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nity to conduct "limited" discovery, petitioners want more, in the form of depositions of (I) FBI Special Agent E. Nesbitt Kuyrkendall; (2) FBI S/A Jason Richards; (3) Jeffrey Sloman, who formerly served as both United States Attorney and First Assistant U.S. Attorney; (4) Matt Menchel, who formerly served as
yrkendall; (2) FBI S/A Jason Richards; (3) Jeffrey Sloman, who formerly served as both United States Attorney and First Assistant U.S. Attorney; (4) Matt Menchel, who formerly served as Chief of the Criminal Division; (5) Assistant U.S. Attorney Marie Villafana; and (6) R. Alexander Acosta, who formerly serv
as the appropriate course to take. Similarly, neither Mr. Sloman, the former First Assistant U.S. Attorney and former Acting U.S. Attorney, nor Mr. Menchel, the former Chief of the Criminal Division, were involved in any consultation with the victims. Their mental processes in making decisions on the E
of Florida, Jane Doe No. 1 was contacted to be advised regarding the investigation. On October 26, 2007, Special Agents E. Nesbitt Kuyrkendall and Jason Richards met in person with Jane Doe No. 1 because she was recognized as a "victim' of Epstein's crime. 15 EFTA00081130 Case 9:08-cv-80736-KAM Document 2
dmits that it has information about a personal or business relationship between Jeffrey Epstein and another prosecutor involved in the Epstein case, Matthew Menchel. Answers I0 EFTA00081125 Case 9:08-cv-80736-KAM Document 225-1 Entered on FLSD Docket 08/16/2013 Page 11 of 64 to Requests for Admission at I 2
chel has a personal or business relationship with defendant Jeffrey Epstein. Gov't Answers to RFA's ¶ 20. This could potentially show misconduct by Menchel, and also potentially a motive to violate the victims' rights as explained previously. The Government's privilege log has numerous entries showing
bout October 26 or 27, 2007, after the initial plea agreement was signed, FBI agents contacted Jane Doe I. Special Agents E. Nesbitt Kuyrkendall and Jason Richards met in 78 US_Atty_Cor. 00220-00226 (Exhibit 78). 79 000551.000554 (Exhibit 79). 8° Exhibit 64 at 4. 81 Exhibit 62. 82 Id. 83 Id.; Exhibit 63 at
sentiments.' 17. However, by August 3, 2007, the Government had disproven or rejected Epstein's various arguments against federal charges, as AUSA Matt Menchel sent a letter to Epstein's counsel stating, "[w]e would reiterate that the agreement to Section 2255 liability applies to all of the minor girls id
contacted to be advised regarding the resolution of the investigation. On October 26, 2007, EFTA00206738 Special Agents E. Nesbitt Kuyrkendall and Jason Richards met in person with Jane Doe #1. The Special Agents explained that Epstein would plead guilty to state charges, he would be required to register as
n to use 'a' versus `the' and other minutiae. When you and I could not reach agreement, you repeatedly went over my head, involving Messrs. Lourie, Menchel, Sloman, and Acosta in the negotiations at various times." U.S. Attorney's Correspondence at 269. 28. The December 13, 2007, letter also reveals th
ed within the FBI — including, but not limited to those to or from or between any of the following individuals: Val Parlave, Tim Delaney, Ed Nucci, Jason Richards, Nezbitt Kurkendall, Eliasib Ortiz, Alex Acosta or Alan Snatiago -- presenting or reflecting complaints, concerns or questions about possible busin
e clients or other benefit of any kind to any United States Attorney or Assistant United States Attorney, including but not limited to Alex Acosta, Matthew Menchel, and/or Andrew Laurie, prior to Epstein's plea in June of 2008. upplemental Discovery Request 4. Any emails or other documents, including those circ
bout October 26 or 27, 2007, after the initial plea agreement was signed, FBI agents contacted Jane Doe I. Special Agents E. Nesbitt Kuyrkendall and Jason Richards met in 78 US_Atty_Cor. 00220-00226 (Exhibit 78). 79 000551.000554 (Exhibit 79). 8° Exhibit 64 at 4. 81 Exhibit 62. 82 Id. 83 Id.; Exhibit 63 at
sentiments.' 17. However, by August 3, 2007, the Government had disproven or rejected Epstein's various arguments against federal charges, as AUSA Matt Menchel sent a letter to Epstein's counsel stating, "[w]e would reiterate that the agreement to Section 2255 liability applies to all of the minor girls id
of Florida, Jane Doe No. I was contacted to be advised regarding the investigation. On October 26, 2007, Special Agents E. Nesbitt Kuyrkendall and Jason Richards met in person with Jane Doe No. 1 because she was recognized as a "victim' of Epstein's crime. 15 EFTA00179713 Case 9:08-cv-80736-KAM Document 2
nchel has a personal or business relationship with defendant Jeffrey Epstein. Gov't Answers to RFA's 120. This could potentially show misconduct by Menchel, and also potentially a motive to violate the victims' rights as explained previously. The Government's privilege log has numerous entries showing
Entities connected to both Jason Richards and Matthew I. Menchel

Jeffrey Epstein
PERSON
Lesley Groff
PERSON
Prince Andrew
PERSON
A. Marie Villafana
PERSON
Alexander Acosta
PERSONLeon Black
PERSON
Jeffrey Sloman
PERSON
United States
LOCATIONGerald Lefcourt
PERSON
Jay Lefkowitz
PERSON
Ken Starr
PERSON
Kenneth Marra
PERSON
Department of Justice
ORGANIZATION
Bradley Edwards
PERSONJane Doe
PERSONRoy Black
PERSONthe Southern District
LOCATION
Alan Dershowitz
PERSONAnn Sanchez
PERSONJack Goldberger
PERSON