Epstein Secrets

red Under Rule 6(e)(3)(E) The Court Has Inherent Power to Release Grand Jury Materials Victims Have Pro

Objections Box #1 P-000983 thru P-001007 File folder entitled "Attorney Notes from Document Review" containing typed and handwritten attorney (Villafafia) notes, target letters, correspondence re grand jury subpoena Work product 6(e) Contains information subject to investigative privilege. Also

hru summary chart, witness/victim names and Contains information and Anticipation of Litigation; Improper P-002386 contact list, attorney (Villafafia) documents subject to Invocation; Overriding Need; Claims Against handwritten notes, 302s, portions of state investigative privilege. Public Pro

); Dawavendewa v. Salt River Project Agr. Imp. & Power Dist, 276 F.3d 1150, 1157 (9th Cir. 2002) ("[A] p

government about the investigation and potential prosecution of Epstein. At least one attorney for the government (Assistant United States Attorney Villafafia from the USAO-SDFL) had spoken to Petitioners about the offenses committed against them by Epstein prior to the signing of the Non-Prosecution Agre

); Dawavendewa v. Salt River Project Agr. Imp. & Power Dist, 276 F.3d 1150, 1157 (9th Cir. 2002) ("[A] p

government about the investigation and potential prosecution of Epstein. At least one attorney for the government (Assistant United States Attorney Villafafia from the USAO-SDFL) had spoken to Petitioners about the offenses committed against them by Epstein prior to the signing of the Non-Prosecution Agre

ered Under Rule 6(eX3)(E) The Court Has Inherent Power to Release Grand Jury Materials Victims Have Pro

hru summary chart, witness/victim names and Contains information and Anticipation of Litigation; Improper P-002386 contact list, attorney (Villafafia) documents subject to Invocation; Overriding Need; Claims Against handwritten notes, 302s, portions of state investigative privilege. Public Pro

EFTA00193891 COUNT II (TRANSFER OF CORPORATE POWER TO PLAINTIFF ROSENFELDT) 19. Plaintiffs adopt,

United States Attorney, Southern District of Florida 500 S. Australian Avenue Suite 400 West Palm Beach, FL 33401 Re: Jeffrey Epstein Dear Ms. Villafafia: Thank you for your letter of July 27, 2011 to my co-counsel Martin Weinberg concerning the request by the New York District Attorney for copies of

he United States Attorney's Office prepared negotiated lea agreements containing these charges. For example, in a September 18, 2007, email from AUSA Villafafia to Lefkowitz (attached hereto as Exhibit “H’), she attached the proposed plea agreement describing Epstein’s witness tampering as follows: "UNITED

been negotiated with Epstein’s attorneys that would block federal sussecution, To the contrary, AUSA Villafafia mentioned a possible indictment. AUSA Villafafia did indicate that federal investigators had concrete evidence and information that Epstein had sexually molested many underage minor females, includi

than that for which it was designed.” S&J Investments v. Payless Flea Market, Inc., 36 So.3d 909, 917 (Fla. 4" Dist. Ct. App. 2010) (citing Biondo v. Powers, 805 So.2d 67, 69 (Fla. 4" Dist. Ct. App. 2002). As.a consequence, “[w]here the process was used to accomplish the result for which it was intended,