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Case 1:20-cr-00330-PAE Document 204-3 Filed 04/16/21 Page 56 of 348
he is comfortable before proceeding.” Menchel told Villafafia he had “trouble understanding” why
she was in a “rush” “given how lon
Case 1:20-cr-00330-PAE Document 204-3 Filed 04/16/21 Page 55 of 348
Lourie followed up his email to Villafafia with one to Menchel, in which Lourie reiterated
the potential benefits of a pre-indictme
Case 1:20-cr-00330-PAE Document 204-3 Filed 04/16/21 Page 51 of 348
of the state’s victim interviews and partial transcripts provided by defense counsel.*° Villafafia
also pursued other investigative
Case 1:20-cr-00330-PAE Document 204-3 Filed 04/16/21 Page 50 of 348
disagreed with her position. Villafafia and a West Palm Beach AUSA with whom she was
consulting about the investigation, and who se
Case 1:20-cr-00330-PAE Document 204-3 Filed 04/16/21 Page 47 of 348
On July 24, 2006, Villafafia alerted Sloman, who informed Acosta, that the State Attorney’s
Office had charged and arrested Epstein
Case 1:20-cr-00330-PAE Document 204-3 Filed 04/16/21 Page 45 of 348
Epstein massages that were sexual in nature, and that Epstein had used “various types of pressure”
to avoid prosecution by the stat
Case 1:20-cr-00330-PAE Document 204-3 Filed 04/16/21 Page 44 of 348
2. May 2006: The USAO Accepts the Case and Opens a Case File
On May 23, 2006, Villafafia prepared the paperwork to open a USAO cas
Case 1:20-cr-00330-PAE Document 204-3 Filed 04/16/21 Page 42 of 348
other things, prohibit anyone from being present while grand jurors deliberate and vote, and
proscribe the release of the notes, re
Case 1:20-cr-00330-PAE Document 204-3 Filed 04/16/21 Page 40 of 348
they found computer monitors and keyboards in the home, as well as disconnected surveillance
cameras, but the computer equipment it
Case 1:20-cr-00330-PAE Document 204-3 Filed 04/16/21 Page 38 of 348
Timeline of Key Events for Federal Epstein Investigation — May 2006 through October 2008
Sept 7 — Acosta, Sloman, Villafaiia May 1
Case 1:20-cr-00330-PAE Document 204-3 Filed 04/16/21 Page 34 of 348
Wk. JEFFREY EPSTEIN AND HIS DEFENSE ATTORNEYS
A. Jeffrey Epstein
Jeffrey Epstein was born in Brooklyn, New York, in 1953.4 Althoug
Case 1:20-cr-00330-PAE Document 204-3 Filed 04/16/21 Page 36 of 348
[Page Intentionally Left Blank]
10
DOJ-OGR-00003212
Case 1:20-cr-00330-PAE Document 204-3 Filed 04/16/21 Page 33 of 348
USAO Roles and Responsibilities in Epstein Investigation
Mid-2006 through Mid-2009
Alexander Acosta Jeff Sloman (Acting)
United S
SOLICITOR
GENERAL
OFFICE OF THE
SOLICITOR
GENERAL
OFFICE OF
JUSTICE
PROGRAMS
EXECUTIVE
‘OFFICE FOR THE
UNITED STATES
OFFICE OF
DISPUTE
RESOLUTION
‘OFFICE OF
VIOLENCE
AGAINST
WOMEN
Case 1:20-cr-
Case 1:20-cr-00330-PAE Document 204-3 Filed 04/16/21 Page 26 of 348
[Page Intentionally Left Blank]
XXIV
DOJ-OGR-00003202
Case 1:20-cr-00330-PAE Document 204-3 Filed 04/16/21 Page 24 of 348
B. July 7, 2008: The CVRA Litigation Is Initiated ......... eee eeceeeeeeeeeeeeeeeeeeeneeees 236
Cc. July 2008: Villafafia Prepares
Case 1:20-cr-00330-PAE Document 204-3 Filed 04/16/21 Page 22 of 348
CHAPTER THREE: ISSUES RELATING TO THE GOVERNMENT’S INTERACTIONS
AND COMMUNTCATIONS WITEL VICTIMS vxcncnmares sxmmamescomsns saxmme
Case 1:20-cr-00330-PAE Document 204-3 Filed 04/16/21 Page 21 of 348
D. OPR Does Not Find That the Subjects’ Preexisting Relationships with
Defense Counsel, Decisions to Meet with Defense Counsel, and
Case 1:20-cr-00330-PAE Document 204-3 Filed 04/16/21 Page 16 of 348
I. THE FBI AND THE USAO INVESTIGATE EPSTEIN, AND THE
DEFENSE TEAM ENGAGES WITH THE USAO scrsssrsnes enomenessoneoss wovenemunuesws
Case 1:20-cr-00330-PAE Document 204-3 Filed 04/16/21 Page 13 of 348
interactions with victims that ultimately led to public and court condemnation of the government’s
treatment of the victims, reflec
Case 1:20-cr-00330-PAE Document 204-3 Filed 04/16/21 Page 12 of 348
initiate a federal prosecution of Epstein was within the scope of his authority, and OPR did not
find evidence that his decision wa
Case 1:20-cr-00330-PAE Document 204-3 Filed 04/16/21 Page 11 of 348
of immunity, or (6) the deportation of criminal aliens. The potentially applicable standards that
OPR considered as to each of thes
Case 1:20-cr-00330-PAE Document 204-3 Filed 04/16/21 Page 8 of 348
an investigation into the matter and would review the USAO’s decision to resolve the federal
investigation of Epstein through the NP
Case 1:20-cr-00330-PAE Document 204-3 Filed 04/16/21 Page 5 of 348
Soon after he was incarcerated, Epstein applied for the Palm Beach County Sheriffs work
release program, and the Sheriff approved hi
Case 1:20-cr-00330-PAE Document 204-3 Filed 04/16/21 Page 2 of 348
DOJ-OGR-00003178
Case 1:20-cr-00330-PAE Document 204-1 Filed 04/16/21 Page 2 of 2
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DOJ-OGR-00003175
Case 1:20-cr-00330-PAE Document 204 _ Filed 04/16/21 Page 237 of 239
The result is the same even if the defendant’s preferred relevant jury pool is used. The
White Plains Qualified Wheel is comprised
Case 1:20-cr-00330-PAE Document 204-1 Filed 04/16/21 Page 1 of 2
DOJ-OGR-00003174
Case 1:20-cr-00330-PAE
Document 204 Filed 04/16/21 Page 239 of 239
CONCLUSION
For the foregoing reasons, the Court should deny all twelve of the defendant’s pre-trial
motions.
Dated: New York, Ne
Case 1:20-cr-00330-PAE Document 204 _ Filed 04/16/21 Page 236 of 239
source list will be an exact statistical mirror of the community.” United States v. Guzman, 337 F.
Supp. 140, 143 (S.D.N.Y. 1972);
Case 1:20-cr-00330-PAE Document 204 _ Filed 04/16/21 Page 235 of 239
comparator is the jury eligible population of the five counties from which the White Plains Master
Wheel is drawn.
The American C
Case 1:20-cr-00330-PAE Document 204 _ Filed 04/16/21 Page 232 of 239
In sum, the decision to indict the defendant in White Plains was entirely proper, and the
lack of any constitutional or statutory
Case 1:20-cr-00330-PAE Document 204 _ Filed 04/16/21 Page 229 of 239
Because the defendant has no right to insist that either the grand or petit jury be drawn from
any particular geographic area with
Case 1:20-cr-00330-PAE Document 204 _ Filed 04/16/21 Page 228 of 239
courthouse, were drawn from Nassau and Suffolk Counties. /d. at 24. The defendant argued that
the district court erred by selectin
Case 1:20-cr-00330-PAE Document 204 _ Filed 04/16/21 Page 227 of 239
specific than the District where the offense was allegedly committed.”). Rather, “[c]ourts have
broad latitude in defining the geo
Case 1:20-cr-00330-PAE Document 204 _ Filed 04/16/21 Page 223 of 239
https://www.nysd.uscourts.gov/sites/default/files/pdf/juryplan feb 2009.pdf (the “SDNY Jury
Plan,” or the “Plan”).
Under the term
Case 1:20-cr-00330-PAE Document 204 _ Filed 04/16/21 Page 224 of 239
departments, and public officers in the executive, legislative, or judicial branches of the State or
Federal Government who are ac
Case 1:20-cr-00330-PAE Document 204 _ Filed 04/16/21 Page 218 of 239
anticipated witnesses available . . . ten days before trial. There is no need to depart from the
customary rule in this district o
Case 1:20-cr-00330-PAE Document 204 _ Filed 04/16/21 Page 219 of 239
Seventh, the defendant seeks a proffer of all co-conspirator statements that the Government
intends to offer at trial pursuant to
Case 1:20-cr-00330-PAE Document 204 _ Filed 04/16/21 Page 216 of 239
aware, consistent with the Rule 5(f) Brady order previously issued by the Court in this case. See
Fed. R. Crim. P. 5(f); Dkt. No.
Case 1:20-cr-00330-PAE Document 204 _ Filed 04/16/21 Page 211 of 239
with the regular practice in this District, the Government intends to make Section 3500 material
available to the defense at the s
Case 1:20-cr-00330-PAE Document 204 _ Filed 04/16/21 Page 210 of 239
Cir. 1990). Thus, “‘[iJn the absence of a specific showing that disclosure [of a witness list] [is]
both material to the preparati
Case 1:20-cr-00330-PAE Document 204 _ Filed 04/16/21 Page 208 of 239
and the Government has provided the defense with the
birth month and year of each minor victim.”
In other words, as the Governmen
Case 1:20-cr-00330-PAE Document 204 _ Filed 04/16/21 Page 194 of 239
404(b)(2); (ii) is relevant to the crime for which the defendant is on trial; (111) has probative value
that is not substantially
Case 1:20-cr-00330-PAE Document 204 _ Filed 04/16/21 Page 192 of 239
the Court informing the jury that, to convict on any conspiracy count, it must find at least one overt
act in furtherance of the c
Case 1:20-cr-00330-PAE Document 204 _ Filed 04/16/21 Page 189 of 239
public, and so punishable in itself”). Indeed, “[i]t is well settled that the essential elements of
the crime of conspiracy are: (
Case 1:20-cr-00330-PAE Document 204 _ Filed 04/16/21 Page 176 of 239
“such evidence might lead to evidence . . . which would justify forfeiture”). The jury need not
decide the outcome of the defamati
Case 1:20-cr-00330-PAE Document 204 _ Filed 04/16/21 Page 175 of 239
as to those counts, and would consent to a similar limiting instruction, which a jury would be
presumed to follow. And, of course,
Case 1:20-cr-00330-PAE Document 204 _ Filed 04/16/21 Page 173 of 239
in bankruptcy proceeding). And the cases the defendant cites in which a perjury or false statements
count was severed only undersc
Case 1:20-cr-00330-PAE Document 204 _ Filed 04/16/21 Page 166 of 239
F.2d at 929). Offenses may be joined “where the same evidence may be used to prove each count
or if the counts have a sufficient l