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tend that judicial estoppel does not apply to them because the government has not established one of the elements of the three-part test examined in Tampa Bay Water v. HDR Engineering, Inc., 731 F.3d 1171 (11th Cir. 2013). D.E. 416 at 60. Specifically, petitioners contend the government has not demons
ent and learned that Epstein's state court change of plea hearing was scheduled for 8:30 a.m., Monday, June 30, 2008. D.E. 403-19 at 21, 1 38. AUSA Villafafia called attorney Edwards, told him of the June 30, 2008 hearing, and stressed the importance of the hearing.2 Thus, the government provided petitione
o pursue and foist himself upon those victims who have never reached out and asked to confer. Neither Jane Doe 1 nor Jane Doe 2 ever contacted AUSA Villafafia or FBI Special Agent Kuyrkendall regarding the case, despite being provided their phone numbers and addresses. D.E. 403-19,915. Since the Court's s
tend that judicial estoppel does not apply to them because the government has not established one of the elements of the three-part test examined in Tampa Bay Water v. HDR Engineering, Inc., 731 F.3d 1171 (11th Cir. 2013). D.E. 416 at 60. Specifically, petitioners contend the government has not demons
ent and learned that Epstein's state court change of plea hearing was scheduled for 8:30 a.m., Monday, June 30, 2008. D.E. 403-19 at 21, 1 38. AUSA Villafafia called attorney Edwards, told him of the June 30, 2008 hearing, and stressed the importance of the hearing.2 Thus, the government provided petitione
o pursue and foist himself upon those victims who have never reached out and asked to confer. Neither Jane Doe 1 nor Jane Doe 2 ever contacted AUSA Villafafia or FBI Special Agent Kuyrkendall regarding the case, despite being provided their phone numbers and addresses. D.E. 403-19,915. Since the Court's s
each 401 N. Dixie Highway West Palm Beach, FL 33401 Deanna K. Shullman Attornea: Palm Beach Post 400 N.EM Dr., Suite 1100 P.O. Box 2602 (33601) Tampa, FL 33602 Jane Kreusler-Walsh, Esq. Barbara J. Compiani, Esq. Attorneys For: Jcffiey Epstein Kreusler-Walsh, Compiani & Vargas, P.A. 501 S. Fla
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
Entities connected to both Tampa and Ann Marie C. Villafafia

Jeffrey Epstein
PERSON
George W. Bush
PERSON
Joe Biden
PERSONLeon Black
PERSON
United States
LOCATION
Bradley Edwards
PERSON
Department of Justice
ORGANIZATIONJack Goldberger
PERSON
Prince Andrew
PERSON
Kenneth Marra
PERSON
Ghislaine Maxwell
PERSON
John F. Kennedy
PERSON
Michael Jackson
PERSON
Alan Dershowitz
PERSONMaria Farmer
PERSON
Atlanta
LOCATION
Lesley Groff
PERSON
Marc Rich
PERSON
Jacksonville
LOCATION
Virginia Giuffre
PERSON