Epstein Secrets

attorneys. Supplemental Declaration of A. Marie Villafana, Dec. 22, 2008, doe. #35 at 2-3. 49. On July 11,

ein's attorneys. Supplemental Declaration of A. Marie Villafana, Dec. 22, 2008, doe. #35 at 2-3. 49. On July 11,

tter for some time. Indeed, the Government sent notice to Petitioner more than a year ago that 'your case is under investigation?' See Letter from A. Marie Villafatia to C.W. at 2 (June 7, 2007) (attached to Governmen'.'s Response) (emphasis added). The notice went on to tell Petitioner that "as a victim and/or w

t the Government to produce all evidence that it possesses supporting these facts, for reasons the victims explain in their contemporaneously-filed Jane Doe NI and Jane Doe #2's Motion for Order Directing the U.S. Attorney's Office Not to Withhold Relevant Evidence. 3 EFTA00210792 Case 9:08-cv-80736-KAM

attorneys. Supplemental Declaration of A. Marie Villafana, Dec. 22, 2008, doc. #35 at 2-3. 49. On July II,

riminal defense counsel Jay Lefkowitz), and the U.S. Attorney's Office for the Southern District of Florida, represented by Assistant U.S. Attorney A. Marie Villafafia and others. The plea discussions generally began from the premise that Epstein would plead guilty to at least one federal felony offense surrounding

ein's attorneys. Supplemental Declaration of A. Marie Villafana, Dec. 22, 2008, doc. #35 at 2-3. 49. On July II,

that the plea agreement made it impossible to prosecute Epstein federally for his crimes against them, they would have objected to this resolution. Jane Doe NI and Jane Doe #2 thus detrimentally relied on the inaccurate representations of the U.S. Attorney's Office that their cases were still under investi

ant to 28 U.S.C. § 1746, that the foregoing is true and correct to the best of my knowledge and belief. Executed this2b, j day of December, 2008. A.A. Marie Villafafia, q. -4- EFTA00234652 Case 9:08-cv-80736-KAM Document 35-2 Entered on FLSD Docket 12/22/2008 Page 1 of 2 UNITED STATES DISTRICT COURT SOUTHER

Friday, June 27, 2008 10:00 AM To: Jack Goldberger Subject Have a great weekend! EFTA00234612 Exhibit 11 EFTA00234613 Jack Goldberger From: Villafana, Ann Marie C. (USAFLS) [Ann.Marie.C.Villafana@usdoj.gov] Sent: Saturday, June 28, 2008 11:31 AM To: Jack Goldberger Cc: Atkinson, Karen (USAFL

not hesitate to contact me or Special Agent Nesbitt Kuyrkendall at (561) 822-5946. Sincerely, R. Alexander Acosta United States Attorney By: A. Marie Villafala Assistant United States Attorney cc: Special Agent Nesbitt Kuyrkendall, F.B.I. Ms. Clearetha Wright, Victim-Witness Coordinator, U.S. Attorney's

tter that contained the language from "Part 3" of the Agreement. Based upon that communication, your Affiant sent the victim notification letter to Jane Doe NI and attached it to your Affiant's July 9,2008 Declaration. 6. Although copies of all of the victim notification letters, including the one addres

ecution agreement" and the USAO-SDFLA and counsel for the Jane Does, on numerous matters related to Jeffrey Epstein, including contacts with AUSAs "Marie Villafana and Dexter Lee." DE 41 at 3. The Government's filings frame the issue before the Court as to whether the "Government was obligated, under 18 U.S.C.

ey Epstein, including contacts with AUSAs "Marie Villafana and Dexter Lee." DE 41 at 3. The Government's fi

leges that in violation of the CVRA, Jane Doe #1 was not consulted with respect to the USAO-SDFLA's negotiations with Epstein (DE 1 at ¶¶3-6). The "Jane Doe NI and Jane Doe # 2 Status Report and Response to Court's Order to Show Lack of Prosecution" (DE 41) argues that "there [was] an orchestrated decision

ecution agreement" and the USAO-SDFLA and counsel for the Jane Does, on numerous matters related to Jeffrey Epstein, including contacts with AUSAs "Marie Villafafia and Dexter Lee." DE 41 at 3. The Government's filings frame the issue before the Court as to whether the "Government was obligated, under 18 U.S.C.

ecution Agreement. However, it appears from AUSA Villafana's Declaration that during the summer of 2007, neg

leges that in violation of the CVRA, Jane Doe #1 was not consulted with respect to the USAO-SDFLA's negotiations with Epstein (DE 1 at ¶¶3-6). The "Jane Doe NI and Jane Doe # 2 Status Report and Response to Court's Order to Show Lack of Prosecution" (DE 41) argues that "there [was] an orchestrated decision

epresentative will be simultaneously representing parties that may be in conflict, in violation of Rule 1.7. For these reasons, we believe that Ms. Villafana's interpretation of the Agreement in connection with the attorney representative's role in the settlement process must be rejected. Second Issue: W

refer to the plea and sentencing as though it will be in January; Mr. Krisher's office has not confirmed any date; and Mr. Goldberger recently told Marie Villafafia that "there is no date." I must reiterate that a delayed guilty plea and sentencing — now more than two months beyond the original deadline — is un

tter that contained the language from "Part 3" of the Agreement. Based upon that communication, your Affiant sent the victim notification letter to Jane Doe NI and attached it to your Affiant's July 9,2008 Declaration. 6. Although copies of all of the victim notification letters, including the one addres