June 24, 2021 Juan Alessi prep

UNITED STATES DISTRICT COURT

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 08-80736-CI V-Marra/Matthewman JANE DOE # I and JANE DOE #2, Petitioners, I UNITED STATES OF AMERICA, Respondent. UNITED STATES' RESPONSE TO PETITIONERS' FIRST REOUEST FOR ADMISSIONS TO THE GOVERNMENT The United States (hereinafter the "government") hereby responds to Jane Doe #1 and Jane Doe #2's First Request for Admissions to the Government Regarding Questions Relevant to Their Pending Action Concerning the Crime Victims Rights Act (hereinafter the "Request for Admissions"), and states as follows:' I. The government admits that the FBI and the U.S. Attorney's Office for the Southern District of Florida ("USAO") conducted an investigation into Jeffrey Epstein ("Epstein") and developed evidence and information in contemplation of a potential federal prosecution against Epstein for many federal sex offenses. Except as otherwise admitted above, the government denies Request No. I. The government's res

EFTA01317277

The document is a letter from the US Department of Justice to Judge Alison J. Nathan, arguing for th...

The document is a letter from the US Department of Justice to Judge Alison J. Nathan, arguing for the authentication and admissibility of Government Exhibit 52, a contact book belonging to Ghislaine Maxwell, based on the testimony of Juan Alessi, a former employee of Jeffrey Epstein and Maxwell. The letter discusses the applicable law and provides details on Alessi's testimony, which identifies the contact book and corroborates its relevance to the case.

CONFIDENTIAL TREATMENT REQUESTED /

CONFIDENTIAL TREATMENT REQUESTED / FED. R. CRIM. P. 6(e) MATERIAL BSF RESPONSE TO GRAND JURY SUBPOENA v. Maxwell, 15 Civ. 7433 (RWS), S.D.N.Y. In Re: Grand Jury Subpoena, Sealed Order, 19 Misc. 149 (Apr. 9, 2019) PLEADINGS AND ORDERS 2016-2018 Pleadings (Related Sealed) 2015-2018 Orders (Related Sealed) DISCOVERY Rule 26 Disclosures (All) Discovery Requests and Responses (served) PRODUCTIONS Plaintiff's Production 000001 009349 Defendant's Productions MAXWELL 00001 01364 Non-Party Productions CASSELL 000001 014402 MAR-A-LAGO 0001 0607 000001 000558 000001 000009 VICTIMS_REFUSE_SILENCE 0001 0091 Deposition Transcripts (ALL) April 22, 2016 De osition of Ghislaine Maxwell May 3, 2016 Deposition of May 18, 2016 Deposition of May 20, 2016 Deposition of Sky Roberts May 24, 2016 Deposition of Lynn Trude Miller May 26, 2016 Deposition of Dr. Steven Olson June 1, 2016 Deposition Transcript of Juan Alessi June 3, 2016 Deposition of David Rodgers

Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 1 of 70

Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 1 of 70 EXHIBIT A PRIVILEGE LOG - WITH VICTIMS' OBJECTIONS EFTA00208682 Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 2 of 70 PRIVILEGE LOG - WITH VICTIMS' OBJECTIONS Key to Objections (linking to Victims' Motion to Compel Production of Docments that Are Not Prig ileged Objection General Objections -- Inadequate Privilege Log Failure to Prove Factual Underpinnings of Privilege Claim Waiver of Confidentiality Government's Fiduciary Duty to Crime Victims Bars Privilege Communications Facilitating Crime-Fraud-Misconduct Not Covered Factual Materials Not Covered Documents Not Prepared in Anticipation of CVRA Litigation Attorney Client Objections - Ordinary Governmental Communications Not Covered Attorney-Client Relationship Not Established Deliberative Process Objections - Privilege Not Properly Invoked Final Decision Exempted from Privilege Qualified Privilege Ove

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