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efta-efta01783318DOJ Data Set 10Correspondence

EFTA Document EFTA01783318

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From: Jean-Pierre Oriol < Sent: Wednesday, September 7, 20161:19 PM To: Erika Kellerhals Cc: Jeffrey E.; Dawn Henry Subject: Re: Follow up good morning erika, i forwarded your request to the commissioner and she asked me to inform =ou that all of the matters are to be resolved in the meeting friday. regards, JP Jean-Pierre L. Oriol Director DPNR-Division of Coastal Zone Management 8100 Lindberg Bay, Suite 61 CEK Airport, Terminal Bldg Second Floor St. Thomas, VI 00802 ph: fax: </=iv> 1 EFTA_R1_001 03845 EFTA01783318 From: Erika Kellerhals Sent: Tuesday, September 6, 2016 4:08 PM To: Jean-Pierre Oriol Cc: Jeffrey E. Subject: Follow up JP — good afternoon. I left a message for you on your voicemail =t work to follow up on a few items that I had referenced in my email over =he weekend — in particular — the apparent planting restriction=that has been imposed on GSJ and the clean up of debris and trash. However, we have confirmed with Geneva that we will be m=eting with you and the Commissioner on Friday at 1:30. Based upon discussions between Geneva and Mr. Epstein's staff, i= is our understanding that both you and the Commissioner will be unavailab=e for the remainder of the month and it would be extremely disappointing i= we could not reach some agreement as to the clean up of certain areas and the planting at our meeting this Frid=y. These conditions cannot be allowed to continue — as the staff on =S1 has already been exposed to and treated for a parasitic infection, as w=s conveyed to the Commissioner. I have requested surveys for the areas you indicated, but I would appreciate you =etting me know if you need anything else in advance of the meeting on Frid=y and further, if you would please confirm by response to this email= that Mr. Epstein cannot plant any palm or mango trees in the area previously described in the permit application =nd viewed by Mr. Rosa until such time as a permit it issued by DPNR. =/div> Thank you in advance. Feel free to contact me or Mr. Epstein should yo= have any questions. Erika A. Kellerhals Member Kellerhals Ferguson Kroblin PLLC Royal Palms Professional Building 9053 Estate Thomas, Suite 101 St. Thomas, VI 00802 2 EFTA_R1_00103846 EFTA01783319 Notice: This communication may c=ntain privileged or other confidential information. If you are not the intended recipient, or believe that you have received t=is communication in error, please do not print, copy, re-transmit, dissemi=ate, or otherwise use this information. Also, please indicate to the=sender that you have received this e-mail in error, and delete the copy you received. Thank you.=/p> Circular 230: To ens=re compliance with the requirements imposed by the IRS, we inform you that=any tax advice contained in our communication (including any attachments) was not intended or written to be used, and ca=not be used, for the purpose of (i) avoiding any tax penalty or (ii) promo=ing, marketing or recommending to another party any transaction or matter =ddressed herein. 3 EFTA_R1_001 03847 EFTA01783320

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reached in this case, and other information in the possession of the victims, it is also possible that other improper relationships exist between Government agents and Epstein. Please provide any documents, correspondence, and other information regarding the possibility of any improper relationship, including: a) involvement in and/or awareness of any aspect of the Government's criminal investigation and/or possible prosecution/non-prosecution of Epstein; b) Attorney liklimenvolvement in and/or awareness of the Government's interest."( witness, subject, or target of the Epstein investigation, including Sarah Ghislaine Maxwell, Nadia Marcinkova, Lesley Groff, Haley Robson, Louella Ruboyo, Larry Morrison, Larry Visoki, David Rogers, William Hammond, and Robert Roxburgh; c) All documents, correspondence, and other information reflecting telephone calls (includin telephone logs and telephone billing statements) made by or received by m Jeffrey Epstein, the Florida Science

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Case 9:08-cv-80736-KAM Document 435 Entered on FLSD Docket 02/21/2019 Page 1 of 33

Case 9:08-cv-80736-KAM Document 435 Entered on FLSD Docket 02/21/2019 Page 1 of 33 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, Respondent. OPINION AND ORDER This cause is before the Court upon Jane Doe 1 and Jane Doe 2's Motion for Partial Summary Judgment (DE 361); the United States's Cross-Motion for Summary Judgment (DE 408); Jane Doe 1 and Jane Doe 2's Motion to Compel Answers (DE 348) and Jane Doe 1 and Jane Doe 2's Motion for Finding Waiver of Work Product and Similar Protections by Government and for Production of Documents (DE 414). The Motions are fully briefed and ripe for review. The Court has carefully considered the Motions and is otherwise fully advised in the premises. I. Background The facts, as culled from affidavits, exhibits, depositions, answers to interrogatories and reasonably inferred, for the purpose of these motions, are as follows: From betw

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