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

ce with regard to the acts, conduct, or acquiescence; (3) detrimental reliance; and (4) affirmative misconduct by the Government. United States v. McCorkle, 321 F.3d 1292 (11a ' Cir. 2003). Each of these four factors is easily met here. 33 EFTA00210822 Case 9:08-cv-80736-KAM Document 48 Entered on F

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,

ce with regard to the acts, conduct, or acquiescence; (3) detrimental reliance; and (4) affirmative misconduct by the Government. United States v. McCorkle, 321 F.3d 1292 (11th Cir. 2003). Each of these four factors is easily met here. 33 EFTA00079025 Case 9:08-cv-80736-KAM Document 48 Entered on FL

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 Villafana and others. The plea discussions generally began from the premise that Epstein would plead guilty to at least one federal felony offense surrounding

11 Page 42 of 42 CERTIFICATE OF SERVICE The foregoing document was served on March 21, 2011, on the following using the Court's CM/ECF system: A. Marie Villafafta Assistant U.S. Attorney 500 S. Australian Ave., Suite 400 West Palm Beach, FL 33401 (561) 820-8711 Fax: (561) 820-8777 E-mail: ann.marie,c,vill

represented by Assistant U.S. Attorney A. Marie Villafana and others. The plea discussions generally began

ence with regard to the acts, conduct, or acquiescence; (3) detrimental reliance; and (4) affirmative misconduct by the Government. United States' McCorkle, 321 F.3d 1292 (11th Cir. 2003). Each of these four factors is easily met here. 33 EFTA00177041 Case 9:08-cv-80736-KAM Document 48 Entered on F

the past six months. We will leave it to your discretion as to whether this should be brought to the Court's attention. Epstein Agrmt001.pdf it Marie Villafaila Assistant U.S. Attorney 500 S. Australian Ave. Suite 400 West Palm Beach. Ft. 33401 Tracking: 713 08-80736-CV-MARRA RFP WPB-001857 EFTA001850

(VRAF(-13) Prom: Sent; To: Co: Subject: Ann Merle our two client names ere. 2. Ted Leopold tTleopokkanechaw.00mi Thuriutny, Jul.008 4:28 PM Villafana, Ann (USAPL8) Spencer Kuvin RØ; Epstein Investigation If you need any other trtformstion please lel me know. Ted i € -,---Ortglnal Message—

nce with regard to the acts, Conduct, or acquiescence; (3) detrimental reliance; and (4) affirmative misconduct by the Government. United States'. McCorkle, 321 F.3d 1292 (I l" Cir. 2003). Each of these four factors is easily met here. 33 EFTA00185041 Case 90B-cava7236-11CMil Banuarand 3162- etas* R

represented by Assistant U.S. Attorney A. Marie Villafana and others. The plea discussions generally began

th the investigation, you will he no', By: cc: Special Agent Nesbitt Kuyrkendall, F.B.I. Sincerely, R. Alexander Acosta United States Attorney A. Marie Villafafia Assistant United States Attorney f f 08-80736-CV-MARRA 000724 EFTA00230548 Case 9:08-cv-80736-KAM Document 48-5 Entered on FLSD Docket 03/21/2

ement barring federal prosecution of their oases because of a deliberate decisions by the U.S. Attorney's Office, not mere "negligence or inaction." McCorkle, 321 F.3d at 1297. Accordingly, the Government is stopped from arguing that the Crime Victims' Rights Act does not apply to this case. IL THE COU