Subject: Doe
Summary
Subject: Doe US I just read your Response to our Motion to Join Doe 3 and 4. I need some immediate clarification on one argument you make. You cite to an interview conducted b or the proposition that Doe 3 was contacted by the FBI in 2007 and refused to cooperate. However, you recent y pro uced all 302's and did not produce anything from 2007. In fact, the first evidence of any contact made by the FBI was 2011, other than the victim letters sent to her subsequent to Epstein's plea. Our understanding is that it was Epstein's investigator posing as an "FBI agent" on the telephone in "2007" (although Jane Doe No. 3 makes clear that she is uncertain about the date). Jane Doe 3 did not believe it was a real agent, and that consequently she did not provide any information. If you have information suggesting that the FBI or any law enforcement agency actually reached out to Jane Doe NO. 3 in 2007, and that she actually declined cooperation, then we would appreciate receiving that
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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 SUPPLEMENTAL REQUEST FOR PRODUCTION TO THE GOVERNMENT REGARDING CO-CONSPIRATOR IMMUNITY PROVISION AND RELATED SUBJECTS 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 within 30 days 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, the Court's Order denying the Government's motion to dismiss and lifting stay of discovery (DE 189), the Court's Omnibus Order (DE 190), and the Court's Order Denying Motion to Join (DE 324): BACKGROUND As the Government will recall, the victims have repeatedly asked the Government to stipulate to undisputed facts in thi
Case 9:08-cv-80736-KAM Document 311 Entered on FLSD Docket 02/06/2015 Page 1 of 21
Case 9:08-cv-80736-KAM Document 311 Entered on FLSD Docket 02/06/2015 Page 1 of 21 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 9:08-80736-Civ-Marra/Johnson JANE DOE #1 and JANE DOE #2 I UNITED STATES JANE DOE NO. 1 AND JANE DOE NO. 2'S PROTECTIVE MOTION PURSUANT TO RULE 15 TO AMEND THEIR PETITION TO CONFORM TO EXISTING EVIDENCE AND TO ADD JANE DOE NO. 3 AND JANE DOE NO. 4 AS PETITIONERS COME NOW Jane Doe No. 1 and Jane Doe No. 2 (the "current victims"), by and through undersigned counsel, to file this protective motion pursuant to Federal Rule of Civil Procedure I5(a)(2) to amend the petition that they have filed in this case. The amendment would (I) conform their petition to the evidence in the case and (2) add Jane Doe No. 3 and Jane Doe No. 4 (the "new victims") as petitioners. This motion is a "protective" motion because it may be unnecessary. With regard to amending to conform to the evidence, the current victims believe that their existing p
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
.kt5 P0Sh4s.
.kt5 P0Sh4s. $002.08 _ant Clam kik. Fan Pip Weeny. Ye,. ..nortas Cum" Cenwcui Uwe cn -AMIN PAT /001USTIC tea. 425 North Andrews Avenue • Suite 2 Fort Lauderdale. Florida 333O1 Farmer, Jaffe, Weissing, Edwards, Fistos £t Lehrman, P.L. Assistant U.S. Attorneys 500 S. Australian Ave., Suite 400 West Palm Beach, FL 33401 EFTA00184099 CONFIDENTIAL EFTA00184100 CONFIDENTIAL EFTA00184101 CONFIDENTIAL IDENTY OF PSEUDONYMS USED IN DISCOVERY REQUESTS EFTA00184102 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 08-80736-Civ-Marra/Johnson JANE DOE MI and JANE DOE k2, Plaintiffs v. UNITED STATES, Defendants JANE DOE #1 AND JANE DOE #2'S SUPPLEMENTAL REQUEST FOR PRODUCTION TO THE GOVERNMENT REGARDING "VICTIM" STATUS 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 within 30 days the original or best copy of the items listed
(USAFLS)
(USAFLS) From: Roy Black < Sent: Wednesda , Februa 11, 2015 8:50 AM To: (USAFLS) Subject: RE: Your phone call Great. Speak to you then. Original Message From: (USAFLS) Imailt Sent: Wednesday, February 11, 2015 8:49 AM To: Roy Black Subject: Re: Your phone call Hi Roy. Thanks for your message. Dexter wants to participate in the call so it is helpful to have a roadmap of the discussion points. We will call your office at 2:00. If there is a better number to call, just shoot me an email. Talk to you soon. Assistant U.S. Attorney Southern District of Florida 500 S. Australian Ave, Ste 400 West Palm Beach, FL 33401 On Feb 10, 2015, at 7:35 PM, "Roy Black" < mailto: wrote: Marie I was not calling you about the correspondence so don't worry about that. I called you to discuss the plaintiff's replies filed as dockets 310 and 311. We think there are serious misstatements by them in these pleadings. So I just wanted to let you know what our suggested responses are.
Case 9:08-cv-80119-KAM
Case 9:08-cv-80119-KAM Document 66-2 Entered on FLSD Docket 03/26/2009 Page 1 of 3 C UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CV-80232-MARRA-JOHNSON JANE DOE NO. 3, Plaintiff, I. JEFFREY EPSTEIN, Defendant. PLAINTIFF JANE DOE 3'S ANSWERS TO DEFENDANT'S FIRST INTERROGATORIES Plaintiff, JANE DOE 3, by and through their undersigned counsel, and pursuant to Federal Rules of Civil Procedure Rule 33, hereby responds to Defendant, JEFFREY EPSTEIN'S First Set of Interrogatories to Plaintiff as follows: General °Mentions 1. Plaintiff objects to Defendant's Interrogatories to the extent that the Interrogatories call for the disclosure of information protected by the attorney-client privilege, attorney work-product doctrine, or other applicable privilege or immunity, whether created by statute or common law. Plaintiff claims such privileges and protectiOns to the extent implicated by each Interrogatory, and excludes privileged and protected
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