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les of Criminal Procedure, and applies to the Court for an order authorizing: the disclosure of matters occurring before the grand jury to attorney Jonathan Biran of the firm Baker Donelson to allow him to fulfill his obligations in representing Assistant United States Attorney Villafafta) in connection with
. OPR is also investigating allegations stemming from the February 21, 2019 order issued by U.S. District Judge Kenneth A. Marra, in Jane Doe I and Jane Doe 2 I. United States, 9:08-80736-CIV- MARRA (S.D. Fla.), in which Judge Marra concluded that the USAO violated the Crime Victims' Rights Act, 18 U.S.C.
ilty plea, two of Epstein's victims filed suit against the United States alleging violations of the Crime Victim's Rights Act (CVRA). Jane Doe I and Jane Doe 2. United States, S.D. Fla. Case No. 08-80736-CV-KAM. The CVRA requires members of the Justice Department to use their "best efforts" to confer with v
levant material and my memory may be imperfect.' I have organized the response to conform with the April 2, 2019 letter from Jeffrey R. Ragsdale to Jonathan Biran. Please note that there were numerous oral and written communications between others at the U.S. Attorney's Office and the Justice Department with
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
SA Villafafia's attached letter, please contact me at your convenience. Very truly yours, BAKER, DONELSON, BEARMAN, CALDWELL & BERKOWITZ, PC /s/ Jonathan Biran JB/smr Enclosures/Attachment cc: AUSA A. Marie Villafafia 4822.5464-0166x1 2865555-000127 05/10/2019 EFTA00225547 U.S. Department of Justice
of a federal case, but I don't recall discussing that at the time. 35 I had never before used a non-prosecution 34 As I noted in my filings in the Jane Doe' United States litigation, I had concerns about informing the victims that part of the negotiations involved securing for them the right to obtain d
ng Assistant United States Attorney A. Marie Villafaila, and the Justice Department's Office of Professional Responsibility may disclose to attorney Jonathan Biran matters occurring before the grand jury necessary to: (a) allow respond to OPR's written questions; (b) prepare for OPR's interview of (c) partic
fice of Professional Responsibility (OPR) arising out of a decision by United States District Judge Kenneth A. Marra in the matter of Jane Doe I and Jane Doe 2 United States, S.D. Ha. Case No. 08-80736-Civ-Marra; (3) the materials are needed to avoid an injustice in another proceeding, that is, the OPR
ng Assistant United States Attorney A. Marie Villafafia, and the Justice Department's Office of Professional Responsibility may disclose to attorney Jonathan Biran matters occurring before the grand jury necessary to: (a) allow AUSA Villafafia to respond to OPR's written questions; (b) prepare for OPR's interv
Department's Office of Professional Responsibility (OPR) arising out of a decision by United States District Judge Kenneth A. Marra in the matter of Jane Doe 1 and Jane Doe 2I United States, S.D. Fla. Case No. 08-80736-Civ-Marra; (3) the materials are needed to avoid an injustice in another proceeding, th
Entities connected to both Jonathan Biran and Jane Doe

Jeffrey Epstein
PERSON
Bradley Edwards
PERSON
Kenneth Marra
PERSONJack Goldberger
PERSON
United States
LOCATION
Alan Dershowitz
PERSONthe Southern District
LOCATION
George W. Bush
PERSONLeon Black
PERSON
Ghislaine Maxwell
PERSONSouthern District
LOCATION
Alexander Acosta
PERSON
A. Marie Villafana
PERSONRobert C. Josefsberg
PERSON
Department of Justice
ORGANIZATIONRichard Horace Willits
PERSON
Virginia Giuffre
PERSON
Prince Andrew
PERSONRoy Black
PERSON
Jay Lefkowitz
PERSON