Epstein Secrets

gued above, but I will try to collect them into general categories in chronological order. 1. b. I did not want to meet with counsel for Epstein (Lilly Ann and Gerald Lefcourt) prior to completi.n investigation. My co-counsel agreed with me. Our supervisor, M, overruled us. and I did not want to h

email from Jeff that said, "Hold the letter" (Exhibit B-54). On December 10, 2007, I contacted Jim Eisenberg, counsel for Individual # 28, who is Jane Doe #2 in the Jane Doe'. United States suit. As noted on the attached chart, Mr. Eisenberg was paid for by Mr. Epstein. I told Mr. Eisenberg that I was

ad been identified in the state investigation), alleging violations of the Crime Victims' Rights Act. The suit, which is still pending, is captioned Jane Doe 1 and Jane Doe 21 United States, 08-80736-CV-KAM. Page 3 of 58 EFTA00225046 set aside the NPA and see Mr. Epstein federally charged due to violatio

P-013872 E-mailil and p.m., FW: Lefcourt to Sanchez a 22, to Matthew ■ Any work-product May 22, 2007, 3:11 a Mi l with e-mail from , and Lilly Ann 2007 2:05 p.m. attached Suppl. Box 3 P-013873 E-mail 2007, 10:52 . e-mail from (May 14 2007 10:38 to and May 14, Any work-product RE: Oper

Document 361 Entered on FLSD Docket 02/10/2016 Page 1 of 57 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 9:08-cv-80736-KAM JANE DOE 1 AND JANE DOE 2, Petitioners, UNITED STATES, Respondent. JANE DOE 1 AND JANE DOE 2'S CONSOLIDATED STATEMENT OF UNDISPUTED MATERIAL FACTS AND MOTI

m letter to Jane Doe 5 also acknowledged the victims' rights under the CVRA at the same time as the Office was not disclosing the NPA's existence to Jane Doe 5 and the other victiim."6 101. In mid-June 2008, Mr. Edwards contacted the line AUSA handling the case to inform her that he represented Jane Doe 1 a

ommunication or influence" is so vague and potentially broad that a denial is problematic. I also have never seen all of the emails between Guy and Lilly Ann and Alex, Jeff, Matt, Andy, and Rolando (and any others in DC).] 19. [Again, I don't know how to answer this. The RFA does not use the word "former

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 08-80736-Mise-Marra/MatthrA mari JANE DOE #1 and JANE DOE #2, Petitioners, I UNITED STATES OF AMERICA, Respondent. RESPONDENT'S ANSWERS TO PETITIONERS' FIRST REQUESTS FOR ADMISSIONS I. Admit. 2. (a)

ommunication or influence" is so vague and potentially broad that a denial is problematic. I also have never seen all of the emails between Guy and Lilly Ann and Alex, ' cS ",\ . I " ' b (and any others in DC).] 19. [Again, I don't know how to answer this. The RFA does not use the word "former," so

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 08-80736-Mise-Marra/MatthrA mari JANE DOE #1 and JANE DOE #2, Petitioners, I UNITED STATES OF AMERICA, Respondent. RESPONDENT'S ANSWERS TO PETITIONERS' FIRST REQUESTS FOR ADMISSIONS I. Admit. 2. (a)

of Law University of Utah 332 South 1400 East Room 101 Salt Lake City, UT, USA 68333 <i>pro Hac Vice</ I> Email: DEFENDANT ATTORNEY(S): Sanchez, Lilly Ann [COR LD NTC] Fowler White Burnett 1395 Brickell Avenue 14TH Floor Miami, FL, USA 33131-3302 Fax: Email: Goodner, Helaine S [COR LD NTC] Fowler

Confidential Due Diligence Report UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA (West Palm Beach) Doe et al v. Epstein PLAINTIFF: Jane Doe's Stepmother Individually; Jane Doe's Mother Intervenor; Jane Doe's Father Individaully and as Parent and Natural Guardian of Jane Doe; Jane Doe by

(May 23, 2007, 5:00 p.m.), Andrew Lourie to Gerald Lefcourt (May 22, 2007, 6:32 p.m.), and Gerald Lefcourt to Andrew Lourie Marie Villafana, and Lilly Ann Any work-product Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Waiver, Claims Against Public Prosecutor; Overriding Need; Attorney C

FLSD Docket 08/16/2013 Page 1 of 3 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 08-80736-Civ-Marra/Johnson JANE DOE #1 and JANE DOE #2 v. UNITED STATES JANE DOE #1 AND JANE DOE #2'S NOTICE OF FILING OF OBJECTIONS TO PRIVLEGE LOG COME NOW Jane Doe #1 and Jane Doe #2 (also refe

n this case. Moreover, we do not believe that whatever Kenneth Starr or may have said to this office, or what this office said to Kenneth Starr or Lilly Ann , has any bearing on whether a duty existed under 18 U.S.C. 3771(a) to consult with plaintiffs prior to entering into a non-prosecution agreement,

with roughly 19 pages of facts? If so, what is your position on such a motion? Thank you in advance for your position. Paul Cassell, Co-Counsel for Jane Doe #1 and Jane Doe #2 EFTA00206340 Paul G. Cassell Ronald N. Boyce Presidential Professor of Criminal Law S.J. Quinney College of Law at the Univer

n this case. Moreover, we do not believe that whatever Kenneth Starr or may have said to this office, or what this office said to Kenneth Starr or Lilly Ann , has any bearing on whether a duty existed under 18 U.S.C. 3771(a) to consult with plaintiffs prior to entering into a non-prosecution agreement,

filed in the district court. We will respond to your motion seeking access to this information. 4. As I understand the Magistrate Judge's order in Jane Doe No. 2 v. Jeffrey Epstein (D.E. 226), you must give notice to Epstein, prior to making certain correspondence public by either filing the correspond

ON to Quash Service of Process and Supporting Memorandum of Law by Jeffrey Epstein. (Attachments: # 1 Exhibit Affidavit of Richard Barnett)(Sanchez, Lilly Ann) (Entered: 10/29/2010) Clerks Notice to Filer re 6 Certificate of Service. 5 Certificate of Service. Document Not Captioned ; CORRECTIVE ACTION REQ

MOTION to Compel Response to 1st RTP and 1st Interrogs filed by C.M.A.. (Hill. Jack) (Entered: 04/20/2009) 04/22/2009 63 MOTION for Leave to File Jane Doe's No. 101's Motion For Leave to File Brief as Amicus Curiae in Support of Plaintiff's Response in Opposition to Defendant Jeffrey Epstein's Motion to

Marra on 7/20/2010. (ir) (Entered: 07/20/2010) 09/02/2010 NOTICE of Attorney Appearance by Lilly Ann Sanchez on behalf of Jeffrey Epstein (Sanchez, Lilly Ann) (Entered: 09/02/2010) EFTA00226950 09/02/2010 213 Defendant's MOTION for Hearing Jeffrey Epstein's Request for Oral Argument in Connection wit

by Jeffrey Epstein. (Pike. Michael) (Entered: 07/02/2010) 07/05/2010 199 Defendant's MOTION in Limine to Exclude Certain Testimony and Opinions of Jane Doe's Expert Witness by Jeffrey Epstein. (Pike, Michael) (Entered: 07/05/2010) 07/05/2010 200 RESPONSE in Opposition re 190 Plaintiff's MOTION for Cont