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913 KB
Extraction Summary
5
People
1
Organizations
0
Locations
6
Events
5
Relationships
6
Quotes
Document Information
Type:
Legal document
File Size:
913 KB
Summary
This legal document details the actions of government representative Villafaña in July 2008 regarding the implementation of Jeffrey Epstein's Non-Prosecution Agreement (NPA). It describes Villafaña's communications with Epstein's defense team, including Goldberger and Sanchez, to provide an updated victim list and send notification letters to victims. The document highlights the specific legal language used to ensure victims retained their rights to pursue civil damages as if Epstein had been federally convicted.
People (5)
| Name | Role | Context |
|---|---|---|
| Epstein | Defendant |
Mentioned throughout as the subject of a Non-Prosecution Agreement (NPA), a state court plea, and obligations to vict...
|
| Villafaña |
A government representative who prepared and sent victim notification letters in July 2008 and communicated with Epst...
|
|
| Goldberger |
A member of Epstein's defense team who received an updated victim list and other notifications from Villafaña.
|
|
| Acosta |
Mentioned as the author of a December 19, 2007 letter to Epstein's defense attorney, from which language was used in ...
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|
| Sanchez | Epstein defense attorney |
Recipient of a December 19, 2007 letter from Acosta clarifying the damages provision of the NPA.
|
Organizations (1)
| Name | Type | Context |
|---|---|---|
| United States | government agency |
Mentioned as the party agreeing to defer federal prosecution and providing a list of victims to Epstein's attorneys.
|
Timeline (6 events)
2008-07-08
Villafaña provided Goldberger with an updated victim list for 18 U.S.C. § 2255 purposes.
2008-07-10
Villafaña sent Goldberger a “Final Notification of Identified Victims.”
Relationships (5)
Villafaña (representing the government) provided Goldberger (representing the defense) with an updated victim list and other notifications related to the Epstein NPA.
Villafaña was the government representative managing the victim notification process for the NPA involving Epstein.
Goldberger is part of Epstein's defense team, receiving communications on his behalf.
Key Quotes (6)
"one of these victims is entitled to proceed under 18 U.S.C. § 2255"Source
— Villafaña's letter to the defense
(Describing a condition that, if denied by Epstein, would be considered a breach of the NPA.)
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Quote #1
"[i]n light of"Source
— Villafaña's letter to victims
(Used to preface the explanation of the deferred prosecution agreement following Epstein's state court plea.)
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Quote #2
"the United States has agreed to defer federal prosecution in favor of this state plea and sentence, subject to certain conditions."Source
— Villafaña's letter to victims
(Informing victims about the government's decision regarding federal charges against Epstein.)
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Quote #3
"[o]ne such condition to which Epstein has agreed"Source
— Villafaña's letter to victims
(Introducing a paragraph detailing victims' rights to pursue civil action, which was taken from an earlier letter by Acosta.)
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Quote #4
"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 . . . 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."Source
— Language from Acosta's December 19, 2007 letter, used in Villafaña's July 2008 letter
(A specific paragraph included in the victim notification letter to clarify the rights of victims to pursue civil damages as if Epstein had been federally convicted.)
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Quote #5
"Final Notification of Identified Victims,"Source
— Title of a document sent by Villafaña
(The title of a communication sent from Villafaña to Goldberger on July 10, 2008.)
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Quote #6
Full Extracted Text
Complete text extracted from the document (3,374 characters)
Case 22-1426, Document 78, 06/29/2023, 3536039, Page9 of 217
SA-263
Case 1:20-cr-00330-AJN Document 204-3 Filed 04/16/21 Page 263 of 348
SA-263
Case 1:20-cr-00330-AJN Document 204-3 Filed 04/16/21 Page 263 of 348
no federal charges filed against Epstein as a result of the government’s agreement in mid-2007 to defer prosecution to the state.370
C. July 2008: Villafaña Prepares and Sends a Victim Notification Letter to Listed Victims
On July 8, 2008, Villafaña provided Goldberger with an updated victim list for 18 U.S.C. § 2255 purposes, noting that she had inadvertently left off one individual in her June 30, 2008 letter. Villafaña also informed the defense that, beginning the following day, she would distribute notifications to each of the 32 victims and their counsel informing them that Epstein’s attorney would be the contact for any civil litigation, if the victim decided to pursue damages. Finally, the letter informed the defense that the government would consider a denial by Epstein that any “one of these victims is entitled to proceed under 18 U.S.C. § 2255” to be considered a breach of the terms of the NPA.
After exchanging emails and letters with the defense concerning the content of the notice letter, Villafaña drafted a letter she sent, on July 9 and 10, to nine victims who had previously retained counsel. The letter informed the victims and their counsel that, “[i]n light of” Epstein’s June 30, 2008 state court plea to felony solicitation of prostitution and procurement of minors to engage in prostitution, and his sentence of a total of 18 months’ imprisonment followed by 12 months’ community control, “the United States has agreed to defer federal prosecution in favor of this state plea and sentence, subject to certain conditions.” The letter included a reference to the 18 U.S.C. § 2255 provision of the NPA, and although the defense had never agreed to it, used language from Acosta’s December 19, 2007 letter to Epstein defense attorney Sanchez clarifying the damages provision. The paragraph below was described as “[o]ne such condition to which Epstein has agreed”:
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 . . . 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.
On July 10, 2008, Villafaña sent Goldberger a “Final Notification of Identified Victims,” highlighting the defendant’s obligations under the NPA concerning victim lawsuits pursuant to
370 As described in Section XII.G of this Part, the matter continued in litigation for years and resulted in the district court’s February 21, 2019 opinion concluding that the government violated the victims’ rights under the CVRA by failing to consult with them before signing the NPA.
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