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

elements of equitable estoppel since they are not relying upon the terms of the written agreement in asserting their claims. D.E. 416 at 57, citing MS Dealer Service Corp. v. Franklin 177 F.3d 942, 947 (11th Cir. 1999). They maintain that their claims in this litigation are not based on the NPA, but the CVRA. This arg

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

itable estoppel precludes challenging a document only where that party "must rely on the terms of the written agreement in asserting [her] claims." MS Dealer Service Corp. v. Franklin, 177 F.3d 942, 947 (11th Cir. 1999). Here, of course, the victims need not rely on the terms of the Government's non-prosecution agreem

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

elements of equitable estoppel since they are not relying upon the terms of the written agreement in asserting their claims. D.E. 416 at 57, citing MS Dealer Service Corp. v. Franklin 177 F.3d 942, 947 (11'h Cir. 1999). They maintain that their claims in this litigation are not based on the NPA, but the CVRA. This arg