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efta-efta00030763DOJ Data Set 8Correspondence

EFTA00030763

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DOJ Data Set 8
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efta-efta00030763
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EFTA Disclosure
Text extracted via OCR from the original document. May contain errors from the scanning process.
Declaration of Custodian of Records Pursuant to 28 U.S.C. § 1746, I, the undersigned, hereby declare: My name is (name of declarant) I am a United States citizen and I am over eighteen years of age. I am a custodian of records of the business named below (the "Business"), or I am otherwise qualified as a result of my position with the Business to make this declaration. I have reviewed records' of the Business, which have been provided to law enforcement in connection with an investigation and prosecution by the United States Attorney's Office for the Southern District of New York. Those records consist of the following (collectively, the "Records"): AT&T Wireless invoice dated May 5, 2004 for account number 0043811863 in the name of Jeffrey E Epstein Pursuant to Rules 902(11) and 803(6) of the Federal Rules of Evidence, I hereby certify that the foregoing Records of the Business: (1) were made at or near the time of the occurrence of the matters set forth in the records, by, or from information transmitted by, a person with knowledge of those matters; (2) were kept in the course of regularly conducted business activity; and (3) were made by the regularly conducted business activity as a regular practice. I declare under penalty of perjury that the foregoing is true and correct. Executed on (date) (signature of declarant) (name and atk of declarant) (name of business) (business address) I As defined in Fed. R. Evid. 803(6), "record" includes a memorandum, report, record, or data compilation, in any form, of acts, events, conditions, opinions, or diagnoses. The term "business" as used in Fed. R. Evid. 803(6) and the above declaration includes business, institution, association, profession, occupation, and calling of every kind, whether or not conducted for profit. EFTA00030763

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reached in this case, and other information in the possession of the victims, it is also possible that

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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