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

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

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

pulate that this correspondence accurately reflects communications between Epstein and the Justice Department. 8. At the time of plea discussions, AUSA Villafana had drafted an 82-page prosecution memorandum outlining federal offenses committed by Epstein (including offenses committed against Jane Doe #1 and

n the West Palm Beach office of the U.S. Attorney's Office, and supervised portions of the criminal investigation of Jeffrey Epstein. 8. assisted AUSA Villafana during the criminal investigation of.leffrey Epstein. 9. In his revious capacity as Deputy Chief of the Criminal Division, U.S. Attorney's Office

e year of home confinement. Mr Epstein also made a concession regarding the payment of restitution. All of these terms are set out in a letter that AUSA Villafana is going to send out. Do you have a lawyer? Get name and address. If not where do you want letter sent? If you have questions when you receive the l

e year of home confinement. Mr Epstein also made a concession regarding the payment of restitution. All of these terms are set out in a letter that AUSA Villafana is going to send out. Do you have a lawyer? Get name and address. If not where do you want letter sent? If you have questions when you receive the l

component was involved in the process. For example, at the end of 2006, former SDFL U.S. Attorney and EOUSA Executive Director Guy Lewis contacted AUSA Villafana when he learned that she was handling the federal investigation of Epstein. He asked to meet with her but she said that she believed such a meeting

r legal positions, the risk of litigation, and the government's desire to minimize damaging impeachment evidence of its witnesses. As summarized by AUSA Villafana, the USAO-SDFL made the decision to enter the NPA out of a desire to obtain a guaranteed sentence of incarceration, the equivalent of uncontested r

To the extent that the Government is going to rely on representations about its internal motivations in making certain decisions (i.e., what things AUSA Villafana and the FBI agents "concluded" as part of making decisions), the victims respectfully request an opportunity to depose or cross-examine the relevan

never, ever, ever, no, never. Jeffrey is an awesome man, no. At the end of her interview, [LM] was asked if she had any questions for the agents or AUSA Villafana. [LM] responded: A. No, but I hope — I hope Jeffrey, nothing happens to Jeffrey because he's an awesome man and it would really be a shame. It's a

e year of home confinement. Mr Epstein also made a concession regarding the payment of restitution. All of these terms are set out in a letter that AUSA Villafana is going to send out. Do you have a lawyer? Get name and address. If not where do you want letter sent? If you have questions when you receive the l

in favor of prosecution by the State of Florida . . . ." See In re: Jane Doe, Case No. 08- 80736-CIV-Marra/Johnson (S.D. Fla.) (D.E. 14), Decl. of AUSA Villafana, 07/09/08, ¶ 5, attached hereto as Exhibit "A" (emphasis added). Under the Agreement, the USAO presently retains the continuing right to indict Mr

e year of home confinement. Mr Epstein also made a concession regarding the payment of restitution. All of these terms are set out in a letter that AUSA Villafana is going to send out. Do you have a lawyer? Get name and address. If not where do you want letter sent? If you have questions when you receive the

e year of home confinement. Mr Epstein also made a concession regarding the payment of restitution. All of these terms are set out in a letter that AUSA Villafana is going to send out. Do you have a lawyer? Get name and address. If not where do you want letter sent? If you have questions when you receive the

e year of home confinement. Mr Epstein also made a concession regarding the payment of restitution. All of these terms are set out in a letter that AUSA Villafana is going to send out. Do you have a lawyer? Get name and address. If not where do you want letter sent? If you have questions when you receive the

e year of home confinement. Mr Epstein also made a concession regarding the payment of restitution. All of these terms are set out in a letter that AUSA Villafana is going to send out. Do you have a lawyer? Get name and address. If not where do you want letter sent? If you have questions when you receive the

e year of home confinement. Mr Epstein also made a concession regarding the payment of restitution. All of these terms are set out in a letter that AUSA Villafana is going to send out. Do you have a lawyer? Get name and address. If not where do you want letter sent? If you have questions when you receive the