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From: To: (USAFLS)" < Cc Subject: Jane Doe #1 and #2 v. United States - Motion for Ordinary Briefing Date: Mon, 05 Aug 2013 20:51:11 +0000 Importance: Normal Attachments: 218_excess_page_priv.pdf and The victims have filed a motion requesting ordinary briefing for the litigation over the privileges asserted by the government in response to their request for production. The court directed the plaintiffs to file a seven page document, and the government to respond in a seven page document. In their eleven page motion, the victims attempt to justify filing a 20 page memo opposing our invocation of privileges. Interestingly, the victims intend to pierce our invocation of the attorney-client privilege by invoking the crime-fraud exception. I have attached the victims' motion. If you have any questions, please call me at Thanks. EFTA00208755
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Farmer, Jaffe, Weissing,
Farmer, Jaffe, Weissing, Edwards, Fistos £t Lehrman, P.L. 'Ovid Pam ftoisl pet WWW.PATITTOJUSTKE.COM 425 North Andrews Avenue • Suite 2 Fort Lauderdale, Florida 33301 4 00 "ti e 6.‘ tk i r atire CalkAllfle alvdtr aIINNEV rar ,NYTTENNINIP PITNEY 'OWES 02 !F $003 , 50 0 000i3V, wit JAN 2i 2,2!3 .a4P En M ZIP t20-12E 3330 Dexter Lee A. Marie Villafatia 500 S. Australian Ave., Suite 400 West Palm Beach, FL 33401 EFTA00191396 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 08-80736-Civ-Marra/Johnson JANE DOE #1 and JANE DOE #2, Petitioners, 1. UNITED STATES, Respondent. SEALED DOCUMENT EFTA00191397 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 08-80736-Civ-Marra/Johnson JANE DOE #1 and JANE DOE #2, Petitioners, UNITED STATES, Respondent. SEALED DOCUMENT MOTION TO SEAL Petitioners Jane Doc No. 1 and Jane Doe No. 2, joined by movants Jane Doe No. 3 and Jane Doe No. 4, move to file the attached pleading and supporti
Case 9:08-cv-80736-KAM Document 49
Case 9:08-cv-80736-KAM Document 49 Entered on FLSD Docket 03'21'2011 Page 1 of 10 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 08-80736-Civ-Marra/Johnson JANE DOE #1 and JANE DOE #2 1. UNITED STATES JANE DOE #1 AND JANE DOE #2'S MOTION TO HAVE THEIR FACTS ACCEPTED BECAUSE OF THE GOVERNMENT'S FAILURE TO CONTEST ANY OF THE FACTS COME NOW Jane Doe #1 and Jane Doe #2 (also referred to as "the victims"), by and through undersigned counsel, to move this Court to accept all of their facts in their Motion for Finding of Violations of the Crime Victims' Rights Act. The victims have been attempting to negotiate with the Government for more than 30 months on a stipulated set of facts. Despite repeated opportunities to advise the victims of what facts they are contesting, the Government in the last few days has flatly declared that it will not discuss the facts in this case. This is violation of the Court's direction to the parties as well as the local rule on
Case 9:08-cv-80736-KAM Document 50
Case 9:08-cv-80736-KAM Document 50 Entered on FLSD Docket 0372172011 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 1. 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
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
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
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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