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government about the investigation and potential prosecution of Epstein. At least one attorney for the government (Assistant United States Attorney Villafana from the USAO-SDFL) had spoken to Petitioners about the offenses committed against them by Epstein prior to the signing of the Non-Prosecution Agre
y Florida Bar No. 877875 99 N.E. 4th Street Miami, Florida 33132 Tel: (305) 961-9057; Fax: (305) 536-4676 Email: [email protected] A. Marie Villafatia Assistant United States Attorney Florida Bar No. 0018255 500 S. Australian Avenue, Suite 400 West Palm Beach, FL 33401 Tel: (561) 820-8711; Fax:
eement that grants contractual rights to a contracting party (Epstein) who has not been made a party to the proceedings before the Court. See, e.g., School Dist. of City of Pontiac v. Secretary of U.S. Dept. of Ethic., 584 F.3d 253, 303 (6th Cir. 2009) ("It is hombook law that all parties to a contract are
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
States v. Post, 950 F. Supp. 2d 519 (S.D.N.Y. 2013) 150 Valentine v. Konteh, 395 F.3d 626 (6th Cir. 2005) 155 Vernon v. Cassadaga Valley Cent. School Dist., 49 F.3d 886 (2d Cir. 1995) 32, 33 Washington v. Giucksberg, 521 U.S. 702 (1997) 104 Weingarten v. United States, 865 F.3d 48 (2d Cir. 2017)
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
n principles of procedural due process. "It is hornbook law that all parties to a contract are necessary in an action challenging its validity...." School Dist. of City of Pontiac v. Secretary of U.S. Dept of Educ., 584 F.3d 253, 303 (6th Cir. 2009). "No procedural principle is more deeply imbedded in the co
government about the investigation and potential prosecution of Epstein. At least one attorney for the government (Assistant United States Attorney Villafana from the USAO-SDFL) had spoken to Petitioners about the offenses committed against them by Epstein prior to the signing of the Non-Prosecution Agre
eement that grants contractual rights to a contracting party (Epstein) who has not been made a party to the proceedings before the Court. See, e.g., School Dist. of City of Pontiac v. Secretary of U.S. Dept. of Ethic., 584 F.3d 253, 303 (6th Cir. 2009) ("It is hombook law that all parties to a contract are
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
v. Zodhiates, 901 F.3d 137 (2d Cir. 2018) 122, 126, 131 Valentine v. Konteh, 395 F.3d 626 (6th Cir. 2005) 235 Vernon v. Cassadaga Valley Cent. School Dist., 49 F.3d 886 (2d Cir. 1995) 42, 43 xxiv EFTA00099965 Washington v. Glucksberg, 521 U.S. 702 (1997) Weingarten v. United States, 865 F.3d 48
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
v. Zodhiates, 901 F.3d 137 (2d Cir. 2018) 122, 126, 131 Valentine v. Konteh, 395 F.3d 626 (6th Cir. 2005) 235 Vernon v. Cassadaga Valley Cent. School Dist., 49 F.3d 886 (2d Cir. 1995) 42, 43 xxiv EFTA00103023 Washington v. Glucksberg, 521 U.S. 702 (1997) Weingarten v. United States, 865 F.3d 48
Entities connected to both A. Marie Villafana and School Dist

Jeffrey Epstein
PERSON
Alexander Acosta
PERSON
Kenneth Marra
PERSON
Bradley Edwards
PERSONJane Doe
PERSON
United States
LOCATION
Prince Andrew
PERSON
Department of Justice
ORGANIZATION
Bill Richardson
PERSONthe Southern District
LOCATION
George W. Bush
PERSON
Paul Cassell
PERSONFBI
ORGANIZATIONLourie
PERSONMaria Farmer
PERSON
Scarlett Johansson
PERSONMartin Weinberg
PERSON
Ken Starr
PERSON
Sarah Kellen
PERSON
the United States District Court
ORGANIZATION