Described by 11th Circuit as graduating from passive nondisclosure to active misrepresentation.
This document is a page from an OPR report analyzing whether prosecutor Villafaña violated Florida Rules of Professional Conduct (FRPC) by failing to disclose the existence of Epstein's Non-Prosecution Agreement (NPA) to victims and attorney Edwards. It references specific interviews conducted by Villafaña on January 31 and February 1, 2008, where she allegedly stated the matter was 'under investigation' despite knowing the NPA was signed. The text cites the Eleventh Circuit's concern that the government's actions moved from passive nondisclosure to active misrepresentation.
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