Subject: Jane Doe Case
Summary
Subject: Jane Doe Case Date: Mon, 23 Jan 2012 14:17:50 +0000 Importance: Normal Attachments: DE48-3_201 ictim_notification_Ittpdf; DE48- 4 20110321 icti n_ltr.pdf; DE48- 6 20110321 f• DE48- 7 20110321 forSpdf; DE48- 8 20110321 302 of from Jan 2008.pdf; DE48 20110321_Motn_for_finding_a_violation_of_CVRA.pdf; DE48- 2 20110321=M302.pdf Hi Ed - FINALLY, I found it. Now I know why the court wants us to make our documents searchable. See DE 48 at pages 3-4, paragraph #1. They specifically cite the Complaints and refer to Jane Does #1 and #2. On page 5, paragraph 4, they make clear that Jane Doe #1 is they attach as Exhibit B. They also explain that Jane Doe #1 is MI n d Jane Doe #2 is I by referring to their victim notification lette 5&6, paragraphs 6&7, which they attach as Exhibits C&D. (See also paragraph 37 and Exhibit H re Judge White granted my motion for extension of time this morning. I am running off to court now, but should be back by 11:15. Let me know how I
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Case 9:08-cv-80736-KAM Document 50
Case 9:08-cv-80736-KAM Document 50 Entered on FLSD Docket 0372112011 Page 1 of 15 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 08-80736-Civ-Marra/Johnson JANE DOE #1 and JANE DOE #2 v. UNITED STATES JANE DOE #1 AND JANE DOE #2'S MOTION FOR ORDER DIRECTING THE U.S. ATTORNEY'S OFFICE NOT TO WITHHOLD RELEVANT EVIDENCE COME NOW Jane Doe #1 and Jane Doe #2 (also referred to as "the victims"), by and through undersigned counsel, to move for an order from this Court directing the U.S. Attorney's Office not to suppress material evidence relevant to this case. The Court should enter an order, as it would in other criminal or civil cases, requiring the Government to make appropriate production of such evidence to the victims. BACKGROUND In discussions with the U.S. Attorney's Office about this case, counsel for Jane Doe #1 and Jane Doe #2 inquired about whether the Office would voluntarily provide to the victims information in its possession that was mater
UNITED STATES DISTRICT COURT
UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 08-80736-Civ-Marra/Johnson JANE DOES #1 and #2 I UNITED STATES DECLARATION OF BRADLEY J. EDWARDS, ESQ. I. I, Bradley J. Edwards, Esq., do hereby declare that I am a member in good standing of the Bar of the State of Florida. Along with co-counsel, I have represented Jane Doe #1 and Jane Doe #2 in civil suits against Jeffrey Epstein for sexually abusing them. I have also represented other girls who were sexually abused by Epstein. As a result of that representation, I have become familiar with many aspects of the criminal investigation against Epstein and have reviewed discovery and correspondence connected with the criminal investigation. I have also spoken to Jane Doe #1 and Jane Doe #2 at length about the criminal investigation and their involvement in it, as well enforcement (or lack their of) of their rights as crime victims in the investigation. I also represent Jane Doe #1 and Jane Doe #2 in the pen
Case 9:08-cv-80736-KAM Document 50
Case 9:08-cv-80736-KAM Document 50 Entered on FLSD Docket 0372172011 Page 1 of 15 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 08-80736-Civ-Marra/Johnson JANE DOE #1 and JANE DOE #2 1. UNITED STATES JANE DOE #1 AND JANE DOE #2'S MOTION FOR ORDER DIRECTING THE U.S. ATTORNEY'S OFFICE NOT TO WITHHOLD RELEVANT EVIDENCE COME NOW Jane Doe #1 and Jane Doe #2 (also referred to as "the victims"), by and through undersigned counsel, to move for an order from this Court directing the U.S. Attorney's Office not to suppress material evidence relevant to this case. The Court should enter an order, as it would in other criminal or civil cases, requiring the Government to make appropriate production of such evidence to the victims. BACKGROUND In discussions with the U.S. Attorney's Office about this case, counsel for Jane Doe #1 and Jane Doe #2 inquired about whether the Office would voluntarily provide to the victims information in its possession that was mater
UNITED STATES DISTRICT COURT
UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 013-80736-Civ-Marra/Nlatthewman JANE DOE 1 AND JANE DOE 2, Petitioners, vs. UNITED STATES, Respondent. DECLARATION OF IN SUPPORT OF GOVERNMENT'S RESPONSE AND OPPOSITION TO PETITIONERS' MOTION FOR PARTIAL SUMMARY JUDGMENT AND CROSS-MOTION FOR SUMMARY JUDGMENT do hereby declare that I am a member in good standing of the Bar of the State of Florida. I also am admitted to practice in all courts of the states of Minnesota and Florida, the Eighth, Eleventh, and Federal Circuit Courts of Appeals, and the U.S. District Courts for the Southern District of Florida, the District of Minnesota, and the Northern District of California. My bar admission status in California and Minnesota is currently inactive. I am currently employed as an Assistant United States Attorney in the Southern District of Florida and was so employed during all of the events described herein. 2. I am the Assistant United States Attorne
Subjec
Fr • < > Subjec :Deliberative t Process ec aratton rom am Justice - equest or wo ee xtension Date: Fri, 20 Sep 2013 17:59:47 +0000 Importance: Normal We have no objection, provided we get the following accommodation, which you already anticipated. We would request that your motion for extension of time give us an extension on our reply document, such that our reply would be due 10 days after the main Justice Department declaration that will be coming in two weeks. If you would include such language as well in any proposed order, saving us (and the court) drafting time, that would be very much appreciated. Paul Cassell and Brad Edwards for Jane Doe #1 and Jane Doe #2 Paul G Cassell CONFIDENTIAL: This electronic message along with any/all attachments is confidential. This message is intended only for the use of the addressee. If you are not the intended recipient, you may not use, disseminate, distribute or copy this communication. If you have received this message
Epstein Depositions
10. 11. 12. l3. 14. 16. 17. l8. 19. Jeffrey Epstein v. Bradley J. Edwards, et Case No.: 50 2009 CA Attachments to Statement of Undisputed Facts Deposition of Jeffrey Epstein taken March 17, 2010 Deposition of Jane Doe taken March 11, 2010 (Pages 379, 380, 527, 564?67, 568) Deposition of LM. taken September 24, 2009 (Pages 73, 74, 164, 141, 605, 416) Deposition ofE.W. taken May 6, 2010 (1 15, 1.16, 255, 205, 215?216) Deposition of Jane Doe #4 (32-34, 136) Deposition of Jeffrey Eps
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