DS9 Document EFTA00771917

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

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

EFTA Document EFTA01695623

U.S. Department of Justice

U.S. Department of Justice United States Attorney Southern District of Florida 500 S. Australian Ave, Ste 400 West Palm Beach, FL 33401 (561) 820-8711 Facsimile: (561) 820-8777 August 26, 2008 DELIVERY BY ELECTRONIC MAIL Jay P. Lefkowitz, Esq. Kirkland & Ellis LLP Citigroup Center 153 East 53rd Street New York, New York 10022-4675 Roy Black, Esq. Black Srebnick Kornspan & Stumpf P.A. 201 S. Biscayne Blvd, Suite 1300 Miami, FL 33131 Re: Jeffrey Epstein Dear Jay and Roy: Thank you for your letter of August 22nd. I write to follow up on some of the points that you raised. The list of thirty-two victims that was provided to Mr. Goldberger via certified mail on July 10, 2008 is the final list. As I mentioned, copies of the notification letters to each victim will be carbon-copied to an attorney for Mr. Epstein and Mr. Josefsberg. I asked you to advise me whether Mr. Goldberger should continue to be listed as the contact person for the civil litigation in the amende

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

Subject: SDNY News Clips Tuesday, July 9, 2019

From: Cc: Bcc Subject: SDNY News Clips Tuesday, July 9, 2019 Date: Tue, 09 Jul 2019 21:12:37 +0000 Importance: Normal Attachments: 2019_7-9.pdf SDNY News Clips Tuesday, July 9, 2019 EFTA00076625 Contents Public Corruption Epstein Complex Frauds lure Terrorism & Narcotics Wise Honest Matters of Interest Trump Can't Block Twitter Followers US Appeals Court Rules Judicial Review of Claims of Government Misconduct in Parallel Investigations Barr Says Legal Path to Census Citizenship Question Exists but He Gives No Details Public Corruption Epstein Who Protected Jeffrey Epstein? New York Times By The Editorial Board 7/8/19 On Monday, the United States District Court for the Southern District of New York unsealed a 14-page indictment against Jeffrey Epstein, charging the wealthy financier with operating and conspiring to operate a sex trafficking ring of girls out of his luxe homes on Manhattan's Upper East Side and in Palm Beach, Fla., "among other locations."