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efta-efta01803664DOJ Data Set 10Correspondence

EFTA Document EFTA01803664

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From: Sent: Tuesday, October 23, 2012 10:03 PM To: jeffrey epstein Subject: Fw: Please choose 3 Press Release title Suggestions and provide brief quotes/comments about each corresponding linked article tied to your choices cell: email: Forwarded Message From: Philippe Han < ' < >= Sent: Tuesday, October=23, 2012 11:23 AM Subject:<=B> RE: Please choose 3 Press Release title Suggestions and provide brief q=otes/comments about each corresponding linked article tied to your choices=BR> <mailto Thank you <=div> We will have our writers get=to the drafting of these releases. I am hoping to have them coming b=ck to me ready to send out for your approval by EOD tomorrow. Respectfully, Philippe Han: Senior C=ient Account Manager Reputation Changer Direct Fax - NOTICE: This message, includ=ng all attachments transmitted with it, is for the use of the addressee on=y. It may contain proprietary, confidential and/or legally privileged info=mation. No confidentiality or privilege is waived or lost by any mistransm=ssion. If you are not the intended recipient, you must not, directly or in=irectly, use, disclose, distribute, print or copy any part of this message= If you believe you have received this message in error, please delete it =nd all copies of it from your system and notify the sender immediately by =eply e-mail. Thank you. From: [mailto Sent: Tuesday, October 23, 2012 1:56=AM To: Philippe Han Cc: Subject: Re: Please choose 3 Press Release title Suggestions and pr=vide brief quotes/comments about each corresponding linked article tied to=your choices Hi =hilippe and Kevin, EFTA_R1_00148006 EFTA01803664 &nb=p; att=ched are quotes to three articles. I couldn't figure out the last quote co=pletely so hopefully you can flesh something out. &nb=p; tha=ks for sending these articles out. &nb=p; &nb=p; cel=: ema=l: <mailto &nb=p; F=om: Philippe Han To: Cc: Sent: Monday, October 22, 2012 1:23 PM Sub=ect: Please choose 3 Press Release title Suggestions and provide brief=quotes/comments about each corresponding linked article tied to your choic=s Hi a, I have for you some title suggestions for your upcoming p=ess releases for Jeffrey Epstein's ORM Campaign. Pleas= choose 3 from the selection provided and then provide a few sentenc= quote about the article that is linked to your chosen title. =/DIV> By tying into current news stories, we can position Jeffr=y favorably as an authority source giving us the greatest opportunity to r=nk our release multiple times within your search result. Please make=sure you read the articles linked to your preferred title suggestions as t=ese articles will serve as a backstory for your release. Having a qu=te from you enables us to incorporate your stance on the subject4=iv> Your choices are as follows. Please select 3 =nd provide a quote for each: <1=PAN> ht=p://www.philly.com/philly/blogs/evolution/Catching-Diseases-from-our-Evolurionary-Cousins.html &n=sp; ht=p://phys.org/news/2012.10-evolution-genes-captured.html &n=sp; ht=p://www.economist.com/news/science-and-technology/21564824-these-days-anyo=e-can-be-scientific- philanthropist &n=sp; ht=p://charlestown.patch.com/articles/lt-governor-announces-780k-grant-for-sc=ence-education-and-jobs <1=IV> &n=sp; =SPAN style="COLOR: black"> ht=p://phys.org/news/2012.10-advocates-student-centered-approach-science.html=/SPAN> Respectfully, 2 EFTA_R1_00148007 EFTA01803665 Philippe Han: Senior Client Account Manager<=div> Reputation Changer Direct Fax - NOTICE: This message, including all attachments transmi=ted with it, is for the use of the addressee only. It may contain propriet=ry, confidential and/or legally privileged information. No confidentiality=or privilege is waived or lost by any mistransmission. If you are not the =ntended recipient, you must not, directly or indirectly, use, disclose, di=tribute, print or copy any part of this message. If you believe you have r=ceived this message in error, please delete it and all copies of it from y=ur system and notify the sender immediately by reply e-mail. Thank you. 3 EFTA_R1_00148008 EFTA01803666

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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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