Epstein Secrets

ovision expanded as [USAO-SDFL prosecutor Maria] Villafana and defense counsel exchanged drafts of, first,

edged that investigators were aware of Epstein's longtime relationship with a close female friend who was a well- known socialite, but, according to Villafaha, in 2007, they "didn't have any specific evidence against her." Accordingly, Villafaila believed that the only "co-conspirators" of Epstein who wou

Particulars Is Not Warranted 173 1. Applicable Law 174 2. Discussion 177 A. The Defendant's Requests for Early Production of a Witness List and Jencks Act Material Should Be Denied 182 1. Applicable Law 182 2. Discussion 183 A. The Defendant's Additional Requests for Disclosure Should Be Denied

Villafana, Ann Marie C. (USAFLS) From: Villafana, Ann Marie C. (USAFLS) Sent: Thursday, July 26, 2007 8:49 AM To: Menthe', Matthew (USAFLS) Cc: Lourie,

ment. 5. I will add oven acts and counts related to two additional girls who have been identified and interviewed. I will sec you at 2:00. Thanks. A. Marie Villafafla Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 Phone 561 209-1047 Fax 561 820-8777 Tracking: 45 Exhibit 3

e & obtained phone records. Conspiracy to engage in illicit sexual conduct in foreign places in violation of 18 U.S.0 § 2423(e). Defendant seeks Jencks Act material prior to witness testifying. 2422(b); 2423 Consummated *Conspiracy 2423(e) 76 EFTA00226320 COURT . CASES ' FACILITY FACTS/COIV

smissed because of prosecutorial misconduct. 2422(b) Not Consummated Sting S.D. Fla. U.S. I McDaniel, 470 F. Supp. 2d 1372 (S.D. Fla. 2007) (Villafana case) Internet 19 yr-old contacted 12 yr-old & communicated for 18 months; believed to be in love; traveled to meet girl who was 14 yrs-old by

& obtained phone records. Ellitspiracy to engage in illicit sexual conduct in foreign places in violation of 18 U.S.0 § 2423(e). Defendant seeks Jencks Act material prior to witness testifying. 2422(b); 2423 Consummated *Conspiracy 2423(e) 76 EFTA00224210 COURT CASES tati:s: ,11INIF.! , -..

FTA01729544 COURT CoS S i' 6.CIO - :- :SYCO NPOWNI4 CT ION I% ' t S.D. Fla. U.S. v. McDaniel, 470 F. Supp. 2d 1372 (S.D. Fla. 2007) (Villafana case) Internet • 19 yr-old contacted 12 yr-old & communicated for 18 months; believed to be in love; traveled to meet girl who was 14 yrs-old

* conspiracy Conspiracy to engage in illicit sexual conduct in foreign places in violation of 18 U.S.C. § 2423(e). *Conspiracy Defendant seeks Jencks Act material prior to witness testifying. 2423(e) • U.S. v. Rosenberg, 2004 U.S. Dist. LEXIS 19160 (ED. Pa. 2004) Internet 58 yr-old computer ins

ting 60 EFTA00079473 COURT CASES EACH ITV FACTS/COMNIUNICATION CHARGE S.D. Fla. U.S. v. McDaniel, 470 F. Supp. 2d 1372 (S.D. Fla. 2007) (Villafana case) Internet 19 yr-old contacted 12 yr-old & communicated for 18 months; believed to be in love; traveled to meet girl who was 14 yrs-old by

& obtained phone records. Conspiracy to engage in illicit sexual conduct in foreign places in violation of 18 U.S.C. § 2423(e). Defendant seeks Jencks Act material prior to witness testifying. 2422(6); 2423 Consummated *Conspiracy 2423(e) U.S. v. Rosenberg, 2004 U.S. Dist. LEXIS 19160 (E.D. Pa.

ment, the defendant asks the Court to order discovery and conduct a hearing. In short, 10 The OPR Report further reflects that in OPR's interview of Villafana, she reported that she did not have anyone in mind aside from the four individuals named in the "co-conspirator" provision: "Villafaiia told OPR th

Particulars Is Not Warranted 174 1. Applicable Law 174 2. Discussion 178 B. The Defendant's Requests for Early Production of a Witness List and Jencks Act Material Should Be Denied 182 1. Applicable Law 182 2. Discussion 184 C. The Defendant's Additional Requests for Disclosure Should Be Denied

edged that investigators were aware of Epstein's longtime relationship with a close female friend who was a well- known socialite, but, according to Villafana, in 2007, they "didn't have any specific evidence against her." Accordingly, Villafaila believed that the only "co-conspirators" of Epstein who wou

rticulars Is Not Warranted 174 1. Applicable Law 174 2. Discussion 178 B. The Defendant's Requests for Early Production of a Witness List and Jencks Act Material Should Be Denied 182 1. Applicable Law 182 2. Discussion 184 C. The Defendant's Additional Requests for Disclosure Should Be Denied