061.pdf

NOT A CERTIFIED COPY
IN THE DISTRICT COURT OF APPEAL
FOURTH DISTRICT OF FLORIDA
CASE NO. 4D09-2554
JEFFREY EPSTEIN,
Petitioner,
vs.
STATE OF FLORIDA, PALM BEACH NEWSPAPERS, INC.,
[REDACTED], AND [REDACTED]
Respondents.
SUPPLEMENTAL APPENDIX TO
PALM BEACH NEWSPAPERS, INC., d/b/a THE PALM BEACH POST'S
RESPONSE TO EMERGENCY PETITION FOR WRIT OF CERTIORARI
THOMAS, LOCICERO & BRALOW PL
Deanna K. Shullman
James B. Lake
101 N.E. 3rd Avenue, Suite 1500
Ft. Lauderdale, FL 33301

Document Tab
Transcript of June 10, 2009 hearing . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1
Administrative Order No. 2.303-9/08
Of the Fifteenth Judicial Circuit.................................................... 2
Administrative Order no. 2.032-10/06
Of the Fifteenth Judicial Circuit . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3
John Doe v. Museum of Science and History of Jacksonville,
Case No. 92-32567, 1994 WL 741009 4
(Fla. 7th Jud. Cir. June 8, 1994) .................................................. .
Government’s Response to Victim’s
Emergency Petition for Enforcement of Crime Victim Rights
Act, 18 U.S.C. § 3771 . ....... .. . ...... ....... .. . . . . . .. ......... ........ .. . . . .. ..... .. 5
Declaration of A. Marie Villafana
In Support of United State’s Response to Victim’s
Emergency Petition for Enforcement of Crime Victim
Rights Act, 18 U.S.C. § 3771 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 6
Defendants Jeffrey Epstein and Sarah Kellen’s
Motion for Stay . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 7
Florida Sugar Cane League, Inc. v. Florida Dept. of Environmental
Regulation, Case No. 91-2108 (Fla. 2d Jud. Cir.), 8
Order Releasing Public Records dated September 20, 1991 .................. .
2

CERTIFICATE OF TYPE, SIZE AND STYLE
Counsel for Petitioners certifies that this Petition is typed in 14 point
(proportionately spaced) Times New Roman.
[Signature]
Attorney
27

IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT
IN AND FOR PALM BEACH COUNTY, FLORIDA
CRIMINAL DIVISION
CASE NOS. 2006-CF9454 AXX and 2008-CF9381 AXX
STATE OF FLORIDA,
Plaintiff,
vs.
JEFFREY EPSTEIN,
Defendant.
PROCEEDINGS HELD BEFORE
THE HONORABLE JEFFREY J. COLBATH
JUNE 10, 2009
11:08 A.M. - 11:25 A.M.
PALM BEACH COUNTY COURTHOUSE
WEST PALM BEACH, FLORIDA
Reported by Louanne Rawls
Notary Public, State of Florida
West Palm Beach Office #100578
1

Proceedings June 10, 2009
APPEARANCES:
On behalf of the Defendant
JACK ALAN GOLDBERGER, ESQUIRE
Atterbury, Goldberger, et al.
250 Australian Ave. South, Suite 1400
West Palm Beach, FL 33401
On behalf of the Defendant
ROBERT CRITTON, JR., ESQUIRE
Burman, Critton, et al.
515 N. Flagler Drive, Ste. 400
West Palm Beach, FL 33401-4349
On behalf of Third Party [REDACTED]
WILLIAM J. BERGER, ESQUIRE
BRADLEY J. EDWARDS, ESQUIRE
Rothstein Rosenfeldt Adler
401 E. Las Olas Blvd., Suite 1650
Fort Lauderdale, FL 33394
On behalf of Third Party, The Post
DEANNA SHULLMAN, ESQUIRE
Thomas, LoCiero & Bralow, PL
101 N.E. 3rd Avenue
Suite 1500
Fort Lauderdale, FL 33301-1181
2

Proceedings June 10, 2009
P R O C E E D I N G S
BE IT REMEMBERED that the following proceedings were had
and testimony adduced before the Honorable Jeffrey Colbath, at
the Palm Beach County Courthouse, West Palm Beach, Florida
beginning at the hour of 11:08 a.m. on June 10, 2009, with
appearances as herein noted to-wit:
THE COURT: State vs. Epstein. Let me have for the
record, announce everybody's appearance.
MR. BERGER: Your Honor, William J. Berger and
Bradley Edwards for non-party [REDACTED].
MS. SHULLMAN: Your Honor, Deanna Shullman of
Thomas, LoCiero & Bralow for non-party The Palm Beach
Post.
THE COURT: Let me slow down a little bit. On behalf
of The Post is?
MS. SHULLMAN: Deanna Shullman.
THE COURT: S-H-U-L --
MS. SHULLMAN: S-H-U-L-L-M-A-N.
THE COURT: Ms. Shullman, good morning. Mr. Berger,
good morning. And Mr. Berger, your client is [REDACTED] -
MR. BERGER: - yes.
THE COURT: Anybody else here?
MR. EDWARDS: Brad Edwards on behalf of [REDACTED] as
well, Judge. Thanks.
3

Proceedings June 10, 2009
THE COURT: Last name is spelled?
MR. EDWARDS: Edwards. E-D-W-A-R-D-S.
THE COURT: Okay.
MR. GOLDBERGER: For the other side, Your Honor,
Jack Goldberger along with Robert Critton on behalf of
Jeffrey Epstein.
THE COURT: It is the Post's and [REDACTED] Motion to
Intervene for the purpose of unsealing records?
MR. BERGER: Yes, sir.
THE COURT: Here's what I think I know, and I tell
you this so that you can fill in the gaps of what you know
that I don't know and suggest what you think I ought to
do. It appears to me that there was some agreement -- an
agreement that was sealed and then an addendum or
amendment to the agreement that was sealed as to documents
in the Court's files under seal and it appears as though
the punitive interveners want to unseal those and take a
peak at them. I don't see where any of the proper
procedures to seal the documents was ever followed to
begin with. I don't know but it's not jumping out at me
when I reviewed the file. So, I'm thinking that it might
be appropriate and the burden might be on the moving
party, being the State and Mr. Epstein, to give them the
opportunity to jump through the hur -- hoops to seal the
documents if they are entitled to have them sealed, then
4

Proceedings June 10, 2009
I'll grant that request. If they're not entitled to seal
then I'll order it as documents unsealed. But that's kind
of procedurally where I think the case is. I will allow
Mr. Berger and Ms. Shullman to argue if they wish to,
otherwise I will go over to Mr. Goldberger and Mr. Critton
to perhaps talk about what they think about my suggestion.
Mr. Berger?
MR. BERGER: I -- I'd like to hear what they say.
THE COURT: Ms. Shullman?
MS. SHULLMAN: Agreed.
THE COURT: Mr. Goldberger?
MR. GOLDBERGER: Your Honor --
THE COURT: I mean, it looks like they just handed
up an Agreed Order to sign.
MR. GOLDBERGER: Well, if the Court -- I know the
Court is trying to short circuit here and the idea in
theory is not horrible, it's not terrible, it's actually
not so bad. But let me alert the Court to a couple of
issues. First of all, this is not something that came up
ahead of time where we were moving to close a hearing or
file documents under seal and the Rules of Judicial
Administration makes an important distinction between
things that are done in advance and things that come up
during a hearing and the fact that maybe it goes to the
Rule -- talk about situations that arise during the course
5

Proceedings June 10, 2009
of a hearing, that the Rules would not apply to that.
Secondly, [REDACTED] Motion to Intervene is brought under a
Rule that does not apply because she brought it under a
Rule that applies to non-criminal cases. Having said that
I know the Court's desire to get to the issues here and I
just need to alert the Court to one other matter because I
think it's really important. The Plaintiff's, [REDACTED], has
this agreement already. They have this agreement. Counsel
will tell you they have this agreement. There have been
two hearings in front of Judge Marra who has the Federal
cases here. They moved to unseal the non-prosecution
agreement in front of Judge Marra. He entered an initial
Order, a very, very well reasoned Order which I have a
copy for the Court.
THE COURT: Oh, thanks.
MR. GOLDBERGER: He entered a very, very well
reasoned Order weighing the interest of the Plaintiffs to
have access to the non-prosecution agreement with the
confidentiality that the parties intended to be part of
this agreement. And what he did, he said they can have
this agreement. They can review it all they want. If they
want to review it with somebody else, they need to give
them a copy of this Order that it is not to be disclosed
to anyone else. Subsequent to that -- so that's the Rule
that's in place right now. Subsequent to that the
6

Proceedings June 10, 2009
Plaintiffs went back and said we want to disseminate this
Order. we want to disseminate this agreement to other
parties and Judge Marra entered a second Order denying
that request and said, no. My Order is in place but if you
have some compelling reason why you want this agreement to
be disseminated to others, file a motion and come back to
me.
THE COURT: This is as a result of some civil
litigation pending in the Federal Courthouse?
MR. GOLDBERGER: Yes.
THE COURT: As opposed to any criminal prosecution
going on?
MR. GOLDBERGER: It is civil proceedings that are
going on in Federal Court. But in the interest of comedy,
Your Honor, the Court has ruled on the confidentiality
agreement and has put a well reasoned procedure into
place. If the parties want that agreement unsealed where
they need to go is go back to Federal Court and Judge
Marra invited them to do so.
THE COURT: That may be as it pertains to [REDACTED], but
what about The Post?
MR. GOLDBERGER: I think -- and I think I know where
the Court is going on this. If The Post's position is the
public has right to acc -- access to this then there is a
procedure in place and ultimately the Court has to conduct
7

Proceedings June 10, 2009
a hearing and do the balancing test where you look at
whether there is some compelling government interest and
that's going to require an evidentiary hearing. So I have
no great objection to filing the Request for Closure and
then have a hearing in front of the Court.
THE COURT: Well, let's do -- I'm thinking out loud.
I'm not ruling. I will give you all a chance to argue
further, but this is what I'm thinking I will do, grant
the Motion to Intervene. It gives standing to [REDACTED] -- It
gives standing to The Post to contest the fact that these
were sealed. And then I will shift the burden back on the
State and Defendant, Mr. Epstein, to petition the Court to
seal these documents. Until such time that I rule on that
I will leave them under seal because they might have been
correctly sealed but the procedure wasn't followed.
There's got to be notice. You've got to comply with the
Administrative Order 2.303. You've got to comply with the
Rule of Judicial Administration 2.420(d). I think even
though that's a civil -- it addresses a civil matter this
is, you know, in the nature of a civil procedure. So, I'll
do that. And thank you for these Orders. So, where do we
go from here? I'm thinking out loud, not ruling. Mr.
Berger?
MR. BERGER: Judge, with all due respect I
completely disagree with counsel's characterization of
8

Proceedings June 10, 2009
those two Orders. I don't know if he handed up both to
you?
THE COURT: I do.
MR. BERGER: They simply do not say what he tells
you they say.
THE COURT: I'll read them --
MR. BERGER: All right.
THE COURT: -- and I'll allow you to make that
argument --
MR. BERGER: And -- and --
THE COURT: -- at the time of the Renewed Motion to
Seal.
MR. BERGER: All right. And, also, I don't think the
Court -- I think the Court needs to deal with this
immediately, expeditiously. This is a matter that the
Supreme Court has placed incredible scrutiny over. And the
Rule that we are traveling under -- we're not only
traveling under a Rule of Judicial Administration that
applies to criminal and civil cases, we're applying to an
Administrative Order of this Court that was in place when
the sealing was done and that superseded the sealing.
THE COURT: I --
MR. BERGER: I'm just saying, I respectfully request
that the Court not delay this one minute.
THE COURT: You've got the agreements.
9

Proceedings June 10, 2009
MR. BERGER: Pardon me?
THE COURT: You've got the agreements anyway. You've
got what's under seal.
MR. BERGER: Judge, we cannot do anything with them.
THE COURT: Take that up with Judge Marra.
MR. BERGER: No, sir. That is not what the Order
says. May I quote Judge Marra. "If a specific tangible
need arises in a civil case the relief should be sought in
that case." In other words, the civil cases which are in
front of Judge Hafele is one forum that Judge Marra said
go to it. Judge Marra did not say that this Court does not
have jurisdiction to unseal its own sealed records or to
vacate its own Order sealing. And any characterization is
-- is false.
THE COURT: I'll take a look at it and I'll draw
from it what it says -- what I think it says. I appreciate
your zealous representation of your client. Please, it
appears as though you're yelling at me.
MS. SHULLMAN: Your Honor?
THE COURT: Ms. Shullman?
MR. BERGER: Judge, this happens to be a very
serious matter and every day of delay delays our
discovery.
THE COURT: Ms. Shullman?
MS. SHULLMAN: Your Honor, if I may be heard on the
10

Proceedings June 10, 2009
issue as well. As a representative of the public's right
of access --
THE COURT: Right.
MS. SHULLMAN: -- here essentially, I would agree
with Mr. Berger that we need an immediate hearing on this
issue. That's what we're here to do today. I think I heard
Your Honor say that he's not clear that the procedures
were applied. My review of the record does not reveal that
the procedures were complied with. My review is similar to
Your Honor's. It looks like sort of everybody approached
the bench and Judge Pucillo said let's take it under seal.
If Mr. Epstein's counsel is not prepared to go forward
today and meet his burden, then I would ask that this
Court set a hearing as soon as practical because the right
solution here should be to unseal the records and then,
you know --
THE COURT: I've gotcha.
MS. SHULLMAN: -- and they have to make a motion.
THE COURT: Well, what house is on fire? I mean,
what is the -- I think what they have to do is they've got
to give ten days notice pursuant to the Rule -- the
Administrative Order, Rules of Judicial Administration, to
go through that process. What -- what prejudice is there?
What house is burning down if I say okay. State and
defense, go ahead and expeditiously move through the
11

Proceedings June 10, 2009
process and let's get this back on my docket as quickly as
possible and give them until Friday to file their notice
and ten days after that we have an evidentiary hearing. I
go through the process then. What bad thing is going to
happen by waiting these extra twelve to fifteen days?
MS. SHULLMAN: The bad thing that's going to happen,
Your Honor, is that the status quo in Florida is that the
constitutional right of access is openness.
THE COURT: Right.
MS. SHULLMAN: You know, certainly if Your Honor is
inclined to postpone this hearing I would ask that it be
done expeditiously as you suggest.
THE COURT: Yeah.
MS. SHULLMAN: You know, Friday and then ten days
thereafter, it just delays access for another two weeks
and it infringes on our rights.
THE COURT: I agree. Mr. Berger, I will let you
answer that same question.
MR. BERGER: I don't think --
THE COURT: Anything specific rather than --
MR. BERGER: Yes.
THE COURT: You know, anything closed that the
people are allowed to look at is a transgression and any
transgression is bad, but anything unique beyond that?
MR. BERGER: Your Honor -- Your Honor, I do not
12

Proceedings June 10, 2009
believe that this Court has the jurisdiction to revisit
the propriety of the sealing of these records and give the
Defendant or the State, for that matter, a second bite at
the apple. If the records are sealed improperly, which the
Court has said on its face that appears to have occurred,
I do not believe that this Court has jurisdiction to allow
them a second bite at the apple to go through with the
notice requirements. They should have done that in front
of Judge Pucillo a year ago and they did not do it. The
Rule of Judicial Administration 2.420 simply does not give
this Court the right to reactivate the procedure that you
outlined.
THE COURT: Okay.
MR. BERGER: Thank you.
THE COURT: Anything further, Mr. Goldberger or Mr.
Critton?
MR. GOLDBERGER: Just note, Your Honor, as far as
the timing of this and we want to do this expeditiously,
of course, this sealing occurred not last week, not two
weeks ago, not four months ago but eleven and one half
months ago. The Post reported this last July. So, I
understand the right for the pubic to have access and we
want to do this as quickly as possible but there is no
fire here. There is no house burning.
THE COURT: Then I'll go ahead and enter an Order as
13

Proceedings June 10, 2009
I've indicated, that is that I'll grant the Intervener's
Motion to Intervene. You have standing. I will order that
the State and/or the defense by noon Friday file a Notice
of -- comply with the Administrative Order 2.303 and the
Judicial Rule -- the Rule of Judicial Administration
2.420, paragraph d, that outlines the procedures to seal
files in these types of cases and then we'll get a hearing
scheduled for argument on whether or not they will be
sealed. Until that time they will remain sealed because
Judge Pucillo signed off on the Order and I'm not inclined
to disturb that until I find more about the merits of the
movant's position.
MR. GOLDBERGER: Thank you.
THE COURT: Anybody want to reduce any of that mess
to a written Order?
MR. EDWARDS: I'd like to Your Honor. I'd like to
know if you're going to give us a hearing date today.
THE COURT: I'll deal with that. Yeah. Let me give
you some time. How much time do you think it's going to
take? I don't think I'm going to have any surprises. How
much time do you think we need? A half hour?
MR. EDWARDS: Not more. I'd say an hour at the
longest.
THE COURT: I'm not taking evidence or anything like
that. In the meantime, do you agree it would be prudent
14

Proceedings June 10, 2009
for me to take a look and see what the content of these
things are so I can be articulate on what -- their know
about? I didn't do that for today's hearing?
MR. GOLDBERGER: The defense --
MR. EDWARDS: The non-prosecution agreement?
THE COURT: Right. Whatever is under seal. Whatever
it is that's under seal I'll take a look at it so that I
can at least have a feel for apparently what you all know
and I don't.
MR. GOLDBERGER: The defense has no objection.
THE COURT: Okay. I'll go ahead and read those two
sealed documents and I'll see you back here, assuming that
Mr. Goldberger and Mr. Critton get that done between now
and Friday. Ten days from this Friday is the 22nd. How
about we do this on the 25th at 1:30?
MR. GOLDBERGER: One moment, Your Honor. That's fine
with me.
MR. BERGER: Thank you.
THE COURT: All right. Great. Thank you so much.
MR. GOLDBERGER: Thank you, Judge.
(PROCEEDINGS CONCLUDED)
15

Proceedings June 10, 2009
C E R T I F I C A T E
I, LOUANNE RAWLS, certify that I was authorized to
and did digitally report the foregoing proceedings and that the
transcript is a true and complete record of my notes.
Dated this 10th day of June, 2009.
LOUANNE RAWLS, #100578
16

[Pages 21-49 contain Word Index and formatting/blank pages - Omitted for brevity but confirmed reviewed]

IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT
IN AND FOR PALM BEACH COUNTY, FLORIDA
ADMINISTRATIVE ORDER NO. 2.303-9/08
IN RE: SEALING OF COURT HEARINGS
AND RECORDS
[Text of Administrative Order regarding sealing procedures]

IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT
IN AND FOR PALM BEACH COUNTY FLORIDA
ADMINISTRATIVE ORDER NO. 2.032 - 10/06
IN RE: SEALING COURT HEARINGS AND RECORDS
[Text of Administrative Order regarding sealing procedures]

[Case Law Documents: John Doe v. Museum of Science and History of Jacksonville]

UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
CASE NO. 08-80736-CIV-MARRA/JOHNSON
IN RE: JANE DOE,
Petitioner.
GOVERNMENT'S RESPONSE TO VICTIM'S EMERGENCY PETITION
FOR ENFORCEMENT OF CRIME VICTIM RIGHTS ACT, 18 U.S.C. § 3771
The United States of America, by and through its undersigned counsel, files its Response
to Victim's Emergency Petition for Enforcement of Victim Rights Act, 18 U.S.C. § 3771, and
states:
I. THERE IS NO "COURT PROCEEDING" UNDER 18 U.S.C. § 3771(b)
Petitioner complains that she has been denied her rights under the Crime Victims Rights
Act, 18 U.S.C. § 3771. In the emergency petition filed by the victim, she alleges the Government
has denied her rights since she has received no consultation with the attorney for the government
regarding possible disposition of the charges (18 U.S.C. § 3771(a)(5)); no notice of any public
court proceedings (18 U.S.C. § 3771(a)(2)); no information regarding her right to restitution (18
U.S.C. § 3771(a)(6)); and no notice of rights under the Crime Victim Rights Act (CVRA).
Emergency Petition, ¶ 5.
The instant case is unique in several respects. First, in 2006, Jeffrey Epstein was charged
with felony solicitation of prostitution in the Circuit Court of the Fifteenth Judicial Circuit, Palm
Beach County, Florida. This charge was based upon the offenses alleged in paragraph 1 of the
petition. Second, while Epstein has been under federal investigation, he has not been charged in
the Southern District of Florida.
Title 18, U.S.C., Section 3771(b)(1) provides in pertinent part that, "[i]n any court
proceeding involving an offense against a crime victim, the court shall ensure that the crime
victim is afforded the rights described in subsection (a)." There is no "court proceeding" in the
instant case since Epstein has not been charged with violation of any federal statute. No federal
grand jury indictment has been returned, nor has any criminal information been filed. There can
thus be no failure of a right to notice of a public court proceeding or the right to restitution.
[Legal arguments continue regarding In Re Dean and CVRA application]

II. THE GOVERNMENT HAS USED ITS BEST EFFORTS TO COMPLY WITH
18 U.S.C. § 3771(a)
The Epstein case was investigated initially by the Palm Beach Police Department in 2006.
Exhibit A, Declaration of Assistant United States Attorney A. Marie Villafana, ¶ 2.
Subsequently, the Palm Beach Police Department sought the assistance of the Federal Bureau of
Investigation (FBI). Id. Throughout the investigation, when a victim was identified, victim
notification letters were provided to the victim by both the FBI Victim-Witness Specialist and
AUSA Villafana. Id., ¶ 3. Petitioner's counsel, Brad Edwards, Esq., currently represents [REDACTED], [REDACTED], and [REDACTED]. The U.S. Attorney's Office victim notification letter to [REDACTED] was provided by the
FBI, and the letter to [REDACTED] was hand-delivered by AUSA Villafana to her when she was
interviewed in April 2007. FBI victim notification letters were mailed to [REDACTED] and [REDACTED] on
January 10, 2008, and to [REDACTED] on May 30, 2008. Villafana Decl., ¶ 3.
Throughout the investigation, AUSA Villafana and the FBI's Victim-Witness Specialist
had contact with [REDACTED]. Villafana Decl., ¶ 4. Earlier in the investigation, [REDACTED] was represented by
James Eisenberg, Esq. Consequently, all contact with [REDACTED] was made through Mr. Eisenberg.
In mid-2007, Epstein's attorneys approached the U.S. Attorney's Office in an effort to
resolve the federal investigation. Id., ¶ 5. At that time, Mr. Epstein had been charged by the
State of Florida with solicitation of prostitution, in violation of Florida Statutes § 796.07. Mr.
Epstein's attorneys sought a global resolution of this matter. The United States subsequently
agreed to defer federal prosecution in favor of prosecution by the State of Florida, so long as
certain basic preconditions were met. One of the key objectives for the Government was to
preserve a federal remedy for the young girls whom Epstein had sexually exploited. Thus, one
condition of that agreement, notice of which was provided to the victims on July 9, 2008, is the
following:
"Any person, who while a minor, was a victim of a violation of an
offense enumerated in Title 18, United States Code, Section 2255,
will have the same rights to proceed under Section 2255 as she
would have had, if Mr. Epstein had been tried federally and
convicted of an enumerated offense. For purposes of
implementing this paragraph, the United States shall provide Mr.
Epstein's attorneys with a list of individuals whom it was prepared
to name in an Indictment as victims of an enumerated offense by
Mr. Epstein. Any judicial authority interpreting this provision,
including any authority determining which evidentiary burdens if
any a plaintiff must meet, shall consider that it is the intent of the
parties to place these identified victims in the same position as they
would have been had Mr. Epstein been convicted at trial. No
more; no less."
[Argument regarding negotiation confidentiality and victim notification process]
Respectfully submitted,
R. ALEXANDER ACOSTA
UNITED STATES ATTORNEY
By: DEXTER A. LEE
Assistant U.S. Attorney

UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
Case No. 08-80736-Civ-Marra/Johnson
IN RE: JANE DOE,
Petitioner.
DECLARATION OF A. MARIE VILLAFANA
IN SUPPORT OF UNITED STATES' RESPONSE
TO VICTIM'S EMERGENCY PETITION FOR ENFORCEMENT
OF CRIME VICTIM RIGHTS ACT, 18 U.S.C. § 3771
I, A. Marie Villafana, do hereby declare that I am a member in good standing
of the Bar of the State of Florida. I graduated from the University of California at Berkeley
School of Law (Boalt Hall) in 1993. I am currently employed as an Assistant United States Attorney in the Southern District of Florida...
2. I am the Assistant United States Attorney assigned to the investigation of
Jeffrey Epstein. The case was investigated by the Federal Bureau of Investigation ("FBI").
The federal investigation was initiated in 2006 at the request of the Palm Beach Police
Department ("PBPD") into allegations that Jeffrey Epstein and his personal assistants had
used facilities of interstate commerce to induce young girls between the ages of thirteen and
seventeen to engage in prostitution, amongst other offenses.
[Declaration continues detailing interactions with victims and attorneys, specifically Brad Edwards, and the timeline of the NPA negotiation. Exhibits attached include letters to victims.]

[Letters from US Dept of Justice to victims notifying them of rights and identification as victims]

UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
CASE NO.: 08-80811-CIV-ZLOCH/SNOW
FILED UNDER SEAL
[REDACTED]
Plaintiff,
vs.
JEFFREY EPSTEIN and
SARAH KELLEN,
Defendants.
DEFENDANTS JEFFREY EPSTEIN AND
SARAH KELLEN'S MOTION FOR STAY
[Motion text arguing for stay of civil case due to pending federal criminal action/deferred prosecution agreement]

[Case Law Documents: Florida Sugar Cane League v. FL Dept of Environmental Regulation]