LETTER TO EDITORS REGARDING EDITORIAL "The Cowardly Labor
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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 FIRST REQUEST FOR PRODUCTION TO THE GOVERNMENT REGARDING INFORMATION RELEVANT TO THEIR PENDING ACTION CONCERN THE CRIME VICTIMS RIGHTS ACT 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 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. BACKGROUND As the Government will recall, the victims have asked the Government to stipulate to undisputed facts in this case. The Government has declined. Accordingly, the victims filed their Motion for Finding of Violations of the Crime Victims' Rights Act and Request for a Hearing on Appropriate Remedies (DE 48
Case 9:08-cv-80736-KAM Document 48 Entered on FLSD Docket 03/21/2011 Page 1 of 42
Case 9:08-cv-80736-KAM Document 48 Entered on FLSD Docket 03/21/2011 Page 1 of 42 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 FINDING OF VIOLATIONS OF THE CRIME VICTIMS' RIGHTS ACT AND REQUEST FOR A HEARING ON APPROPRIATE REMEDIES COME NOW Jane Doe #1 and Jane Doe #2 (also referred to as "the victims"), by and through undersigned counsel, to move for a finding from this Court that the victims' rights under the Crime Victims Rights Act (CVRA), 18 U.S.C. § 3771, have been violated by the U.S. Attorney's Office, and to request a hearing on the appropriate remedies for these violations. The victims have proffered a series of facts to the Government, which they have failed to contest. Proceeding on the basis of these facts,' it is clear that the U.S. Attorney's Office has repeatedly violated the victims' protected CVRA rights, including thei
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 JANE DOE #1 AND JANE DOE #2'S MOTION FOR FINDING OF VIOLATIONS OF THE CRIME VICTIMS' RIGHTS ACT, REQUEST FOR AN EVIDENTIARY HEARING IF FACTS ARE CONTESTED, AND REQUEST FOR HEARING ON APPROPRIATE REMEDIES COMES NOW Jane Doe #1 and Jane Doe #2 (also referred to as "the victims"), by and through undersigned counsel, to move for a finding from this Court that their rights as crime victims under the Crime Victims Rights Act (CVRA) have been repeatedly violated by the U.S. Attorney's Office, to request an evidentiary hearing to establish those violations if the U.S. Attorney's Office contests the underlying facts, and to request a brief schedule and a hearing on the appropriate remedies for these violations. As recounted in more detail below, the victims have recently-obtained correspondence between the U.S. Attorney's Office and defendant Jeffrey
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 FIRST REQUEST FOR PRODUCTION TO THE GOVERNMENT REGARDING INFORMATION RELEVANT TO THEIR PENDING ACTION CONCERN THE CRIME VICTIMS RIGHTS ACT 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 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. BACKGROUND As the Government will recall, the victims have asked the Government to stipulate to undisputed facts in this case. The Government has declined. Accordingly, the victims filed their Motion for Finding of Violations of the Crime Victims' Rights Act and Request for a Hearing on Appropriate Remedies (DE 48
ROY BLACK
ROY BLACK HOWARD M. SREBNICK SaYIT A. KORNSPAN LARRY A. STUMPY? MARIA NEYRA JACKIE PERCZEK MARK A.J.lAPIRO JARED BLACK SREBNICK KORNSPAN STUMPF P.A. May 18, 2010 VIA EMAIL AND U.S. MAIL Assistant United States Attorney United States Attorney's Office Southern District of Florida 500 South Australian Avenue Suite 400 West Palm Beach, Florida 33401 RE: Jeffrey Epstein Dear Counsel: JESSICA FONSECA-NADER KATHLEEN P. PHILLIPS AARON ANTHON MARCOS BEATON, JR. JENIPER J. SOULUCIAS NOAH FOX JOSHUA SHORE E-Mail: RBlack(lfioyBlack.com Jeff Sloman, Esq. United States Attorney 99 N.E. 4th Street Miami, FL 33132 Assistant United States Attorney 99 N.E. 4th Street Miami, FL 33132 We received notice this morning that Podhurst Orseck, P.A. has filed a civil complaint seeking over $2,000,000 in addition to the $526,000 they have already been paid by Jeffrey Epstein for their work as attorney representatives. As we communicated to you during our February 3, 2010
Memorandum
Memorandum Subject Jane Does Nos. 1 and 2.'. United States, Case No. 08-80736-CIV-MARRA (S.D.Fla.) Daft April 26, 2011 To From Assistant Counsel Office of Professional Responsibility U.S. Department of Justice VIA FEDERAL EXPRESS 99 N.E. 4th Street Miami, Florida 33132 Attached please fmd a CD-ROM containing the victims' Motion for Finding of Violations of the Crime Victims Rights Act and Request for a Hearing on Appropriate Remedies (unredacted), and a complete set of exhibits, including the e-mails in Exhibit A. The e-mails in Exhibit A are between Epstein's defense attorney and AUSA Villafaba. They were produced in civil litigation between Epstein and some of his victims. Epstein's attorneys redacted their side of the e-mail transmission. I will attempt to obtain a complete set, which includes the transmission from Epstein's attorneys. If you have any questions, please call me Thank you. Enclosure 08-80736-CV-MARRA 000670 EFTA00230494 Case 9:08-cv-8073§-KA
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