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efta-efta00017781DOJ Data Set 8Correspondence

EFTA00017781

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EFTA Disclosure
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STATE OF NEW MEXICO OFFICE OF THE ATTORNEY GENERAL HECTOR H. BALDERAS ATTORNEY GENERAL September 1 7, 2019 Assistant United States Attorney Southern District of New York I St. Andrew's Plaza New York, NY 10007 Via email & U.S Mail Re: Continued investigation into possible collaborators of Jeffrey Epstein Dear Thank you for speaking with myself and others from the New Mexico Office of the Attorney General last week. Pursuant to our telephone conversation, this Office is providing the enclosed materials related to the criminal investigation and potential prosecution of Jeffrey Epstein's co-conspirators. The enclosed documents include police reports, recorded witness interviews, correspondence amongst New Mexico State agencies, and documents related to Epstein's leasing of New Mexico public lands. As previously discussed, all conduct described in our investigation occurred prior to 2008, the year New Mexico enacted its human-trafficking statute. See NMSA 1978, Sections 30-52-1 to -2.1. Should you have any questions, require any law-enforcement assistance in New Mexico, or become aware of any criminal charges implicating New Mexico law not barred by New Mexico's statute of limitations, NMSA 1978, Section 30-1-8, I ask that you do not hesitate to contact me directly. Should further investigation reveal additional survivors of crimes occurring in New Mexico, know that this Office intends to work in union with the United States Attorney for the District of New Mexico to ensure that these brave survivors have the opportunity to see that justice is achieved in a court of law. Again, please contact me personally if your investigation reveals survivors of crimes occurring in New Mexico not mentioned in the provided investigative materials. TOLL FREE 1-844-255-9210 TELEPHONE: (505)490-4060 FAX: (505)490-4883 www.nmag.gov MAILING ADDRESS: P.O. DRAWER 1508 - SANTA FE, NEW MEXICO 87504-1508 STREET ADDRESS: 408 GALISTEO STREET - SANTA FE, NEW MEXICO 87501 EFTA00017781 Epstein's death should not be the end of this criminal inquiry. I thus thank you for continuing to give this serious matter the attention it deserves. This Office will continue to update you in a timely manner should we become aware of any new information that could be assistive to you. Respectfully, Clara Moran Chief Deputy Attorney General EFTA00017782

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reached in this case, and other information in the possession of the victims, it is also possible that other improper relationships exist between Government agents and Epstein. Please provide any documents, correspondence, and other information regarding the possibility of any improper relationship, including: a) involvement in and/or awareness of any aspect of the Government's criminal investigation and/or possible prosecution/non-prosecution of Epstein; b) Attorney liklimenvolvement in and/or awareness of the Government's interest."( witness, subject, or target of the Epstein investigation, including Sarah Ghislaine Maxwell, Nadia Marcinkova, Lesley Groff, Haley Robson, Louella Ruboyo, Larry Morrison, Larry Visoki, David Rogers, William Hammond, and Robert Roxburgh; c) All documents, correspondence, and other information reflecting telephone calls (includin telephone logs and telephone billing statements) made by or received by m Jeffrey Epstein, the Florida Science

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Case 9:08-cv-80736-KAM Document 435 Entered on FLSD Docket 02/21/2019 Page 1 of 33

Case 9:08-cv-80736-KAM Document 435 Entered on FLSD Docket 02/21/2019 Page 1 of 33 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 08-80736-CIV-MARRA JANE DOE 1 AND JANE DOE 2, Petitioners, vs. UNITED STATES, Respondent. OPINION AND ORDER This cause is before the Court upon Jane Doe 1 and Jane Doe 2's Motion for Partial Summary Judgment (DE 361); the United States's Cross-Motion for Summary Judgment (DE 408); Jane Doe 1 and Jane Doe 2's Motion to Compel Answers (DE 348) and Jane Doe 1 and Jane Doe 2's Motion for Finding Waiver of Work Product and Similar Protections by Government and for Production of Documents (DE 414). The Motions are fully briefed and ripe for review. The Court has carefully considered the Motions and is otherwise fully advised in the premises. I. Background The facts, as culled from affidavits, exhibits, depositions, answers to interrogatories and reasonably inferred, for the purpose of these motions, are as follows: From betw

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