RE: FW: Request for Written Staff Opinion ATTN Elizabeth Clark Tarbert
Hi Marie,
I have Mike's support for the New York trip (funding may be an issue though). I have the request prepared but need to add dates of travel when we get them. Talk to you later.
Original Message
From: Villafana, Ann Marie C. (USAFLS) Ann.Marie.C.Villafana@usdoj.gov
To: Sloman, Jeff (USAFLS)
Cc: Atkinson, Karen (USAFLS)
Sent: Fri Jun 13 15:06:07 2008
Subject: FW: Call -- Urgent!
Jeff -- Someone really needs to talk to Barry. I am happy to do so, if you want, and I will be very nice about it.
Hi guys — sorry to bother you, but I need this info about Marina asap so I can get the paperwork down to Miami. Thanks.
Birth Date of Witness:
FBI I.D. No.:
Birthplace:
Social Security No.:
Alias:
Address of Witness:
Also, do you have the name and number of the AUSA in New York? I want to run this by him/her first.
Thanks.
A. Marie Villafaffa
AssistantU.S. Attorney
500 S. Australian Ave, Suite 400
West Palm Beach, FL 33401
Phone 561 209-1047
Fax 561 820-8777
Unfortunately, the only info we have for marina is her address. Source info indicates she's from Brazil. There are numerous name matches in ice records. We need to review the a files of the ones that match closest to determine her dob and soc. Any way we could get those particulars through her attorney?(Needed for travel arrangements?)
---- Original Message
From: Villafana, Ann Marie C. (USAFLS) Ann.Marie.C.Villafana@usdoj.gov
To: Richards, Jason R.; Kuyrkendall, E N.
Sent: Tue Jun 17 14:45:31 2008
Subject: Marina
Hi guys - sorry to bother you, but I need this info about Marina asap so I can get the paperwork down to Miami. Thanks.
Birth Date of Witness:
FBI I.D. No.:
Birthplace:
Social Security No.:
Alias:
Address of Witness:
Also, do you have the name and number of the AUSA in New York? I want to run this by him/her first.
Thanks.
A. Marie Villafaha
Assistant U.S. Attorney
500 S. Australian Ave, Suite 400
West Palm Beach, FL 33401
Phone 561 209-1047
Dear Brendan:
I have attached the revised grand jury subpoena along with the list of documents and items that I am hoping Ms. Lacerda can bring with her to the grand jury. I have put 10:30 as the time for the appearance, but our grand jury coordinator will give us a more specific time when we are closer to the date.
I also am preparing the paperwork requesting immunity, and I need to include the following information:
Birth Date of Witness:
FBI I.D. No.:
Birthplace:
Social Security No.:
Alias:
Address of Witness:
I think we will need the same information to do the travel expense authorization, and I would ask that you provide that information to me at your earliest convenience. I do not expect that Ms. Lacerda has an FBI I.D. No. or an alias, but if she does, please include those.
If I receive approval for immunity, would you consider meeting with me and the agents in New York next week
rather than traveling to Florida on July 1m for the grand jury? If you are amenable to that suggestion, please let
me know what days and times you and Ms. Lacerda are available.
Thank you for your assistance.
A. Marie Villafaffa
Assistant U.S. Attorney
500 S. Australian Ave, Suite 400
West Palm Beach, FL 33401
Phone 561 209-1047
Fax 561 820-8777
Dear Ms. Villafana:
I have a call in to Ms. Lacerda for the requested information. I will contact you once I have it.
One concern: I have an appearance In New York State court on Wednesday morning, July 2nd. Will we be able to wrap things up in one day, or would it make sense to pick another date? Let me know what you think. Thanks,
Brendan White
— Original Message ---- From: Villafana. Ann Marie C. (USAFLSI To: Brendan White Cc: Odell, Karen (USAELS1; Ball. Shawn fUSAFLS1 Sent: Tuesday, June 17, 2008 4:01 PM Subject: Grand Jury Appearance
Dear Brendan:
I have attached the revised grand jury subpoena along with the list of documents and items that I am hoping Ms. Lacerda can bring with her to the grand jury. I have put 10:30 as the time for the appearance, but our grand jury coordinator will give us a more specific time when we are closer to the date.
I also am preparing the paperwork requesting immunity, and I need to include the following information:
Birth Date of Witness:
FBI I.D. No.:
Birthplace:
Social Security No.:
Alias:
Address of Witness:
I think we will need the same information to do the travel expense authorization, and I would ask that you provide that information to me at your earliest convenience. I do not expect that Ms. Lacerda has an FBI I.D. No. or an alias, but if she does, please include those.
If I receive approval for immunity, would you consider meeting with me and the agents in New York next week rather than traveling to Florida on July 1*for the grand jury? If you are amenable to that suggestion, please let me know what days and times you and Ms. Lacerda are available.
Thank you for your assistance.
A. Marie VillafaHa
Assistant U.S. Attorney
500 S. Australian Ave, Suite 400
West Palm Beach, FL 33401
Phone 561 209-1047
Dear Mr. White:
If we go forward with the grand jury rather than meeting in New York, I will make certain that you are finished by the early afternoon on July I g.
Thank you.
A. Marie Villafatla
Assistant U.S. Attorney
500 S. Australian Ave, Suite 400
West Palm Reach, FL 33401
Phone 561 209-1047
Fax 561 820-8777
From: Brendan White [mallto:brendan@whlwhl.com] Sent: Tuesday, June 17, 2008 4:43 PM To: Villafana, Ann Marie C. (USAFLS) Subject: Re: Grand Jury Appearance
Dear Ms. Villafana:
I have a call in to Ms. Lacerda for the requested information. I will contact you once I have it.
One concern: I have an appearance in New York State court on Wednesday morning, July 2nd. Will we be able to wrap things up in one day, or would it make sense to pick another date? Let me know what you think. Thanks,
Brendan White
---- Original Message ---- From: Villafana, Ann Marie C. (USAFLSI To: Brendan White Cc: Odell, Karen (USAFLS); Ball Shawn (USAFLS) Sent: Tuesday, June 17, 2008 4:01 PM Subject: Grand Jury Appearance
Dear Brendan:
I have attached the revised grand jury subpoena along with the list of documents and items that I am hoping Ms. Lacerda can bring with her to the grand jury. I have put 10:30 as the time for the appearance, but our grand jury coordinator will give us a more specific time when we are closer to the date.
I also am preparing the paperwork requesting immunity, and I need to include the following information:
Birth Date of Witness:
FBI I.D. No.:
Birthplace:
Social Security No.:
Alias:
Address of Witness:
I think we will need the same information to do the travel expense authorization, and I would ask that you provide that information to me at your earliest convenience. I do not expect that Ms. Lacerda has an FBI I.D. No. or an alias, but if she does, please include those.
If i receive approval for immunity, would you consider meeting with me and the agents in New York next week rather than traveling to Florida on July I d for the grand jury? If you are amenable to that suggestion, please let me know what days and times you and Ms. Lacerda are available.
Thank you for your assistance.
A. Marie Villafalia
Assistant U.S. Attorney
500 S. Australian Ave, Suite 400
West Palm Beach, FL 33401
Phone 561 209-1047
Fax 561 820-8777
Dear Barry:
I just wanted to let you know that Karen and I spoke with Roy Black yesterday regarding the Epstein case. Roy asked whether there was a way to resolve the federal and state litigation simultaneously and mentioned your desire to wrap up the case before you retired. We informed him that the Office's position is that ifEpstein promptly abides by the terms of the signed non-prosecution agreement entered into by the Office and Mr. Epstein, we will end our investigation. If Mr. Epstein chooses to go forward with a different plea in the State, that is his prerogative, but we will consider it a breach of the federal non-prosecution agreement and will proceed accordingly.
The federal non-prosecution agreement signed by Mr. Epstein and his counsel requires Mr. Epstein to plead guilty to the current state indictment and also to an information charging a state offense that requires sex offender registration, specifically the charge of procuring minors to engage in prostitution, at least 18 months imprisonment, and an agreement that the victims can pursue damages claims as though Mr. Epstein had been convicted of the federal offenses. Our agreement does not address probationary periods following the term of incarceration. Those are statutorily set on the federal side, so we have left that issue to the defense to negotiate with you.
If you have any questions, please let me know.
A. Marie Villafafia
Assistant U.S. Attorney
500 S. Australian Ave, Suite 400
West Palm Beach, FL 33401
Phone 561 209-1047
Fax 561 820-8777
Roy, thank you for your response and your assistance. I will forward your request to Dexter Lee, who is representing the United States in the civil suit.
Can you please ask Jack Goldberger to send me an exact copy of what was filed under seal in the state court? I want to insure that all of us are presenting the same packet of documents as the final agreement.
Regards,
Marie
A. Marie Villafaha
Assistant U.S. Attorney
500 S. Australian Ave, Suite 400
West Palm Beach, FL 33401
Phone 561 209-1047
Fax 561 820-8777
Original Message
From: Roy BLACK [mailto:RBLACK@royblack.com]
Sent: Monday, August 11, 2008 11:40 PM
To: Villafana, Ann Marie C. (USAFLS)
Subject: Jeffrey Epstein
Marie: I have conferred with the lawyers on the team. They all thank you for agreeing to oppose any disclosure of the 9/24/07 agreement. We firmly believe this document is not discoverable in the civil cases. However if the court rules against you on this we request that you further ask that any disclosure be subject to a strong protective order prohibiting dissemination to anyone except counsel to the petitioners. We are particularly concerned because civil lawyers are more apt to publicize something like this than those of us who litigate on the criminal side of the docket. You may recall one lawyer standing on the bridge to palm beach railing over his misconceptions of the case. This is the typical vehicle they use to get more plaintiffs. You had also asked what documents were disclosed in the state court. As part of counsels obligation to fully disclose any promises or inducements which led to the plea agreement, the 9/24/07 agreement was filed with the court. It was filed under seal. Once again I want to re-assure you that Mr. Epstein and his counsel intend to stand by their agreements. If you or anyone in the USAO have any concern about a possible breach please call or email me again so we can discuss any dispute or misunderstanding and allay any concerns. Thanks again. Roy
Ili Lanna — Sorry to he a bother, but we need to file our response with the Court this week, so 1really need a
copy of what was filed in your case and also the procedures to obtain the transcript of the change of plea
hearing.
Thank you.
A. Marie Villafaña
Assistant U.S. Attorney
500 S. Australian Ave, Suite 400
West Palm Beach, FL 33401
Phone 561 209-1047
Fax 561 820-8777
It looks like they only filed the original September agreement not either of the addenda.
A. Marie Villafaña
Assistant U.S. Attorney
500 S. Australian Ave, Suite 400
West Palm Beach, FL 33401
Phone 561 209-1047
Fax 561 820-8777
From: Lanna Belohlavek [mailto:Lbelohla@sal5.state.fl.us) Sent: Tuesday, August 12, 2008 11:35 AM To: Villafana, Ann Marie C. (USAFLS) Subject:RE: Non-Prosecution Agreement in Epstein Case
Marie
The 7 page agreement was filed under seal with the attached signature pages.
As to a transcript, you would have to contact court administration and arrange for that together with payment.
Good luck.
From: Villafana, Ann Marie C. (USAFLS) [mailto:Ann.Marle.C.Villafana@usdoj.gov] Sent: Tuesday, July 01, 2008 11:51 AM To: Lanna Belohlavek Cc: Atkinson, Karen (USAFLS) Subject: Non-Prosecution Agreement in Epstein Case
Ili Lanna — I am attaching the agreement, with addenda, for filing with the Court under seal.
We also noticed a couple of "misstatements" during the change of plea and wanted to call them to your attention. First, the Division of Corporations' documents show that the Florida Science Foundation was incorporated in November 2007, not a "couple of years ago" as reported by Mr. Epstein. The address provided for the "office" of the Florida Science Foundation is Jack Goldberger's office suite, and neither the office building directory nor the office suite door reflects that such a business is located there, and neither the security guard nor any building tenant that FBI questioned knows of the existence of such a business. And, of course, Mr. Epstein could not have been working there "every day" when he hasn't been in Palm Beach County in the past six months.
We will leave it to your discretion as to whether this should be brought to the Court’s attention.
<
A. Marie Villaña
Hi Roy -- Can you give me a call? We need to discuss something.
A. Marie Villafana
Assistant U.S. Attorney
500 S. Australian Ave, Suite 400
West Palm Beach, FL 33401
Phone 561 209-1047
Fax 561 820-8777
Original Message
From: Roy BLACK [mailto:RBLACK@royblack.com]
Sent: Monday, August 11, 2008 11:40 PM
To: Villafana, Ann Marie C. (USAFLS)
Subject: Jeffrey Epstein
Marie: I have conferred with the lawyers on the team. They all thank you for agreeing to oppose any disclosure of the 9/24/07 agreement. We firmly believe this document is not discoverable in the civil cases. However if the court rules against you on this we request that you further ask that any disclosure be subject to a strong protective order prohibiting dissemination to anyone except counsel to the petitioners. We are particularly concerned because civil lawyers are more apt to publicize something like this than those of us who litigate on the criminal side of the docket. You may recall one lawyer standing on the bridge to palm beach railing over his misconceptions of the case. This is the typical vehicle they use to get more plaintiffs. You had also asked what documents were disclosed in the state court. As part of counsels obligation to fully disclose any promises or inducements which led to the plea agreement, the 9/24/07 agreement was filed with the court. It was filed under seal. Once again I want to re-assure you that Mr. Epstein and his counsel intend to stand by their agreements. If you or anyone in the USAO have any concern about a possible breach please call or email me again so we can discuss any dispute or misunderstanding and allay any concerns. Thanks again. Roy
The clerk's office finally unsealed Tein's reply brief in the Epstein civil litigation. While the agreement was not filed with the court, Tein quotes extensively from the agreement. He also describes the agreement as "a highly unusual and unprecedented deferred-prosecution agreement."
I still have not heard back from Roy Black regarding the agreement that the defense filed with the state court.
DE38_080812_R
ply re Motn to S.
A. Marie Villafafia
Assistant U.S. Attorney
500 S. Australian Ave, Suite 400
West Palm Beach, FL 33401
Phone 561 209-1047
Fax 561 820-8777
Ili Bob — Karen and I are doing a conf call with Roy at 4:15. Can you give me a call before then? Thanks.
A. Marie Villafana
Assistant U.S. Attorney
500 S. Australian Ave, Suite 400
West Palm Beach, FL 33401
Phone 561 209-1047
Fax 561 820-8777
Here is the correspondence that I just faxed to Jay.
Bob — Karen and I will call you tomorrow morning before we speak with Jay.
FOR
Lefkowitz
080813008.pdf
A. Marie Villafaña
Assistant Attorney [ ]
561 209-1047
Jay — Here is a scanned version of the fax, in case you have already left.
Lefkowitz
080813008.pdf
A. Marie Yillafacia
Assistant U.S. Attorney
500 S. Australian Ave, Suite 400
West Palm Beach, FL 33401
Phone 561 209-1047
Fax 561 820-8777
Thx Marie - speak tomorrow. I will call you around 1130-1200.
Jay
From: "Villafana, Ann Marie C. (USAFLS)" [Ann.Marie.C.Villafana@usdoj.gov]
Sent: 08/13/2008 06:20 PM AST
To: Jay Lefkowitz
Cc: "Roy BLACK" <RBLACK®royblack.cony
Subject: Electronic Copy ofmy Fax
Jay - Here is a scanned version of the fax, in case you have already left.
<<Lefkowitz 080813008.pdf>>
A. Marie Villafaña
Assistant U.S. Attorney
500 S. Australian Ave, Suite 400
West Palm Beach, FL 33401
Phone 561 209-1047
Fax 561 820-8777
The information contained in this communication is confidential, may be attorney-client privileged, may constitute inside information, and is intended only for the use of the addressee. It is the property of Kirkland & Ellis LLP or Kirkland & Ellis International LLP. Unauthorized use, disclosure or copying of this communication or any part thereof is strictly prohibited and may be unlawful. If you have received this communication in error, please notify us immediately by return e-mail or by e-mail to postmaster@kirkland.com, and destroy this communication and all copies thereof, including all attachments.
Hi Bob — Just talked to Dexter and he disagrees with our strategy. He is going to call and explain his reasoning. Here are the three documents.
POF
Epstein
Agrmt00 .pdf
A. Marie Villafaha
Assistant U.S. Attorney
500 S. Australian Ave, Suite 400
West Palm Beach, FL 33401
Phone 561 209-1047
Fax 561 820-8777
Alex and Jeff,
We have a status conference with Judge Marra today at 3:30 p.m. When Marie and I met with Brad Edwards last Thursday, we agreed there was no need for an evidentiary hearing. He did want the government to disclose the non-prosecution agreement with Epstein and any Report of Interview conducted with C.W. when the FBI agents met with her in October 2007.
The government filed a response stating that it could not voluntarily disclose the non-prosecution agreement since it contained a confidentiality clause. As to the Report of Interview, we stated that no such document existed. Epstein's counsel has requested that, if the agreement is disclosed pursuant to a court order, that disclosure be accomplished pursuant to a protective order which would prevent further dissemination by Edwards.
Marie spoke with Edwards yesterday, and he agreed that a protective order could be issued by the Court. I anticipate that the parties will advise Judge Marra that (1) no evidentiary hearing is desired by either party; (2) the government will provide petitioners with a copy of the non-prosecution agreement, subject to an agreed protective order entered by the Court; and (3) the parties will enter into a stipulation of dismissal without prejudice.
As to the non-prosecution agreement, I understand there is now a dispute over what constitutes the Agreement. I believe we should provide to Edwards the original agreement, the addendum, and the December 2007 letter, and advise him and the Court that there is currently a dispute over what constitutes the Agreement. I do not believe it to be appropriate for either the government or the victims to ask Judge Marra to resolve the dispute over what constitutes the Agreement, in the context of a lawsuit seeking enforcement of the Crime Victims Rights Act. The only dispute before the Court is whether rights under 18 U.S.C. 3771(a) were violated by the Government when it negotiated the non-prosecution agreement with Epstein. Epstein is not a party to this action, so it is unlikely Judge Marra would hear any dispute over the Agreement when one of the parties is absent from the litigation. The appropriate forum for litigating any dispute over the Agreement is when one of the parties acts in a fashion which the other believes is a breach of the Agreement, and takes action which the other party believes is improper.
Dexter
Hi Roy — Sorry to bother you early in the morning. Jay Lefkowitz is supposed to call soon to discuss the agreement. We would prefer to have you on the call as well.
A. Marie Villafafla
Assistant U.S. Attorney
500 S. Australian Ave, Suite 400
West Palm Beach, FL 33401
Phone 561 209-1047
Fax 561 820-8777
Hi Jay — Can you give me a specific time for the call so that i can conference call you and Karen?
Thank you.
A. Marie Villafaila
Assistant U.S. Attorney
500 S. Australian Ave, Suite 400
West Palm Beach, FL 33401
Phone 561 209-1047
Fax 561 820-8777
Fine.
A. Marie Villafafla
Assistant U.S. Attorney
500 S. Australian Ave, Suite 400
West Palm Beach, FL 33401
Phone 561 209-1047
Fax 561 820-8777
From:Jay Lefkowltz [mallto:JLetkowItz@ldrkland.com]
Sent: Thursday, August 14, 2008 12:26 PM
To: Villafana, Ann Marie C. (USAFLS)
Cc: Atkinson, Karen (USAFLS)
Subject: Re: Telephone Call
How about 10 minutes?
From: "Villafana, Ann Marie C. (USAFLS)" [Ann.Marie.C.Villafana@usdoj.gov]
Sent: 08/14/2008 12:19 PM AST
To: Jay Leflcowitz
Cc: "Atkinson, Karen (USAFLS)" JCaren.Atkinson@usdoj.gov
Subject: Telephone Call
Hi Jay — Can you give me a specific time for the call so that I can conference call you and Karen?
Thank you.
A. Marie Villafaña
Assistant U.S. Attorney
500 S. Australian Ave, Suite 400
West Palm Beach, FL 33401
Phone 561 209-1047
Fax 561 820-8777
Hi Jay — I forgot to mention that I can no longer argue that the Court shouldn't force us to produce the agreement because we have already provided the victims with the relevant portion when I now understand from you that I have NOT provided them with the relevant portion.
A. Marie Villafaila
Assistant U.S. Attorney
500 S. Australian Ave, Suite 400
West Palm Beach, FL 33401
Phone 561 209-1047
Fax 561 820-8777
Karen and I just finished up with Jay. It is his position that "the agreement is the agreement" and that Tein and Goldberger's actions after Jeffrey entered his guilty plea cannot modify the agreement. He then said, well, this isn't ripe anyway and it won't be until a victim files suit and tries to enforce the agreement.
I said, no, it is ripe now in two ways. First, Judge Marra is probably going to order us to produce the agreement and we need to provide him with a document. Second, if December isn't in effect we am back to October and I need to supplement my list of victims and we need to get a Special Master to appoint an attorney to represent the girls who currently are unrepresented. He tried to push that off but 1 said, no, we need to do this right away.
So, he says he is going to call Jeffrey and get back to me before our 3:30 hearing with Judge Marra.
A. Marie Villafaila
Assistant U.S. Attorney
500 S. Australian Ave, Suite 400
West Palm Beach, FL 33401
Phone 561 209-1047
Fax 561 820-8777
Marie - In reviewing your December proposal, there are a couple of things I don't understand.
What limits are placed upon individuals who proceed under 2255 as if "Mr. Epstein had been tried federally and convicted of an enumerated offense." In other words, what individuals would have this right? And would these individual only have this right if they proceeded exclusively under 2255? Also, to what enumerated offenses do you think would Mr. Epstein have to make constructive admissions of conviction? and how many such offenses? And against whom? Remember that while you may have investigated various offenses, he only plead guilty to certain state crimes.
Finally, would paragraphs 8-10 of the September Agreement still be operative?
I am trying hard to understand what you have intended by the December letter. Alex has says he thinks it benefits Jeffrey, and I am open to understanding it that way. But I would like some clarity on these issues.
Thanks -- Jay
"Villafana, Ann Marie C. (USAFLS)"
Ann.Marie.C.Villafana@usdoj.gov
08/14/2008 12:44 PM
To lefkowitz@kirkland.com
cc "Atkinson, Karen (USAFLS)" Karen.Atkinson@usdoj.gov
Subject Follow-up point
f fi Jay — I forgot to mention that I can no longer argue that the Court shouldn't force us to produce the agreement because we have already provided the victims with the relevant portion when I now understand from you that I have NOT provided them with the relevant portion.
A. Marie Villafaña
Assistant U.S. Attorney
500 S. Australian Ave, Suite 400
West Palm Reach, FL 33401
Phone 561 209-1047
Fax 561 820-8777
The information contained in this communication is
confidential, may be attorney-client privileged, may
constitute inside information, and is intended only for the use of the addressee. It is the property of Kirkland & Ellis LLP or Kirkland & Ellis International LLP. Unauthorized use, disclosure or copying of this communication or any part thereof is strictly prohibited and may be unlawful. If you have received this communication in error, please notify us immediately by return e-mail or by e-mail to postmaster@kirkland.com, and
Ahh, the plot thickens. Apparently December is looking better than October.
I will drag a response and send to you shortly.
A. Marie Villafafia
Assistant U.S. Attorney
500 S. Australian Ave, Suite 400
West Palm Beach, FL 33401
Phone 561 209-1047
Fax 561 820-8777
From: Jay Lefkowltz (mailto:3LefRowit@kirkland.comj Sent: Thursday, August 14, 2008 2:39 PM To: Villafana, Ann Marie C. (USAFLS) Cc: Atkinson, Karen (USAFLS); lefkowitz@klrkland.com Subject: Re: Follow-up point
Marie - In reviewing your December proposal, there are a couple of things I don't understand.
What limits are placed upon individuals who proceed under 2255 as if "Mr. Epstein had been tried federally and convicted of an enumerated offense." In other words, what individuals would have this right? And would these individual only have this right if they proceeded exclusively under 2255? Also, to what enumerated offenses do you think would Mr. Epstein have to make constructive admissions of conviction? and how many such offenses? And against whom? Remember that while you may have investigated various offenses, he only plead guilty to certain state crimes.
Finally, would paragraphs 8-10 of the September Agreement still be operative?
I am trying hard to understand what you have intended by the December letter. Alex has says he thinks it benefits Jeffrey, and I am open to understanding it that way. But I would like some clarity on these issues.
Thanks -- Jay
"Villafana, Ann Marie C. (USAFLS)"
Ann.Marie.C.Villafana@usdoj.gov
To lefkowitz@kirkland.com>
cc "Atkinson, Karen (USAFLS)" <Karen Atkinson@usdoj.gov>
Subject Follow-up point
08/14/2008 12:44 PM
I-li Jay — I forgot to mention that I can no longer argue that the Court shouldn't force us to produce the agreement because we have already provided the victims with the relevant portion when I now understand from you that I have NOT provided them with the relevant portion.
Hereis my proposed response.
Dear Jay:
Pursuant to the December letter, only those "individuals whom [the United States] was prepared to name in an Indictment as victims of an enumerated offense" are the beneficiaries of the agreement. That is the list of names that I provided to Messrs. Goldberger and Tein following the change of plea. Under the September/October agreement, all "individuals whom [the United States] has identified as victims" are the beneficiaries, so 1 would prepare a supplement to the earlier list to include identified victims whom we were not yet prepared to name in an indictment.
The December modification replaces paragraphs 7 and 8 of the Agreement, including paragraphs 7A through 7C that are included in the October Addendum. This means that Mr. Epstein's waiver of "his right to contest damages up to an amount as agreed to between the identified individual and Epstein" will no longer exist, nor will Mr. Epstein's obligation to pay for the victims' counsel. Paragraphs 9 and 10 are still in effect. This includes the statement that there is no admission of civil or criminal liability, and that, "[e]xcept as to those individuals who elect to proceed EXCLUSIVELY under 18 USC § 2255, ... Epstein's signature [cannot] be construed as admissions or evidence of civil or criminal liability." I believe that this means that Mr. Epstein's agreement that the individuals on our list are "victims" as defined by statute applies only if the victims proceed exclusively under 18 USC 2255.
I don't think that Mr. Epstein has to make any constructive admissions of conviction. He only needs to admit that the 32 girls whose names 1 have provided to Mr. Goldberger are "victims" of an offense listed in 18 U.S.C. 2255.
Please let me know if you have any additional questions. Thank you.
A. Marie Mafia&
Assistant U.S. Attorney
500 S. Australian Ave, Suite 400
West Palm Beach, FL 33401
Phone 561 209-1047
Fax 561 820-8777
From: Jay Lefkowltz [mallto:JLelkowilz@kirkland.com] Sent: Thursday, August 14, 2008 2:39 PM To: Villafana, Ann Made C. (USAFLS) Cc: Atkinson, Karen (USAFLS); leflwwitz@ldrldand.com Subject: Re: Follow-up point
Marie - In reviewing your December proposal, there are a couple of things I don't understand.
Just received a response from Jay. I'm not sure what he means about talking "this morning," since I haven't spoken to him today.
I don't believe that we should wait two weeks for them to confer. They have the ability to confer over the telephone or to come and visit him (as reported in the Palm Beach Post).
Here is my proposed response:
Dear Jay:
Thank you for your response. It is our position that Mr. Epstein accepted the December modification by his performance. If you prefer to return to the language of the October addendum, we have no objection, but, as you know, I have been ordered to produce the Non-Prosecution Agreement and I cannot wait two weeks to do so. Please advise me by noon on Monday in writing, preferably signed by your client, whether Mr. Epstein intends to perform according to the terms of the December modification or whether he elects to return to the October addendum.
If Mr. Epstein elects to perform according to the terms of the October addendum, then please prepare a proposed written submission to the Special Master, in accordance with Paragraph 7B, for my review by Monday afternoon. The extensive delays of the past will no longer be tolerated, and the Office will insist upon a showing of good faith performance in the selection of the attorney representative and all other terms of the Agreement.
Sincerely,
Marie
A. Marie Villafalia
Assistant U.S. Attorney
500 S. Australian Ave, Suite 400
West Palm Beach, FL 33401
Phone 561 209-1047
Fax 561 820-8777
From: Jay Lefkowltz (mailtoaefkowitzOldridand.com] Sent: Friday, August 15, 2008 10:53 AM To: Villafana, Ann Mane C. (USAF-LS) Cc: Atkinson, Karen (USAFLS); Roy BLACK; Martin Weinberg Subject: Re: Follow-up point
Marie - thanks for responding to my email. You have narrowed down some of the implementation issues.
As I told you this morning, we cannot accept your contention that Mr. Epstein is bound by an agreement he
Are we really proposing the Special Master? Is he still on board?
I thought we had said that compliance with that was an impossibility given the passage of time?
From: Villafana, Ann Marie C. (USAFLS) Sent: Friday, August 15, 2008 11:08 AM To: Acosta, Alex (USAFLS); Sloman, Jeff (USAFLS); Senior, Robert (USAFLS); Atkinson, Karen (USAFLS); Lee, Dexter (USAFLS) Subject: PM: Follow-up point
Just received a response from Jay. I'm not sure what he means about talking "this morning," since 1 haven't spoken to him today.
1 don't believe that we should wait two weeks for them to confer. They have the ability to confer over the telephone or to come and visit him (as reported in the Palm Beach Post).
Here is my proposed response:
Dear Jay:
Thank you for your response. It is our position that Mr. Epstein accepted the December modification by his performance. If you prefer to return to the language of the October addendum, we have no objection, but, as you know, I have been ordered to produce the Non-Prosecution Agreement and I cannot wait two weeks to do so. Please advise me by noon on Monday in writing, preferably signed by your client, whether Mr. Epstein intends to perform according to the terms of the December modification or whether he elects to return to the October addendum.
If Mr. Epstein elects to perform according to the terms of the October addendum, then please prepare a proposed written submission to the Special Master, in accordance with Paragraph 7B, for my review by Monday afternoon. The extensive delays of the past will no longer be tolerated, and the Office will insist upon a showing of good faith performance in the selection of the attorney representative and all other terms of the Agreement.
Sincerely,
Marie
A. Marie VillafaFia
Assistant U.S. Attorney
500 S. Australian Ave, Suite 400
West Palm Beach, FL 33401
Phone 561 209-1047
Fax 561 820-8777
We either have to do the October Agreement or the December Agreement, I don't think we can let them get away with doing neither. Two-thirds of the victims do not have any representation.
The language of the agreement gives us the right to select the Special Master, and we should choose someone quickly. We then have to create a written submission, and we should give them a very short time frame to do so. If we keep their feet to the fire, this can be completed within a week.
A. Marie Villafaha
Assistant U.S. Attorney
500 S. Australian Ave, Suite 400
West Palm Beach, FL 33401
Phone 561 209-1047
Fax 561 820-8777
From: Acosta, Alex (USAFLS) Sent: Friday, August 15, 2008 11:12 AM To: Villafana, Ann Marie C. (USAFLS); Sloman, Jeff (USAFLS); Senior, Robert (USAFLS); Atkinson, Karen (USAFLS); Lee, Dexter (USAFLS) Subject: RE: Follow-up point
Are we really proposing the Special Master? Is he still on board?
I thought we had said that compliance with that was an impossibility given the passage of time?
From: Villafana, Ann Marie C (USAFLS) Sent: Friday, August 15, 2008 11:08 AM To: Acosta, Alex (USAFLS); Sloman, Jeff (USAFLS); Senior, Robert (USAFLS); Atkinson, Karen (USAFLS); Lee, Dexter (USAFLS) Subject: FW: Follow-up point
Just received a response from Jay. I'm not sure what he means about talking "this morning," since I haven't spoken to him today.
I don't believe that we should wait two weeks for them to confer. They have the ability to confer over the telephone or to come and visit him (as reported in the Palm Beach Post).
Here is my proposed response:
Dear Jay:
Thank you for your response. It is our position that Mr. Epstein accepted the December modification by his performance. If you prefer to return to the language of the October addendum, we have no objection, but, as you know, I have been ordered to produce the Non-Prosecution Agreement and I cannot wait two weeks to do so. Please advise me by noon on Monday in writing, preferably signed by your client, whether Mr. Epstein intends to perform according to the terms of the December modification or whether he elects to return to the October addendum.
If Mr. Epstein elects to perform according to the terms of the October addendum, then please prepare a proposed written submission to the Special Master, in accordance with Paragraph 7B, for my review by Monday afternoon. The extensive delays of the past will no longer be tolerated, and the Office will insist upon a showing of good faith performance in the selection of the attorney representative and all other terms of the Agreement.
Sincerely,
Marie
A. Marie Villafaha
Assistant U.S. Attorney
500 S. Australian Ave, Suite 400
West Palm Beach, FL 33401
Phone 561 209-1047
Fax 561 820-8777
Brad,
Attached please find a draft protective order regarding the disclosure of the non-prosecution agreement to you and Jane Does 1 and 2. Please let us know if there are any changes you wish to make. Thanks.
Dexter
Protective
Order.doc
Dear Jay:
Thank you for your response. Our communications with Roy Black and later with you were solely to determine what Mr. Epstein considered to be the terms of the Non-Prosecution Agreement. You have now made clear that Mr. Epstein did not accept the December modification and does not intend to perform the obligations set forth therein. The Office is not going to continue negotiating the terms of the Agreement. We only sought finality and you have answered our question. Accordingly, the December proposed modification is hereby withdrawn.
The United States has been ordered to produce the Non-Prosecution Agreement and, in accordance with that Order, will produce the September Agreement with the October Addendum signed by your client. Mr. Goldberger should be advised that we understand he has not provided the state court with a true copy of the complete Agreement, and he should take steps to correct that error. I will prepare an Amended Notification that contains the name of additional identified victims and will provide that to you promptly.
In accordance with Paragraph 7B of the Agreement, please provide me with a proposed written submission to the Special Master by Monday afternoon. We will expect a showing of good faith in the selection of the attorney representative and all other terms of the Agreement and excessive delays, like those that have occurred in the past, will be considered a breach of that duty of good faith.
Sincerely,
A. Marie Villajaltia
Assistant U.S. Attorney
500 S. Australian Ave, Suite 400
West Palm Beach, FL 33401
Phone 561 209-1047
Fax 561 820-8777
Marie,
This Is Brad's version of the protective order. It says more than it needs to, and is really more than a protective order.
Dexter
From: Brad Edwards [mailto:be@bradedwardslaw.com]
Sent: Friday, August 15, 2008 11:39 AM
To: Lee, Dexter (USAFLS)
Subject:
Hi Dexter,
Take a look at the Protective order and let me know if you agree with the language. I would like to get this filed today if possible. If you have any questions or want to discuss anything, I am in the office until 2:30 so feel free to call. Thanks
Brad Edwards, Esquire
Law Office of Brad Edwards & Associates
2028 Street
Suite 202
Hollywood, Florida 33020
Telephone: 954-414-8033 (Broward)
305-935-2011 (Miami-Dade)
Facsimile: 954-924-1530(Broward)
305/9354227 (Miami-Dade)
e-mail: be®bradedwardslaw.com
PRIVILEGED AND CONFIDENTIAL: The information contained in this e-mail message is intended for the use of the individual or entity to which it is
addressed and may contain information that is proprietary, privileged, confidential, and exempt from disclosure under applicable laws. If the reader of this
message is not the intended recipient, or the employee or agent responsible for delivery to the intended recipient, you are hereby notified that any use, printing,
reproduction, disclosure or dissemination of this communication may be subject to legal restriction or sanction.
How about a slightly different version:
Thank you for your response. Our communications with Roy Black and later with you were solely to determine what Mr. Epstein considered to be the terms of the Non-Prosecution Agreement. We appreciate your answering our question with finality. You have now made clear that Mr. Epstein did not accept the December modification, and accordingly, we will now consider that modification to be a nullity.
Pursuant to our Agreement, I will prepare an Amended Notification that contains the name of additional identified victims. In accordance with Paragraph 7B, please provide me with a proposed written submission to the Special Master by Monday afternoon.
Finally, as you are aware, yhe United States has been ordered to produce the Non-Prosecution Agreement. In accordance with that Order, we will produce the September Agreement with the October Addendum signed by your client. We understand that Mr. Goldberg may not have provided the state court with a true copy of the complete Agreement, and he should take steps to correct that error.
From: Villafana, Ann Marie C. (USAFLS) Sent: Friday, August 15, 2008 11:42 AM
To: Acosta, Alex (USAFLS); Sloman, Jeff (USAFLS); Senior, Robert (USAFLS); Lee, Dexter (USAFLS); Atkinson, Karen (USAFLS)
Subject: New proposed response to Jay
Dear Jay:
Thank you for your response. Our communications with Roy Black and later with you were solely to determine what Mr. Epstein considered to be the terms of the Non-Prosecution Agreement. You have now made clear that Mr. Epstein did not accept the December modification and does not intend to perform the obligations set forth therein. The Office is not going to continue negotiating the terms of the Agreement. We only sought finality and you have answered our question. Accordingly, the December proposed modification is hereby withdrawn.
The United States has been ordered to produce the Non-Prosecution Agreement and, in accordance with that Order, will produce the September Agreement with the October Addendum signed by your client. Mr. Goldberger should be advised that we understand he has not provided the state court with a true copy of the complete Agreement, and he should take steps to correct that error. I will prepare an Amended Notification that contains the name of additional identified victims and will provide that to you promptly.
In accordance with Paragraph 7B of the Agreement, please provide me with a proposed written submission to the Special Master by Monday afternoon. We will expect a showing of good faith in the selection of the attorney representative and all other terms of the Agreement and excessive delays, like those that have occurred in the past, will be considered a breach of that duty of good faith.
Sincerely,
A. Marie Villafaha
Assistant U.S. Attorney
500 S. Australian Ave, Suite 400
West Palm Beach, FL 33401
Phone 561 209-1047
Fax 561 820-8777
This is my proposed Order. I think it comports with the Judge's order from yesterday and I think it is slightly more thorough. It is very similar to your Motion. If you are more satisfied with your wording or layout for the motion, then please incorporate the additional points made in my proposed order.
My only real problem with your proposed Order is paragraph C. This just further delays us from getting the agreement, and I do not believe the Judge placed this burden on us. I think, as I wrote in my proposed order, that it is my duty to instruct my clients on the protective order and its function and to otherwise ensure that it is not violated by my clients. Getting my clients to "acknowledge receipt of the order and agree to its terms" could take awhile and cause unnecessary delay. I plan to talk to my clients about "the agreement" and at the same time instruct them as to the rules outlined in the protective order. That is all the Judge indicated as needed to be done.
From: Lee, Dexter (USAFLS) [mallto:Dexter.Lee@usdoj.gov] Sent: Friday, August 15, 2008 11:41 AM To: Brad Edwards Cc: Villafana, Ann Marie C. (USAFLS) Subject: Draft Protective Order
Brad,
Attached please find a draft protective order regarding the disclosure of the non-prosecution agreement to you and Jane Does 1 and 2. Please let us know if there are any changes you wish to make. Thanks.
Dexter
<
Hey Dexter — I am going to leave this to you, if that is alright. I know it is difficult when too many cooks get involved.
A. Marie Villafana
Assistant U.S. Attorney
500 S. Australian Ave, Suite 400
West Palm Beach, FL 33401
Phone 561 209-1047
Fax 561 820-8777
From: Brad Edwards [mailto:be@bradedwardslaw.com] Sent: Friday, August 15, 2008 11:59 AM To: Lee, Dexter (USAFLS) Cc: Villafana, Ann Marie C. (USAFLS); Paul Cassell Subject: RE: Draft Protective Order
This is my proposed Order. I think it comports with the Judge's order from yesterday and I think it is slightly more thorough. It is very similar to your Motion. If you are more satisfied with your wording or layout for the motion, then please incorporate the additional points made in my proposed order.
My only real problem with your proposed Order is paragraph C. This just further delays us from getting the agreement, and I do not believe the Judge placed this burden on us. I think, as I wrote in my proposed order, that it is my duty to instruct my clients on the protective order and its function and to otherwise ensure that it is not violated by my clients. Getting my clients to "acknowledge receipt of the order and agree to its terms" could take awhile and cause unnecessary delay. I plan to talk to my clients about "the agreement" and at the same time instruct them as to the rules outlined in the protective order. That is all the Judge indicated as needed to be done.
From: Lee, Dexter (USAFLS) [mailto:Dexter.Lee@usdolgov] Sent: Friday, August 15, 2008 11:41 AM To: Brad Edwards Cc: Villafana, Ann Marie C. (USAFLS) Subject: Draft Protective Order
Brad,
Attached please find a draft protective order regarding the disclosure of the non-prosecution agreement to you and Jane Does 1 and 2. Please let us know if there are any changes you wish to make. Thanks.
Dexter
<
Hi Jeff — Two things on the special master issue:
I. Did Epstein's attorneys and you ever finalize a "joint written statement"? If so, I don't think we should give them the opporttalto fiddle with it again.
- Do you think Judge will be willing to give it another go? If not, any thoughts?
Thanks.
A. Marie Villafana
Assistant U.S. Attorney
500 S. Australian Ave, Suite 400
West Palm Beach, FL 33401
Phone 561 209-1047
Fax 561 820-8777
Hello Dexter and Ann Marie,
First, I don't know if we've been formally introduced. Nice to meet you ... electronically at least.
Second, on the language -- As Brad mentioned, we need to see this document quite quickly in view of the Government's representations yesterday that Epstein is trying to ignore the agreement. As a result - - and in view of the difficulty of making immediate contact with our clients -- I propose one change. Instead of this:
Prior to producing the documents to Petitioners' counsel, a copy of this Order must be provided to counsel and their clients, who must review and acknowledge their receipt of and agreement to abide by the tams of this Order, and who must provide a copy of that acknowledgment to the USAO.
How about this:
Before counsel for Petitioner's show the agreement to their clients or discuss the specific terms with them, they must provide a copy of this Order to Petitioners, who must review and acknowledge their receipt of and agreement to abide by the terms of this Order. Counsel for Petitioner's must promptly provide a copy of that acknowledgment to the USAO.
I assume that the USAO is not concerned about us as attorneys somehow ignoring the Court's protective order, so this change would focus in on the non-law trained clients.
Paul G. Cassell
Ronald M. Boyce Presidential Professor of Law
S. J. Quinney College of Law
University of Utah
332 South 1400 East, Room 101
Sall Lake City, UT 84112
(801) 585-5202
casselloralaw.utah.edu
Judge Cassell and Brad,
I have incorporated the change suggested by Judge Cassell to paragraph (c). I also added language in paragraph (e), referring to other victims, which also provides for petitioners' counsel to promptly provide a copy of the acknowledgment to the U.S. Attorney's Office. The government has no doubts that counsel for petitioners will ensure the authorized recipients are aware of the protective order and agree to abide by it, prior to disclosure. We do not require the acknowledgment in writing prior to the non-prosecution agreement being disclosed to an authorized recipient.
We believe the petitioners' proposed protective order goes well beyond what is at issue, the government's disclosure of the non-prosecution agreement, conditioned on limited dissemination of the document upon receipt by petitioners. Consequently, we believe the attached proposed order, incorporating your revisions, Is appropriate for the task at hand. Thanks.
Dexter
From: Paul Cassell [mailto:cassellp@LAW.UTAH.EDU] Sent: Friday, August 15, 2008 12:21 PM To: Brad Edwards; Lee, Dexter (USAFLS) Cc Villafana, Ann Marie C. (USAFLS) Subject: RE: Draft Protective Order - slight tweak
Hello Dexter and Ann Marie,
First, I don't know if we've been formally introduced. Nice to meet you ... electronically at least.
Second, on the language -- As Brad mentioned, we need to see this document quite quickly in view of the Government's representations yesterday that Epstein is trying to ignore the agreement. As a result - - and in view of the difficulty of making immediate contact with our clients -- I propose one change. Instead of this:
Prior to producing the documents to Petitioners' counsel, a copy of this Order must be provided to counsel and their clients, who must review and acknowledge their receipt of and agreement to abide by the terms of this Order, and who must provide a copy of that acknowledgment to the USAO.
How about this:
Before counsel for Petitioner's show the agreement to their clients or discuss the specific terns with them, they must provide a copy of this Order to Petitioners, who must review and acknowledge their receipt of and agreement to abide by the terms of this Order. Counsel for Petitioner's must promptly provide a copy of that acknowledgment to the USAO.
I assume that the USAO is not concerned about us as attorneys somehow ignoring the Court's protective order, so this change would focus in on the non-law trained clients.
Paul G. Cassell
Ronald M. Boyce Presidential Professor of Law
S. J. Quinney College of Law
University of Utah
332 South 1400 East, Room 101
Sall Lake City, UT 84112
(801) 585-5202
casselloralaw.utah.edu
It looks ok. Go ahead and submit it. While we would disagree with your statement that our proposed order goes well beyond what is at issue, since it actually covers very thoroughly the ruling by Judge Marra yesterday, at this point we feel that time is of the essence and we will agree with you submitting your proposed order as is. I think we all heard Judge Marra and are thus all clear as to the terms of the protective order and what is required.
I would prefer that there is some language that the protective order is entered without prejudice to petitioners (seems like it would go in paragraph b), but if you are unable to incorporate it in your order, then I am sure there is a record from yesterday that could be used to help us get relief from the protective order at a later hearing. Anyway, thanks for preparing the order. We will look out for the "agreement". Thanks
From: Lee, Dexter (USAFLS) [mailto:Dexter.Lee@usdoj.gov] Sent: Friday, August 15, 2008 1:24 PM To: Paul Cassell; Brad Edwards Cc: Villafana, Ann Marie C. (USAFLS) Subject: RE: Draft Protective Order - slight tweak
Judge Cassell and Brad,
I have incorporated the change suggested by Judge Cassell to paragraph (c). I also added language in paragraph (e),
referring to other victims, which also provides for petitioners' counsel to promptly provide a copy of the
acknowledgment to the U.S. Attorney's Office. The government has no doubts that counsel for petitioners will ensure
the authorized recipients are aware of the protective order and agree to abide by it, prior to disclosure. We do not
require the, acknowledgment in writing prior to the non-prosecution agreement being disclosed to an authorized
recipient.
We believe the petitioners' proposed protective order goes well beyond what is at issue, the government's disclosure of the non-prosecution agreement, conditioned on limited dissemination of the document upon receipt by petitioners. Consequently, we believe the attached proposed order, incorporating your revisions, is appropriate for the task at hand. Thanks.
Dexter
From: Paul Cassell [mallto:cassellp@tAW.UTAH.EDU] Sent: Friday, August 15, 2008 12:21 PM To: Brad Edwards; Lee, Dexter (USAFLS) Cc: Villafana, Ann Marie C. (USAFLS) Subject:RE: Draft Protective Order - slight tweak
Hello Dexter and Ann Marie,
First, I don't know if we've been formally introduced. Nice to meet you ... electronically at least.
Second, on the language -- As Brad mentioned, we need to see this document quite quickly in view of the Government's representations yesterday that Epstein is trying to ignore the agreement. As a result - - and in view of the difficulty of making immediate contact with our clients -- I propose one change. Instead of this:
Prior to producing the documents to Petitioners' counsel, a copy of this Order must be provided to counsel and their clients, who must review and acknowledge their receipt of and agreement to abide by the terms of this Order, and who must provide a copy of that acknowledgment to the USAO.
How about this:
Before counsel for Petitioner's show the agreement to their clients or discuss the specific terms with them, they must provide a copy of this Order to Petitioners, who must review and acknowledge their receipt of and agreement to abide by the terms of this Order. Counsel for Petitioner's must promptly provide a copy of that acknowledgment to the USAO.
I assume that the USAO is not concerned about us as attorneys somehow ignoring the Court's protective order, so this change would focus in on the non-law trained clients.
Paul G.Cassell
Ronald M. Boyce Presidential Professor of Law
S. J. Quinney College of Law
University of Utah
332 South 1400 East, Room 101
Salt Lake City, UT 84112
(801) 585-5202
cassellpelaw.utah.edu
Dear Ms. Tarbert — Is there any update on my Ethics inquiry of September 18d17 We have located additional victims and I would like to send notifications to them.
Thank you.
A. Marie Villafafia
Assistant U.S. Attorney
500 S. Australian Ave, Suite 400
West Palm Beach, FL 33401
Phone 561 209-1047
Fax 561 820-8777
From: MAIL [mallto:MAIL@flabar.org] on Behalf Of Ethics Opinions Sent: Monday, September 29, 2008 1:33 PM To: villafana, Ann Marie C. (USAFLS) Subject: Re: FW: Request for Written Staff Opinion ATTN Elizabeth Clark Tarbert
Dear Ms. Villafana:
Thank you for re-sending the inquiry. Most inquiries receive a reply within 3-5 weeks.
Sincerely,
Elizabeth Clark Tarbert Ethics Counsel "Villafana, Ann Marie C. (USAFLS)" <Ann.Marie.C.Villafana®usdoj.gov> on 09t29/2008 12:05:05 PM
To: "Ethics Opinions" <etopinion®flabar.org> ce: Subject: FW: Request for Written StatTOpinion ATTN Elizabeth Clark Tarbert
Staff:
Dear Ms. Tarbert — Here is my earlier e-mail.
Thank you.
A. Marie Villafaña
Assistant U.S. Attorney
500 S. Australian Ave, Suite 400
1
EFTA00193211
West Palm Beach, FL 33401
Phone 561 209-1047
Fax 561 820-8777
From: Villafana, Ann Marie C. (USAFLS) Sent: Thursday, September 18, 2008 7:21 PM To:eto@flabar.org Cc: Atkinson, Karen (USAFLS); Lee, Dexter (USAFLS) Subject: Request for Written Staff Opinion
Dear Sir or Madam: Please see the attached correspondence. Thank you for your assistance.
<<Florida Bar Ltr re Ethics Opinion.pdf»
<<Final Victim Notification -- Sample.pdf>>
<
A. Marie Villafaña
Assistant U.S. Attorney
500 S. Australian Ave, Suite 400
West Palm Beach, FL 33401
Phone 561 209-1047
Fax 561 820-8777(See attached file: Florida Bar Dr re Ethics Opinion.p4B(See attached file: Final Victim Notification —Sample.pd)(See attachedfile: Final Victim Notification Represented Sample.pdfi
2
EFTA00193212