Case 9:08-cv-80736-KAM Document 312 Entered on FLSD Docket 02/23/2015 Page 1 of 3

Case 9:08-cv-80736-KAM Document 312-1 Entered on FLSD Docket 02/23/2015 Page 1 of 25

Case 9:08-cv-80736-KAM Document 312-1 Entered on FLSD Docket 02/23/2015 Page 1 of 25 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 OPPOSITION TO 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 Respondent United States, by and through its undersigned counsel, files its Opposition to Jane Doe No. 1 and Jane Doe No. 2's 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, and states: I. THE CAREFUL BALANCE THAT CONGRESS STRUCK WITH THE CVRA COUNSELS AGAINST THE EXPANSION OF THESE CVRA PROCEEDINGS TO INCLUDE ADDITIONAL CLAIMS OR PARTIES. Petitioners have filed their "protective" motion to amend their petit

Case 9:08-cv-80736-KAM Document 298 Entered on FLSD Docket 01/26/2015 Page 1 of 8

Case 9:08-cv-80736-KAM Document 298 Entered on FLSD Docket 01/26/2015 Page 1 of 8 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 9:08-cv-80736-ICAM JANE DOE #1 and JANE DOE #2. Petitioners, vs. UNITED STATES OF AMERICA, Respondent. VICTIMS' RESPONSE TO ORDER REQUESTING JUSTIFICATION FOR ESPTEIN'S UNOPPOSED MOTION FOR A SUPPLEMENTAL PROTECTIVE ORDER COME NOW petitioners Jane Doe No. I and Jane Doe 2, as well as movants Jane Doe No. 3 and Jane Doe No. 4 ("the victims"'), to respond to the Court's Order Requesting Justification for Intervenor Epstein's Unopposed Motion for a Protective Order (DE 286). The victims believe that the motion should be denied. The only reason the victims' did not oppose the motion earlier was their (perhaps mistaken) belief that the Court had already directed that they were not to file the most recently-disclosed plea bargain correspondence in the public court file and that they must agree on protective order language with

(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.

Epstein Exhibits

Case 18-2868, Document 278, 08/09/2019, 2628230, Page1 of 648 EXHIBIT A Case 18-2868, Document 278, 08/09/2019, 2628230, Page2 of 648 6114:2016 Prince Andrew and girl, 17, who sex o?er?er friend flew to Britain to meet him Daily Mail Ontine Daily ail .com Home I U.K. Sports Showbiz [Australia [Femail [Health [Science [Money [Video [Travel [Columnists tr am .22: ,t Latest wisestii?tr?e Prince Andrew and the 17-year-old girl his 1 sex offender friend flew to Britain to

Case 9:08-cv-80736-KAM Document 312-1 Entered on FLSD Docket 02/23/2015 Page 1 of 25

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 OPPOSITION TO 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 Respondent United States, by and through its undersigned counsel, files its Opposition to Jane Doe No. 1 and Jane Doe No. 2's 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, and states: I. UNDER THE FEDERAL RULES OF CIVIL PROCEDURE, FED.R.CIV.P. 15 GOVERNS ATTEMPTS TO AMEND A PETITION TO ADD NEW PETITIONERS Petitioners have filed their "protective" motion to amend their petition and to add two new petitioners, Jane Doe No. 3 and Jane Doe No. 4. As the Government has previously explained (se