Epstein Secrets

ct of Florida Dexter A. Lee, Assistant U.S. Attorney 99 N.E. 4th Street Miami, Florida 33132 Telephone: 305-961-9320 Facsimile: 305-530-7139 Ann Marie C. Villafana, AUSA United States Attorney's Office 500 South Australian Avenue Suite 400 West Palm Beach, Florida 33401 s/ Brad Edwards Brad Edwards, Esquir

d: 09/25/2008) 10/08/2008 29 RESPONSE in Opposition re 28 MOTION to Unseal Document Non-Prosecution Agreement filed by United States of America. (Villafana, Ann Marie) (Entered: 10/08/2008) 10/16/2008 3Q RESPONSE/REPLY to 29 Response in Opposition to Motion to Unseal Non-Prosecution Agreement filed by

office file a corrected declaration and accompanying explanation. The first statement is found at page 3 to 4 of the July 916, 2008 declaration of Marie Villafafla. 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

Notice, taken before Victoria Aiello, Court Reporter, pages 1-32. For the Plaintiff: Bradley Edwards, Esquire For the Defendant: Dexter Lee, AUSA Maria Villafana, AUSA STEVEN M. IARIM CLERK U. S. GIST. S. D. of FLA-MV GJT C. sedans ,v • •••I, • .hrt/...•0•1•••41•, OFFICIAL REPO NG SERVICES, LLC (954)

jury and the causal conduct; and (3) a likelihood that the injury will be redressed by a favorable decision. Granite State Outdoor Advertising, Inc. I. City of Clearwater, Fla., 351 F.3d 1112, 1116 (11ffi Cir. 2003). Petitioners already have obtained access to the agreement, so they cannot claim a denia

/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

y, or property interest implicated in the CVRA, and courts arc hesitant to find that a substantive due process right has been created. See Collins I. City of Harker Heights. Texas, 503 U.S. 115, 5 EFTA00177151 Case 9:08-cv-80736-KAM Document 59 Entered on FLSD Docket 04/07/2011 Page 6 of 9 125 (19

arra/Johnson (S.D. Fla.) (D.E. 14), Decl. of AUSA Villafana, 07/09/08, ¶ 5, attached hereto as Exhibit "A" (

expand or create an exemption to Florida's public records law. Wait I. Florida Power & Light Co., 372 So. 2d 420 (Fla. 1979); Times Publishing Co. I. City of St. Petersburg, 558 So. 2d 487 (Fla. 2d DCA 1990). Principles of federal preemption under the Supremacy Clause may, in limited circumstances, a