EXHIBIT A
Summary
EXHIBIT A EFTA00095741 To: Gmax From: Jeffrey Epstein Sent: Fri 7/31/2009 3:48:17 PM Subject: Re: no there is no criminal anything„ we can file a rotective order, saying you were nowhere near the person during the relevant dates.. you will never have to testify.. it is the same as if sued you for harrasment On Fri, Jul 31, 2009 at 11:24 AM, Gmax < › wrote: If I get served what does it mean - I have a set court date to attend and ans questions about you - a grand jury - or what? — Original Message --- From: Jeffrey Epstein To: Gmax Sent: Thu Jul 30 23:08:22 2009 Subject: Re: its a different lawsuit„ they are serving anyone they have read about On Thu, Jul 30, 2009 at 9:25 PM, Gmax < wrote: He came to the house and asked if I was there - sounded like the description of guy who tried to serve it had jane doe and my name on it Original Message — From: Gmax To:' Sent: u u Some guy apparently is trying to serve me win subpeoena..what is this about CONFIDENTIAL
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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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