Subject: Jane Does v. United States -- New Filing by Roy Black on Behalf of Epstein and his Counsel
Summary
Subject: Jane Does v. United States -- New Filing by Roy Black on Behalf of Epstein and his Counsel Date: Tue, 17 Apr 2012 22:13:21 +0000 Importance: Normal Attachments: pdf.pdf This just arrived via CM/ECF. Remember that Judge Marra just recently granted Epstein and his attorneys' motions to intervene. «pdtpdf» EFTA00205541
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UNITED STATES DISTRICT COURT
UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 08-80736-Civ-MarratIVIatthewman JANE DOE #1 AND JANE DOE #2, Petitioners, UNITED STATES OF AMERICA, Respondent. UNITED STATES' NOTICE OF FILING THIRD SUPPLEMENTAL PRIVILEGE LOG Pursuant to the Court's June 18, 2013 Omnibus Order (DE 190), the Respondent, United States of America, by and through the undersigned Assistant United States Attorney, hereby gives notice of its filing of its Third Supplemental Privilege Log. The index has been marked with Bates Numbers P-014924 thru P-015267. The documents referenced in the Third Supplemental Privilege Log will be delivered tomorrow to the Chambers of U.S. District Judge Kenneth A. Marra for ex parte in camera review, pursuant to the Court's Omnibus Order. Respectfully submitted, WIFREDO A. FERRER UNITED STATES ATTORNEY By: s/A. Marie Villafafia A. MARIE VILLAFAFIA Assistant United States Attorney Florida Bar No. 0018255 500 South Australian Ave, Suite 40
Memorandum
Memorandum Subject Re: Operation Leap Year Date May 1, 2007 (Revised 9/13/07) (2nd Revision 2/19/08)' To From R. Alexander Acosta, United States Attorney First Assistant United States Attorney Chief, Criminal Division MAUSA, Northern Region , Chief, Northern Region I. Introduction This memorandum seeks approval for the attached indictment char in Jeffrey Epstein, Min a/k/a' JEGE Inc., and Hyperion Air, Inc. The proposed indictment contains 60 counts and seeks the forfeiture of Epstein's Palm Beach home and two airplanes? The FBI has information regarding Epstein's whereabouts on May 16th and May 19th and they would like to arrest him on one of those dates. Epstein is considered an extremely high flight risk' and, from information we have received, a continued danger 'The second revision amends the Jane Doe numbering system to correspond with the most recent indictment. It also removes the references to the overt acts and substantive allegations related to each
5122 a 2, 1:31 PM
5122 a 2, 1:31 PM WIKIPEDIA Jeffrey Epstein - Wikipedia Jeffrey Epstein Jeffrey Edward Epstein (flpstin/ EP-steenAl January 20, 1953 — August to, 2019) was an American financier and convicted sex offender.13)[4] Epstein, who was born and raised in Brooklyn, New York Citr, began his professional life by teaching at the Dalton School in Manhattan, despite lacking a college degree. After his dismiccsl from the school, he entered the banking and finance sector, working at Bear Stearns in various roles; he eventually started his own firm. Epstein developed an elite social circle and procured many women and children; he and some of his associates then sexually abused them Is&DNA. In zoo ice in Palm Beach Florida be an investi atin Epstein after a parent complained that he had sexually abused her 14-year-old dauv,hter.g. Epstein pleaded guilty and was convicted in 2008 by a Florida state court of procuring a child for prostitution and of soliciting a prostitute.a-9.1 He ser
Bcc: "Acosta, Alex (USAFLS)"
From To Cc: Bcc: "Acosta, Alex (USAFLS)" Roy BLACK' Subject: Reply Brief in Jane Does I United States Date: Thu, 16 Oct 2008 20:23:13 +0000 Importance: Normal Attachments: DE30_081016_Reply_re_Motn_Unseal.pdf; DE30-2_081016_Ex_tpdf; DE30- 3_081016_Ex_2.pdf Dear Roy and Jay: I am attaching the reply brief filed by Brad Edwards with two pieces of correspondence that he attached to his pleading as exhibits. I had not seen Mr. Edwards' October 15th letter before he filed it in connection with his Reply, so I do not know whether Mr. Lee has even received it yet. Mr. Edwards argues that Mr. Epstein has no interest in keeping the agreement confidential because he has not responded to Mr. Edwards' motion to unseal. As you know, in our Response, the United States argued that this issue should be litigated in one of the suits filed by Mr. Edwards against Mr. Epstein. Mr. Edwards apparently believes it is to his benefit to argue these issues, instead, in his lawsuit against the Un
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
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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