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efta-efta00098447DOJ Data Set 9Other

Subject: Re:

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DOJ Data Set 9
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EFTA 00098447
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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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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 circumstances, I am going to be filing a motion to have sentence reduced. I have discussed this with EDNY AUSA and provided her with a draft of the motion. It is my great hope that she will join in it. I am attaching here the portion of the motion that discusses her assistance to your investigation for two reasons. First, I don't want to misrepresent/misstate any aspect of her assistance or characterize your position on it in any way that you disagree with. Second, while I understand you might not feel a Rule 35 motion is merited, I am hoping you will agree to advise the Court (or allow me to) that she did try to assist you. Please let me know your thoughts. I am happy to discuss by phone, as well. I should note that the motion will be filed under seal. Stay safe, Sarah The information contained in this email message is intended only for use of the individual or entity named above. If the reader of this message is not the intended recipient, or the employee or agent responsible to deliver it to the intended recipient, you are hereby notified that any dissemination, distribution or copying of this communication is strictly prohibited. If you have received this communication in error, please immediately notify us by email, and destroy the original message. Thank you. The information contained in this email message is intended only for use of the individual or entity named above. If the reader of this message is not the intended recipient, or the employee or agent responsible to deliver it to the intended recipient, you are hereby notified that any dissemination, distribution or copying of this communication is strictly prohibited. If you have received this communication in error, please immediately notify us by email, and destroy the original message. Thank you. EFTA00098448

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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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