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From: ' To: Brad Edwards <brad®eplIc.com> Cc: ' " Subject: RE: July 14th hearing Date: Thu, 09 Jul 2020 23:37:52 +0000 Attachments: 2020.07.09_Scheduling_Order.pdf Brad, Attached is a scheduling order the Court issued this evening. It contains the dial-in instructions for individuals who wish to hear the audio feed of the conference, as well as information about the Court's overflow room for anyone who wishes to observe the video feed there. If possible, we would like to let the Court know tomorrow whether victims wish to exercise their right to be heard at the hearing, so that the Court can make the necessary arrangements, but we recognize you may still be discussing that matter with Ms Please feel free to reach out to our team at any point if you have questions. Thanks, From: Sent: Wednesday, July 8, 2020 3:02 PM To: Brad Edwards <[email protected]> Cc: Subject: July 14th hearing >; Brad, Attached is a copy of the Court's scheduling order, in case this is helpful.
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From: Paul Cassell •ci
From: Paul Cassell •ci To: "IN (USAFLS)" ' Cc: , • (USAFLS)" USAFLS)" >, Brad Edwards Subject: RE: Judge Marra's Order Granting the Victims Motion to Compel Discovery Within 30 Days Date: Tue, 25 Jun 2013 00:46:56 +0000 Importance: Normal Attachments: ORDER-omnibus-wrapup.pdf [tried to send this earlier, but it may not have gone out] Dear We haven't seen the sealed order granting the Government's motion for stay either. (Have you?). But, in any event, Judge Marra's order on June 19, 2013 (DE 190) specifically stated that "The petitioners' motion to compel discovery from the Government [DE 130] is GRANTED. Within THIRTY (30) DAYS from the date of entry of this order, the Government shall . . . [produce various discovery]." For your convenience, I attach a copy of DE 190 ordering the Government to produce discovery within 30 days. So we are expecting to see you produce the bulk of our discovery on July 19, 2013, as specifically directed in DE 190 which granted our mo
(USAFLS)" </DI
From: (USAFLS)" </DI To: "Brad Edwards Subject: Confidential Settlement Negotiations Date: Sat, 25 Jun 2016 20:17:08 +0000 Importance: High Attachments: Proposed_Order_Approving_Stip_for_Dismissal.pdf; Proposed_Stipulation_for_Dismissal.pdf; USAO_Letter_to Jane_Doe_l_-_06-22- 2016_with_watermark.pdf; 20160625_Jane_Doe_Settlement_Agreement.pdf Ili Brad —I am sending you our complete packet, that is: (1) Proposed Settlement Agreement, including title of DOJ official for meeting (2) Proposed Stipulation of Dismissal and Order accepting it (this would be Appendix "B") (3) Proposed letter (this would be Appendix "C") Sealed Appendix A is the victim list from you with my one addition. I need from you: Appendix D (proposed amendments to the "Attorney General Guidelines for Victim and Witness Assistance" and to the procedures for filing complaints with the Justice Department's Crime Victims' Rights Ombudsman) Appendix E (proposed amendments to the U.S. Attorney's Manual) I am
Deutsche Bank Epstein victim questionnaire
EXHIBIT A-1 Case 1:22-cv-10018-JSR Document 90-2 Filed 06/16/23 Page 1 of 12 1 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK Case No. 1:22-CV-10018 (JSR) NOTICE OF PROPOSED SETTLEMENT OF CLASS ACTION TO: ALL VICTIMS OF JEFFREY EPSTEIN’S SEX TRAFFICKING VENTURE DURING THE TIME PERIOD AUGUST 19, 2013 TO AUGUST 10, 2019 (THE “CLASS PERIOD”). IN ORDER TO QUALIFY FOR A SETTLEMENT PAYMENT, YOU (OR CLASS COUNSEL ON YOUR BEHALF) MUST TIMELY SUBMIT A TIER ONE FORM BY ___________, 20
To: "Paul Cassell"
From: To: "Paul Cassell" Cc: ' "Brad Edwards" Subject: : ovemments osition on Several Pending Issues? Still Waiting for Answer Date: Thu, 17 Mar 2011 16:56:28 +0000 Importance: Normal Paul, 1. Yesterday, I provided you with the name and phone number for OPR Acting Associate Counsel, who received your December 10, 2010 letter to Mr. Ferrer, asking for an investigation of the Jeffrey Epstein prosecution. 2. The government will not be making initial disclosures to plaintiffs, because we do not believe Fed.R.Civ.P. 26 applies to this matter. 3. The CVRA applies to the criminal case which has been filed in district court, where an individual is deemed to be a "victim," not any civil litigation which may be initiated to enforce those claimed rights. We do not believe there is any right to discovery in this case. Moreover, we do not believe that whatever Kenneth Starr or Lilly Ann Sanchez may have said to this office, or what this office said to Kenneth Starr or Lilly Ann S
UNITED STATES DISTRICT COURT
UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 08-80736-Civ-Marra/Johnson JANE DOES #1 and #2 I UNITED STATES DECLARATION OF BRADLEY J. EDWARDS, ESQ. I. I, Bradley J. Edwards, Esq., do hereby declare that I am a member in good standing of the Bar of the State of Florida. Along with co-counsel, I have represented Jane Doe #1 and Jane Doe #2 in civil suits against Jeffrey Epstein for sexually abusing them. I have also represented other girls who were sexually abused by Epstein. As a result of that representation, I have become familiar with many aspects of the criminal investigation against Epstein and have reviewed discovery and correspondence connected with the criminal investigation. I have also spoken to Jane Doe #1 and Jane Doe #2 at length about the criminal investigation and their involvement in it, as well enforcement (or lack their of) of their rights as crime victims in the investigation. I also represent Jane Doe #1 and Jane Doe #2 in the pen
Florida Office
Cr 1) '.1.d Florida Office Bradley J. Edwards *Ol Seth M. Lehrman 't Brittany N. Henderson *0 Matthew D. Weissing EDWARDS POTTINGER LLC October 21, 2020 FOIA PRIVACY EXEMPTION VIA E-MAIL AND FEDEX The Honorable Geoffrey S. Berman United States Attorney for the Southern District of New York Assistant United States Attorney 86 Chambers Street, Third Floor New York. New York 10007 Dear New York Office J. Stanley Pottinger j Admitted in California 0 Admitted in I>istrict of Columbia • Admitted m Florida t Admitted in New York Beard (:crtified Civil Trial lau)rr Re: Re tuest for Tangible and Documentary Evidence (Touhy Request) Doe v. Darren K. Indyke, et al., SDNY Case No. 1:19-cv-07773 Victim: In follow up to our previous communications, please accept this as our formal written request for documentary and tangible evidence currently in the in the possession, custody, and control of the Department of Justice by way of the Southern District of New York relatin
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