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

3771(d)(3). Petitioners' attempt to engraft a right of access to government information to section 3771(c)(1) should be rejected. In Pennsylvania'. Ritchie, 480 U.S. 39 (1987), the Supreme Court recognized that the Confrontation Clause grants a criminal defendant a trial right to cross- examine a witnes

/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

3771(d)(3). Petitioners' attempt to engraft a right of access to government information to section 3771(cXI) should be rejected. In Pennsylvania'. Ritchie, 480 U.S. 39 (1987), the Supreme Court recognized that the Confrontation Clause grants a criminal defendant a trial right to cross- examine a witnes

eriff Investigator Media rep (?) Media rep (?) -1- EFTA00600049 Michael Sanka Patrick Roberts Nesbitt Kirkendahl Jason Richards Dexter Lee Maria Villafana Mark Epstein Judge Stone Deborah Villegas Bart' Bekkadan A.J. Discala Alfredo Rodriguez Michael Szafranski Dominic Ponatchio Moto Ban Mon S

itt Kirkendahl Jason Richards Dexter Lee Maria Villafana Mark Epstein Judge Stone Deborah Villegas Bar

estments or Fortress Capital Drawbridge Banyon Investments Cetnurion Credit Fund Platinum Management Fund NAMES FROM S. Discala Chris Podaras Thane Ritchie Michael Szafranski Barry Bekkedam Elizabeth Friedland Michael Legomaro Ken Jenne Mike Fisten Saudi Prince Bill Clinton Naomi Campbell Ted W

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

3771(d)(3). Petitioners' attempt to engraft a right of access to government information to section 3771(cXI) should be rejected. In Pennsylvania v. Ritchie, 480 U.S. 39 (1987), the Supreme Court recognized that the Confrontation Clause grants a criminal defendant a trial right to cross- examine a witnes

s typically apply to exculpatory material within the possession or control of the state. 3° For example, in the Supreme Court case of Pennsylvania v. Ritchie, the defendant sought recorded statements made to a youth counselor concerning an alleged assault. 3°7 The recorded statements were taken and possess

phasis added). Courts have held that Brady obligations extend only to prosecutors, because the Supreme Court has not imposed this duty on others. See Villasana v. Wilhoit, 368 F.3d 976, 979 (8th Cir. 2004). w 4 See Brady, 373 U.S. at 88. w > 162 F.3d 937 (7th Cir. 1998). DAVID SCHOEN HOUSE_OVERSIGHT_01