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and growing number of identified victims and sentencing guidelines if found guilty of committing a sex- trafficking offense against just one victim. AUSA Villafafia would not provide many answers or comments to any of my direct questions and, in fact, expressed that while she wished she could answer my question
riminal case against Jeffrey Epstein and she wanted my assistance in getting some answers. 11. In mid-June 2008, I had several telephone calls with AUSA Villafafia. In her affidavit, Villafafia only recounts certain fragments of these calls. (See DE 403-19, para. 37-38). However, to the extent the substance o
rt its argument, the Government relies on the presumption "that Congress intends to change the law when it enacts amendments." DE 401-2 at 8 (citing Bailey v. United States 52 Fed. Cl. 105, 110 (2002)). According to the Government, the fact that Congress 19 EFTA00799906 Case 9:08-cv-80736-KAM Docume
on to be resolved without charges being filed against Epstein. Several months after that videotaped interview, Attorney Eisenberg was asked whether AUSA Villafafia could contact Jane Doe No. 2 directly and was told that contact had to occur via Mr. Eisenberg. Ex. S. 1 14. In seeking summary judgment, Jane Doe
No. 2 refused to be interviewed by the FBI and U.S. Attorney's Office unless she was granted immunity. Ex. A, Sept. 21, 2006 Ltr. from Eisenberg to AUSA Villafafia; Ex. S, 6-12. Thus, she was unwilling to provide any information regarding her encounters with Epstein unless she was assured her statements would
s.... This legislation will help for all of those reasons."). The presumption is that Congress intends to change the law when it enacts amendments. Bailey v. United States, 52 Fed. Cl. 105, 110 (2002), citin Wallace v. Jaffree 472 U.S. 38, 59 n.48 (1985). Here, not only did Congress change the law by c
on to be resolved without charges being filed against Epstein. Several months after that videotaped interview, Attorney Eisenberg was asked whether AUSA Villafafia could contact Jane Doe No. 2 directly and was told that contact had to occur via Mr. Eisenberg. Ex. S,1 14. In seeking summary judgment, Jane Doe N
No. 2 refused to be interviewed by the FBI and U.S. Attorney's Office unless she was granted immunity. Ex. A, Sept. 21, 2006 Is. from Eisenberg to AUSA Villafafia; Ex. S, ¶16-12. Thus, she was unwilling to provide any information regarding her encounters with Epstein unless she was assured her statements would
s.... This legislation will help for all of those reasons."). The presumption is that Congress intends to change the law when it enacts amendments. Bailey v. United States, 52 Fed. Cl. 105, 110 (2002), citin Wallace v. Jaffree 472 U.S. 38, 59 n.48 (1985). Here, not only did Congress change the law by c
tters in approximately June 2007 [Jane Doe #1] and August 2006 [Jane Doe #2] wherein they were advised of this right and given the phone numbers of AUSA Villafafia, FBI Special Agent Kuyrkendall, and the Justice Department's Office for Victims of Crime. The letters specifically advised that if the Petitioners
anon of statutory construction that "discourages courts from adopting a reading of a statute that renders any part of the statute mere surplusage." Bailey v. United States, 516 U.S. 137, 146 (1995)(noting that each word in a statute is intended to have "particular, nonsuperfluous meaning"). Congress i
Entities connected to both AUSA Villafafia and Bailey

Jeffrey Epstein
PERSON
George W. Bush
PERSON
United States
LOCATION
Department of Justice
ORGANIZATIONLeon Black
PERSON
Prince Andrew
PERSON
Virginia Giuffre
PERSON
Donald Trump
PERSON
Scarlett Johansson
PERSON
Ghislaine Maxwell
PERSON
Julie K. Brown
PERSON
Alexander Acosta
PERSON
Joe Biden
PERSONthe Southern District
LOCATION
Bradley Edwards
PERSONFBI
ORGANIZATION
Bill Clinton
PERSONMaria Farmer
PERSON
Alan Dershowitz
PERSON
Michigan
LOCATION