e New York Times—including descriptions of the prosecution’s theory of the case and specific terms of a plea negotiation between the parties. Second, AUSA Villafana attempted to enrich friends and close acquaintances by bringing them business in connection with this matter. Specifically, she attempted to appoint

ention of the parties’ Non Prosecution Agreement—and issued yet another subpoena seeking evidence in this case. See Tab 19, Subpoena In the subpoena, AUSA Villafana directs | appear on July 1, 2008 to give testimony and produce documents to FGJ 07-103 West Palm Beach. The attachment to the subpoena seeks document

n of the parties’ Non Prosecution Agreement—and issued yet another subpoena seeking evidence in this case. See Tab 19, Subpoena to | In the subpoena, AUSA Villafana directs MMMto appear on July 1, 2008 to give testimony and produce documents to FGJ 07-103 West Palm Beach. The attachment to the subpoena seeks docu

atter, will be handled by AUSA Marie Villafana and/or her supervisor, Karen Atkinson, so he does not intend to respond to your e-mail or calls unless AUSA Villafana and/or her supetvisors advise him otherwise. Furthermore, you make reference to “our July 8 deadline.” Respectfully, the United _ States.Attorney’s

Epstein denies that your client is a victim of an enumerated offense, please provide notice of that denial to the undersigned [AUSA]." See Deel. of AUSA Villafana, Exhs. 6 & 7, at 2 (July 9, 2008). The clear implication of the USAO's request (by which the USAO appears to involve itself in the instant litigati

ael Tein, former counsel for Defendant, along with Mr. Jack Goldberger, who still represents Defendant, entered into a verbal agreement at the time AUSA Villafana provided the USAO List to them, whereby neither Defendant, Jeffrey Epstein, nor his agents would have any direct or indirect contact with the victi

of years on probation. Re: The position of the U.S. Attorney's office on early termination of the State's case against Epstein, I again spoke with AUSA Villafana and inquired specifically of any knowledge that she had in reference to representations made by her or anyone associated with her office regarding E

AK --- Case 9:08-cv-80736-KAM Document 19 Entered on FLSD Docket 08/01/2008 Page 7 of 16 assist Jane Doe #1 in avoiding the improper deposition. AUSA Villafana secured pro bono counsel by contacting Meg Garvin, Esq. of the National Crime Victims' Law Institute in Portland, Oregon, which is based in the Lew