Villafana, Ann Marie C. (USAFLS)¶
From: Villafana, Ann Marie C. (USAFLS) Sent: Thursday, September 20, 2007 5:33 PM To: Lourie, Andrew Subject: RE: Draft Plea Agreement¶
I usually start with, “If the case had gone to trial, the United States would prove the following facts beyond a reasonable doubt.” I am just looking forward to hearing what Sarah and Nadia actually tell us.¶
A. Marie Villafaña Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 Phone 561 209-1047 Fax 561 820-8777¶
-----Original Message----- From: Lourie, Andrew Sent: Thursday, September 20, 2007 5:10 PM To: Villafana, Ann Marie C. (USAFLS) Subject: RE: Draft Plea Agreement¶
Can we say “this is what the evidence would show if this case went to trial”?¶
-----Original Message----- From: Villafana, Ann Marie C. (USAFLS) [mailto:Ann.Marie.C.Villafana@usdoj.gov] Sent: Thursday, September 20, 2007 3:34 PM To: Lourie, Andrew Subject: RE: Draft Plea Agreement¶
This is what I wrote up, but it is based solely on what Jay has told me. The agents have to actually interview Kellen and Marcinkova before I can finalize this.¶
A. Marie Villafaña Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 Phone 561 209-1047 Fax 561 820-8777¶
-----Original Message----- From: Lourie, Andrew Sent: Thursday, September 20, 2007 2:54 PM To: Villafana, Ann Marie C. (USAFLS)¶
3017¶
08-80736-CV-MARRA¶
P-014150¶
EFTA00189159¶
Subject: RE: Draft Plea Agreement¶
Pls send me your factual proffer¶
| -----Original Message---- |
| From: Villafana, Ann Marie C. (USAFLS) [mailto:Ann.Marie.C.Villafana@usdoj.gov] |
| Sent: Wednesday, September 19, 2007 4:06 PM |
| To: Garcia, Rolando (USAFLS); Lourie, Andrew |
| Subject: FW: Draft Plea Agreement |
Here are their new versions.¶
A. Marie Villafaña¶
Assistant U.S. Attorney¶
561 209-1047¶
-----Original Message-----¶
From: Jay Lefkowitz [mailto:JLefkowitz@kirkland.com]¶
Sent: Wednesday, September 19, 2007 3:44 PM¶
To: Villafana, Ann Marie C. (USAFLS)¶
Subject: Fw: Draft Plea Agreement¶
Confidential¶
For settlement purposes only¶
Marie - I wanted to get this to you before I took off for nyc. I am landing at 7 and would like to speak shortly thereafter.¶
I am still considering which of the options you suggested Sunday. In this email, I am sending you a redline of your federal resolution. I am also working on a deferred prosecution agreement because it may well be that we cannot reach agreement here. I don’t think there are that many issues left open, although clearly we still need to have further discussions. I also like your suggestion from Sunday that we consider a C plea.¶
I know that Alex would have to sign off on it and that he has not done so as of now.¶
Regarding my schedule, I am available tonight to speak, all afternoon tomorrow (I am in fed court in nyc on another criminal matter tomorrow am), and then all day Friday.¶
I will plan on seeing you Monday. I am confident that one of the approaches we have discussed will work out.¶
Jay¶
----- Original Message -----¶
3018¶
08-80736-CV-MARRA¶
P-014151¶