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pated in the trafficking of Jane Doe No. 3. Where sexual issues are relevant to a case, they must not be stricken. See, e.g., Zdenekl School Bd. of Broward County, No. 07-CV-61110, 2007 WL 4521489, at •2 (S.D. Fla. Dec. 19, 2007) ("given the Eleventh Circuit standards on what constitutes actionable sexual hara
kswilawoom FAITH A. FRIEDMAN IM•cimweelcoutlaw.com BY FEDERAL EXPRESS July 6, 2007 Jeffrey Sloman, Esq., First Assistant United States Attorney Matthew Menchel, Esq., Chief, Criminal Division The United States Attorney's Office Southern District of Florida 99 NE 4'h Street Miami, Florida 33132 Andrew Lo
s Office Southern District of Florida 500 South Australian Avenue, Suite-400 West Palm Beach, Florida 33401 Jeffrey Epstein Dear Messrs. Sloman, Menchel and Lourie and Ms. Villafafia: We write as counsel to Jeffrey Epstein to follow-up on our meeting on June 26, 2007. We thought the meeting was extr
ts against Jeffrey Epstein for sexually abusing them. I am also familiar with the criminal justice system, having served as state prosecutor in the Broward County State Attorney's Office. 2. This affidavit covers factual issues regarding the Government's assertions of privilege to more than 13,000 pages of do
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
ts against Jeffrey Epstein for sexually abusing them. I am also familiar with the criminal justice system, having served as state prosecutor in the Broward County State Attorney's Office. 2. This affidavit covers factual issues regarding the Government's assertions of privilege to more than 13,000 pages of do
No Attorney-Client Relationship; Waiver; Claims Against Public Prosecutor, Overriding Need; Attorney Conduct at Issue Epstein, with e- mail from Menchel (July 5, 2007, 3:30 p.m.), Villafana to Menchel (July 4, 2007, 5:16 p.m.), and Sloman to Villafana (July 3, 2007, 1:47 p.m.), attached Suppl. Bo
Entities connected to both Broward County and Matthew I. Menchel

Jeffrey Epstein
PERSON
Prince Andrew
PERSONLeon Black
PERSON
Alan Dershowitz
PERSON
Lesley Groff
PERSON
Bradley Edwards
PERSON
Alexander Acosta
PERSONJane Doe
PERSON
United States
LOCATIONJack Goldberger
PERSON
Kenneth Marra
PERSON
Department of Justice
ORGANIZATIONthe Southern District
LOCATION
A. Marie Villafana
PERSONRoy Black
PERSON
George W. Bush
PERSONMaria Farmer
PERSON
Ghislaine Maxwell
PERSONGerald Lefcourt
PERSON
Ken Starr
PERSON