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efta-efta00162956DOJ Data Set 9Other

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From: " To: Cc: "- Subject: FW: Media Request Date: Thu, 24 Jan 2019 20:24:23 +0000 Importance: Normal FYI only. From: Sent: Thursday, January 24, 2019 3:24 PM To: 'Hakimah Shah' <[email protected]> Cc: Subject: RE: Media Request Hakimah, Thank you for your interest in the FBI. Unfortunately, we have to decline your request for interview given the ongoing litigation in this matter. Regards, Public Information Officer FBI Miami From: Hakimah Shah [mailto:[email protected]] Sent: Wednesday, January 23, 2019 4:16 PM To: Subject: Media Request Hello My name is Hakimah Shah. I'm a producer at Radical Media. We are developing a series about wealth and justice in America - part of which focuses on convicted sex offender, Jeffrey Epstein. I am writing to request an interview with you and/or one of the bureau's agents who was involved in the Jeffery Esptein investigation for our series. The F.B.I.'s voice is integral to our story and hope that you will consider

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From: " To: Cc: "- Subject: FW: Media Request Date: Thu, 24 Jan 2019 20:24:23 +0000 Importance: Normal FYI only. From: Sent: Thursday, January 24, 2019 3:24 PM To: 'Hakimah Shah' <[email protected]> Cc: Subject: RE: Media Request Hakimah, Thank you for your interest in the FBI. Unfortunately, we have to decline your request for interview given the ongoing litigation in this matter. Regards, Public Information Officer FBI Miami From: Hakimah Shah [mailto:[email protected]] Sent: Wednesday, January 23, 2019 4:16 PM To: Subject: Media Request Hello My name is Hakimah Shah. I'm a producer at Radical Media. We are developing a series about wealth and justice in America - part of which focuses on convicted sex offender, Jeffrey Epstein. I am writing to request an interview with you and/or one of the bureau's agents who was involved in the Jeffery Esptein investigation for our series. The F.B.I.'s voice is integral to our story and hope that you will consider participating - at the very minimum, off camera. Below I have provided some information about our production company. About Radical Media: Radical Media is an Oscar®, Emmy®, Grammy® and Peabody® Award-winning studio whose work includes the Oscar®- winning documentary, The Fog of War, Oscar®-nominated and Emmy®-winning film, What Happened, Miss Simone? Among others. Additionally, the executive producer of this program is Joe Berlinger — a recognized pioneer in the genre of true crime documentaries. He has drawn attention to social justice issues in the U.S. and abroad in landmark films such as: Brother's Keeper, a DGA Award-winner and his trilogy for HBO titled Paradise Lost, about the West Memphis Three, (a group of teenage boys sentenced to death and life imprisonment for crimes they didn't commit). The Paradise Lost series is widely credited with helping to win the release of the wrongfully convicted boys, and won both Emmy and Peabody Awards, and earned Berlinger an Academy Award® nomination. EFTA00162956 We plan to film in the South Florida area this spring. In the meantime, it would be great to know if this is something you can speak on publicly and if any of the investigators who worked the case would be available for a call and possibly on camera. Please let me know there are further questions. I look forward to your response. Best, Hakimah Shah Producer office: 212-462-1667 cell: 917-767-1729 EFTA00162957

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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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