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Correspondence · July 9, 2008

Email chain among federal prosecutors on filing a response under seal, July 2008

Email chain among prosecutors including Alex Acosta discussing DOJ clearance, victim-witness provisions, and a motion to seal the government's court response.Machine-written summary

EFTA00180099

Villafana, Ann Marie C. (USAFLS)

From:Lee, Dexter(USAFLS)
Sent:Wednesday,July09,20083:10PM
To:Villafana,Ann Marie C.(USAFLS)
Subject:RE:Revised Draft with DOJ Edits

Marie,

Yes, we are ready to file. As far as statutory authority, we can cite the Privacy Act, 5 U.S.C. 552a, et. Seq. Also, are there any special victim-witness provisions regarding restrictions on disclosure of victims’ names and personal identifying information?

Dexter

From:Villafana, Ann Marie C. (USAFLS)
Sent:Wednesday, July 09, 2008 3:06 PM
To:Lee, Dexter (USAFLS)
Subject:RE: Revised Draft with DOJ Edits

Hi Dexter – Does this mean your response is good to go? On the sealed document tracking form, is there a particular statute or rule that you think gives us the right to file under seal? Thank you.

A. Marie Villafaña

Assistant U.S. Attorney

561 209-1047

From: Lee, Dexter (USAFLS)

Sent: Wednesday, July 09, 2008 3:04 PM
To: Herd, Kim(USAEO); Villafana, Ann Marie C.(USAFLS); Acosta, Alex(USAFLS); Sloman, Jeff(USAFLS)
Cc: Jacobus, Wendy(USAFLS); Rothenberg, Laurence E(SMO); Wood,Seth M(SMO); Neal, Kristina(USAEO); Manning, Katharine(USAEO)

Subject: RE: Revised Draft with DOJ Edits

Kim,

Thanks to you, Kristina and Katherine for all your help. We’ll let you know what happens.

Dexter

From: Herd, Kim (USAEO)

Sent: Wednesday, July 09, 2008 3:02 PM

To: Lee, Dexter (USAFLS); Villafana, Ann Marie C. (USAFLS); Acosta, Alex (USAFLS); Sloman, Jeff (USAFLS)

Cc: Jacobus, Wendy (USAFLS); Rothenberg, Laurence E (SMO); Wood, Seth M (SMO); Neal, Kristina (USAEO); Manning, Katharine (USAEO)

Subject: RE: Revised Draft with DOJ Edits

571

EFTA00180100

We have checked with OLP and they have cleared the language in your latest revision (per your e-mail below).

Please let us know if you have additional questions.

Thank you for your patience on this –

Kim

From: Lee, Dexter (USAFLS)

Sent: Wednesday, July 09, 2008 2:26 PM

To: Herd, Kim(USAEO); Neal, Kristina(USAEO); Villafana, Ann Marie C.(USAFLS); Acosta, Alex(USAFLS); Sloman, Jeff(USAFLS)

Cc: Jacobus, Wendy (USAFLS)

Subject: Revised Draft with DOJ Edits

Colleagues,

Attached please find the latest revision, which includes the edits suggested by EOUSA. I have also incorporated the word “place”, per Jeff’s suggestion. For our DOJ colleagues, there is a new Section III, which goes into detail regarding the contact Marie had with the three victims.

Also, as to whether Edwards raises the right to fairness being violated, I was referring to paragraph five of the emergency petition, which only alleges violations of the right to consultation, notice of public court proceedings, information regarding right to restitution, and notice of rights under the CVRA.

A motion to seal has been prepared, seeking leave of the Court to seal the government’s response, Marie’s declaration, and the attachments to the declaration.

Dexter Lee

<< File: victim_resp_USArev corrected_DOJedits.wpd >>

572

Email chain among federal prosecutors on filing a response under seal, July 2008

Emails and letters

Email chain among prosecutors including Alex Acosta discussing DOJ clearance, victim-witness provisions, and a motion to seal the government's court response.

DOJ Epstein Files, Data Set 9 · July 9, 2008

EFTA00180099 Villafana, Ann Marie C. (USAFLS) <table border="1" <tr <td From:</td <td Lee, Dexter(USAFLS)</td </tr <tr <td Sent:</td <td Wednesday,July09,20083:10PM</td </tr <tr <td To:</td <td Villafana,Ann Marie C.(USAFLS)</td </tr <tr <td Subject:</td <td RE:Revised Draft with DOJ Edits</td </tr </table Marie, Yes, we are ready to file. As far as statutory authority, we can cite the Privacy Act, 5 U.S.C. 552a, et. Seq. Also, are there any special victim-witness provisions regarding restrictions on disclosure of victims' names and personal identifying information? Dexter <table <thead <tr <t…