Subject: LITIGATION HOLD REMINDER - Jane Does I U.S. - Case No.: 9:08-ov-80736-KAM -re
Summary
Subject: LITIGATION HOLD REMINDER - Jane Does I U.S. - Case No.: 9:08-ov-80736-KAM -re Jeffrey Epstein) Date: Fri, 31 May 2013 21:20:24 +0000 Importance: Normal In accordance with USAP USAP 3-13.300.003, this is a reminder that the Litigation Hold in the above-referenced matter remains in place. Employees of the USAO-FLS must continue to preserve "hard copy" documents and electronically stored information ("ESI") that may be potentially relevant to a claim or defense of a party, until receiving formal written notice of termination of the Litigation Hold. Thank you. EFTA00207960 In accordance with USAP USAP 3-13.300.003, this is a reminder that the Litigation Hold in the above-referenced matter remains in place. Employees of the USAO-FLS must continue to preserve "hard copy" documents and electronically stored information ("ESI") that may be potentially relevant to a claim or defense of a party, until receiving formal written notice of termination of the Litigation Hold. T
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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
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
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
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
JANE DOE I JEFFREY EPSTEIN LITIGATION
JANE DOE I JEFFREY EPSTEIN LITIGATION RELEVANT PLEADINGS Docket No. Date Description 12 6/20/08 Defendant's Motion to Stay 13 6/20/08 Defendant's Motion for Enlargement of Time to Answer 16 7/1/08 Defendant's Notice Concerning Motion to Stay 23 7/17/08 Defendant's Motion to File Ex Parte and Under Seal 24 7/17/08 Defendant's "Notice of Continued Pendency of Federal Criminal Action" 31 7/29/08 Defendant's Notice of Filing Exhibits (Attaching Villafaiia Declaration from victims' rights suit) 33 8/5/08 Order Denying Motion to Stay 34 8/5/08 Order Denying Motion to Seal 37 8/12/08 Defendant's Motion to File Under Seal 38 8/12/08 Defendant's Reply in Support of Motion to Stay 40 9/4/08 Defendant's Motion to Dismiss Complaint 41 9/22/08 Plaintiff's Memorandum in Response to Defendant's Motion to Dismiss Complaint 45 9/30/08 Order Setting Trial Date and Discovery Deadlines 46 10/6/08 Defendant's Motion to Dismiss Amended Complaint and Motion fo
Case 9:08-cv-80736-KAM Document 324 Entered on FLSD Docket 04/07/2015 Page 1 of 10
Case 9:08-cv-80736-KAM Document 324 Entered on FLSD Docket 04/07/2015 Page 1 of 10 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.:08-CV-80736-ICAM JANE DOE 1 and JANE DOE 2, Petitioners, vs. UNITED STATES OF AMERICA, Respondent. ORDER DENYING PETITIONERS' MOTION TO JOIN UNDER RULE 21 AND MOTION TO AMEND UNDER RULE 15 This cause is before the Court on Jane Doe 3 and Jane Doe 4's Corrected Motion Pursuant to Rule 21 for Joinder in Action ("Rule 21 Motion") (DE 280), and Jane Doe 1 and Jane Doe 2's Protective Motion Pursuant to Rule 15 to Amend Their Pleadings to Conform to Existing Evidence and to Add Jane Doe 3 and Jane Doe 4 as Petitioners ("Rule 15 Motion") (DE 311). Both motions are ripe for review. For the following reasons, the Court concludes that they should be denied. I. Background This is an action by two unnamed petitioners, Jane Doe 1 and Jane Doe 2, seeking to prosecute a claim under the Crime Victims' Rights Act (CVRA), 18 U.S.C. § 377
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