Subject: RE: Jane Does 1 U.S. (re Jeffrey Epstein) - Litigation Hold - Additional
Summary
Subject: RE: Jane Does 1 U.S. (re Jeffrey Epstein) - Litigation Hold - Additional Date: Thu, 04 Nov 2010 14:20:37 +0000 Importance: Normal Thank you very much Enjoy your cruise! u : : lane (re uoes Us. in - Litigation - Aaai y P.s. I think you have to take your start date back much further -- 2005 or 2006. Subject: RE: Jane Does U.S. (re Jeffrey Epstein) - Litigation Hold - Additional Good Afternoon: In furtherance of the Lit Hold materials I sent to you, please know that I have to inform the National Preservation Officer at EOUSA in Washington as well as Jacquie Varela (here in the S.D. Fla) of the Lit Hold and inform them of key names. To that end, I gathered from the unsealed Court filings the names set forth below. Please let me know if there are any other names that should be identified. Please let me know first name. I will also need the names of the victims that would be Jane Doe # 1 and Jane Doe #2 for preservation purposes. This information will be kept
Persons Referenced (7)
“...d be identified. Please let me know first name. I will also need the names of the victims that would be Jane Doe # 1 and Jane Doe #2 for preservation purposes. This information will be kept confide...”
United States“...acity as the Electronic Discovery Coordinator within the Civil Division of the United States Attorney's Office for the Southern District of Florida (USAO-SDFLA) to advise...”
United States Attorney“...acity as the Electronic Discovery Coordinator within the Civil Division of the United States Attorney's Office for the Southern District of Florida (USAO-SDFLA) to advise you of th...”
Jane Doe #2“...name. I will also need the names of the victims that would be Jane Doe # 1 and Jane Doe #2 for preservation purposes. This information will be kept confidential. If the USAO-SDFLA Lit Hold efforts a...”
Jack Goldberg“...SDFLA Non-Prosecution Agreement • Lilly Ann Sanchez, Counsel For Epstein • Jack Goldberger, Counsel for Epstein Palm Beach Florida Police Department Subject: Jane Does I U.S. (re Jeffrey Epstei...”
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EFTA DisclosureRelated Documents (6)
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 JANE DOE #1 AND JANE DOE #2'S MOTION FOR FINDING OF VIOLATIONS OF THE CRIME VICTIMS' RIGHTS ACT, REQUEST FOR AN EVIDENTIARY HEARING IF FACTS ARE CONTESTED, AND REQUEST FOR HEARING ON APPROPRIATE REMEDIES COMES NOW Jane Doe #1 and Jane Doe #2 (also referred to as "the victims"), by and through undersigned counsel, to move for a finding from this Court that their rights as crime victims under the Crime Victims Rights Act (CVRA) have been repeatedly violated by the U.S. Attorney's Office, to request an evidentiary hearing to establish those violations if the U.S. Attorney's Office contests the underlying facts, and to request a brief schedule and a hearing on the appropriate remedies for these violations. As recounted in more detail below, the victims have recently-obtained correspondence between the U.S. Attorney's Office and defendant Jeffrey
Case 9:08-cv 80119-KAM
Case 9:08-cv 80119-KAM Document 180 Entered on FLSD Docket 06/24/2009 Page 1 of 51 1 2 3 4 5 6 7 8 9 10 11 12 13 16 2Y) UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA WEST PALM BEACH DIVISION CASE NO. 08-80119-CIV-MARRA JANE DOE, et al., Plaintiffs, vs. JEFFREY EPSTEIN, Defendant. x APPEARANCES: WEST PALM BEACH, FLORIDA JUNE 12, 2009 TRANSCRIPT OF MOTION HEARING BEFORE THE HONORABLE KENNETH A. MARRA, UNITED STATES DISTRICT JUDGE FOR THE PLAINTIFFS: For Jane Doe TOTAL ACCESS COURTROOM NETWORK REALTIME TRANSCRIPTION EFTA00212053 Case 9:08-cv 80119-KAM Document 180 Entered on FLSD Docket 06/24/2009 Page 2 of 51 2 I I I I I 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 FOR THE DEFENDANT: REPORTED BY: ROBERT D. CRITTON, JR., ESQ. MICHAEL BURMAN, ESQ. Burman Critton, etc. 515 North Flagler Street West Palm Beach, FL 33401 JACK A. GOLDBERGER, ESQ. Atterbury Goldberger Weiss 250 Australian Avenue Sou
UNITED STATES DISTRICT COURT
UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 08-80736-Civ-Marra/Johnson JANE DOES #1 and #2 v. UNITED STATES JANE DOE #1 AND JANE DOE #2'S MOTION FOR FINDING OF VIOLATIONS OF THE CRIME VICTIMS' RIGHTS ACT, REQUEST FOR AN EVIDENTIARY HEARING IF FACTS ARE CONTESTED, AND REQUEST FOR HEARING ON APPROPRIATE REMEDIES COMES NOW Jane Doe #1 and Jane Doe #2 (also referred to as "the victims"), by and through undersigned counsel, to move for a finding from this Court that their rights as crime victims under the Crime Victims Rights Act (CVRA) have been repeatedly violated by the U.S. Attorney's Office, to request an evidentiary hearing to establish those violations if the U.S. Attorney's Office contests the underlying facts, and to request a brief schedule and a hearing on the appropriate remedies for these violations. As recounted in more detail below, the victims have recently-obtained correspondence between the U.S. Attorney's Office and defendant Jeffre
U.S. Department of Justice
U.S. Department of Justice United States Attorney Southern District of Florida 99 N.E. 4 Street Miami, FL 33132 305.961.9290 November 2, 2010 Via E-Mail Wifredo A. Ferrer, United States Attorney Office of the United States Attorney Southern District of Florida 99 NE slIt' Street Miami, Florida 33132 Privileged Commication Re: Litigation Hold re: Jane Does #1 and #21 United States, Case No.: 08-80736-CIV- MARRA/Johnson AND Jeffrey Epstein As a follow-up to your recent meeting concerning the above-referenced case, I write this letter in my capacity as the Electronic Discovery Coordinator within the Civil Division of the United States Attorney's Office for the Southern District of Florida (USAO-SDFLA). I write to advise you of the USAO-SDFLA's legal obligation to preserve documents and data relevant to the lawsuit and to enlist your assistance in this regard. The USAO-SDFLA is required by law to take all reasonable steps to preserve all documents and data relating t
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
UNITED STATES DISTRICT COURT
UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 08-80736-Civ-Marra/Johnson JANE DOE #1 and JANE DOE #2, Plaintiffs I UNITED STATES, Defendants 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 COME NOW Jane Doe #1 and Jane Doe #2 ("the victims"), by and through undersigned counsel, and request the defendant United States (hereinafter "the Government") to produce the original or best copy of the items listed herein below for inspection and/or copying, pursuant to the Court's Order (DE #99) directing discovery in this case. BACKGROUND As the Government will recall, the victims have asked the Government to stipulate to undisputed facts in this case. The Government has declined. Accordingly, the victims filed their Motion for Finding of Violations of the Crime Victims' Rights Act and Request for a Hearing on Appropriate Remedies (DE 48
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