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

ively by the Federal Rules of Criminal Procedure, the USAO would not be entitled to compel pre-trial production of any of this information. See Fed. R. Cr. P. 16(b)(1)(A), (C), and 16(bX2); United States v. Argomaniz, 925 F.2d 1349, 1355-56 (11th Cir. 1991) (explaining act-of-production privilege). T

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

ively by the Federal Rules of Criminal Procedure, the USAO would not be entitled to compel pm-trial production of any of this information. See Fed. R. Cr. P. 16(bX1)(A), (C), and 16(bX2); United States v. Argomaniz, 925 F.2d 1349, 1355-56 (11th Cir. 1991) (explaining act-of-production privilege). Th

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

ively by the Federal Rules of Criminal Procedure, the USAO would not be entitled to compel pre-trial production of any of this information. See Fed. R. Cr. P. 16(b)(1)(A), (C), and 16(b)(2); United States I Argomaniz, 925 F.2d 1349, 1355-56 (11th Cir. 1991) (explaining act-of-production privilege). T