From: "Lee, Dexter (USAFLS)" <[email protected]>
From: "Lee, Dexter (USAFLS)" <[email protected]> To: "Blumenschein, John M. (OGC) (FBI)" <[email protected]> Cc: "Ball, Julio (MM) (FBI)" <[email protected]>, "Villafana, Ann Marie C. (USAFLS)" <AVillafana®usa.doj.gov>, "Sanchez, Eduardo (USAFLS)" <ESanchez1 ®usa.doj.gov>, "Bessee, Cecilia O. (OGC) (FBI)" <[email protected]>, "Stanford, Jennifer L. (OGC) (FBI)" [email protected]>, "Jacobs, James T. (OGC) (CON) (FBI)" <James.Jacobs®ic.fbi.gov> Subject: RE: Jane Doe 1 and 2 1 United States Petitioners' Fourth Request for Production Date: Tue, 08 Nov 2016 16:08:00 +0000 Importance: Normal John, We asked for and received a thirty day extension on November 4, 2016. Our due date is December 5, 2016. Thanks. Dexter Lee From: Blumenschein, John M. (OGC) (FBI) [mailto:[email protected]] Sent: Tuesday, November 08, 2016 10:57 AM To: Lee, Dexter (USAFLS) <[email protected]> Cc: Ball, Julio (MM) (FBI) <[email protected]>; Villafana, An
Summary
From: "Lee, Dexter (USAFLS)" <[email protected]> To: "Blumenschein, John M. (OGC) (FBI)" <[email protected]> Cc: "Ball, Julio (MM) (FBI)" <[email protected]>, "Villafana, Ann Marie C. (USAFLS)" <AVillafana®usa.doj.gov>, "Sanchez, Eduardo (USAFLS)" <ESanchez1 ®usa.doj.gov>, "Bessee, Cecilia O. (OGC) (FBI)" <[email protected]>, "Stanford, Jennifer L. (OGC) (FBI)" [email protected]>, "Jacobs, James T. (OGC) (CON) (FBI)" <James.Jacobs®ic.fbi.gov> Subject: RE: Jane Doe 1 and 2 1 United States Petitioners' Fourth Request for Production Date: Tue, 08 Nov 2016 16:08:00 +0000 Importance: Normal John, We asked for and received a thirty day extension on November 4, 2016. Our due date is December 5, 2016. Thanks. Dexter Lee From: Blumenschein, John M. (OGC) (FBI) [mailto:[email protected]] Sent: Tuesday, November 08, 2016 10:57 AM To: Lee, Dexter (USAFLS) <[email protected]> Cc: Ball, Julio (MM) (FBI) <[email protected]>; Villafana, An
Persons Referenced (3)
“...Beach Circuit Court, in accordance with the terms of the NPA. On July 7, 2008, Jane Does 1 and 2 filed their CVRA lawsuit. We are seeking responsive emails for the pe...”
Jeffrey Epstein“...rated by FBI personnel regarding potential improper influences being exerted by Jeffrey Epstein on United States Attorney's Office senior officials, including U.S. Attorney R. Alexander Acosta; Crimi...”
Alexander Acosta“...n United States Attorney's Office senior officials, including U.S. Attorney R. Alexander Acosta; Criminal Division Chief Matt Menchel; and Supervisory AUSA (West Palm Beach) Andew Laurie. The reques...”
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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-Marra/Johnson JANE DOES #1 and #2 Petitioners, v. UNITED STATES OF AMERICA, Respondent. RESPONDENT'S OPPOSITION TO VICTIMS' MOTION TO UNSEAL NON-PROSECUTION AGREEMENT Respondent, by and through its undersigned counsel, files its Opposition to Victims' Motion to Unseal Non-Prosecution Agreement, and states: I. THE MOTION TO UNSEAL SHOULD BE DENIED BECAUSE THE NON-PROSECUTION AGREEMENT HAS NEVER BEEN FILED UNDER SEAL IN THIS COURT. Petitioners have filed their motion to unseal the non-prosecution agreement, claiming that no good cause exists for sealing it. As an initial matter, the motion should be denied because the non-prosecution agreement entered into between the United States Attorney's Office and Jeffrey Epstein was never filed in the instant case by the United States, either under seal or otherwise. On August 14, 2008, this Court held a telephonic hearing to discuss petitioners' r
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
Memorandum
Memorandum Subject Re: Operation Leap Year Date May 1, 2007 (Revised 9/13/07) (2nd Revision 2/19/08)' To From R. Alexander Acosta, United States Attorney First Assistant United States Attorney Chief, Criminal Division MAUSA, Northern Region , Chief, Northern Region I. Introduction This memorandum seeks approval for the attached indictment char in Jeffrey Epstein, Min a/k/a' JEGE Inc., and Hyperion Air, Inc. The proposed indictment contains 60 counts and seeks the forfeiture of Epstein's Palm Beach home and two airplanes? The FBI has information regarding Epstein's whereabouts on May 16th and May 19th and they would like to arrest him on one of those dates. Epstein is considered an extremely high flight risk' and, from information we have received, a continued danger 'The second revision amends the Jane Doe numbering system to correspond with the most recent indictment. It also removes the references to the overt acts and substantive allegations related to each
Case 9:08-cv-80736-KAM Document 329 Entered on FLSD Docket 06/23/2015 Page 1 of 2
DOJ EFTA Data Set 10 document EFTA01325031
UNITED STATES DISTRICT COURT
UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 08-80736-CIV-MARRA JANE DOE #1 and JANE DOE #2, Petitioners, vs. UNITED STATES OF AMERICA, Respondent. RESPONDENT'S INITIAL DISCLOSURES Respondent United States of America, by and through its undersigned counsel, makes its Initial Disclosures, pursuant to Fed.R.Civ.P. 26(a)(1)(A), and state: Fed.R.Civ.P. 26(a)(1)(A)fil: 1. R. Alexander Acosta Dean, School of Law Florida International University Rafael Diaz-Balart Hall 11200 S.W. 8'h Street Miami, Florida 33199 (305) 348-1118 Dean Acosta was the United States Attorney, Southern District of Florida, during the time when the criminal investigation of Jeffrey Epstein was opened in the U.S. Attorney's Office, and the non-prosecution agreement was negotiated. 2. was the First Assistant U.S. Attorney in the U.S. Attorney's Office, during the time when the criminal investigation of Jeffrey Epstein was opened, and the non-prosecution agreement was negot
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