2010) (citation omitted). "Parties to a contract are ind

ess as a witness for the prosecution of Epstein. Villafana Decl, 1 14. Her exculpatory statements regarding

stoppel does not apply to them because the government has not established one of the elements of the three-part test examined in Tampa Bay Water v. HDR Engineering, Inc., 731 F.3d 1171 (11th Cir. 2013). D.E. 416 at 60. Specifically, petitioners contend the government has not demonstrated the second factor, that petit