From: Jay Lefkowitz <[email protected]>
Summary
From: Jay Lefkowitz <[email protected]> Subject: Follow up to your call last week Date: Mon, 04 Apr 2011 20:40:19 +0000 Importance: Normal It was good to hear from you last week. Following up on our conversation, I looked into the question of the request to unseal various letters written by DOJ to Mr. Epstein's counsel. A review of the correspondence between you and others in the USAO and myself and others representing Mr. Epstein (the very correspondence that is now the subject of both a request to unseal and a request for further discovery filed by counsel for Jane Doe 1 and 2 in the 3771 case currently before Judge Marra (08-80736)), demonstrates that it contains substantial information that would fall within the heartland of Federal Rule of Criminal Procedure 6(e). For instance, some of the letters refer to recipients of grand jury subpoenas, the nature of the offenses for which the grand jury was prepared to indict, the number of victims claimed by the Government,
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EFTA DisclosureRelated Documents (6)
EFTA Document EFTA01355640
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
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
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
UNITED STATES DISTRICT COURT
UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 013-80736-Civ-Marra/Johnson JANE DOE #1 and JANE DOE #2 v. UNITED STATES JANE DOE #1 AND JANE DOE #2'S MOTION FOR FINDING OF VIOLATIONS OF THE CRIME VICTIMS' RIGHTS ACT AND REQUEST FOR A HEARING ON APPROPRIATE REMEDIES COME 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 the victims' rights under the Crime Victims Rights Act (CVRA), 18 U.S.C. § 3771, have been violated by the U.S. Attorney's Office, and to request a hearing on the appropriate remedies for these violations. The victims have proffered a series of facts to the Government, which they have failed to contest. Proceeding on the basis of these facts,' it is clear that the U.S. Attorney's Office has repeatedly violated the victims' protected CVRA rights, including their right to confer with prosecutors generally about the case and specifically abou
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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