Epstein Secrets

• This motion is filed under seal because the deferred-prosecution agreement between the United States Attorney's Office (by Assistant U.S. Attorney Marie C. Villafana, Esq.) and Mr. Epstein, discussed herein, contains a confidentiality clause. 09/1212019 LewjAIsinn. 3059 Owe Awns. Sum 310, Cccoodur Owns hoes 33

ILLAFARA IN SUPPORT OF UNITED STATES' RESPONSE TO VICTIM'S EMERGENCY PETITION FOR ENFORCEMENT OF CRIME VICTINLRIGHTS ACT. 18 U.S.C. 6 3771 I. I, A. Marie Villafalia, do hereby declare that I am a member in good standing of the Bar of the State of Florida. I graduated from the University of California at Berkeley

ney's Office (by Assistant U.S. Attorney Marie C. Villafana, Esq.) and Mr. Epstein, discussed herein, contai

cuit recently construed "the plain language of § 3509(k)" as "regaining" a stay in a case . . . where . . a parallel criminal action [is] pending." Doe v. Francis, No. 5:03 CV 260, 2005 WL 950623, 6 laNeMaTEin 1059 Gmtro Avon". Sing 340.COttwur Gaon. FLORIDA 33B1 09/1212019 CONFIal53ENTIAL Agency to Agenc

on, Inc. Page 46 1 A. No, sir. 2 MR. LEOPOLD: Objection. Asked and 3 answered. 4 BY MR. TEIN: 5 Q. So if I say the name to you Marie 6 Villafona, you don't know who that is? 7 A. No, sir. 8 Q. How many women and how many men came to 9 your house? 10 A. I want to say two ladies and t

r. 13 Q. Does it refresh your recollection that he's 14 the number two prosecutor at the U.S. Attorney's Office? 15 A. No. 16 Q. That he's Marie Villafona's boss? 17 A. No. 18 Q. Does it refresh your memory that he's the 19 ex-partner of Jeff Herman, the first lawyer who sued 20 you -- sued Mr.

s pled here. Thus, in resorting to fraudulent joinder, the plaintiff has sought to avoid any application of this otherwise controlling statute. Cf. Doe v. Francis, No. 5:03 CV 260 MCR/WCS, 2005 WL 517847, at *1-2 (N.D. Fla. Feb. 10, 2005) (staying civil diversity action over plaintiffs' objections on grounds

Marra/Johnson (S.D. Fla.) (DE 14), Decl. of AUSA Villafana, 07/09/08, 1 5, attached hereto as Exhibit "A" (e

8. The District Court for the Northern District of Florida confirmed this position and specifically rejected the plaintiffs' contrary argument. See Doe v. Francis. No. 5:03 CV 260, 2005 WI 950623, at "2 (N.D. Fla. 2005). The plaintiffs there argued that "the stay should be lifted due to the fact that the mino