Epstein Secrets

P-003634 Thru P-003646 File folder bearing victim name containing FBI interview report from May 2008, telephone activity report with attorney (Villafanafia) handwritten notes, related grand jury material Work product Attorney-client privilege 6(e) Investigative privilege Also contains information

08/16/2013 Page 30 of 70 Bates Range Description Privilege(s) Asserted Victims' Objections Box #2 P409114 Tint P-009115 7/3/2008 Email from A. Marie Villafafia to Col. M. Gauger at PBSO re Epstein work release with attachment [not being withheld as privileged — produced to opposing counsel] N/A Box

Underpinnings; Fiduciary Duty; Court Compelled Disclosure; Factual Materials; Waiver Box #3 P-013231 Thai P-013239 April 22, 2008 Letter from A. Marie Villafafia to Office of Professional Responsibility re Self-Report of Allegation of Conflict of Interest Privacy Act Inadequate Log; No Factual Underpinni

aiver; Claims Against Public Prosecutor, Overriding Need; Attorney Conduct at Issue Epstein, with e- mail from Menchel (July 5, 2007, 3:30 p.m.), Villafana to Menchel (July 4, 2007, 5:16 p.m.), and Sloman to Villafana (July 3, 2007, 1:47 p.m.), attached Suppl. Box 3 P-013866 E-mail, Marie Villafana

rom Stake Center and other victims, and pleaded guilty to one count of tax evasion and three counts of wire fraud. Pursuant to her plea agreement, DiFrancesco agreed to make restitution to Stake ' Stake Center previously petitioned this court for mandamus, and we denied this petition as premature. See Sta

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

in his sentence until the [review by writ] is concluded . . ..'" LAFAVE ET AL., CRIMINAL Procedure § 26.7(b) (Nov. 2010) (quoting United States v. DiFrancesco, 449 U.S. 117, 146 (1980)). 40 EFTA00210829 Case 9:08-cv-80736-KAM Document 48 Entered on FLSD Docket 03/21/2011 Page 41 of 42 DATED: March 21.

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,

ty in his sentence until the [review by writ] is concluded ...."' LAFAVE ET AL., CRIMINAL Procedure § 26.7(b) (Nov. 2010) (quoting United States v. DiFrancesco, 449 U.S. 117, 146 (1980)). 40 EFTA00079032 Case 9:08-cv-80736-KAM Document 48 Entered on FLSD Docket 03/21/2011 Page 41 of 42 DATED: March 21,2