Case 9:08-cv-80736-KAM Document 224 Entered on FLSD Docket 08/16/2013 Page 1 of 3
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Case 9:08-cv-80736-KAM Document 224 Entered on FLSD Docket 08/16/2013 Page 1 of 3 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 NOTICE OF FILING OF OBJECTIONS TO PRIVLEGE LOG COME NOW Jane Doe #1 and Jane Doe #2 (also referred to as "the victims"), by and through undersigned counsel, to give notice of their filing of objections to the Government's two privilege logs (DE 212 and DE 216). The objections are attached hereto. The victims are filing these objections concurrently with a motion to compel production of the materials at issue. DATED: August 16, 2013 Respectfully Submitted, /s/ Bradley J. Edwards Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L. 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 Telephone (954) 524-2820 Facsimile (954) 524-2822 Florida Bar No.: 542075 E-mail: brad ®pathtojustice
Persons Referenced (7)
“..., Suite 1000 Boston, MA 02116 Email: owlmgw@att.net (617) 338-9538 Criminal Defense Counsel for Jeffrey Epstein /s/ Bradley J. Edwards 3 EFTA00208754”
The victim“...NS TO PRIVLEGE LOG COME NOW Jane Doe #1 and Jane Doe #2 (also referred to as "the victims"), by and through undersigned counsel, to give notice of their filing of objections to the Government's two...”
United StatesJane Doe #1Roy Black“...doj.gov E-mail: ann.marie.c.villafanaeusdoj.gov Attorneys for the Government Roy Black, Esq. Jackie Perczek, Esq. Black, Srebnick, Komspan & Stumpf, P.A. 201 South Biscayne Boulevard, Suite 1300...”
Jane Doe #2“...THERN 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 NOTICE OF FILING OF OBJECTIONS TO PRIVLEGE LOG COME NOW ...”
Jeffrey Epstein“..., MA 02116 Email: owlmgw@att.net (617) 338-9538 Criminal Defense Counsel for Jeffrey Epstein /s/ Bradley J. Edwards 3 EFTA00208754...”
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EFTA DisclosureRelated Documents (6)
U.S. Department of Justice
U.S. Department of Justice United States Attorney Southern District of Florida First AuLstant U.S. 4liortrty 99 NE thStreti Miam& FL 31132 DELIVERY BY FEDERAL EXPRESS June 3, 2008 Honorable Mark Filip Office of the Deputy Attorney General United States Department of Justice 950 Pennsylvania Avenue, N.W. Washington, D.C. 20530 Re: Jeffrey Epstein Dear Judge Filip, Jeffrey Epstein was a part-time resident of Palm Beach County, Florida.' In 2006, the Federal Bureau of Investigation began investi tin alle ations that over a two-year period, Epstein paid approximately 28 minor females to come to his house for sexual favors? In July 2006, the matter was presented to AUSA of our West Palm Beach branch office to pursue a formal criminal investigation. That investigation resulted in the discovery of approximately one dozen additional minor victims. Over the last several months, approximately six more minor victims hive been identified. AUSA has been ready to present an
Case No. 08-80736-CV-MARRA
Case No. 08-80736-CV-MARRA P-0 I 1789 EFTA00192835 Memorandum Subjeci Operation Leap Year: Notification of Breach USAO No. 2006R0 181 June 9, 2009 To Jeffrey H. Sloman Acting United States Attorney Robert K. Senior First Assistant U.S. Attorney Rolando Garcia Deputy Chief, Criminal Division, West Palm Beach Karen Atkinson, Chief Chief, Criminal Section I, Northern Division, WPB From A. Marie Villafan AUSA, Ft Laude INTRODUCTION. This memorandum seeks approval to serve the attached letter providing notice of a breach of the Non-Prosecution Agreement on attorneys for Jeffrey Epstein. On Friday, June 12, 2009, Judge Marra will be presiding ova a hearing on Jeffrey Epstein's motions to stay all of the civil lawsuits filed against him by victims identified through our investigation. In his Order setting the matter for a hearing, Judge Marra stated: This hearing shall be limited to the issue of whether Defendant Epstein's defense of the civil actions filed against h
UNITED STATES DISTRICT COURT
UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 9:08-ev-80736-Civ-ICAM JANE DOE 1 and JANE DOE 2 I UNITED STATES JANE DOE 1 AND JANE DOE 2'S RESPONSE IN OPPOSITION TO EPSTEIN'S MOTION FOR A PROTECTIVE CONFIDENTIALITY ORDER COME NOW Jane Doe 1 and Jane Doe 2 (also referred to as "the victims"), by and through undersigned counsel, to file this response in opposition to Epstein's Motion for a Protective Confidentiality Order (DE 247). Epstein's motion is a thinly-disguised attempt to relitigate issues already covered by the court's earlier ruling eleven months ago (DE 188), which allowed the victims to file correspondence relating to Epstein's non-prosecution agreement in the public court file. Rather than reverse its previous ruling, this Court should reaffirm it — and allow the important issues presented by this case to be litigated in the light of day. BACKGROUND Because of Epstein's penchant for relitigating issues that have already been decided, it
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 ADMISSIONS TO THE GOVERNMENT REGARDING QUESTIONS RELEVANT TO THEIR PENDING ACTION CONCERNING 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 admit or deny the following facts: 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) (the victims' "summary judgment motion") along with a Motion to Have Their Facts Accepted Because of the Government's Failure to Cont
Case 9:08-cv-80736-KAM Document 161 Entered on FLSD Docket 04/17/2012 Page 1 of 23
Case 9:08-cv-80736-KAM Document 161 Entered on FLSD Docket 04/17/2012 Page 1 of 23 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE No. 08-80736-CIV-MARRA/JOHNSON JANE DOE 1 and JANE DOE 2, Plaintiffs, v. UNITED STATES OF AMERICA, Defendant. SUPPLEMENTAL BRIEFING OF INTERVENORS ROY BLACK, MARTIN WEINBERG, AND JAY LEFKOWITZ IN SUPPORT OF THEIR MOTION FOR A PROTECTIVE ORDER CONCERNING PRODUCTION, USE, AND DISCLOSURE OF PLEA NEGOTIATIONS During the hearing on August 12, 2011, the Court directed the proposed intervenors to file additional briefing on their argument that plea negotiations are privileged and not subject to discovery or use as evidence in these proceedings. Proposed intervenors submit the following memorandum of law, which is identical to Parts I and II of the memorandum of law submitted by proposed intervenor Jeffrey Epstein in support of his motion for a protective order and his opposition to the motions of the plaintiffs for production, use,
Case 9:08•cv-80736•KAM Document 190 Entered on FLSD Docket 06/19/2013 Page 1 of 3
Case 9:08•cv-80736•KAM Document 190 Entered on FLSD Docket 06/19/2013 Page 1 of 3 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 08-80736-CIV-MARRA JANE DOE NI and JANE DOE #2, petitioners, vs. UNITED STATES OF AMERICA, respondent. FILED by D.C. JUN 1 8 2013 STEVEN M LARIMORE CLERK U S DIST. CT S 0 of FLA - W PB OMNIBUS ORDER THIS CAUSE is before the court on various motions. Upon consideration, it is ORDERED AND ADJUDGED: I. The petitioners' protective motion seeking recognition of the availability of various remedies attaching to the CVRA violations alleged in this proceeding [DE 128] is DENIED WITHOUT PREJUDICE to renew the request for any particular form of relief or remedy in connection with the court's fmal disposition of petitioners' CVRA petition on the merits. 2. The intervenors' motion to strike the petitioners' supplemental authority regarding privilege claims [DE 177] is DENIED AS MOOT. 3. The petitioners' sealed motion for the co
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