Epstein Secrets

/2011 Page 10 of 10 CERTIFICATE OF SERVICE The foregoing document was served on March 21, 2011. on the following using the Court's CM/ECF system: A. Marie Villafafia 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.lill

ave placed victims of Epstein's sexual abuse in "the same position as they would have been had Mr. Epstein been convicted at trial." Declaration of Marie Villafana, July 9, 2008 (doc. #14) at 3-4. The affidavit also goes on to say that "these provisions were discussed," id. at 4, apparently referring to this

e of the unfounded allegations made against AUSA Villafana by Epstcin's counsel during the "higher level re

cv-80736-KAM Document 60 Entered on FLSD Docket 04/07/2011 Page 4 of 10 of secrecy which is waived once public disclosure occurs." In re Motions of Dow Jones & Co., Inc., 142 F.3d 496, 505 (D.C. Cir. 1998) (quoting In re North, 16 F.3d 1234, 1245 (D.C. Cir. 1994)). "[E]ven if material concerning the grand jury

/2011 Page 10 of 10 CERTIFICATE OF SERVICE The foregoing document was served on March 21, 2011, on the following using the Court's CM/ECF system: A. Marie Villafafla 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

office file a corrected declaration and accompanying explanation. The first statement is found at page 3 to 4 of the July 9th, 2008 declaration of Marie Villafafia. There a provision in a plea agreement with Mr. Jeffrey Epstein is recounted. As we understand the Government's current position in this case, it is

n been convicted at trial." Declaration of Marie Villafana, July 9, 2008 (doe. #14) at 3-4. The affidavit

ve disclosures of grand jury material, "Rule 6(e) does not create a type of secrecy which is waived once public disclosure occurs." In re Motions of Dow Jones & Co., 142 F.3d 496, 505 (D.C. Cir. 1998) (quoting in re North,16 F.3d 1234, 1245 (D.C. Cir. 1994)). "[E]ven if material concerning the grand jury invest

scope of Mr. Epstein's fee- EFTA00233057 Marie Villafana, Esq. February 18, 2010 Page 2 related payment

strongly believe that significant amounts of the fees and costs billed by Mr. Josefsberg are outside the scope of Mr. Epstein's fee- EFTA00233057 Marie Villafana, Esq. February 18, 2010 Page 2 related payment obligations under the NPA. We hope that the fee-related issues can be resolved by further settleme

well as actual transcripts, the strategy or direction of the investigation, the deliberations or questions of jurors, and the like.") (citing In.m Dow Jones & Co., Inc.„, 142 F.3d 496, 500 (D.C. Cir. 1998)); see SEC v Dresser Indust'. Inc., 628 F.2d 1368, 1382 (D.C. Cir. 1980); Fund for Constitutional Gov't v

United States Attorney, Southern District of Florida 500 S. Australian Avenue Suite 400 West Palm Beach, FL 33401 Re: Jeffrey Epstein Dear Ms. Villafana: Thank you for your letter of July 27, 2011 to my co-counsel Martin Weinberg concerning the request by the New York District Attorney for copies of

o Hong Kong London Los Angeles Munich Palo Alto San Francisco Shanghai Washington, D.C. K&E 19439748.1 EFTA00586200 KIRKLAND & ELLIS LLP A. Marie Villafana July 29, 2011 Page 2 paragraph 13, for you to disclose it absent a subpoena -- which we could oppose in the jurisdiction from which it emanated.

s that either testified or were identified during Grand Jury proceedings are subject to the secrecy provisions of F.R.Crim.P 6(e). Ste, tg,,, In re Dow Jones & Co., Inc., 142 F.3d 496, 500 (D.C. Cir. 1998) ("Consistent with these purposes, we have recognized that grand jury secrecy covers `the identities of wit

13) (citing Declaration of Asst. U.S. 5 EFTA00230177 Case 9:08-cv-80736-KAM Document 51 Entered on FLSD Docket 03/21/2011 Page 6 of 10 Attorney Marie Villafafia). These same subjects were also discussed at length at the Court's July 11, 2008, hearing on the matter. See, e.g., Tr. July 11, 2008, at 3-4, 18-1

n been convicted at trial." Declaration of Marie Villafana, July 9, 2008 (doe. #14) at 3-4. The affidavit

ve disclosures of grand jury material, "Rule 6(e) does not create a type of secrecy which is waived once public disclosure occurs." In re Motions of Dow Jones & Co., 142 F.3d 496, 505 (D.C. Cir. 1998) (quoting in re North,16 F.3d 1234, 1245 (D.C. Cir. 1994)). "[E]ven if material concerning the grand jury invest

se who seek compensation from the Trust. See draft proposal sent from Jay Lelliowitz to Andrew I ,nurle dated September 15, 2007. In response, Ms. Villafana demanded that the Agreement contain language considering the inclusion of a guardian ad hum in the proceedings. despite the fact that. we are now le

ve disclosures of grand jury material, "Rule 6(e) does not create a type of secrecy which is waived once public disclosure occurs." In re Motions of Dow Jones & Co., 142 F.3d 496, 505 (D.C. Cir. 1998) (quoting In re North, 16 F.3d 1234, 1245 (D.C. Cir. 1994)). "[Elven if material concerning the grand jury inves