Epstein Secrets

ovision expanded as [USAO-SDFL prosecutor Maria] Villafana and defense counsel exchanged drafts of, first,

edged that investigators were aware of Epstein's longtime relationship with a close female friend who was a well- known socialite, but, according to Villafaha, in 2007, they "didn't have any specific evidence against her." Accordingly, Villafaila believed that the only "co-conspirators" of Epstein who wou

006) 165 United States v. Payner, 447 U.S. 727 (1980) 82, 110 United States v. Pena, 932 F. Supp. 2d 464 (S.D.N.Y. 2013) 147 United States v. Perez, 940 F. Supp. 540 (S.D.N.Y.I996) 189 United States v. Pierre-Louis, No. 16 Cr. 541 (CM), 2018 WL 4043140 (S.D.N.Y. Aug. 9, 2018) passim United

E OF SERVICE I HEREBY CERTIFY that a true and correct copy of the above and foregoing has been provided by United States mail and via facsimile to: ANN MARIE C. VILLAFANA, AUSA, United States Attorney's Office, 500 South Australian Avenue, Suite 400, West Palm Beach, Florida 33401, this ab day of July, 2008. Brad Ed

ed States mail and via facsimile to: ANN MARIE C. VILLAFANA, AUSA, United States Attorney's Office, 500 Sout

ings include the likelihood of success on the merits, the likelihood of harm if not stay is granted, and the remedial quality of any such harm. See Perez v. Perez, 769 So. 2d 389, 391 n.4 (Fla. 3d DCA 1999); see also State ex rel. Price v. McCord, 380 So. 2d 1037, 1038 n.3 (Fla. 1980). The trial cour

h Cir. 2020). Discovery has revealed that during these negotiations, several drafts of the NPA were exchanged. See, e.g., Exh. C (9/17/07 email from Villafana to Lefkowitz attaching draft NPA); Exh. D (9/21/07 email from Villafana to Lefkowitz attaching draft NPA). In addition, the parties exchanged sever

Innes v. Dalsheim, 864 F.2d 974 (2d Cir. 1988) 14 LaSalle Bank Nat'l Ass 'n v. Nomura Asset Capital Corp., 424 F.3d 195 (2d Cir. 2005) 21, 27 Perez v. United States, Nos. 14 Civ. 846, 04 Cr. 937-1, 2015 WL 3413596 (S.D.N.Y. 2015) 18 Port Consol., Inc. v. Intl Ins. Co. of Hannover, PLC, 826 F

h Cir. 2020). Discovery has revealed that during these negotiations, several drafts of the NPA were exchanged. See, e.g., Exh. C (9/17/07 email from Villafana to Lefkowitz attaching draft NPA); Exh. D (9/21/07 email from Villafana to Lefkowitz attaching draft NPA). In addition, the parties exchanged sever

Innes v. Dalsheim, 864 F.2d 974 (2d Cir. 1988) 14 LaSalle Bank Nat'l Ass 'n v. Nomura Asset Capital Corp., 424 F.3d 195 (2d Cir. 2005) 21, 27 Perez v. United States, Nos. 14 Civ. 846, 04 Cr. 937-1, 2015 WL 3413596 (S.D.N.Y. 2015) 18 Port Consol., Inc. v. Intl Ins. Co. of Hannover, PLC, 826 F

ment, the defendant asks the Court to order discovery and conduct a hearing. In short, 10 The OPR Report further reflects that in OPR's interview of Villafana, she reported that she did not have anyone in mind aside from the four individuals named in the "co-conspirator" provision: "Villafaiia told OPR th

253 United States v. Payner, 447 U.S. 727 (1980) 115, 161, 162 United States v. Pena, 932 F. Supp. 2d 464 (S.D.N.Y. 2013) 22I United States v. Perez, 940 F. Supp. 540 (S.D.N.Y.1996) 281 United States v. Pierre-Louis, No. 16 Cr. 541 (CM), 2018 WL 4043140 (S.D.N.Y. Aug. 9, 2018) passim United

edged that investigators were aware of Epstein's longtime relationship with a close female friend who was a well- known socialite, but, according to Villafana, in 2007, they "didn't have any specific evidence against her." Accordingly, Villafaila believed that the only "co-conspirators" of Epstein who wou

253 United States v. Payner, 447 U.S. 727 (1980) 115, 161, 162 United States v. Pena, 932 F. Supp. 2d 464 (S.D.N.Y. 2013) 221 United States v. Perez, 940 F. Supp. 540 (S.D.N.Y.I996) 281 United States v. Pierre-Louis, No. 16 Cr. 541 (CM), 2018 WL 4043140 (S.D.N.Y. Aug. 9, 2018) passim United

Villafana, Ann Marie C. (USAFLS) From: Vi°Mena. Ann Mane C. (USAFLS) Sent: Tuesday. July 31, 2007 1:37 PM To: Sloman, Jeff (USAFLS); Menchel, Matthew (US

n doctrine because Plaintiff claims that Defendant engaged in a continuous course of conduct that in- jured her upon each instance of abuse. See Perez v. Laredo Junior Coll., 706 F2d 731, 733 (5th Cir.1983) (noting that if the violation "does not occur at a single moment but in a series of separa