To: "Gerald Lefcourt" <6

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

Jeffrey Epstein, Billionaire Pedophile, Goes Free - The Daily Beast

Jeffrey Epstein, Billionaire Pedophile, Goes Free - The Daily Beast Page 1 of 4 THE DAILY BEAST READ THIS SKIP THAT BLOGS & STORIES Billionaire Pedophile Goes Free PRINT Hedge fund mogul Jeffrey Epstein became a free man Wednesday, five years after he was first accused of sexually abusing underage girls. After months of reporting, The Daily Beast's reveals exclusive details of the investigation and the legal wrangling that saved him from a long prison term. She reports: • Palm Beach's police chief objected to Epstein's "special treatment" and gave The Daily Beast an exclusive look at his nine-hour deposition about the investigation. • Earlier versions of the U.S attorney's charges, including a sealed 53-page indictment, could have landed Epstein in prison for 20 years. • Victims alleged that Epstein molested underage girls from South America. Europe. and the former Soviet republics. including three 12-year-old girls brought over from France as a birthday gift. • The v

EFTA00014046

IN RE:

IN RE: INVESTIGATION OF JEFFREY EPSTEIN ADDENDUM TO THE NON-PROSECUTION AGREEMENT IT APPEARING that the panics seek to clarify certain provisions of page 4, paragraph 7 of the Non-Prosecution Agreement (hereinafter "paragraph 7"), that agreement is modified as fol lows: 7A. The United States has the right to assign to an independent third-party the responsibility fur consulting with and, subject to the good faith approval of Epstein's counsel, selecting the attorney representative for the individuals identified under the Agreement. If the United States elects to assign this responsibility to an independent third-patty, both the United States and Epstein retain the right to make good faith objections to the attorney representative suggested by the independent third-party prior to the final designation of the attorney representative. 7II. The parties will jointly prepare a short written submission to the independent third-party regarding the role of the attorney represen

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

EFTA00178386

EFTA00178386 United States District Court SOUTHERN DISTRICT OF FLORIDA TO: SUBPOENA TO TESTIFY BEFORE GRAND JURY FGJ 07-103(WPB)-Fti./No. OLY-80/z SUBPOENA FOR: PERSON X DOCUMENTS OR OBJECTISI YOU ARE HEREBY COMMANDED to appear and testify before the Grand Jury of the United States District Court at the place, date and time specified below. PLACE: United States District Courthouse 701 Clematis Street West Palm Beach, Florida 33401 ROOM: Grand Jury Room DATE AND TIME: April 15, 2008 1:00pm YOU ARE ALSO COMMANDED to bring with you the following documents) or object(s): ANY AND ALL NOTES, LETTERS, CARDS, GIFTS, PAYMENTS, AND PHOTOGRAPHS YOU HAVE RECEIVED FROM JEFFREY EPSTEIN, LESLEY GROFF, AND/OR OR ANY EMPLOYEE OF JEFFREY EPST IMI L. ANY AND ALL PHOTOGRAPHS, WHETHER PRINTED OR DIGITAL, OF JEFFREY EPSTEIN, LESLEY GROFF, AND/OR ANY AND ALL E-MAILS, INSTANT MESSAGES, CHATS, TEXT MESSAGES, VOICEMAILS, OR TELEPHONE MESSAGES THAT YOU HAVE SENT TO AND/ORRECEIVED FR