Epstein Secrets

ess as a witness for the prosecution of Epstein. Villafana Decl, 1 14. Her exculpatory statements regarding

nt United States Attorney 99 ■. 4th Street, Suite 300 Miami, Florida 33132 Tel: (305) 961-9320; Fax: (305) 530-7139 E-mail: [email protected] A. Marie Villafafia Assistant United States Attorney 500 S. Australian Avenue, Suite 400 West Palm Beach, Florida 33401 Tel: (561) 820-8711; Fax: (561) 820-8777 E-m

s personally injured by her conduct. Id. at 450-51(citations omitted). In Calloway, the defendants in a wage discrimination action claimed plaintiff Calloway lied about receiving a college degree when she applied for employment, and that barred her wage discrimination claim. The Eleventh Circuit rejected

f's wrongdoing does not bar relief unless the defendant can show that it was personally injured by her conduct. Id. at 450-51(citations omitted). In Calloway, the defendants in a wage discrimination action claimed plaintiff Calloway lied about receiving a college degree when she applied for employment, a

thew Menchel, Esq. Andrew Lourie, Esq. A. Marie Villafana, Esq. The United States Attorney's Office South

. Matthew Menchel, Esq. Andrew Lourie, Esq. A. Marie Villafana, Esq. The United States Attorney's Office South

d in 2006. MIA_CEOS_00077 EFTA00191444 LAW °VICES OF GERALD B. LEFCOURT. P.C. Jeffrey Sloman, Esq. Matthew Menchel, Esq. Andrew Lourie, Esq. A. Marie Villafafia, Esq. The United States Attorney's Office Southern District of Florida July 6, 2007 Page 2 those who deliberately, knowingly, and intentionally

rshowitz for sexual purposes. Numerous courts have declined to allow a mere "reputational" interest to justify mandatory intervention. For example, Calloway" Westinghouse Eke. Cop., 115 F.R.D. 73 (M.D. Ga. 1987), denied a motion to intervene where the alleged interest was a doctor's "own reputation and

ess as a witness for the prosecution of Epstein. Villafana Decl, 1 14. Her exculpatory statements regarding

s personally injured by her conduct. Id. at 450-51(citations omitted). In Calloway, the defendants in a wage discrimination action claimed plaintiff Calloway lied about receiving a college degree when she applied for employment, and that barred her wage discrimination claim. The Eleventh Circuit rejected

f's wrongdoing does not bar relief unless the defendant can show that it was personally injured by her conduct. Id. at 450-51(citations omitted). In Calloway, the defendants in a wage discrimination action claimed plaintiff Calloway lied about receiving a college degree when she applied for employment, a

-mail: Dexter. [email protected] E-mail: ann.marie.c.villafana@usdoj.gov and Attorneys for the Government Paul G

o the Court, Jane Doe #3’s Response takes remarkable liberties in describing what is claimed to be the law to Court. For example, the Response quotes Calloway v. Westinghouse Elec. Corp., 115 F.R.D. 73, 74 (M.D. Ga. 1987) for the proposition that “a witness’ interest in his reputation alone . . . does not c