Subject: Re:
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From: To: Cc: Subject: Re: Motion Date: Fri, 03 Apr 2020 18:40:13 +0000 Many thanks Yes, it will be entirely under seal. I'm waiting to hear back from that, I will file. Hopefully soon Please stay safe and thanks very much for getting back to me so quickly. Sarah Sarah Coyne Partner Weil, Gotshal & Manges LLP New York, NY 10153 to see what her position will be on it and as soon as I know On Apr 3, 2020, at 2:38 PM, wrote: Hi Sarah, Thank you, we hope you are safe and well too. We will review this. For planning purposes, when do you intend to file this, and would it (or at least this portion) be under seal? Thanks. From: Coyne, Sarah Sent: Friday, April 3, 2020 12:16 PM To Subject Motion Hi I hope this email finds you and your families safe and healthy. EFTA00098447 As you also know, has attempted to cooperate on a number of matters at the SDNY, including with the investigation into the events surrounding Jeffrey Epstein's death. In light of all these ci
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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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