Epstein Secrets

g CM/ECF. SERVICE LIST Jane Doe 1 and Jane Doe 2 Case No.: 08-80736-CIV-MARRA/JOHNSON United States District Court, Southern District of Florida Dexter A. Lee, Assistant U.S. Attorney 99 N.E. 4th Street Miami, Florida 33132 Telephone: 305-961-9320 Facsimile: 305-530-7139 Ann Marie C. Villafana, AUSA

. Marra on 7/7/08. (ir) (Entered: 07/07/2008) 07/09/2008 4 NOTICE of Attorney Appearance by Dexter Lee on behalf of United States of America (Lee, Dexter) (Entered: 07/09/2008) 07/09/2008 6 Sealed Document. (rb) UNSEALED see DE 12 . Modified on 7/15/2008 (bs). (Entered: 07/10/2008) 07/09/2008 7 Se

t position in this case, it is that this provision is not in fact part of the plea agreement in this case. If our understanding is correct, then Ms. Villafaila has filed a false affidavit with the court, albeit inadvertently. We respectfully request that she file a new affidavit that corrects this false in

f 3 CERTIFICATE OF SERVICE I certify that the foregoing document was served on August 16, 2013, on the following using the Court's CM/ECF system: Dexter Lee A. Marie Villafafia 500 S. Australian Ave., Suite 400 West Palm Beach, FL 33401 (561) 820-8711 Fax: (561) 820-8777 E-mail: [email protected] E-

derpinnings; Fiduciary Duty; Claims Against Public Prosecutor, Overriding Need; Attorney Conduct at Issue Suppl. Box 3 P-013842 Email from Dexterr Lee . to Ruth Plagenhoef (OPR), February 25, 2011, 4:31 p.m., Re: request for OPR Investigation — Jeffrey Epstein Non- Prosecution Agreement

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

d the USAO-SDFLA and counsel for the Jane Does, on numerous matters related to Jeffrey Epstein, including contacts with AUSAs "Marie Villafafia and Dexter Lee." DE 41 at 3. The Government's filings frame the issue before the Court as to whether the "Government was obligated, under 18 U.S.C. § 3771(a)(5),

.M.", and "S.R." by AUSA Villafatia and the FBI's Victim-Witness Specialist Twiller Smith. DE 14. In addition, appended to the Declaration are AUSA Villafaila's letters to the victim's counsel, Bradley J. Edwards, Esq. DE 14. Special Agent Nesbitt Kuyrkendall, F.B.I. is copied on AUSA Villafafia's letters

illafana, Ann Marie C. (USAFLS) From: Villafana, Ann Marie C. (USAFLS) <[email protected]> Sent: Monday, October 20, 2008 5:02 PM To: Lee, Dexter (USAFLS) Cc: Acosta, Alex (USAFLS); Sloman, Jeff (USAFLS) Subject: RE: Draft Response Letter to Edwards' October 9, 2008 letter Ili Dexter — We

nd contained the "incorrect" info (i.e., the December 2007 info). The second notification was sent on September 3rd, with the correct info. A. Made Villafaila Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL. 33401 Phone 561 209-1047 Fax 561 820-8777 From: Lee, Dexter (USAF