Subject: FW: Jane Doe #1 and Jane Doe #2 vs. US
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From: To: Subject: FW: Jane Doe #1 and Jane Doe #2 vs. US Date: Mon, 03 Oct 2011 19:42:49 +0000 Importance: Normal Attachments: Plaintiffs_lst_RFP_to_US_ATTY.pdf Inline-Images: image001 jpg Hi everyone — I am forwarding to you the Jane Does first Requests for Production of Documents, which just arrived. This will give us some context for our discussion on Wednesday. Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 Fax From: Maria Kelljchian [mailto:[email protected]] Sent: Monday, October 03, 2011 2:06 PM To: Villafana, Ann Marie C. (USAFLS); Lee, Dexter (USAFLS);[email protected]' Cc: 'Paul Cassell'; [email protected] Subject: Jane Doe #1 and Jane Doe #2 vs. US Attached please find: JANE DOE #1 AND JANE DOE #2'S FIRST REQUEST FOR PRODUCTION TO THE GOVERNMENT REGARDING INFORMATION RELEVANT TO THEIR PENDING ACTION CONCERN THE CRIME VICTIMS RIGHTS ACT Copy has also been sent via US Mail today. Maria W. Kelljchian Flor
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Case 9:08-cv-80736-KAM Document 212-1 Entered on FLSD Docket 07/19/2013 Page 1 of 23
Case 9:08-cv-80736-KAM Document 212-1 Entered on FLSD Docket 07/19/2013 Page 1 of 23 PRIVILEGE LOQ Bates Range Description Privilege(s) Asserted Box #1 P-000001 thru P-000039 Box #1 P-000040 thru P-000549 File folder entitled "CORR RE GJ SUBPOENAS" containing correspondence related to various rand jury subpoenas and attorney handwritten notes 6(e) Work Product Operation Leap Year Grand Jury Log containing subpoenas OLY-01 through OLY-81, correspondence and research related to enforcement of same, documents produced in response to some subpoenas; and attorney ( ) handwritten notes 6(e) Work Product Contains documents subject to investigative privilege Also contains documents subject to privacy rights of victims who are not parties to this litigation Box #1 P-000550 thru P-000621 File folder entitled "Ritz Compact Flash SW" containing copies of a sealed search warrant application, warrant, and supporting documents 6(e) Contains information subjec
Case 9:08-cv-80736-KAM Document 225-1 Entered on FLSD Docket 08/16/2013 Page 1 of 64
Case 9:08-cv-80736-KAM Document 225-1 Entered on FLSD Docket 08/16/2013 Page 1 of 64 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 08-80736-Civ-Marra/Johnson JANE DOE No. 1 and JANE DOE No. 2 v. UNITED STATES AFFIDAVIT OF BRADLEY J. EDWARDS, ESQ. REGARDING NEED FOR PRODUCTION OF DOCUMENTS 1. 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 represent Jane Doe No. 1 and Jane Doe No. 2 (as referred to as "the victims") in the above-listed action to enforce their rights under the Crime Victims Rights Act (CVRA). I also represented them (and several other victims) in civil suits against Jeffrey Epstein for sexually abusing them. I am also familiar with the criminal justice system, having served as state prosecutor in the Broward County State Attorney's Office. 2. This affidavit covers factual issues regarding the Government's assertions of privilege to more tha
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
Virginia Roberts v. Alan Dershowitz – Allegations of Sex Trafficking, NPA Manipulation, and Defamation
The complaint provides a dense web of alleged connections between Alan Dershowitz, Jeffrey Epstein, former U.S. Attorney Alexander Acosta, and the 2008 non‑prosecution agreement (NPA). It cites specif Roberts alleges she was trafficked by Epstein from 2000‑2002 and forced to have sex with Dershowitz. Dershowitz is accused of helping draft and pressure the government into the 2008 NPA that shielded
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
Case 9:08-cv-80736-KAM Document 216 Entered on FLSD Docket 07/27/2013 Page 1 of 2
Case 9:08-cv-80736-KAM Document 216 Entered on FLSD Docket 07/27/2013 Page 1 of 2 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 08-80736-Civ-Marra/Matthewman JANE DOES #1 AND #2, Petitioners, I UNITED STATES OF AMERICA, Respondent. UNITED STATES' NOTICE OF FILING 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 Privilege Log, which is attached hereto. The documents referenced in the Privilege Log are being delivered today to the Chambers of U.S. District Judge Kenneth A. Marra for ex pane in camera review, pursuant to the Court's Omnibus Order. Respectfully submitted, WIFREDO A. FERRER UNITED STATES ATTORNEY By: I I I I a EFTA00209306 Case 9:08-cv-80736-KAM Document 216 Entered on FLSD Docket 07/27/2013 Page 2 of 2 CERTIFICATE OF SERVICE I HEREBY CERTIF
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